1. Who We Are
WhiteRabbit Agro Limited (“we”, “us”) operates the OriginTrace agricultural traceability platform. We are the data controller for personal data processed through the Platform. Our registered address is Lagos, Nigeria.
2. Data We Collect
Account data: Name, email address, phone number, organisation name, and role when you register.
Farmer and field agent data: Names, phone numbers, national ID references, GPS farm coordinates, compliance attestation records, and KYC information uploaded by your organisation. You are responsible for obtaining consent from farmers and agents whose data you upload.
Transaction data: Payment records, subscription history, and billing contact information.
Usage data: API calls, page views, feature usage, error logs, and device/browser information for platform operation and security.
3. How We Use Your Data
We use personal data to: (a) provide and operate the Platform; (b) process payments; (c) send transactional emails (document expiry alerts, payment receipts, security notices); (d) comply with our own legal obligations; (e) investigate security incidents and prevent fraud; (f) improve the Platform through aggregated, anonymised analytics.
We do not sell personal data. We do not use personal data for advertising.
4. Legal Basis for Processing
Under the Nigeria Data Protection Act 2023 and GDPR (for EU-linked data subjects), we process personal data on the following bases: (a) contractual necessity — to deliver the service you subscribe to; (b) legal obligation — to comply with tax, anti-money-laundering, and export regulations; (c) legitimate interests — for security monitoring and fraud prevention; (d) consent — for any processing you explicitly authorise.
5. Data Sharing
We share personal data only with: (a) Supabase (database and storage infrastructure, hosted in EU-West); (b) Resend (transactional email delivery); (c) Paystack (payment processing); (d) Sentry (error monitoring, anonymised); (e) competent authorities where legally required. All sub-processors are bound by data processing agreements.
6. International Data Transfers
Your data may be stored in data centres outside Nigeria, including the European Union. Where data is transferred internationally, we ensure appropriate safeguards are in place including standard contractual clauses or adequacy decisions.
7. Data Retention
We retain account and traceability data for the duration of your subscription plus 3 years, to comply with commodity traceability obligations under EUDR and related regulations. Payment records are retained for 7 years for accounting and tax purposes. You may request earlier deletion subject to legal retention obligations.
8. Your Rights
Depending on your jurisdiction, you may have the right to: access your personal data; correct inaccurate data; request deletion (right to erasure); receive your data in a portable format (data portability); object to or restrict processing; withdraw consent at any time.
You can exercise your right to deletion and data export directly from your account settings. For other requests, contact us at privacy@origintrace.trade. We will respond within 30 days.
9. Security
We implement row-level security, encrypted data at rest and in transit (TLS 1.2+), rate limiting, audit logging, and regular security reviews. Access to production data is restricted to authorised personnel. We will notify affected users within 72 hours of becoming aware of a data breach where required by law.
10. Cookies
We use session cookies necessary for authentication. We do not use advertising or tracking cookies. Analytics, if implemented, use anonymised, aggregate data only.
11. Children
The Platform is not directed at individuals under 18 years of age. We do not knowingly collect personal data from minors.
12. Changes to This Policy
We may update this policy to reflect changes in our practices or applicable law. We will notify you by email and update the effective date. The current version is always available at origintrace.trade/legal/privacy.
13. Contact
Data protection enquiries: privacy@origintrace.trade
WhiteRabbit Agro Limited, Lagos, Nigeria.