Privacy policy
This is our privacy policy
Date of posting: 08/12/2020
This Privacy Policy contains 10 sections.
1. Introduction
Welcome to iFarm crowd funding which is a wholly owned operation of Ifarmkonnect Limited
Kenya. This policy explains how we handle and use your personal information and your rights in
relation to that information. Under Kenya data protection law, Ifarmkonnect Limited is the
controller of that information and responsible for its use and protection. As we operate a platform
that allows our members to run fundraising projects and reach out to others for funding, those
members may also be separately legally responsible for the use of your information in
connection with those projects.
Ifarmkonnect Limited (referred to throughout as “iFarm crowd funding” “we”, “our” or “us”) is
committed to protecting and respecting your privacy.
This Privacy Policy explains why and how we will use the personal information that we have
obtained from you or others, with whom we share it and the rights you have in connection with
the information we use. Please read the following carefully.
This policy describes the way we handle and use the personal information that we obtain from all
the different interactions you may have with us as a business, including when you visit our
offices, social media pages or website currently located at www.ifarmkonnect.com (Site) or
when you contact us or take part in any of our competitions or promotions.
We, Ifarmkonnect Limited, are the controller in relation to the processing activities described
below. This means that we decide why and how your personal information is processed. Please
see the section at the end of this policy for our contact and legal information.
Our members/partners run fundraising campaigns from our Site and in doing so may collect
personal information from you if you pledge funds to their projects. Their use of that information
during and after their campaign (e.g. to keep in contact with you about progress of their project
and their achievements) are uses of your information for which those members determine,
independently of us. As a result, those members will be separate controllers of your personal
information.
We refer to ‘project owners’, ‘backers’ and ‘pledges’ throughout this document. For more
information regarding these, please see our Terms.
This policy was last updated on the date that appears at the top of this page.
2. How and when we collect personal information about you
We receive personal information about you that you give to us, that we collect from your use of
our Site and social media pages and that we obtain from other sources. We only collect personal
information which we need and that is relevant for the purposes for which we intend to use it.
Personal information that you give to us
This is personal information about you that you give to us when: submitting personal information
via our Site
Following us, interacting with us and posting on our social media pages including our Facebook,
Twitter and LinkedIn pages
  Participating in surveys for research purposes
  You visit our offices
  We interact with you at events
  Corresponding with us by phone, email or in another way.
This information is provided by you entirely voluntarily.
This includes information provided on the Site at the time of registering as a member, posting
details of projects, using any of the communication tools we provide for our members, pledging
funds to a project on the Site or cancelling a pledge and when generally using our Site. For
example you may give us your personal information by filling in forms, uploading profile
information and other content to the Site, managing your account online, engaging in
correspondence with us by phone, email or otherwise and meeting with us at events (e.g. you
may provide us with your business card). We may also ask you for information and copies of
identity documents when you wish to apply for partner funding, when you report a problem with
our Site or when you exercise your legal rights.
If we do not receive this information, you may be unable to register with the Site, list or raise
funds, pledge funds to projects, communicate with other members or communicate with us
effectively or allow us to comply with our own obligations. Information that we collect about
you. We may automatically collect the following information:
Information that we collect about you
We may automatically collect the following information:
  Details of your visits to our site, including, but not limited to traffic data, location data,
weblogs and other communication data, and the resources you access;
  Technical information, including anonymous data collected by the hosting server for
statistical purposes, the Internet protocol (IP) address used to connect your computer or
device to the Internet, browser type and version, time zone setting, browser plug-in types
and versions, operating system and platform. Please see our Cookies for further
information; and
  Details regarding when and how you consented to receive marketing communications
from us (including the time and date you provided your consent).
We may also view any personal information which you allow to be shared, such as the
information you upload to the Site (such as your iFarm crowd funding profile), and information
you share on third party social networks.
When you visit our social media pages we collect:
  The information you post on those pages;
  Information regarding your interactions with the content we post; and
  Statistical information regarding all our followers’ activities (but from which we cannot
identify you as we only have access to this information in aggregated form).
Personal information we may receive from other sources:
We may obtain certain personal information about you from other sources (including those
outside of our business) which may include our suppliers and our clients. The third parties that
may send us personal information about you are as follows:
Source of personal
The circumstances in which we may obtain personal information (as
information
about you from this source
Other members
Members of the Site may share personal information about you with
us, for example if you misuse the Site or breach our Terms of service
We may receive your personal information from our funding partners
Our funding partners
if you have indicated to them that you would like us to contact you
about funding opportunities.
Social media networks We may view your social media profile registration data where you
(publicly available
choose to register with our Site using your existing social media
source)
profile and log-in details
Anonymous data
Please note we do not knowingly collect personal information about children or personal data
that is ‘sensitive data’ from a legal perspective or that relates to criminal convictions or
offences. We may invite you to complete an optional survey in which we collect age, ethnicity
and disability information at the time you create a project. However, we collect and process this
information in such a way that it cannot be linked to you and which we therefore receive as
anonymous data (and not personal information). This anonymous data may be shared with our
funding partners who will not link or attempt to link the data to you. Except in relation to those
surveys, please do not provide any sensitive data or information about children to us whether
directly or by posting it to the Site. If we receive this type of information in a way that is not
anonymous, we will promptly delete it.
3. Categories of personal information we use about you
We process different types of personal information about you. To make it easier to understand
the information that we use about you, we have categorized this information in the table below
and provided a short explanation of the type of information each category covers.
We process the following categories of personal information about you:
Category
Personal information included in this category
Behavioural
your activities, actions and behaviours
Biographical
your life experiences
Contact
information which can be used to address, send or otherwise communicate a
message to you
Banking/Billing information used to send/receive funds to/from you
Fraud
information relating to the occurrence, investigation or prevention of fraud
Identity
information that verifies your identity including formal identification
documents or unique identification numbers linked to you
Legal
information relating to legal claims made by you or against you or the claims
process
Fundraising
information relating to your pledges and fundraising
Marketing
your preferences in respect of any marketing communications form us from
Preferences
time to time in relation to products or services which we believe may be of
interest to you
information contained in our correspondence or other communications with
Correspondence you about projects and other activities on our Site, our services or our
business
4. Use of your personal information
We use your personal information for a variety of reasons. We rely on different legal grounds to
process your personal information, depending on the purposes of our use and the risks to your
privacy. You will only receive unsolicited marketing communications from us if you have
consented and can opt-out of receiving them at any time. We do not share your personal
information with companies that would send their marketing to you.
We use your personal information in the following ways:
4.1 Where you have provided CONSENT
We may use and process your personal information for the following purposes where you have
consented for us to do so:
  to contact you via email with marketing information about our projects, funding
opportunities and business (see Marketing for further details);
You may withdraw your consent for us to use your information in any of these ways at any time.
Please see your rights over your personal information for further details.
4.2 Where necessary for us to carry out PRE-CONTRACT STEPS you have requested or for the
performance of our CONTRACT
We will use your personal information where this is necessary for us to perform our contract
with you or to carry out any pre-contract steps you’ve asked us to so that you can enter into that
contract, for the following purposes:
  To register and set you up as a member on our Site;
  To publish details of your pledges (unless you choose to pledge anonymously), your
projects and the rewards you wish to offer;
  To process your pledges and share your details with our payment processors so that
payments can be made from you;
  To share your personal information with our funding partners to obtain funding for your
projects;
  To run our competitions and promotions that you enter from time to time and to distribute
prizes.
4.3 Where necessary to comply with our LEGAL OBLIGATIONS
We will use your personal information to comply with our legal obligations:
  To keep a record relating to the exercise of any of your rights relating to our processing
of your personal information;
  To perform anti-money laundering and related checks where the law requires these;
  To anonymise, pseudonymise and destroy your personal information in accordance with
our retention policies and data protection law;
  To handle and resolve any complaints we receive relating to the services we provide.
4.4 Where necessary for us to pursue a LEGITIMATE INTEREST
We may use and process your personal information where it is necessary for us to pursue our
legitimate interests as a business for the following purposes:
Processing necessary for us to promote our business, brand and activities and measure the reach
and effectiveness of our campaigns
  for analysis and insight conducted to inform our marketing strategies, and to enhance
your visitor experience;
  To tailor and personalize our marketing communications based on your attributes;
  To supply your details to social media and other online platforms operated by other
companies for them to contact you with our targeted advertising online, unless you
object. You may receive advertising based on information about you that we have
provided to the platform or because, at our request, the platform has identified you as
having similar attributes to the individuals whose details it has received from us. To find
out more, please refer to the information provided in the help pages of the platforms on
which you receive advertising from us;
  To identify and record when you have received, opened or engaged with our website or
electronic communications (please see our Cookie Policy for more information).
Processing necessary for us to support our members with their enquiries
  To respond to correspondence you send to us and fulfil the requests you make to us.
Processing necessary for us to respond to changing market conditions and the needs of our guests
and visitors
  To analyze, evaluate and improve our Site and other services so that your visit and use of
our Site, fundraising support and other services and social media pages, are more useful
and enjoyable (we will generally use data amalgamated from many people so that it does
not identify you personally);
  To undertake market analysis and research (including contacting you with surveys) so
that we can better understand you as a guest;
  For the purposes of developing new initiatives and features on our Site (for example new
types of fundraising options or support.
Processing necessary for us to operate the administrative and technical aspects of our business
efficiently and effectively
  To administer our Site and our social media pages and for internal operations, including
troubleshooting, testing, statistical purposes;
  For the prevention of fraud and other criminal activities;
  To verify the accuracy of data that we hold about you and create a better understanding of
you as an account holder or visitor;
  For network and information security in order for us to take steps to protect your
information against loss or damage, theft or unauthorized access, including to archive,
destroy, pseudonyms or anonymous your personal information;
  To comply with a request from you in connection with the exercise of your rights (for
example where you have asked us not to contact you for marketing purposes, we will
keep a record of this on our suppression lists in order to be able to comply with your
request);
  For the purposes of corporate restructure or reorganization or sale of our business or
assets;
  For efficiency, accuracy or other improvements of our databases and systems, for
example, by combining systems or consolidating records we hold about you;
  To enforce or protect our contractual or other legal rights or to bring or defend legal
proceedings;
  To inform you of updates to our terms and conditions and policies; and
  For other general administration including managing your queries, complaints, or claims,
and to send service messages to you.
Marketing communications: If you give your consent, we may use your personal information to
contact you by email to send you newsletters or to notify you with details of projects, services
and competitions. We try to adapt any marketing material that we send to you, for example by
notifying you of projects that apply to your interests and in your location. If you do not wish to
receive email communications from us, please inform us by using the unsubscribe link inside the
email messages we send, by using our comments form or, if you have a registered account on our
Site, by changing your Profile settings from within your account.
We provide tools that allow project owners to send backers news and updates on their projects.
However, we do not permit project owners to send fundraising requests or any other type of
marketing communications using these tools. Project owners can access contact details for the
backers relating to their projects. Any communications they send using these details will be sent
solely based on their decisions and for which they will be acting as the controller of your
personal information. Please see the Introduction to this policy above.
If you opt-out of receiving marketing communications from us, we keep your email address on
our suppression list for a defined period to ensure that we comply with your wishes. Please see
further the periods for which we retain your personal information.
5. Disclosure and sharing of your personal information by us
We only disclose and share your personal information outside our business in limited
circumstances. If we do, we will put in place a contract that requires recipients to protect your
personal information, unless we are legally required to share that information. Any contractors or
recipients that work for us will be obliged to follow our instructions. We do not sell your
personal information to third parties.
We may disclose your information to the following:
  Our funding partners with whom we work to make further sources of funding available to
project owners. Our partners include private sector organizations such as banks, retailers,
media companies and also organizations in the public sector such as local councils. We
also administer and promote competitions with some of our partners from time to time.
When we do so we and the relevant partner may make joint decisions regarding how we
use your personal information in connection with those competitions and will provide a
further notice to you explaining the relationship between us;
  Project owners for them to contact you in connection with their project and backers to
allow them to identify the project owners responsible for the projects to which they
pledge, in each case in accordance with our Terms;
  Our third party service providers, agents and subcontractors (Suppliers) for the purposes
of providing services to us or directly to you on our behalf, including the operation and
maintenance of our Site and social media pages. Our Suppliers can be categorized as
follows:
Recipient / relationship to us
Industry sector (& sub-
sector)
Professional Services
Accountants and legal and security advisers and consultants
(Accountancy, Security &
Legal)
Advertising, PR, digital and creative agencies
Media (Advertising & PR)
Banks, payment processors and financial services providers
Finance (Banking & Payment
(Payoneer, M-pesa, Pesapal, iPay, Mangopay, PayPal)
Processing)
Business intelligence and performance services (Segment,
Tableau, Redshift, BIG Consultancy, Geckoboard, Redash,
IT (Business Performance)
Zapier)
Cloud software system providers, including database, email and
document management/monitoring providers (Mailchimp, Google IT (Cloud Services)
Docs, Dropbox)
Customer support services tool (JivoSite, Zoho Mail,)
Customer Services (Support)
Customer relationship management services (Pipedrive)
IT (Customer Relationship
Management)
Delivery and mailing services providers (Royal Mail for Kenya
only)
Logistics (Delivery Service)
Event booking service provider (Eventbrite)
Events (Booking)
Facilities and technology service providers including scanning and
data destruction providers
IT (Data Management)
Fraud and identity verification services (SSL, LetsEncrypt)
IT (Verification)
Tax administration (HMRC for Kenya only)
Government (Tax
Administration)
Health and safety claims administrators and consultants
Health & Safety (Claims)
Insurers and insurance brokers
Insurance (Underwriting &
Broking)
Market and customer research providers
Media (Market Research)
Online survey platforms and services (Survey Monkey, Typeform,
USSD Code, Google Forms, ODK)
IT (Survey)
Social media platforms (Facebook, Twitter, Instagram, and
LinkedIn)
Media (Social Media)
Team and remote collaboration tools and services (Trello, Asana,
Slack, Google Docs)
IT (Collaboration)
Website and data analytics platform providers, and website
performance tools (Google Analytics, Google Search Console)
IT (Data Analytics)
Website and App developers (Kifaru Dev Solutions)
IT (Software Development)
Website marketing, search and integration services (Ruby on
IT (Software Development
Rails)
and Marketing)
Website hosting services providers (Amazon Web Services)
IT (Hosting)
File and data transfer providers (Google Docs)
IT (Cloud)
When we use Suppliers, we only disclose to them any personal information that is necessary for
them to provide their services and only where we have a contract in place that requires them to
keep your information safe and secure.
We may disclose the personal information to other third parties as follows:
  Any third party who is restructuring, selling or acquiring some or all of our business or
assets or otherwise in the event of a merger, re-organization or similar event; and
  If we are under a duty to disclose or share your information in order to comply with any
legal or regulatory obligation or request, including by the police, courts, tribunals or
regulators.
6. Security and links to other websites
We take the security of your personal information seriously and use a variety of measures based
on good industry practice to keep it secure. Nonetheless, transmissions over the internet and to
our Site may not be completely secure, so please exercise caution. When accessing links to other
websites, their privacy policies, not ours, will apply to your personal information.
We employ security measures to protect the personal information you provide to us, to prevent
access by unauthorized persons and unlawful processing, accidental loss, destruction and
damage. When we have provided (or you have chosen) a password or pin allowing you access to
certain parts of the Site, you are responsible for safeguarding it and keeping it confidential and
you promise not to allow it to be used by third parties. Unfortunately, the transmission of
information via the internet is not completely secure. Although we will do everything possible to
protect your personal information, we cannot guarantee the security of any personal information
during its transmission to us online. You accept the inherent security implications of using the
internet and will not hold us responsible for any breach of security unless we are at fault.
Our Site and social media pages may contain links to other websites run by other organizations
which we do not control. This policy does not apply to those other websites‚ so we encourage
you to read their privacy policies. We are not responsible for the privacy policies and practices of
other websites (even if you access them using links that we provide) and we provide links to
those websites solely for your information and convenience. We specifically disclaim
responsibility for their content, privacy practices and terms of use, and we make no
endorsements, representations or promises about their accuracy, content or thoroughness. Your
disclosure of personal information to third party websites is at your own risk.
In addition, if you linked to our Site from a third party website, we cannot be responsible for the
privacy policies and practices of the owners and operators of that third party website and
recommend that you check the policy of that third party website.
7. The periods for which we retain your personal information
We will not hold your personal information in an identifiable format for any longer than is
necessary for the purposes for which we collected it. For certain purposes we retain your
personal information for a very short period whilst for others we retain it for a period of 7 years
after the information is no longer required for business reasons so that we can deal with any legal
proceedings that could arise.
We retain your personal information for the following periods:
Type of personal information How long do we keep your personal information?
Registration information
7 years from the date your account is closed for any reason.
Information (other than
registration information)
For unsuccessful projects, 7 years from the date your account is
relating to projects/project
closed for any reason. For successful projects, indefinitely (but
owners including pledged
please see exceptions below).
amounts
Information relating to backers
(other than registration
information) including pledge
7 years from the date your account is closed for any reason.
history
If we require these for financial or fraud verification purposes, 7
Identity documents
years. If we require these to share with our payment processors
for client verification purposes, 6 months. If we require these to
verify your identity for a request by you in connection with your
rights over your personal information (see below), 2 years.
Web traffic and device
information
26 months from the date of collection.
Social media handles
Until you stop following our social media account or page.
For as long as you have not opted-out and if you opt-out,
Marketing preferences
indefinitely after we place you on our suppression list to ensure
we honour your wishes.
Complaints and queries
2 years, except where these relate to legal claims, in which case
7 years.
The only exceptions to the periods mentioned above are where:
  You exercise your right to have the information erased (where it applies) and we do not
need to hold it in connection with any of the reasons permitted or required under the law.
  You exercise your right to require us to retain your personal information for a period
longer than our stated retention period.
  we bring or defend a legal claim or other proceedings during the period we retain your
personal information, in which case we will retain your personal information until those
proceedings have concluded and no further appeals are possible;
  we archive the information, in which case we will delete it in accordance with our
deletion cycle; or
  In limited cases, existing or future law or a court or regulator requires us to keep your
personal information for a longer or shorter period.
8. Your rights in relation to your personal information
You have a number of rights in relation to your personal information under data protection law.
In relation to certain rights, we may ask you for information to verify your identity and, where
applicable, to help us to search for your personal information. Except in rare cases, we will
respond to you within 30 days after we have received this information or, where no such
information is required, after we have received full details of your request. You have the
following rights, some of which may only apply in certain circumstances:
8.1. To be informed about the processing of your personal information (this is what this policy
sets out to do);
8.2. To have your personal information corrected if it is inaccurate and to have incomplete
personal information completed;
The accuracy of your information is important to us and we make it easy for you to review and
correct the personal information that we hold about you in your Profile. If you change your name
or address/email address, or you discover that any of the other information we hold is inaccurate
or out of date, you can let us know by contacting us in any of the details described at the end of
this policy but we ask you to first check that you cannot correct your details using the tools in
your Profile.
When downloading a list of backers on their project, project owners will see the address details
of those members who pledged on their project. Please note that if you change your address after
the project owner has downloaded this data (this usually happens once their project is successful)
the details the project owner may become out of date, until the project owner downloads a new
list of data - so we would recommend also contacting the project owner to inform them of a
change to your contact details.
8.3. To object to processing of your personal information;
Where we rely on our legitimate interests as the legal basis for processing your personal
information for particular purposes, you may object to us using your personal information for
these purposes by emailing or writing to us at the address at the end of this policy. Except for the
purposes for which we are sure we can continue to process your personal information, we will
temporarily stop processing your personal information in line with your objection until we have
investigated the matter. If we agree that your objection is justified in accordance with your rights
under data protection laws, we will permanently stop using your data for those purposes.
Otherwise we will provide you with our justification as to why we need to continue using your
data.
You may object to us using your personal information for direct marketing purposes and we will
automatically comply with your request. If you would like to do so, please use our unsubscribe
tool.
8.4. To withdraw your consent to processing your personal information;
Where we rely on your consent as the legal basis for processing your personal information, you
may withdraw your consent at any time by contacting us using the details at the end of this
policy. If you would like to withdraw your consent to receiving any direct marketing to which
you previously opted-in, you can also do so using our unsubscribe tool.
You can also opt out of receiving our newsletter at any time by editing your Profile settings
(login, click your name at the top right of the website then choose Profile settings).
You can choose to receive or opt-out of future marketing from Projects you have pledged on.
The project owner will be responsible for handling your information after they receive it from us.
The project owner, when downloading a list of backers on their project will see who has elected
to receive further updates.
You can also choose to receive or opt-out of updates from Projects you have pledged on.
Please note that our standard receipt emails and notifications or a Project closing successfully or
unsuccessfully contain important financial information regarding your pledge and so cannot be
turned off.
If you withdraw your consent, our use of your personal information before you withdraw is still
lawful.
8.5. To restrict processing of your personal information;
You may ask us to restrict the processing your personal information in the following situations:
where you believe it is unlawful for us to do so, you have objected to its use and our
investigation is pending or you require us to keep it in connection with legal proceedings.
In these situations, we may only process your personal information whilst its processing is
restricted if we have your consent or are legally permitted to do so, for example for storage
purposes, to protect the rights of another individual or company or in connection with legal
proceedings.
8.6. To have your personal information erased;
In certain circumstances, you may ask for your personal information to be removed from our
systems by emailing or writing to us at the address at the end of this policy. Unless there is a
reason that the law allows us to use your personal information for longer, we will make
reasonable efforts to comply with your request.
8.7. To request access to your personal information and information about how we process it;
You have the right to ask for a copy of the information that we hold about you by emailing or
writing to us at the address at the end of this policy. We may not provide you with a copy of your
personal information if this concerns other individuals or we have another lawful reason to
withhold that information.
Remember, you can access a lot of your personal information through your account: You can see
a record of the Investment you have made in the My Investment section (login, click your name
at the top right of the website then choose My Investment).
  You can also see a record of the projects you have created and run - see the My Farms
section.
  You can also review and edit the personal information you have provided to
iFarmkonnect via your Profile settings.
If you wish to make a Subject access request please first check you cannot get the data from the
areas listed above. If you wish to access data not listed there please be specific in your request
and send us a message to info@ifarmkonnect.com. We will then respond to your request.
9.8. To electronically move, copy or transfer your personal information in a standard, machine-
readable form;
Where we rely on your consent as the legal basis for processing your personal information or
need to process it in connection with a contract in place directly with you, you may ask us to
provide you with a copy of that information in a structured data file. We will provide this to you
electronically in a structured, commonly used and machine readable form, such as a CSV file.
You can ask us to send your personal information directly to another service provider, and we
will do so if this is technically possible. We may not provide you with a copy of your personal
information if this concerns other individuals or we have another lawful reason to withhold that
information.
9.9. Rights relating to automated decision making, including profiling.
We do not envisage that any decisions that have a legal or significant effect on you will be taken
about you using purely automated means, however we will update this policy and inform you if
this position changes.
After completing an expression of interest form for funding from one of our partners we will
show you partner funds you may be eligible for. You can view the full list of funds at any time.
Part of your eligibility for a fund may include automated processes, but the decision to approve
funding will not be purely automated.
You have the right to lodge a complaint with a data protection regulator in Kenya, Europe, US,
Canada, or in a particular country you work or live or where your legal rights have been
infringed. As a Kenyan organization we follow the guidelines issued by the communication
authority of Kenya and data protection commissioner.
The contact details for communications authority of Kenya, the data protection regulator in
Kenya, are available on the Communications Authority of Kenya website, where your personal
information has or is being used in a way that you believe does not comply with data, however,
we encourage you to contact us before making any complaint and we will make every effort to
resolve any issues or concerns you may have.
9. Changes to our Privacy Policy
Please check this page regularly for changes to this policy. We will email you with changes if we
hold a valid email address for you.
We may review this policy from time to time and any changes will be notified to you by posting
an updated version on our Site and, where appropriate, by contacting you by email. Any changes
will take effect 7 days after we post the modified terms on our Site or after the date we notify
you by email. We recommend you regularly check this page for changes and review this policy
each time you visit our Site.
10. Contact and legal information
You can contact us with your queries in relation to this policy or for any other reason using our
web form or by post or email.
To contact us in relation to this policy, including to exercise any of your rights in relation to your
personal information, please contact us or write to us by email at info@ifarmkonnect.com
Ifarmkonnect Limited’s company registration number is PVT-Y2UAQX8, and registered office
address is P.O Box 7369-00200 Nairobi.