INTERNATIONAL TRANSFER AND RECIPIENT REGISTER
Effective Date: 24 August 2026
Version: 1
This Register supports the Privacy Policy, Operator Agreement and Suboperator List. It identifies the standard Service's principal recipients and international-processing routes. It does not promise that processing occurs only in a principal location. A country-exclusive commitment applies only where a signed Enterprise Annex identifies the covered data, service and processing state.
Standard and Enterprise arrangements: The standard position described in this document applies unless a signed Enterprise Annex expressly varies an eligible, identified contractual matter. Where legally and operationally available, any enhanced or non-standard scope, service level, support, infrastructure, assurance, reporting, implementation or other commitment must be separately requested, assessed, approved and priced under the Enterprise Agreement. An Enterprise Annex cannot alter statutory rights or mandatory legal obligations.
1. Transfer Standard
1.1. Where Henry controls a transfer of Personal Information outside South Africa, Henry will use a ground permitted by section 72 of POPIA. For an Operator or Suboperator route, Henry's standard safeguard is a written contract requiring substantially similar protection, limited-purpose processing, confidentiality, security, incident assistance and deletion, supported by proportionate risk and provider review.
1.2. Other lawful grounds may include binding corporate rules, adequate foreign law, contractual necessity in the Data Subject's interest, consent or another statutory ground appropriate to the transfer.
1.3. A Tenant is responsible for a transfer it independently directs through its own source, recipient, tenant-controlled Microsoft or Google environment, external workflow or configuration. Henry remains responsible for its own express Operator duties.
1.4. A new material country, recipient, provider, purpose, onward-transfer route, support-access route or residency representation requires Henry's documented internal privacy, compliance, provider and technical approval before activation. A customer instruction, meeting statement, demonstration, proposal, email or individual representative's approval does not establish an approved transfer or vary this Register.
2. Standard Provider Routes
| Recipient/provider | Typical role | Purpose and data | Principal or expected locations | Standard safeguard/qualification | Products |
|---|---|---|---|---|---|
| Supabase | Henry's Operator or Suboperator according to the underlying data role | Database, application-user authentication, Edge Functions and storage of account data, Tenant Data, structured records, documents and metadata where appropriate | United States or configured region | Written provider terms and DPA; purpose restriction; access/security controls; region depends on configuration | Ingest, Insights, Exchange and shared platform |
| Amazon Web Services | Henry's Operator or Suboperator according to the underlying data role | Default production hosting through Fargate, EC2, S3, Route 53, Lambda and related services; compute, object storage, exports, logs, temporary data and backups | South Africa including af-south-1, and other enabled regions |
Written provider terms and DPA; managed security and encryption; no standard country-exclusive commitment | Ingest, Insights, Exchange and shared platform |
| Zoho cloud services | Henry's Operator, Suboperator or independent service provider by function | Hosted files, CRM, support, analytics, chat and internal operations | United States, India or another configured Zoho region | Written service/data terms; role and cookie basis depend on feature; content minimisation required | Shared operations; optional product support |
| Google Cloud / Gemini | Henry's Operator or Suboperator for enabled AI according to the underlying data role | Relevant document/email content, prompts, retrieved context, outputs and AI metadata for extraction, classification, OCR, redaction and insights | United States or provider-configured region | Business/API terms and available no-general-model-training settings; provider safety, security or troubleshooting retention may apply | Ingest and Insights; optional Exchange features |
| Microsoft Azure AI Foundry | Henry's Operator or Suboperator for enabled AI according to the underlying data role | Relevant Tenant Data, prompts, retrieved context, documents, extracted data, outputs and AI metadata for hosted AI processing and safety functions | Tenant-selected or provider-configured Microsoft regions | Microsoft business terms and DPA; approved model/endpoint; no-general-model-training setting; retention, human-review and region qualifications recorded before activation | Ingest, Insights and optional Exchange features |
| Yield Point AI | Henry's Operator, Suboperator or professional service provider by engagement | Workflow information, prompts, outputs and automation metadata | Provider locations | Written confidentiality, purpose, security and deletion duties required before production access | Enabled AI/automation workflows |
| Microsoft integration services | Independent Tenant provider and/or Henry's Operator or Suboperator for connector operations | Authorised Outlook, SharePoint, OneDrive, Teams and directory data; tokens and integration metadata | Tenant-selected Microsoft Geo, United States and other Microsoft support/processing locations | Tenant's Microsoft agreement governs Microsoft service; Tenant configuration is an instruction to Henry; Henry secures connector tokens and copied data | Ingest and enabled Insights workflows |
| Google integration services | Independent Tenant provider and/or Henry's Operator or Suboperator for connector operations | Authorised Google Drive files, documents, folders and sharing metadata; Gmail messages, attachments and contacts; Google Calendar calendars, events and attendee information; account and directory information, tokens and integration metadata | United States and configured Google Workspace regions | Tenant's Google agreement governs the Google services; Tenant configuration is an instruction to Henry; Henry secures connector tokens and copied data | Ingest and enabled Insights workflows |
| Google Analytics | Henry's Operator or independent Responsible Party according to configuration | Website/application events, device/browser data, approximate location and identifiers | United States and other provider regions | Consent or other lawful basis as applicable; minimise Tenant content; configured retention; not used for Tenant document content | Website and shared platform analytics |
| Third-party data source | Suboperator or independent validation provider according to the workflow | VIN, registration, microdot, vehicle specifications and check reason; vehicle identity, police/insurance-interest, stolen/wanted/illegal/suspect, cloning, false-number-plate, homologation, valuation and risk results | South Africa | Provider contract, purpose limitation, access control and retention terms; combined applicant/vehicle records remain protected Personal Information | Exchange and approved vehicle workflows |
| Paystack South Africa | Operator for Henry-controlled subscription payments | Customer/contact data, transaction identifiers, payment status, amount, currency, timestamps, invoice information and masked card metadata; full card number and CVV remain with Paystack | South Africa and approved foreign provider locations, including Paystack infrastructure and suboperators | Merchant terms and DPA; section 72 assessment for foreign processing; payment security, incident and statutory retention duties | Subscription payments across applicable products |
| Microsoft 365 used by Henry | Henry's Operator or independent Responsible Party recipient by activity | Business contacts, support correspondence, contracts and operational records | Henry's configured Microsoft Geo and other Microsoft support/processing locations | Microsoft business terms and DPA where applicable; access and retention limited by Henry purpose | Internal operations and support |
| Sprinto | Henry's Operator, Suboperator or compliance provider according to the information and service | Security/compliance evidence, configuration, asset, personnel, policy and audit metadata | United States and other provider regions | Written provider terms; access minimisation; no ordinary Tenant document content | Shared security and compliance |
3. Ecosystem and Professional Recipients
| Recipient type | Role and purpose | Data | Location and safeguard |
|---|---|---|---|
| Tenant-selected lender, bank, dealer, vehicle provider, referral partner or transaction participant | Operator, independent Responsible Party or other authorised recipient according to the workflow; qualification, underwriting, transaction and fulfilment | Lead, applicant, vehicle, finance, communication, consent and transaction data | Location shown or reasonably apparent in the workflow; Tenant/Henry must establish the role, notice and section 72 ground before a cross-border route |
| Validation, valuation, bureau or bank-statement provider | Suboperator, Operator or independent Responsible Party according to service | Identifiers and the minimum information required for the check | Provider contract, applicable sector law, authority/consent and transfer ground required |
| Professional advisers, auditors and insurers | Confidential recipient for advice, assurance, claim or legal duty | Minimum business, contract, incident or claim information | Professional/confidentiality duty and lawful transfer ground where outside South Africa |
| Regulator, court or law-enforcement body | Legally authorised recipient | Minimum information legally required | Henry follows the compulsory-request process in the Terms and Operator Agreement; statutory transfer/disclosure basis applies |
| Confidential financier, investor or acquirer | Confidential due-diligence recipient | Minimized business information; identifiable Tenant content only where necessary and lawful | NDA or equivalent confidentiality, data-room controls and lawful transfer basis |
4. Processing-State Qualifications
4.1. Data at rest means stored Customer or Tenant Data in the identified production storage. It does not by itself cover transient processing, network transit, directory or account data, security telemetry, remote support access or every backup.
4.2. Principal location identifies a main or expected provider location, not an exclusive boundary. Provider affiliates, support teams, resilience systems and suboperators may operate elsewhere under the applicable terms.
4.3. A Tenant-selected Microsoft 365 or Azure Geo does not automatically become Henry's storage Geo. Data copied into Henry is governed by Henry's Agreement, Product Schedule, providers and configuration.
4.4. Enabling a connector or recipient is the Tenant's documented instruction for the reasonably required transfer. Disabling it stops new transfers but does not erase data already lawfully received; the applicable retention schedule governs those copies.
5. Review, Changes and Objections
5.1. Henry reviews this Register when a material provider, recipient, location or purpose changes and at least annually.
5.2. A material new Suboperator follows the 30-day notice and objection process in the Suboperator List. An urgent change may occur earlier only under that process.
5.3. A Tenant may request the information reasonably necessary to evaluate an identified transfer by writing to legal@henryai.co.za. Security-sensitive and third-party confidential information may be supplied under confidentiality or in summary form.
5.4. Henry will not enable a material new transfer while its required assessment or approval remains incomplete. An urgent provider or security change remains subject to the documented emergency process, minimum necessary action, prompt review and the notices required by the Agreement.
END OF INTERNATIONAL TRANSFER AND RECIPIENT REGISTER