Terms of service · Sentinel

These terms govern your organisation's use of Sentinel, a software service provided by Drame Corp ("we", "us"). By creating an account or using Sentinel on behalf of an organisation, you confirm that you have authority to accept these terms for it ("you", the "customer"). If your organisation has signed an order form or master agreement with us, that document takes precedence where it differs from these terms.

1. The service

Sentinel provides transaction monitoring, screening, identity verification, case management, decisioning and reporting tools through a web dashboard and APIs. We may improve and change features over time; we will not materially reduce the core functionality of a paid plan during a paid billing period.

The sandbox environment is provided free of charge for testing, with no service commitment, and must not be used with real customer data.

2. Your regulatory responsibility

Sentinel is a tool that supports your anti-money laundering, counter-terrorist financing and counter-proliferation financing programme. It is not licensed, approved or endorsed by the Central Bank of Nigeria, the NFIU or any other regulator. You remain solely responsible for:

your compliance with all laws, regulations and regulatory guidance that apply to you;
configuring rules, thresholds and screening to suit your risk assessment;
reviewing alerts and decisions, and every action you take on your customers, including blocking, holding or exiting a relationship; and
reviewing, approving and submitting regulatory reports, including STRs and CTRs, to the NFIU or any other authority.

Scores, alerts, matches and recommendations produced by Sentinel are inputs to your own judgement, not determinations of guilt or suspicion.

3. Accounts and security

You are responsible for the people you invite, the roles you give them and all activity under your account and API keys. Keep credentials and signing secrets confidential, enable two-factor authentication for your users, and tell us promptly at [email protected] if you suspect unauthorised access.

4. Acceptable use

You must not use Sentinel to break the law; to process data you have no lawful basis to process; to probe, overload or attempt to bypass the security of the service; to access another customer's data; to reverse engineer the service except as the law permits; or to resell it without our written agreement. You must not share confirmed-fraud signals with the Sentinel network except in line with the network terms you accept in the dashboard.

5. Data protection

For the personal data you send to Sentinel about your customers, you are the data controller and we are your data processor. Our data processing agreement forms part of these terms and sets out how we process that data, the sub-processors we use, our security measures and how we help you meet your obligations under the Nigeria Data Protection Act 2023. You confirm that you have a lawful basis, and any consent required, for the data you send us, including for identity verifications. Our privacy policy explains how we handle the personal data of your staff who use the dashboard.

6. Fees and payment

Paid plans are billed in advance, monthly or annually, at the prices shown at sign-up or in your order form, plus VAT and any other applicable taxes.
Usage above your plan's included volume is billed at the overage rate for your plan. Identity checks are paid for from a prepaid credit wallet.
Subscriptions renew automatically at the end of each period unless cancelled before the renewal date.
If payment fails, we may restrict your organisation to read-only access after notice. We will not make the decisions API block your customers because of a billing problem.
Fees already paid are non-refundable except where the law or these terms say otherwise.

7. Confidentiality and intellectual property

Each party will protect the other's confidential information and use it only for the purposes of this agreement. You own your data. We own Sentinel, including its software, models, rule templates and documentation, and grant you a non-exclusive, non-transferable right to use it during your subscription. Each machine-learning model trained on your data is used only for your organisation. You may give us feedback, which we may use freely.

8. Availability and support

We work to keep Sentinel available at all times and our SDKs are designed to fail open, so that an interruption on our side does not block your customers' transactions. Service levels, if any, are those set out in your order form. Support is provided by email at [email protected].

9. Warranties and disclaimers

We will provide Sentinel with reasonable skill and care. Except as stated in these terms, Sentinel is provided "as is", and we do not warrant that it will detect every instance of fraud, money laundering or sanctions exposure, that it is free of errors, or that its use will satisfy any regulator.

10. Liability

To the extent the law allows, neither party is liable for indirect or consequential loss, or for loss of profits, revenue or goodwill, and each party's total liability arising from these terms in any 12-month period is limited to the fees paid or payable by you for Sentinel in that period. These limits do not apply to liability that cannot be limited by law, to your payment obligations, or to breach of confidentiality or data protection obligations, which are subject to the limits in the data processing agreement.

11. Term and termination

These terms apply for as long as you use Sentinel. Either party may terminate for material breach that is not remedied within 30 days of notice. You may cancel your subscription at any time, effective at the end of the current billing period. After termination, you may export your data for 30 days, after which we will delete or anonymise it, except where we must keep it by law.

12. General

These terms are governed by the laws of the Federal Republic of Nigeria, and the courts of Lagos State have jurisdiction over disputes, unless your order form says otherwise. We may update these terms by giving you at least 30 days' notice of material changes. Neither party may assign the agreement without the other's consent, except to a successor of its business. Notices to us should be sent to [email protected].