Legal

Tenant Terms of Service

Version 1.1 · effective 2026-07-31. Superseded by v1.2 on 2026-11-15. Published here because it remains the version in force until then, and because an acceptance row recorded against [email protected] must stay readable for as long as the row does.

These are the terms a farm accepts inside the Koklo Nya application, recorded against this version number. They are not the website terms, which govern use of www.koklonya.com.

Version: 1.1 Effective date: 2026-07-31 Acceptance: required on first sign-in by every user; recorded in public.tenant_ts_acceptance (id, tenant_id, user_id, version, accepted_at, ip_address, user_agent)

⛔⛔ MATERIAL CORRECTION, 14 September 2026 — §2's CROSS-BORDER PARAGRAPH BELOW IS WRONG ABOUT THE LAW, AND THIS VERSION IS STILL IN FORCE. §2 ("Cross-border transfer rationale") states that the Ghana Data Protection Commission has recognised the UK and EU as providing "adequate" protection, and that transfer is therefore lawful without Standard Contractual Clauses or your consent. There is no such recognition, because there is no mechanism to make one. The Data Protection Act 2012 (Act 843) contains no provision permitting or restricting the transfer of personal data out of Ghana, no mechanism for declaring a foreign country adequate, and no such function among the Commission's functions under s.3. So there is no adequacy decision for anyone to rely on, and the sentence claiming one should never have been written.

⚠ WHAT THIS DOES AND DOES NOT CHANGE. It does not change where your data is stored, and it does not make the transfer unlawful — Act 843 simply does not gate it. What was wrong was the stated BASIS. §2 of v1.2 carries the corrected statement in full, including the duties that do follow the data, and v1.2 takes effect 2026-11-15. Until that date this version governs, which is why the correction is given here rather than left to the new edition.

⚠ The archived §2 text below is left standing, not rewritten — it is what was accepted against [email protected], and an acceptance record whose document has been edited underneath it is worth less than one with a correction attached. This paragraph is the correction. Recorded in Addendum 2 of docs/audit-reviews/CA_DETERMINATION_data_residency_act915_s27_2026-09-07.md (errand D-6).

⛔ EDITORIAL CORRECTION, 7 September 2026 — read this before the note below. This is the archived text of v1.1, published so that an acceptance recorded against [email protected] stays readable for as long as the row does. Two editorial changes were made to it, neither of which touches an operative term: the footer said "End of Tenant Terms of Service v1.0", a version marker never updated when v1.1 was issued; and the note immediately below asserts that public.tenant_ts_acceptance did not exist. That was true when v1.1 was written and is no longer true — migration 20260722000142_tenant_terms_acceptance created the table, the API reads and writes it, and the acceptance step is live. The note is left standing rather than rewritten, because it is part of the archived document; this paragraph is the correction. See §14 of v1.2 for the change process that now governs, and Addendum 2 of docs/audit-reviews/CA_DETERMINATION_data_residency_act915_s27_2026-09-07.md for how the stale claim was found.

Note on this version. v1.1 adds §1.1 (statutory positions, not advice) and a related responsibility in §6. That is a material change, so §14 would normally require 30 days' notice and explicit re-acceptance. There is no incumbent acceptance to supersede: public.tenant_ts_acceptance does not exist in any migration and no tenant has ever accepted v1.0, so no notice window is running and none is owed. v1.1 is simply the version that will be presented the first time an acceptance step exists. The §14 process governs every change after that.

This Terms of Service governs your tenant's use of Koklonya. By signing into Koklonya you confirm that you have read, understood, and agree to these terms on behalf of your farm or organization (the "tenant"). If you do not agree, do not sign in.

Plain-English version first. A more formal contract section follows for legal review. Where the two conflict, the formal section governs.

1. What Koklonya is

Koklonya is a multi-tenant ERP for poultry farms, operated from Ghana by Edem Segbefia trading as Koklonya (the "operator"). It records your farm's daily production, mortality, sales, procurement, payroll, and accounting data, and produces IFRS-acceptable financial reports for your auditor.

You retain ownership of all data you put into Koklonya. The operator processes that data on your behalf to deliver the service you signed up for, and for no other purpose.

1.1 Statutory positions, not advice

Koklonya applies published rules — tax rates, thresholds, accounting standards — to the figures you enter, and shows you the position those rules produce. That is a computation of general application, not advice about your particular circumstances.

In plain terms:

• What the software does. It surfaces the statutory position that the rules produce on your own data, and shows the provision it relied on so you can check it.
• What it does not do. It does not advise you on your tax affairs, does not tell you what you ought to do about your position, and does not act for you before the Ghana Revenue Authority or any other authority.
• What remains yours. Every return, declaration and filing is made and signed by your own authorised officer. You are the taxpayer of record.
• Please confirm. Statutory positions the software surfaces should be confirmed with your own tax adviser, or with the GRA, before you rely on them — particularly where the amounts are material or your circumstances are unusual.

Where the software shows a figure or an obligation, it is telling you what the rules produce on the facts entered. It is not telling you what to do.

The operator is not your tax adviser, accountant or auditor, and nothing in the service creates that relationship. Where the operator has obtained professional opinions to configure the software correctly, those opinions were obtained for the operator's own purposes — they are quality assurance on the configuration, not advice given to you, and you may not rely on them as such.

2. Where your data lives

Cross-border transfer rationale. Your data is collected in Ghana and stored in the United Kingdom (post-Brexit). The Ghana Data Protection Act 2012 (Act 843) permits cross-border transfer of personal data when the destination jurisdiction provides "adequate" protection. The UK and EU jurisdictions have been recognised as adequate by the Ghana Data Protection Commission, and the UK separately maintains its own GDPR-equivalent regime (UK GDPR + Data Protection Act 2018). Transfer is therefore lawful under Ghanaian law without requiring additional Standard Contractual Clauses or your individual consent for each transfer event.

A Ghana-resident read-only mirror of your data is maintained on operator hardware once your tenant reaches Phase 1 of the operator's infrastructure plan (typically when you sign as a paying customer). The mirror improves analytics performance and offers a disaster-recovery target; it does not change the writeable system of record, which remains in eu-west-2.

If your farm has a regulatory or contractual requirement that data must be hosted inside Ghana, contact the operator before signing in. Koklonya cannot satisfy that requirement today.

3. Security & access

• Encryption in transit: TLS 1.3 enforced on every connection to and from the system.
• Encryption at rest: Supabase Pro encrypts the database with KMS-managed keys. Storage buckets (mortality photos, branding assets, user avatars) are private by default and accessed via signed URLs with finite TTLs.
• Authentication: email + password via Supabase Auth, with optional TOTP-based two-factor. Two-factor is required for any user assigned a role that holds tenant.billing.manage or financials.period.close permissions, after that user's first 30 days.
• Authorization: role-based access control with system, default, and tenant-custom roles. Every mutation is gated by an explicit permission key.
• Audit log: every change to your data writes an append-only audit row recording who did what, when, from which IP, and with what before/after state. Audit rows are retained for seven years from the date of the action and exported on request.
• Idempotency: safe retries are supported via a 24-hour idempotency-key replay window so a flaky network connection cannot cause double charges, double mortality entries, or duplicate batch placements.

The operator does not access your tenant's data except for support work you have requested. When operator staff act on a tenant's behalf, the action runs through an explicit time-limited "impersonation" mechanism that records both a tenant-side audit row and an operator-side audit row, both linked to a support ticket reference.

4. Backups & disaster recovery

• Supabase Pro takes daily logical backups with 7-day point-in-time recovery (PITR) on the application database.
• The operator runs a nightly off-site backup pipeline that exports an encrypted logical dump to Backblaze B2 cold-tier storage, retained for 90 days.
• A restore-drill exercise is performed quarterly on a staging environment to verify the recovery procedure. Results are documented in docs/RUNBOOK_restore_drill.md and available on request.

Recovery objectives:

• RPO (recovery point objective): ≤ 24 hours
• RTO (recovery time objective): ≤ 12 hours for the application; ≤ 24 hours for the database

These objectives are best effort, not contractually guaranteed in this version of the terms. A future enterprise tier may carry contractual SLAs.

5. Service level (Phase 0)

For the first phase of the service (pre-30 tenants), the operator targets:

Service credits, refunds, and contractual SLAs are not available in this version. The operator publishes a public status page at https://status.koklonya.com for incident communication.

6. Your responsibilities

You agree to:

• keep your sign-in credentials secret;
• enable two-factor authentication for any user with elevated permissions;
• review and approve the role assignments for every user you invite;
• pay for the service plan you have selected;
• comply with applicable Ghanaian tax law, the Companies Act 2019, and the Ghana Veterinary Council's notifiable-disease reporting requirements when using the corresponding modules;
• satisfy yourself that any statutory position the software surfaces is correct for your circumstances before relying on it, and confirm it with your own tax adviser or the GRA where the amounts are material (see §1.1) — you remain the taxpayer of record and your own authorised officer signs every return;
• use the service for lawful purposes only.

You agree NOT to:

• attempt to reverse-engineer, decompile, or scrape the application except for legitimate data-export purposes via the published export tools;
• circumvent rate limits or RLS policies;
• use the service to store data unrelated to the operation of a poultry farm;
• introduce malicious code or attempt to compromise the operator's infrastructure.

7. Pricing & billing

The pricing model in effect at sign-up is documented separately and forms part of these terms by reference. You may upgrade or downgrade your plan via Settings → Billing. The operator may change pricing for future billing cycles with at least 30 days' notice; your existing billing cycle is unaffected.

Phase 0 (pre-public launch). During the operator's Phase 0 trial period, Koklonya is provided to invited tenants at no charge. Phase 0 may be ended with 60 days' notice, after which a paid plan must be selected to continue using the service. Your data is preserved across this transition.

8. Suspension & termination

The operator may suspend or terminate your tenant for:

• non-payment of fees overdue more than 30 days;
• material breach of these terms after 14 days' written notice and an opportunity to cure;
• legal compulsion (court order, regulatory action) in which case the operator will notify you to the extent legally permitted.

You may terminate your tenant at any time via Settings → Data & privacy → Request termination. On termination:

1. The operator immediately stops accepting new writes to your tenant.
2. A full data export (CSV + JSONL) is generated and made available to you for 30 days.
3. After 30 days, all tenant data is deleted from the application database and from the off-site backup tier within 90 days, except for records the operator is legally required to retain (see §10 below).
4. Aggregated, fully de-identified usage metrics may be retained indefinitely for product analytics.

9. Data export & portability

You may export your tenant's data at any time without termination via Settings → Data & privacy → Export. Exports are produced as a single ZIP containing:

• a JSONL file per table you have access to;
• a CSV file per major report (DPR, mortality log, payroll register, etc.);
• an audit-log slice covering the export window;
• attached files (mortality photos, branding assets, user avatars) preserved at original resolution.

Export generation is rate-limited to one full export per 24 hours per tenant.

10. Legal retention obligations

The operator may retain certain records beyond your termination date if required by Ghanaian law. As of the effective date of these terms, retention obligations include:

Retained records are encrypted, access-restricted, and used only to discharge the legal obligation that triggered retention. They are deleted at the end of the obligation window without further notice.

11. Limitation of liability

To the fullest extent permitted by Ghanaian law:

• the operator's total aggregate liability to your tenant under these terms in any 12-month period is limited to the fees you paid the operator during that period;
• the operator is not liable for indirect, consequential, special, exemplary, or punitive damages;
• the operator is not liable for losses arising from third-party services (Supabase, Cloudflare, telecommunications providers, payment gateways) where the loss is caused by the third-party's fault and not the operator's;
• nothing in these terms limits liability for fraud or for any liability that cannot be excluded under Ghanaian law.

The service is provided "as is." Specific warranties of merchantability or fitness for a particular purpose are disclaimed except as expressly stated in these terms.

12. Privacy

A standalone Privacy Policy is published at https://koklonya.com/privacy and forms part of these terms by reference. The Privacy Policy describes what personal data Koklonya processes, why, with whom it is shared (no third party for advertising; Supabase / Cloudflare / Backblaze as named sub-processors), how it is secured, and the rights of data subjects under the Ghana Data Protection Act 2012.

You are responsible for the lawful basis on which your tenant collects personal data about its own employees, customers, and suppliers, and for providing them with the privacy notices required under Ghanaian law. Koklonya is the processor of that data on your behalf; your tenant is the controller.

13. Sub-processors

The operator engages the following sub-processors as of the effective date:

The operator gives at least 30 days' notice via email and via the in-app notifications channel before adding or replacing a sub-processor that processes personal data.

14. Changes to these terms

The operator may update these terms from time to time. Material changes (anything affecting your data, your liability, your costs, or your termination rights) require:

• at least 30 days' written notice to the tenant owner's contact email;
• presentation of the new terms in the application on next sign-in;
• explicit re-acceptance by a user with tenant.settings.manage permission, recorded in tenant_ts_acceptance.

If you do not accept the new terms within the notice window, the operator will prepare and offer your full data export, and your tenant will be terminated under §8.

15. Governing law & dispute resolution

These terms are governed by the laws of Ghana. Any dispute arising under these terms will first be addressed by good-faith negotiation between you and the operator. If unresolved within 60 days, the dispute will be referred to mediation in Accra under the Ghana ADR Act 2010. Litigation is a last resort and lies with the courts of the Greater Accra Region.

16. Contact

Acceptance

By signing into Koklonya, you confirm that:

• you are at least 18 years old;
• you have authority to bind your farm or organization to these terms;
• you have read this document end-to-end (or have had it explained to you in a language you understand);
• you accept these terms as written.

Acceptance is recorded with your user id, the version of the terms, the timestamp, the IP address you signed in from, and the user agent. The recorded acceptance is exportable on request.

End of Tenant Terms of Service v1.1.