SUBOPERATOR LIST

Effective Date: 24 August 2026
Version: 2

Related Documents: Privacy Policy Sections 6 to 8 | Cookies Policy | Operator Agreement Section 6 | International Transfer and Recipient Register | applicable Product and Processing Schedule | Terms of Service Section 5

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. Scope

1.1. To provide a secure and reliable Service, Henry AI (Pty) Ltd, registration number 2023/620906/07, trading as Henry, Henry AI, Henry Ingest, Henry Insights and Henry Exchange (Henry), uses carefully selected third-party providers for hosting, security, support and operations. A provider processes information only where relevant to a selected plan, enabled feature, configured workflow or legitimate internal business activity.

1.2. Provider roles follow the actual processing and are governed by the Privacy Policy Section 1. Inclusion in this list does not, by itself, determine whether a provider is a Suboperator, Henry's operator or an independent responsible party.

1.3. To support transparency, this list identifies principal or expected processing locations. The International Transfer and Recipient Register identifies the relevant purpose, data, role and transfer safeguard. A principal or primary location is not a promise that support, security, transient processing, network transit or backups occur only there. The standard Service does not include a country-specific data-residency commitment; any such commitment must identify the covered data, service and processing state in a signed Enterprise Annex.

1.4. Ecosystem Tenants receiving Henry Lead Data are governed by the Operator Agreement, not this provider list. Their identity and authorised role are shown in the applicable workflow or Commercials Record.

1.5. For each enabled provider, Henry's authoritative internal provider and transfer record must contain the contracting legal entity, service and feature, role, information categories, processing purpose, production or optional status, configured region, support and backup locations where known, onward-transfer chain, section 72 ground, contract/DPA, security assurance, retention qualification, approval owner and last review date. The public tables below use recognisable provider group or service names; the contracting-entity detail applicable to a Tenant is available on reasonable request, subject to provider confidentiality and security.

1.6. Role classification: a provider acting as Henry's Operator processes Personal Information for a purpose Henry determines; a Suboperator processes Tenant Data only for Henry's delegated Operator purpose; an independent Responsible Party determines its own purpose or essential means; and a professional or ordinary recipient receives only the minimum information for advice, payment, law or another stated purpose. A provider may occupy different roles for different services or data flows. An ecosystem lender, dealer, insurer or product provider is not a Suboperator merely because the Service routes information to it.

2. Current Providers

2.1. Infrastructure, Hosting and File Storage

Production information may be distributed between providers. Logical Tenant separation does not constitute dedicated physical infrastructure.

The database/authentication and object-storage routes are standard production dependencies when the relevant product uses them. Zoho file storage is enabled only for an approved configured workflow. The applicable Product Schedule or Online Order Record must identify which provider and region are enabled for the Tenant.

2.2. AI and Machine Learning

To protect customer information, Henry uses business or API offerings and available settings under which identifiable Tenant Data is not used to train a provider's general-purpose or shared foundation model, except on the Tenant's separate documented instruction. Processing inputs to generate outputs is not training. Provider retention, automated safety review or authorised human review for security, abuse prevention, troubleshooting or operation may apply only as disclosed for the selected feature. Model, endpoint and region selection may vary and are recorded in the applicable Product and Processing Schedule, Online Order Record or Enterprise Annex.

AI providers are optional Suboperators unless the accepted Product Schedule identifies the AI feature as included. Before production activation, Henry must record the account tier, model/endpoint, no-general-model-training setting, provider retention, possible human review and configured location in the provider record.

2.3. Integrations

Microsoft or Google may also act as an independent provider contracted by the Tenant. The Tenant's applicable provider agreement, licences, permissions and configuration govern that relationship.

For connector operations, Microsoft or Google may be the Tenant's independent provider for the source service and Henry's Operator or Suboperator for connector processing according to Henry's underlying role. The Product Schedule and transfer record must state the stage-specific role; disabling a connector stops new transfers but does not delete lawful copies already received by Henry.

2.4. Analytics

To protect privacy, Henry intends to minimise substantive Tenant content, mask sensitive fields and interactions where supported, and use cookieless or pseudonymous configurations where appropriate. Cookie and similar-technology information is governed by the Cookies Policy.

The listed analytics, replay, personalisation and chat services are enabled on designated website or application surfaces, but optional collection is blocked until the visitor's applicable consent or choice is recorded. Session recording excludes financial, identity, authentication, free-text, Children's and Special Personal Information fields; if reliable exclusion is not available, recording remains disabled on that surface.

2.5. Vehicle Verification and Payments

Third-party data source results concern a vehicle and are not treated as person-level criminal information merely because they indicate police or insurance interest. If Henry links the result to an identifiable applicant, owner, driver or transaction, the combined record is protected as Personal Information. Paystack hosts payment-card credentials; Henry retains only the transaction and masked payment metadata required for subscription administration, accounting, fraud handling and proof.

2.6. Internal Operations

Henry may also use advisers, auditors, insurers, banks, payment providers, telecommunications providers and ordinary business suppliers. Such a provider is not necessarily a Suboperator merely because it receives payment instructions, business-contact information, a legally required disclosure or confidential information for professional advice.

3. Provider Changes

3.1. Henry periodically reviews its providers to maintain or improve the Service and may add, replace or remove them as the Service evolves. Henry will give at least 30 days' advance notice before a material new Suboperator receives Tenant Data for Operator processing. A Tenant may subscribe through its registered account contact or by requesting provider-change notices at legal@henryai.co.za. Henry will retain the notice version, recipient, dispatch time and effective date.

3.2. Henry may make an immediate change where reasonably necessary to protect customers, privacy or the Service, comply with law, preserve continuity, respond to an unexpected provider withdrawal or prevent material harm. Henry will notify affected Tenants as soon as reasonably practicable and, unless law or an active security risk prevents it, no later than ten Business Days after emergency access begins. The notice will explain the reason, provider, role, data, location, safeguard and available objection or exit route.

3.3. Provider name, ownership, non-material support-location or service-description changes may be recorded without advance notice where processing risk does not materially change.

3.4. Henry will not appoint or enable a material new provider, Suboperator, processing purpose, data category, country, support-access route or onward-transfer chain until its required internal provider, privacy, security, compliance and technical approvals are recorded. No meeting statement, customer request, proposal, email or individual representative's approval bypasses that review or varies this list.

4. Tenant Objections

4.1. By accepting the Terms of Service, a Tenant gives general written authorisation for Henry to appoint the listed Suboperators.

4.2. Henry will bind a Suboperator to use Tenant Data only for the delegated service, prohibit an unrelated purpose, require protection no less protective in substance than Henry's applicable Operator duties, and remain responsible for performance of those duties subject to the lawful limits in the Agreement.

4.3. Henry welcomes substantiated data-protection concerns, and its objection process is designed to assess them constructively. A Tenant may object to a material new Suboperator during the notice period on specific data-protection-law grounds by identifying the Tenant, affected Service and provider, explaining the concern and its application to the actual workflow, and writing to legal@henryai.co.za before the notice period expires.

4.4. An objection under this Section requires a specific data-protection basis. General commercial, procurement, provider-preference or competitor concerns may be discussed separately, but do not constitute objections under this Section.

4.5. Henry will address a valid objection in good faith and may provide information or safeguards, offer an available alternative at additional cost, or suspend the optional feature. If the concern cannot reasonably be resolved before the notice period ends, either party may terminate the affected Service by written notice, and Henry will refund unused prepaid recurring Fees for the post-termination period. These options are the Tenant's contractual remedies for the objection.

4.6. After a material incident or material processing or location change, a Tenant may request additional assurance reasonably necessary to evaluate the affected Suboperator. Henry will first provide available contract, configuration or independent-assurance information and will not charge for ordinary existing evidence. Material custom review or audit work may be scoped at a fair cost only where it is not required to enable the Tenant to meet a legal duty.

4.7. To preserve commercial clarity, an objection does not permit withholding an unrelated undisputed payment or require Henry to build an alternative, create a residency commitment, or grant source-code or unrestricted audit rights. A fixed provider list, approval right, longer notice period or specific region is not included in the standard Service.

5. Contact

Provider questions, notice subscriptions, substantiated objections and urgent provider-related security concerns may be sent to legal@henryai.co.za. Henry's full contact details are stated in the Privacy Policy Section 1.

END OF SUBOPERATOR LIST