Privacy Policy

1. Introduction

Excel Agro Value Chain Nigeria Limited (“EXCELAGROVC”, “we”, “us”, “our” or “Company”) is committed to protecting the privacy, security and rights of individuals whose personal information is processed through our AI-Powered Digital Agriculture Infrastructure Platform and related services (collectively, the “Platform”).

The Platform is designed to connect and enable farmers, agricultural cooperatives, agribusinesses, financial institutions, insurers, input suppliers, aggregators, processors, logistics providers, off-takers, government institutions, development organisations, investors and other participants within the agricultural value chain.

This Privacy Policy explains how EXCELAGROVC collects, receives, uses, stores, protects, shares and otherwise processes personal data when you:

• visit or use our websites, applications or digital platforms;
• register as a farmer, agribusiness, partner, buyer, supplier or other participant;
• use agricultural, financial-inclusion, marketplace, insurance or value-chain services made available through the Platform;
• communicate with us;
• participate in agricultural programmes, surveys or field activities;
• interact with our agents, representatives or authorised partners; or
• otherwise engage with EXCELAGROVC.

This Policy should be read together with EXCELAGROVC’s Data & Consent Policy, Terms & Conditions, Partner Terms, Marketplace Terms and any service-specific terms applicable to you.

2. Who We Are

Data Controller:
Excel Agro Value Chain Nigeria Limited (EXCELAGROVC)

Registered Address:
No. 1, Ojonugwa Edmond-Ekele Close, Opposite 500 Housing Units, By Mobile Filling Station, Ganaja-Ajaokuta Road, Lokoja, Kogi State.

Email:
enquiry@excelagrovc.com

Telephone:
08098953334, 08121746855

Data Protection Contact/DPO:
privacy@excelagrovc.com
No. 1, Ojonugwa Edmond-Ekele Close, Opposite 500 Housing Units, By Mobile Filling Station, Ganaja-Ajaokuta Road, Lokoja, Kogi State.
08098953334, 08121746855

EXCELAGROVC may act as a data controller, joint controller or data processor depending on the particular service, relationship and purpose for which personal data is processed.

Where EXCELAGROVC processes data on behalf of a bank, insurer, government institution, payment provider or other partner, the relevant partner may remain the data controller for the relevant processing activity.

3. Personal Data We May Collect

Depending on your relationship with EXCELAGROVC, we may collect different categories of information.

3.1 Identity and Registration Data

This may include:

• full name;
• date of birth;
• gender where legitimately required;
• photograph;
• nationality;
• identification information;
• identity-verification information;
• signature;
• farmer or enterprise identification number; and
• other information necessary for registration or verification.

3.2 Contact Information

This may include:

• telephone number;
• email address;
• residential or business address;
• community, village, Local Government Area and State;
• emergency or authorised contact information where appropriate.

3.3 Agricultural and Farm Data

For farmers and agricultural businesses, this may include:

• farm location;
• farm size;
• GPS/geospatial information;
• crops cultivated;
• livestock or aquaculture activities;
• planting and harvesting information;
• production records;
• input usage;
• yields;
• farm assets;
• equipment information;
• agricultural practices;
• historical farm activities;
• aggregation information;
• sales and off-take information;
• weather or agronomic information associated with a farm;
• photographs, videos and field records; and
• other information required to support agricultural services.

3.4 Financial and Transaction Information

Where relevant and lawfully permitted, this may include:

• transaction records;
• payment history;
• invoices;
• purchase and sales records;
• financing applications;
• repayment information;
• insurance-related information;
• account identifiers;
• information necessary for financial or risk assessment; and
• records supplied by authorised financial institutions or service providers.

EXCELAGROVC does not require users to provide financial credentials or passwords to EXCELAGROVC through insecure channels.

Where regulated financial transactions are conducted by a licensed financial institution or payment provider, that institution’s privacy policy and terms may also apply.

3.5 Device and Technical Information

When you use the Platform, we may collect:

• IP address;
• device type;
• operating system;
• browser information;
• application version;
• device identifiers;
• log information;
• approximate location;
• network information;
• usage information;
• authentication information; and
• information relating to security events.

3.6 Communications and Support Data

We may retain information you provide when you contact:

• customer support;
• field agents;
• relationship managers;
• help desks;
• programme officers;
• technical support;
• dispute-resolution channels; or
• other EXCELAGROVC personnel.

3.7 Information Received From Third Parties

We may receive personal information from:

• financial institutions;
• insurance companies;
• payment service providers;
• agricultural cooperatives;
• government agencies;
• development organisations;
• employers or business partners;
• approved verification providers;
• off-takers;
• suppliers;
• logistics companies;
• authorised representatives; and
• other lawful sources.

4. How We Collect Information

We may collect information:

• directly from you;
• through EXCELAGROVC websites and applications;
• through authorised field agents;
• through farmer registration and enumeration exercises;
• through farm mapping and verification;
• through transactions conducted through the Platform;
• from participating partners;
• from public or lawfully accessible sources;
• through devices, cookies and similar technologies; and
• through information provided by government or programme partners where legally permitted.

5. Why We Process Personal Data

EXCELAGROVC may process personal data for lawful purposes including:

5.1 Platform Registration and Account Management

To create, verify, manage and secure user accounts and digital identities.

5.2 Agricultural Services

To provide:

• agricultural information;
• farm mapping;
• extension support;
• production monitoring;
• aggregation;
• market linkage;
• agricultural advisory services;
• value-chain coordination; and
• other agricultural services.

5.3 Financial Inclusion

Where permitted and subject to applicable regulation, data may be used to facilitate introductions, applications, assessments and transactions involving licensed financial institutions, payment providers or other authorised financial service providers.

EXCELAGROVC does not represent itself as a bank, lender, insurer or payment institution unless and to the extent separately authorised under applicable law.

5.4 Insurance and Risk Management

Where relevant, information may be shared with licensed insurers or authorised insurance partners for quotation, underwriting, claims administration, agricultural risk management or related purposes.

5.5 Marketplace and Commercial Transactions

To facilitate transactions between farmers, suppliers, buyers, processors, aggregators, logistics providers and other marketplace participants.

5.6 AI, Analytics and Decision Support

EXCELAGROVC may use data, including aggregated, anonymised or appropriately protected data, to:

• provide agricultural insights;
• forecast agricultural activity;
• identify operational risks;
• improve services;
• support agricultural planning;
• detect fraud or unusual activity;
• improve platform performance;
• develop analytical models; and
• support decision-making.

Where an automated system is used in a manner that has significant consequences for an individual, EXCELAGROVC will implement appropriate safeguards, including applicable rights relating to automated decision-making and human review.

5.7 Compliance and Security

We may process information to:

• prevent fraud;
• detect abuse;
• investigate security incidents;
• enforce our agreements;
• comply with legal requirements;
• respond to lawful requests from authorities; and
• protect the rights, property and safety of EXCELAGROVC and Platform users.

6. Lawful Basis for Processing

EXCELAGROVC will process personal data only where there is a lawful basis under applicable data-protection law.

Depending on the circumstances, this may include:

• performance of a contract;
• compliance with a legal obligation;
• protection of vital interests;
• performance of a task carried out in the public interest or exercise of official authority where applicable;
• legitimate interests, where permitted and appropriately balanced; and
• consent.

Consent will not be presented as the sole legal basis where another lawful basis appropriately applies.

Where consent is relied upon, it will be obtained in a manner that is appropriately informed, specific, freely given and unambiguous.

7. Data Sharing

EXCELAGROVC may share personal data only where there is a lawful basis and where such sharing is necessary and proportionate.

Recipients may include:

• banks and licensed financial institutions;
• payment service providers;
• licensed insurers;
• agricultural aggregators;
• buyers and off-takers;
• processors;
• logistics providers;
• technology and cloud-service providers;
• identity and verification providers;
• government authorities;
• programme sponsors;
• development organisations;
• professional advisers;
• auditors;
• legal advisers;
• regulators; and
• other authorised ecosystem participants.

We will not sell personal data merely as a commodity.

Where information is shared with partners, EXCELAGROVC will seek to ensure that contractual, technical and organisational safeguards appropriate to the relationship are in place.

8. Data Minimisation

EXCELAGROVC will seek to collect and process information that is reasonably necessary for the particular purpose for which it is being used.

We will avoid requesting unnecessary personal information.

9. Agricultural Data and Farm Information

Agricultural data may constitute an important commercial asset for farmers, agribusinesses, government programmes and the wider agricultural ecosystem.

EXCELAGROVC will distinguish between:

• personal data belonging to identifiable individuals;
• farm and enterprise data;
• aggregated or anonymised datasets;
• platform-generated analytics;
• proprietary EXCELAGROVC technology and intellectual property; and
• data supplied by government or other partners subject to contractual ownership rights.

Where farmers or partners provide data, EXCELAGROVC will process it according to the applicable consent, contract, law and data-governance arrangements.

EXCELAGROVC will not imply that registration automatically transfers ownership of a person’s personal data to EXCELAGROVC.

10. Cookies and Similar Technologies

The Platform may use cookies and similar technologies to:

• maintain sessions;
• authenticate users;
• remember preferences;
• improve functionality;
• monitor performance;
• analyse usage; and
• improve security.

Where required, users will be provided with appropriate choices concerning non-essential cookies.

11. Data Security

EXCELAGROVC will implement reasonable technical and organisational safeguards designed to protect personal data from:

• unauthorised access;
• unlawful processing;
• accidental loss;
• destruction;
• alteration;
• inappropriate disclosure; and
• other security threats.

Measures may include:

• access controls;
• role-based permissions;
• encryption where appropriate;
• authentication controls;
• secure backups;
• logging and monitoring;
• vulnerability management;
• incident-response procedures;
• staff confidentiality requirements; and
• security reviews.

No digital system can be guaranteed to be completely secure.

12. Data Retention

EXCELAGROVC will retain personal data only for as long as reasonably necessary for the purpose for which it was collected, unless a longer period is required or permitted by law, regulation, contractual obligations or legitimate business requirements.

Retention periods may differ depending on:

• the category of information;
• the nature of the service;
• legal obligations;
• financial records;
• dispute resolution;
• audit requirements;
• government programmes; and
• security and fraud-prevention requirements.

When information is no longer required, EXCELAGROVC will seek to securely delete, anonymise or otherwise dispose of it in accordance with applicable requirements.

13. Data Subject Rights

Subject to applicable law and legitimate exceptions, individuals may have rights including:

• the right to be informed;
• the right to access personal data;
• the right to rectification;
• the right to erasure where applicable;
• the right to restriction of processing;
• the right to object to certain processing;
• the right to data portability where applicable;
• the right to withdraw consent where processing is consent-based; and
• rights concerning certain forms of automated decision-making.

The NDPC recognises these types of data-subject protections under Nigeria’s data-protection framework.

Requests may be submitted through:

Privacy/Data Rights Email: privacy@excelagrovc.com

EXCELAGROVC may need to verify the identity of the person making a request before disclosing or changing personal information.

14. Withdrawal of Consent

Where processing is based on consent, you may withdraw your consent.

Withdrawal of consent does not affect the lawfulness of processing that occurred before withdrawal and does not necessarily require EXCELAGROVC to stop processing where another lawful basis applies.

15. Children and Persons Lacking Legal Capacity

Where EXCELAGROVC services are made available to children or persons lacking legal capacity to consent, EXCELAGROVC will implement appropriate safeguards.

Where consent is the applicable lawful basis, EXCELAGROVC will obtain the consent of a parent or legal guardian as required by law. The NDPA specifically provides safeguards for children and persons lacking legal capacity.

16. Cross-Border Data Transfers

EXCELAGROVC may use technology providers, infrastructure or partners located outside Nigeria.

Where personal data is transferred outside Nigeria, EXCELAGROVC will comply with applicable requirements governing international or cross-border transfers, including appropriate safeguards and lawful transfer mechanisms.

The NDPC identifies adequacy decisions and other legally recognised mechanisms for cross-border transfers.

17. Third-Party Platforms

The EXCELAGROVC Platform may contain links, integrations or services provided by third parties.

EXCELAGROVC is not responsible for the privacy practices of third-party websites or services that it does not control.

Users should review the privacy notices and terms applicable to those third-party services.

18. Data Breaches and Incident Response

EXCELAGROVC will maintain procedures for identifying, assessing, containing, investigating and responding to personal-data security incidents.

Where applicable law requires notification to affected individuals, regulators or other parties, EXCELAGROVC will make the required notifications within the applicable timeframe.

19. Direct Marketing

Where required, EXCELAGROVC will obtain the appropriate consent or rely on another lawful basis permitted by law before sending direct marketing communications.

Users may unsubscribe from marketing communications at any time.

Transactional, security, account and legally required communications may continue where necessary.

20. Changes to This Policy

EXCELAGROVC may update this Privacy Policy periodically to reflect:

• changes to the Platform;
• new services;
• technological developments;
• legal or regulatory changes; or
• improvements in our privacy practices.

The updated version will be published through the Platform and will indicate the new effective date.

21. Contact and Complaints

For privacy questions, requests or complaints, contact:

EXCELAGROVC Privacy/Data Protection Office
Excel Agro Value Chain Nigeria Limited
No. 1, Ojonugwa Edmond-Ekele Close, Opposite 500 Housing Units, By Mobile Filling Station, Ganaja-Ajaokuta Road, Lokoja, Kogi State.
Email: privacy@excelagrovc.com
Telephone: 08098953334, 08121746855

Where a data subject believes that their rights have not been adequately addressed, they may also exercise any applicable statutory right to lodge a complaint with the Nigeria Data Protection Commission.

22. Governing Law

This Privacy Policy shall be interpreted in accordance with the laws of the Federal Republic of Nigeria and other applicable laws and regulations governing data protection, privacy, electronic transactions, consumer protection and digital services.

END OF PRIVACY POLICY