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IRUGBINPRIVACY NOTICE

Privacy notice

Your records are yours. Nobody sees them unless you send them. This is the long version of that sentence.

EFFECTIVE
VERSION
1.0
GOVERNING LAW
NIGERIA

Irugbin is at demonstration stage. The season on the home page is a specimen computed from nine sample messages, the WhatsApp number is a placeholder, and no live farmer data is being collected through this site. These documents describe how the service operates and will operate at launch, so that anyone evaluating it can read the terms before there is anything to sign.

1. Who is responsible

Irugbin Technologies Ltd is the data controller for the personal data described here, and processes it under the Nigeria Data Protection Act 2023 (NDPA) and the regulations of the Nigeria Data Protection Commission (NDPC).

Data protection contact: privacy@irugbin.com. Postal: Kaduna, Kaduna State, Nigeria.

2. What we collect

WHATWHY WE HAVE IT
Phone numberIt identifies your book. Without it there is nothing to write in.
Messages and voice notes you sendThey are the entries. Voice notes are transcribed; the audio is deleted once the entry is confirmed.
The parsed ledgerDates, items, quantities, amounts, yields and sales — the structured form of what you said.
Farm details you tell usCrop, hectares, state or nearest market. Used for per-hectare figures and local prices.
Your name, if you give itIt appears on the record document. You can keep the book under a nickname.
Delivery metadataWhen a message arrived, whether a document was sent. Needed to run the service and to keep the record trustworthy.
Website usagePage requests, coarse country, referring page. First-party and aggregated. No advertising trackers.

We do not collect bank details, BVN, NIN, government ID, GPS location, contacts or photographs. If a lender needs those, they collect them directly, under their own terms.

3. Why we are allowed to hold it

PURPOSELAWFUL BASIS UNDER THE NDPA
Keeping your book and producing your recordPerformance of a contract with you
Reading your messages so they become entriesPerformance of a contract with you
Sharing a record with a named lender or insurerYour specific, separate consent
Improving the costing engine using aggregated figuresLegitimate interest, with data de-identified first
Keeping records for tax and legal obligationsLegal obligation
Preventing fraud and abuse of the serviceLegitimate interest in a service that lenders can trust

4. Who else sees it

By default: nobody outside Irugbin. Your records are not published, not sold, and not offered to lenders on your behalf.

Your record leaves Irugbin in exactly three situations:

  • You ask us to send it — to a named lender, co-operative, insurer or buyer, for a named season. That consent is asked for each time and recorded in your book.
  • You send it yourself, by forwarding the document. At that point where it goes is up to you.
  • A Nigerian court or a lawful order requires it. We will tell you unless the order forbids it.

Service providers who help us run Irugbin — hosting, messaging delivery, speech transcription — process data only on our written instructions, only for that purpose, and may not use it for their own.

We have never received a government request for farmer records, and we will say so here for as long as it stays true.

5. Where it is held

Records are stored on infrastructure in the Republic of South Africa and the European Union, both of which the NDPC recognises as offering adequate protection, with contractual safeguards required by the NDPA for every transfer.

Messages travel over WhatsApp, which is operated by Meta under its own terms and encryption. That leg of the journey is between you and WhatsApp; we receive the message at our end.

6. How long we keep it

DATAKEPT FOR
Voice note audioUntil the entry is confirmed, then deleted
Ledger entries and season recordsAs long as your book is open, plus 7 years — a farm record is only useful as a history, and lenders ask for prior seasons
Records of consent to share7 years, so it can always be shown who received what and on whose authority
Website logs90 days
Closed booksDeleted or irreversibly anonymised within 30 days of your request, except where the law requires us to keep something

7. Your rights

Under the NDPA you may, at any time and free of charge:

  • Ask what we hold about you and get a copy — say “send me everything” in the chat.
  • Correct anything wrong. Corrections keep an audit trail; nothing is silently rewritten.
  • Delete your book. Say “close my book”.
  • Take your data elsewhere, in a machine-readable file.
  • Withdraw consent to share with a lender, for anything not already sent.
  • Object to processing based on legitimate interest.
  • Ask that no decision about you is made by automated means alone. Irugbin does not make credit decisions; lenders do, under their own rules.

Requests are answered within 30 days. If you are not satisfied, you may complain to the Nigeria Data Protection Commission, or write to us first at privacy@irugbin.com — we would rather fix it.

8. How it is protected

  • Encrypted in transit and at rest.
  • Access limited to staff who need it to answer a support request, logged each time.
  • Records segregated by book; no bulk export path in the support tools.
  • Breach affecting your data reported to the NDPC within 72 hours and to you without undue delay.

9. Cookies and this website

This website sets no advertising cookies, no third-party analytics, no social pixels and no cross-site trackers. Nothing on it needs a consent banner, which is why there isn't one.

The only browser storage used is a first-party preference remembering which page of the specimen record you last looked at. It never leaves your device.

10. Children

Irugbin is for adults running a farm business. We do not knowingly keep books for anyone under 18. Where a young person farms under a guardian, the book belongs to the guardian.

11. Changes to this notice

This notice was last revised on 14 August 2026. Material changes are sent to you in the chat before they take effect, in plain language, with the date they start.

LAST REVISED 14 AUGUST 2026 · THIS DOCUMENT IS WRITTEN TO BE UNDERSTOOD. IF A LINE IN IT IS NOT CLEAR TO YOU, THAT IS OUR FAULT — WRITE AND WE WILL REWORD IT.