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Privacy Policy

Last updated: 1st May, 2026

Farmstarck is committed to protecting the personal data of every individual who interacts with our platform. This Privacy Policy (“Policy”) explains how Starcks Novation Limited (“Farmstarck”, “we”, “us”, or “our”) collects, processes, stores, shares and protects your personal data when you access or use www.farmstarck.com (the “Site”) or any Farmstarck mobile or web-based application (the “App”).

This Policy is issued in compliance with the Nigeria Data Protection Act (NDPA) 2023, the Nigeria Data Protection Regulation (NDPR) 2019, and other applicable data protection laws. By accessing or using our Site or App, you acknowledge that you have read and understood this Policy. This Policy should be read alongside our Terms and Conditions. If you do not agree, please discontinue use of our platforms immediately.

1. Identity of the Data Controller

The Data Controller responsible for your personal data under this Policy is:

Starcks Novation Limited (trading as Farmstarck)

Registered Address: 294 Herbert Macaulay Way, Sabo, Yaba, Lagos State, Nigeria

Company Registration Number: RC: 8102199

Email: farmstarck@gmail.com

Website: www.farmstarck.com

As the Data Controller, Farmstarck determines the purposes and means of processing your personal data. Where Farmstarck engages third parties to process data on its behalf, such parties act as Data Processors and are bound by the terms of this Policy and applicable data protection law.

2. Definitions

For the purposes of this Policy, the following terms carry the meanings assigned to them:

Personal Data”:Any information relating to an identified or identifiable natural person, whether directly or indirectly identifiable, including by reference to an identifier such as a name, identification number, location data, or online identifier.
Processing”:Any operation performed on Personal Data, including collection, recording, storage, alteration, retrieval, use, disclosure, transmission, erasure or destruction.
Data Controller”:The entity that determines the purposes and means of Processing Personal Data.
Data Processor”:A person or organisation that Processes Personal Data on behalf of the Data Controller.
Data Subject”:A living natural person whose Personal Data is being Processed.
Consent”:A freely given, specific, informed, and unambiguous indication of the Data Subject's agreement to the Processing of their Personal Data.
NDPA”:The Nigeria Data Protection Act 2023.
NDPC”:The Nigeria Data Protection Commission, the regulatory authority responsible for overseeing data protection compliance in Nigeria.
Sensitive Personal Data”:Data revealing racial or ethnic origin, political opinions, religious beliefs, health data, biometric data or data relating to criminal convictions.

3. Personal Data We Collect

Farmstarck collects the following categories of Personal Data, depending on your interaction with our platforms:

3.1 Identity Data

  • Full name, gender, date of birth, and profile photograph
  • Government-issued identification numbers (such as National Identification Number, BVN, or Passport Number) where required for verification purposes

3.2 Contact Data

  • Residential or business address
  • Phone number and email address

3.3 Account and Access Data

  • Login credentials (username and password — stored in encrypted form)
  • Unique user or customer identification numbers assigned by Farmstarck

3.4 Transactional Data

  • Payment method details (processed through third-party payment providers; Farmstarck does not store full card details)
  • Transaction history, order records, and procurement activity
  • Agricultural produce listings, inventory records, and marketplace activity

3.5 Technical Data

  • Internet Protocol (IP) address
  • Device type, operating system, and browser type
  • Time zone, geolocation data (where permitted), and access timestamps

3.6 Usage Data

  • Activity logs, session duration, and browsing behaviour on the Site and App
  • Features accessed, content viewed, and interactions recorded

3.7 Agricultural and Business Data

  • Farm details, crop types, harvest quantities, and storage information (for farmers and agri-businesses)
  • Business registration details and commercial profile information

3.8 Marketing and Communications Data

  • Marketing preferences, survey responses, and feedback submissions
  • Records of communications between you and Farmstarck

3.9 Sensitive Personal Data

Farmstarck does not intentionally collect Sensitive Personal Data. If you are required to submit any sensitive information for identity verification or regulatory compliance, it will be handled with heightened security measures and processed only on the basis of explicit consent or legal obligation.

4. How We Collect Your Data

4.1 Direct Collection

We collect Personal Data directly from you when you:

  • Register for an account on the Site or App
  • Complete a transaction or procurement request
  • Submit a support ticket, inquiry or feedback form
  • Participate in surveys, promotions or competitions
  • Communicate with us via email, telephone or social media

4.2 Automated Collection

We collect certain Technical and Usage Data automatically through:

  • Cookies and similar tracking technologies (see Section 8)
  • Web beacons, pixel tags and analytics tools
  • Server logs and application performance monitoring tools

4.3 Third-Party Sources

We may receive Personal Data about you from:

  • Payment processors and financial service providers
  • Identity verification services and Know-Your-Customer (KYC) providers
  • Logistics and delivery partners
  • Publicly available sources, regulatory databases, and government registries
  • Social media platforms where you connect your account to Farmstarck

5. Legal Grounds for Processing

Farmstarck processes your Personal Data on the following lawful bases as recognised under the NDPA 2023:

Consent:Where you have freely, specifically, and unambiguously given permission for us to process your data for a defined purpose. You may withdraw consent at any time without affecting the lawfulness of prior processing.
Contractual Necessity:Where Processing is necessary for the performance of a contract to which you are a party or to take steps at your request prior to entering into a contract.
Legal Obligation:Where Processing is required for Farmstarck to comply with a legal or regulatory obligation imposed under Nigerian law or applicable African jurisdiction law.
Legitimate Interest:Where Processing is necessary for the pursuit of Farmstarck's legitimate business interests, such as fraud prevention, platform security and service improvement, provided such interests are not overridden by your fundamental rights and freedoms.
Vital Interest:In rare circumstances, where Processing is necessary to protect the life or physical safety of a Data Subject or another person.
Public Interest:Where Processing is carried out in the exercise of official public interest functions or in support of regulatory compliance activities.

6. Purposes of Processing

We process your Personal Data for the following purposes:

  • Account Management: To create, verify, and manage your Farmstarck account and user profile.
  • Service Delivery: To fulfill product orders, procurement requests and other services you request through the platform.
  • Transaction Processing: To process payments, issue receipts and maintain accurate financial records.
  • Customer Support: To respond to inquiries, resolve complaints and provide technical assistance.
  • Security and Fraud Prevention: To detect, investigate, and prevent fraudulent transactions, misuse or security threats on our platform.
  • Regulatory Compliance: To meet our obligations under Nigerian law, including Know-Your-Customer (KYC) requirements, anti-money laundering regulations and applicable agricultural trade regulations.
  • Platform Improvement: To analyse usage patterns, conduct research and improve the functionality and performance of our Site and App.
  • Personalisation: To deliver content, recommendations, and services tailored to your interests and usage history.
  • Marketing and Communications: To send promotional content, product updates and relevant offers where you have consented or where permitted by applicable law.
  • Legal Proceedings: To establish, exercise or defend legal claims where necessary.

7. Data Sharing and Disclosures

Farmstarck does not sell your Personal Data. We may share your data with the following categories of recipients, under strict confidentiality obligations and only to the extent necessary for the stated purpose:

7.1 Service Providers and Data Processors

  • Cloud hosting and infrastructure providers
  • Payment processing platforms (including SmartCash, Bolt Business, and Kwik logistics)
  • Identity verification and KYC service providers
  • Marketing, analytics and communication platforms
  • Customer support software providers

7.2 Business Partners

Agricultural cooperatives, aggregators, merchants, and logistics partners who are part of the Farmstarck ecosystem, where sharing is necessary to fulfill a transaction or service request.

7.3 Regulatory and Legal Authorities

  • Government agencies, law enforcement bodies, and regulatory authorities where required by applicable law, court order, or enforceable legal process
  • The Nigeria Data Protection Commission (NDPC) and any equivalent authority in applicable jurisdictions

7.4 Professional Advisors

Legal counsel, auditors, and compliance consultants, subject to confidentiality obligations.

7.5 Corporate Transactions

In the event of a merger, acquisition, restructuring or sale of all or substantially all of Farmstarck's assets, your Personal Data may be disclosed to prospective or actual acquirers, subject to equivalent data protection standards being maintained.

All third parties with whom we share Personal Data are required to implement appropriate technical and organisational measures to protect such data and to process it only in accordance with our instructions and applicable data protection law.

8. Cookies and Tracking Technologies

Farmstarck uses cookies and similar technologies on our Site and App. Cookies are small text files stored on your device that help us recognise you and enhance your experience.

8.1 Types of Cookies We Use

Strictly Necessary Cookies:Required for the basic functioning of our platforms. These cannot be disabled without affecting service performance.
Performance and Analytics Cookies:Collect anonymised data about how users interact with the Site and App, used to improve functionality and user experience.
Functional Cookies:Allow the platform to remember your preferences and provide enhanced features.
Marketing and Targeting Cookies:Used to deliver relevant advertising and track the effectiveness of our marketing campaigns. These are activated only with your consent.

8.2 Managing Cookies

You may manage your cookie preferences at any time through the cookie settings panel on our Site or through your browser settings. Please note that disabling certain cookies may affect the functionality of our platforms. Continued use of our Site or App without adjusting your browser settings constitutes acceptance of our use of cookies.

9. Your Data Protection Rights

As a Data Subject under the NDPA 2023, you have the following rights with respect to your Personal Data:

Right of Access:You may request a copy of the Personal Data we hold about you, along with information about how it is processed.
Right to Rectification:You may request that we correct or update any inaccurate, incomplete, or outdated Personal Data.
Right to Erasure:You may request the deletion of your Personal Data where it is no longer necessary for the purpose for which it was collected, where consent is withdrawn, or where the data has been unlawfully processed, subject to applicable legal retention obligations.
Right to Restrict Processing:You may request that we limit the Processing of your Personal Data in certain circumstances, such as where you contest its accuracy or where you object to its use.
Right to Data Portability:Where Processing is based on consent or contractual necessity, you may request that we provide your Personal Data in a structured, commonly used, and machine-readable format or transmit it to another controller where technically feasible.
Right to Object:You may object to the Processing of your Personal Data where we rely on legitimate interest as the legal basis, including profiling based on legitimate interest.
Right to Withdraw Consent:Where Processing is based on consent, you may withdraw that consent at any time without affecting the lawfulness of Processing carried out prior to withdrawal.
Right Not to Be Subject to Automated Decision-Making:You have the right not to be subject to a decision based solely on automated Processing, including profiling, that produces legal or similarly significant effects concerning you.
Right to Lodge a Complaint:You have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC) at www.ndpc.gov.ng, or with any other competent supervisory authority in your jurisdiction.

To exercise any of the rights above, please contact our Data Protection Officer using the details set out in Section 14. We will respond to all verified requests within 30 days, or within such shorter period as may be required by applicable law. We may request proof of identity before acting on any request.

10. Children's Data

Farmstarck's platforms are not directed at or intended for use by persons under the age of 18 years. We do not knowingly collect or process the Personal Data of minors. If you are a parent or guardian and believe that a minor has provided us with Personal Data without your consent, please contact us immediately using the details in Section 14. We will take prompt steps to delete such data from our systems.

11. Data Security

Farmstarck implements appropriate technical and organisational measures to protect your Personal Data against unauthorised access, disclosure, alteration or destruction. Our security measures include:

  • End-to-end encryption for data in transit using industry-standard protocols (TLS/SSL)
  • Encryption and pseudonymisation of data at rest
  • Role-based access controls and multi-factor authentication for system access
  • Regular vulnerability assessments, penetration testing and security audits
  • Documented data breach response and incident management procedures
  • Ongoing staff training on data protection obligations and best practices

While we are committed to maintaining strong security standards, no method of electronic transmission or storage is completely secure. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify you and the NDPC as required by the NDPA 2023, within the prescribed timeframes.

12. Data Retention

Farmstarck retains your Personal Data only for as long as is necessary to fulfill the purposes for which it was collected, to comply with applicable legal and regulatory obligations, or for the establishment, exercise or defence of legal claims. The following general retention principles apply:

Account Data:Retained for the duration of your account and for a period of 6 years following account closure, in compliance with applicable financial and commercial law.
Transactional Data:Retained for 7 years to comply with the Financial Reporting Council of Nigeria requirements and anti-money laundering regulations.
KYC and Identity Data:Retained for a minimum of 5 years from the date of the last transaction or more, in compliance with the Money Laundering (Prevention and Prohibition) Act 2022.
Marketing Data:Retained until you withdraw consent or opt out of marketing communications.
Technical and Usage Data:Retained for a maximum of 24 months unless a longer period is required for security or legal purposes.

At the expiry of the applicable retention period, Personal Data will be securely deleted, destroyed, or anonymised in a manner that prevents reconstruction or identification.

13. International Data Transfers

Where the operation of Farmstarck's business requires the transfer of Personal Data outside Nigeria, we ensure that such transfers are conducted in compliance with the NDPA 2023. Specifically, we ensure that:

  • Transfers are made only to countries, territories, or international organisations that the NDPC has determined to provide an adequate level of data protection; or
  • Appropriate safeguards are in place, including standard contractual clauses, binding corporate rules, or equivalent mechanisms approved under applicable law; and
  • Technical and organisational safeguards are applied where the level of protection in the receiving jurisdiction may be lower than that afforded by Nigerian law.

You may contact our Data Protection Officer to obtain further information about the safeguards in place for any specific international transfer.

14. Data Protection Officer and Contact Information

Farmstarck has designated a Data Protection Officer (DPO) responsible for overseeing compliance with this Policy and applicable data protection laws. For all enquiries, complaints, or requests relating to your Personal Data, please contact:

Data Protection Officer — Legal Department, Farmstarck (Starcks Novation Limited)

Email: farmstarck@gmail.com

Address: 294 Herbert Macaulay Way, Sabo, Yaba, Lagos State, Nigeria

Website: www.farmstarck.com

If you are not satisfied with our response, you have the right to escalate the matter to the Nigeria Data Protection Commission (NDPC) at www.ndpc.gov.ng.

15. User Responsibilities

You are responsible for:

  • Reviewing this Policy regularly, as it may be updated from time to time
  • Ensuring that all Personal Data you provide to Farmstarck is accurate, complete and current
  • Keeping your account login credentials strictly confidential and not sharing them with any third party
  • Notifying us promptly if you believe your account has been compromised or your data has been misused
  • Complying with applicable laws when using our platform, including laws governing agricultural trade, data protection, and financial transactions

16. Third-Party Links and Platforms

Our Site and App may contain links to external websites, applications, or social media platforms that are not operated or controlled by Farmstarck. This Policy does not apply to those third-party platforms. We do not accept responsibility for the data practices, content or privacy policies of any external platform. We encourage you to review the privacy policy of any third-party site before submitting your Personal Data.

17. Automated Decision-Making and Profiling

Farmstarck may use automated processing technologies, including profiling, to personalise your experience on our platform, deliver relevant product recommendations and assess certain transactional risks. Where any automated decision-making produces legal or similarly significant effects on you, we will inform you and provide you with the right to request human review of the decision, to express your point of view and to contest the outcome.

18. Updates to This Policy

Farmstarck reserves the right to update or revise this Policy at any time to reflect changes in applicable law, regulatory requirements or our business practices. The revised Policy will be published on our Site and App with an updated “Last Reviewed” date. Where the changes are material, we will notify you by email or through a prominent notice on our platforms prior to the changes taking effect. Your continued use of our Site or App following notification of changes constitutes acceptance of the updated Policy.

Effective Date: 1st May, 2026

Last Reviewed: 1st May, 2026

For questions about this Privacy Policy, contact us at farmstarck@gmail.com or write to us at 294 Herbert Macaulay Way, Sabo, Yaba, Lagos State, Nigeria.