Data Governance, Data Use & Consent Policy

1. Purpose

This Data Governance, Data Use & Consent Policy establishes the principles under which EXCELAGROVC collects, validates, processes, shares, analyses, protects and uses information within its AI-Powered Digital Agriculture Infrastructure Platform.

The purpose of this Policy is to ensure that agricultural data and personal data are processed responsibly while enabling EXCELAGROVC to deliver digital agricultural infrastructure, financial inclusion, insurance access, agricultural intelligence, marketplace connectivity and value-chain services.

2. Our Data Principles

EXCELAGROVC adopts the following core principles:

2.1 Lawfulness

Data will be processed on a lawful basis.

2.2 Fairness

EXCELAGROVC will not intentionally use data in a manner that unfairly exploits or discriminates against data subjects.

2.3 Transparency

Users should understand what information EXCELAGROVC collects, why it is required and, where applicable, who may receive it.

2.4 Purpose Limitation

Data collected for one stated purpose will not automatically be used for unrelated purposes without an appropriate lawful basis.

2.5 Data Minimisation

EXCELAGROVC seeks to collect only data that is relevant and reasonably necessary.

2.6 Accuracy

EXCELAGROVC will take reasonable steps to maintain accurate and up-to-date information.

2.7 Security

Data will be protected using appropriate technical and organisational measures.

2.8 Accountability

EXCELAGROVC will maintain appropriate governance, documentation and controls over data-processing activities.

2.9 Privacy by Design and Default

Privacy considerations will be incorporated into the design, development, deployment and operation of EXCELAGROVC’s digital products and services.

Nigeria’s data-protection framework expressly recognises privacy by design and default as an important safeguard.

3. Categories of Data

EXCELAGROVC may manage several categories of data.

A. Personal Data

Information relating to an identifiable individual.

B. Agricultural Data

Information relating to farms, agricultural activities, production, inputs, livestock, crops, yields, locations, transactions and value-chain operations.

C. Enterprise Data

Information concerning cooperatives, SMEs, agribusinesses, suppliers, processors, off-takers and other organisations.

D. Transaction Data

Information concerning orders, payments, financing applications, insurance transactions and marketplace activity.

E. Operational Data

Information generated by the operation of the Platform.

F. Analytics and Derived Data

Insights, indicators, scores, classifications, predictions and analyses generated from lawful processing.

4. Consent

Where EXCELAGROVC relies on consent, consent must be:

• voluntary;
• specific;
• informed;
• understandable;
• unambiguous; and
• capable of being withdrawn.

Consent may be obtained electronically, digitally, in writing, orally where legally appropriate, or through another legally recognised affirmative action.

EXCELAGROVC will avoid treating silence, inactivity or pre-ticked boxes as affirmative consent where affirmative action is required.

5. Consent Must Be Purpose-Specific

A farmer registering on EXCELAGROVC’s Platform may encounter separate consent requests for different purposes.

For example:

Platform Service Consent

“I consent to EXCELAGROVC processing my information to create and administer my EXCELAGROVC account and provide the services I request.”

Financial Services Consent

“I authorise EXCELAGROVC to share relevant information with participating licensed financial institutions for the purpose of assessing and processing financial products I request.”

Insurance Consent

“I consent to relevant information being shared with participating insurers for insurance services that I request.”

Marketplace Consent

“I consent to relevant transaction and delivery information being shared with marketplace participants where necessary to complete my transactions.”

Marketing Consent

“I consent to receiving promotional communications from EXCELAGROVC and its approved partners.”

Each optional consent should be distinguishable from mandatory information necessary to provide the underlying service.

6. Withdrawal of Consent

Users may withdraw consent where processing is based on consent.

Withdrawal may be initiated through:

• Platform settings;
• customer support;
• written request;
• designated privacy channel; or
• another method communicated by EXCELAGROVC.

Withdrawal does not invalidate processing that occurred before the withdrawal.

7. Farmer Data Consent

EXCELAGROVC recognises that farmers may be contributing information that has economic value.

A farmer’s participation in the Platform does not automatically mean that EXCELAGROVC owns all information relating to that farmer.

Where appropriate:

• personal data remains subject to the rights of the data subject;
• government-supplied datasets remain subject to applicable government ownership and contractual arrangements;
• partner data remains subject to applicable agreements; and
• EXCELAGROVC retains rights in its proprietary software, systems, methodologies, algorithms, platform architecture and other intellectual property.

8. Government-Supplied Farmer Data

Where a government ministry, agency or programme provides historical farmer or agricultural records to EXCELAGROVC, the applicable agreement will determine:

• ownership;
• permitted uses;
• data-access rights;
• security obligations;
• update responsibilities;
• retention;
• sharing rights;
• commercialisation of value-added services; and
• rights of farmers to provide fresh consent where required.

EXCELAGROVC will not assume ownership of government datasets merely because it digitises or manages them.

9. Data Enrichment

Where legally permitted and appropriately authorised, EXCELAGROVC may enrich agricultural records using additional information such as:

• farm mapping;
• production history;
• transaction history;
• agricultural programme participation;
• market information;
• weather information;
• geospatial information;
• logistics information;
• verified enterprise information; and
• other lawful datasets.

Data enrichment will be undertaken for legitimate and stated purposes.

10. AI and Analytics

EXCELAGROVC may use AI and analytics to support:

• agricultural advisory services;
• yield forecasting;
• crop and livestock monitoring;
• fraud detection;
• operational optimisation;
• agricultural risk assessment;
• market intelligence;
• financial inclusion;
• insurance-related risk analysis;
• supply-chain planning; and
• other legitimate Platform functions.

AI outputs may be probabilistic or predictive and should not automatically be treated as factual or guaranteed outcomes.

Where an automated decision may have significant consequences for an individual, EXCELAGROVC will provide appropriate safeguards in accordance with applicable law, including applicable rights to challenge or seek human review.

11. Agricultural AI Advisory Disclaimer

Agricultural recommendations generated by EXCELAGROVC’s AI systems are intended as decision-support tools.

They do not automatically constitute professional agricultural, veterinary, financial, legal, insurance or investment advice.

Users should consider relevant professional advice and local conditions before making material decisions.

12. Credit and Risk Information

Where permitted and where the user has requested or is participating in a relevant financing process, EXCELAGROVC may provide information or analytical outputs to a licensed financial institution.

Such outputs may include:

• production history;
• transaction behaviour;
• farm characteristics;
• repayment information;
• verified enterprise information;
• risk indicators; and
• other lawful information relevant to the financial institution’s assessment.

The final decision to approve, decline, price or otherwise administer a regulated financial product remains with the relevant licensed institution unless otherwise lawfully agreed.

13. Data Sharing with Partners

EXCELAGROVC may establish data-sharing arrangements with:

• banks;
• insurers;
• payment providers;
• government agencies;
• agribusinesses;
• off-takers;
• processors;
• suppliers;
• logistics providers;
• development organisations;
• technology providers; and
• other approved ecosystem participants.

Access should be limited to the information reasonably necessary for the relevant purpose.

14. Data Access Levels

EXCELAGROVC may establish role-based access controls such as:

Level 1 – User Access:
Users see their own permitted information.

Level 2 – Partner Access:
Approved partners receive only relevant information necessary for their service.

Level 3 – Programme Access:
Government or development-programme stakeholders may receive approved programme information.

Level 4 – Internal Restricted Access:
EXCELAGROVC personnel receive access according to operational need and role.

Level 5 – System/Administrative Access:
Highly restricted technical access subject to enhanced security controls.

15. Anonymised and Aggregated Data

Where appropriate, EXCELAGROVC may create aggregated or anonymised information from Platform data.

Such information may be used for:

• agricultural research;
• market intelligence;
• sector analysis;
• planning;
• product development;
• investor reporting;
• impact measurement;
• policy development; and
• Platform improvement.

EXCELAGROVC will seek to ensure that such information cannot reasonably identify individual data subjects where it is represented as anonymised.

16. Data Commercialisation

EXCELAGROVC may develop lawful data-enabled services, analytics, dashboards, reports, market intelligence and other value-added products.

EXCELAGROVC will not interpret this provision as giving it unrestricted ownership or permission to commercially exploit an individual’s personal data contrary to applicable law.

Any commercial use involving identifiable personal data must have an appropriate lawful basis and appropriate disclosures.

17. Consent Records

EXCELAGROVC may maintain records showing:

• what consent was requested;
• the purpose;
• when consent was given;
• how consent was obtained;
• the version of the relevant notice;
• what information was presented to the user; and
• when consent was withdrawn.

18. Data Retention

Retention periods will be determined according to:

• the purpose of processing;
• contractual obligations;
• statutory requirements;
• financial and audit obligations;
• agricultural programme requirements;
• dispute resolution;
• fraud prevention;
• security considerations; and
• legitimate operational requirements.

19. Special Categories of Personal Data

EXCELAGROVC will apply heightened safeguards to information classified as sensitive personal data or otherwise requiring special protection under applicable law.

Such information will not be collected merely because it is technologically possible to collect it.

20. Children and Vulnerable Persons

Where EXCELAGROVC services involve children or persons lacking legal capacity, appropriate legal and technical safeguards will be applied.

Where consent is required, appropriate parental or guardian consent mechanisms will be implemented.

21. Third-Party Processors

Where EXCELAGROVC engages a third-party technology provider to process data, EXCELAGROVC will seek to establish appropriate contractual obligations covering:

• confidentiality;
• security;
• authorised processing;
• data retention;
• incident management;
• sub-processing;
• deletion or return of data;
• regulatory cooperation; and
• other appropriate safeguards.

22. Cross-Border Processing

Where EXCELAGROVC or its technology partners process personal data outside Nigeria, appropriate legal safeguards will be implemented in accordance with applicable cross-border data-transfer requirements.

23. Data Breach Management

EXCELAGROVC will maintain a data-security incident response process covering:

• detection;
• containment;
• investigation;
• risk assessment;
• remediation;
• documentation;
• regulatory notification where required; and
• communication to affected data subjects where required.

24. User Responsibility

Users must provide information that is truthful, accurate and not misleading.

Users must not:

• register another individual without lawful authority;
• impersonate another person;
• submit fraudulent documentation;
• provide false farm information;
• unlawfully obtain another person’s data;
• misuse another person’s account; or
• attempt to access restricted Platform data.

25. Consent for Partner Services

Where EXCELAGROVC acts as the digital infrastructure connecting users to third-party services, users may be required to review and accept the terms and privacy notices of the relevant partner.

For example, a farmer applying for a loan may need to separately accept the lender’s:

• loan terms;
• credit assessment terms;
• privacy notice; and
• applicable regulatory disclosures.

26. Data Rights Requests

Requests concerning personal data may be submitted to:

EXCELAGROVC Data Protection Office
Email: enquiry@excelagrovc.com
Address: No. 1, Ojonugwa Edmond-Ekele Close, Opposite 500 Housing Units, By Mobile Filling Station, Ganaja-Ajaokuta Road, Lokoja, Kogi State.

EXCELAGROVC may verify the identity of the requester before processing a data-rights request.

27. Policy Review

This Policy will be reviewed periodically and may be amended to reflect changes in:

• law;
• regulation;
• technology;
• EXCELAGROVC services;
• partner arrangements;
• AI systems; and
• data-governance practices.

END OF DATA & CONSENT POLICY