Effective date: 20 July 2026 • Last updated: 20 July 2026
This Privacy Policy explains how Gondal Fulbe Dairy Cooperative ("we", "us", the "Cooperative")
collects, uses, stores, and protects personal data through the AgentConnect mobile application
(the "App"). AgentConnect is a field-operations tool used by authorised field agents of the Cooperative to
register farmers, record milk collection, sell agricultural inputs, and log field visits, syncing with the
Gondal ERP system.
We are the data controller for the personal data processed through the App. This policy is
governed by the Nigeria Data Protection Act (NDPA) 2023 and the Nigeria Data Protection Regulation (NDPR).
1. Who this policy covers
Field agents — the people who log in and use the App (our staff or contractors).
Farmers and cooperative members — individuals whose information agents record in the App
("data subjects").
2. Data we collect
2.1 Field-agent account data
Agent email address (used to sign in)
Agent name and agent code
Role, permissions, and assigned communities
An authentication token stored securely on the device
2.2 Farmer / data-subject data (entered by agents)
Category
Examples
Identity
Full name, gender, date of birth, photograph
Government ID (sensitive)
National Identification Number (NIN), tax number
Contact & location
Phone number, community, village, state, LGA, cooperative
Financial (sensitive)
Bank name, bank account number, account name
Membership
Validation status, farmer code/tier
NIN, financial details, and photographs are sensitive personal data. We collect them only to
the extent necessary to enrol farmers into the cooperative, verify identity, and process payments, and we apply
additional safeguards to them.
2.3 Activity records
Milk collection records (volume, collection period, date, associated farmer)
Records you create are queued in an encrypted local database on the device and synced to
our servers when a connection is available (the App is offline-first).
Cached reference data (e.g. communities, product catalogue) to allow offline use.
Basic diagnostic/crash information, only if crash reporting is enabled (see Section 8).
The App does not collect precise GPS location, and does not contain
advertising or third-party marketing trackers.
3. How we use data
To register and validate farmers and cooperative members.
To record and reconcile milk collection, input sales, and field visits.
To process cooperative payments and credit.
To authenticate agents and enforce their assigned permissions.
To operate the offline sync engine and keep records consistent with the ERP.
To maintain security, prevent fraud, and comply with legal obligations.
4. Legal basis for processing
Performance of a contract / cooperative membership — to deliver cooperative services.
Legitimate interests — to operate, secure, and improve field operations.
Consent — for sensitive data (NIN, financial details, photographs), obtained from the data
subject at the point of enrolment.
Legal obligation — where required by applicable law or regulator.
5. How we share data
We do not sell personal data. We share data only:
With the Gondal ERP platform operated by us, which is the system of record.
With service providers who process data on our behalf under contract (e.g. hosting, and crash reporting if
enabled), bound to confidentiality and security obligations.
Where required by law, regulation, or valid legal process.
6. Storage, security & retention
Data in transit is protected using HTTPS/TLS.
Authentication tokens are stored in the device's secure keystore/keychain.
Pending records are held in a local database on the device until they sync, then retained on our servers.
We retain personal data only as long as necessary for the purposes above and to meet legal/accounting
requirements, after which it is deleted or anonymised.
7. Your rights
Subject to the NDPA/NDPR, you have the right to access, correct, delete, restrict, or object to the processing
of your personal data, and to lodge a complaint with the Nigeria Data Protection Commission (NDPC).
7.1 Requesting deletion of your data
To request deletion of your account and associated personal data, email
privacy@gondalfulbe.ng with the subject "Data Deletion Request", or
use the in-app request under Settings → Profile → Request account deletion. We will verify your identity
and action the request within the period required by law. Records we are legally required to keep (e.g. financial
transaction records) may be retained for the mandated period before deletion.
8. Third-party services
If crash and stability reporting is enabled in a future release (e.g. Google Firebase Crashlytics), limited
diagnostic data may be processed by that provider under its own terms. This section will be updated before any
such service is activated, and the App's Data Safety disclosure will be updated accordingly.
9. Permissions the App requests
Permission
Why
Camera
To capture farmer photographs and scan farmer QR codes.
Internet & network state
To sync queued records with the server when a connection is available.
10. Children
The App is a professional tool not directed at children and is not intended for use by anyone under 18.
11. International transfers
Where data is processed outside Nigeria by a service provider, we ensure an adequate level of protection
consistent with the NDPA.
12. Changes to this policy
We may update this policy from time to time. Material changes will be posted at this URL with a revised
effective date.