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Legal · Kilimora CLG · Effective January 2026

Privacy Policy

How Kilimora CLG collects, stores, uses, and protects personal data from farmers, cooperative members, partners, and website visitors. We take this seriously — your data belongs to you.

Effective: January 2026 Governed by: Laws of Kenya CLG-OZTKDDO8
01

Who We Are

This Privacy Policy applies to Kilimora Company Limited by Guarantee ("Kilimora", "we", "us", "our"), registration number CLG-OZTKDDO8, a social enterprise registered in Kenya under the Companies Act, 2015. Our registered address is Baraza Media Lab, Keystone Park, 95 Riverside Drive, Nairobi, Kenya.

Kilimora is the data controller for personal data collected through:

  • The AgriKonnekt platform (USSD, mobile app, and web interfaces)
  • Our website at kilimora.africa
  • Our advisory, grant-writing, and technical assistance programmes
  • Our research activities and field data collection
  • Any direct communications you initiate with us

We are committed to protecting your personal data and handling it responsibly under the Kenya Data Protection Act, 2019 and any applicable supplementary regulations.

02

What Data We Collect

Data you give us directly

  • Name, phone number, and national ID or equivalent identification
  • Location data (county, sub-county, GPS coordinates of enrolled plots)
  • Cooperative or organisation name and membership details
  • Bank account or mobile money details (M-Pesa) for payment processing
  • Email address and any messages you send us through contact forms or email
  • Documents submitted for advisory or fundraising engagements (financial statements, business plans, impact reports)

Data we generate through our services

  • Soil sensor readings from IoT devices deployed on enrolled plots
  • Satellite cross-validation data (Sentinel-2 imagery processed against enrolled plot coordinates)
  • USSD session logs (anonymised by default, linked to phone number)
  • Carbon credit verification records and payment timestamps
  • Agricultural practice records submitted through training modules

Data collected automatically from this website

  • IP address and approximate geographic location
  • Browser type, operating system, and device type
  • Pages visited, time on site, and referring URL
  • Cookie identifiers (see Section 10)
We do not collect what we do not need
Kilimora only collects personal data that is necessary for the specific purpose stated at the point of collection. We do not collect sensitive data such as ethnicity, religious belief, or health information unless it is directly relevant to a specific programme and you have given explicit consent.
03

Why We Collect It

We use personal data for the following purposes:

Service Delivery
To operate the AgriKonnekt platform, process carbon credit verifications, deliver training content, and send direct M-Pesa payments to enrolled farmers.
Programme Administration
To manage advisory engagements, grant-writing programmes, and cooperative technical assistance. To maintain records required by funders and regulatory bodies.
Research & Impact
To generate anonymised or aggregated research outputs, impact reports, and programme evaluations. Published research never identifies individual farmers.
Compliance
To meet Know-Your-Customer (KYC), Anti-Money Laundering (AML), and donor compliance requirements for climate finance programmes.
Communications
To respond to your enquiries, send programme updates you have requested, and provide notices required under our contracts or legal obligations.
Website Improvement
To understand how visitors use kilimora.africa and improve our content and navigation based on usage patterns.

We do not use your personal data for advertising, sell it to third parties, or use it for any purpose other than those listed above.

04

Lawful Basis for Processing

Under the Kenya Data Protection Act, 2019, we process your personal data on one or more of the following lawful bases:

  • Consent — where you have given us clear consent to process your data for a specific purpose, such as enrolling in AgriKonnekt or subscribing to our research publications. You may withdraw consent at any time.
  • Contractual necessity — where processing is necessary to perform a contract with you or to take steps at your request before entering a contract, such as processing advisory engagements.
  • Legal obligation — where processing is necessary to comply with a legal requirement, including donor reporting, KYC, or regulatory mandates under Kenyan law.
  • Legitimate interests — where processing is necessary for our legitimate interests as a social enterprise, provided those interests are not overridden by your rights. This includes website analytics and programme evaluation.
  • Vital interests — in rare cases where processing is necessary to protect someone's life, this may apply in field safety contexts.
05

Farmer & Cooperative Data — Data Sovereignty

Kilimora holds a foundational principle of data sovereignty: farmers and cooperatives own their data. We act as stewards, not owners.

Your data rights as an enrolled farmer
Every enrolled farmer can request a copy of their full data record at any time via USSD by dialling the AgriKonnekt access code. You can request correction, deletion, or withdrawal from the programme without penalty. Your data will never be sold or shared with third parties without your explicit consent.

Soil and plot data

Sensor data and satellite imagery processed for your enrolled plot is linked to your individual account. Aggregated, anonymised versions of this data may be used in research outputs. Individual plot data is only shared with verified carbon buyers after your explicit enrolment in a carbon credit programme.

Payment data

M-Pesa payment records are maintained for audit and compliance purposes. Individual payment records are not shared with third parties except as required by Safaricom's terms of service, applicable financial regulations, or court orders.

Training and practice records

Records of training modules completed and agricultural practices adopted are used solely for programme monitoring and impact reporting in anonymised, aggregated form.

06

Storage & Security

We take the security of your personal data seriously and implement appropriate technical and organisational measures to protect it from unauthorised access, loss, disclosure, alteration, or destruction.

Where your data is stored

Personal data is stored on servers located in Kenya or within the East African Community, wherever possible. Where data is processed by third-party service providers located outside Kenya, we ensure adequate data protection agreements are in place and that the relevant jurisdiction offers equivalent protection standards.

Security measures we apply

  • Encryption of data in transit (TLS) and at rest for sensitive records
  • Role-based access controls limiting staff access to the minimum necessary
  • Regular security audits and vulnerability assessments
  • Incident response procedures aligned with KDPA breach notification requirements
  • Staff training on data protection and information security
No system is completely secure
While we implement rigorous security measures, no data transmission or storage system is 100% secure. If you have reason to believe that your data has been compromised, please contact us immediately at hello@kilimora.africa.
07

Sharing & Disclosure

We do not sell personal data. We share data only in the following circumstances:

Service Providers
Technology and infrastructure providers who assist us in delivering AgriKonnekt and our website, bound by data processing agreements that restrict their use of your data to our instructions only.
Carbon Buyers
Verified carbon credit buyers receive aggregated, plot-level carbon data after farmer enrolment in a carbon credit programme. Individual identifying information is only shared with buyer consent and farmer consent.
Funders & Donors
Grant funders may receive programme-level impact data in anonymised, aggregated form for reporting purposes. Individual data is not shared with funders without your explicit consent.
Research Partners
Academic research partners (including Kenyatta University) receive anonymised, aggregated datasets for independent verification of MRV methodology. No individual is identifiable in shared research datasets.
Legal Requirements
We may disclose personal data where required by law, court order, or regulatory authority. We will notify you of such requests to the extent permitted by law.
M-Pesa / Safaricom
Payment processing through M-Pesa is governed by Safaricom's own privacy policy. We share only the minimum data required to process payments (phone number and payment amount).
08

Data Retention

We retain personal data only for as long as necessary for the purpose for which it was collected, or as required by applicable law or contract.

Farmer programme data
Retained for the duration of programme participation plus 7 years for audit and carbon credit verification integrity. Soil sensor and satellite records are retained indefinitely in anonymised, aggregated form for longitudinal research.
Payment records
Retained for 7 years from the date of transaction in compliance with Kenyan financial record-keeping requirements and donor audit obligations.
Advisory client data
Retained for the duration of the engagement plus 5 years for contractual and compliance purposes.
Website analytics
Retained for 26 months from collection, after which they are deleted or anonymised.
Contact form submissions
Retained for 2 years from the date of submission, unless a longer engagement results from the contact.

When data is no longer required, we securely delete or anonymise it in line with our data disposal procedures.

09

Your Rights

Under the Kenya Data Protection Act, 2019, you have the following rights with respect to your personal data:

Right of Access
Request a copy of the personal data we hold about you, including the purposes for which it is processed and who it has been shared with.
Right to Rectification
Request correction of any inaccurate or incomplete personal data we hold about you. We will update records promptly on verified request.
Right to Erasure
Request deletion of your personal data where it is no longer necessary, where consent has been withdrawn, or where it has been unlawfully processed.
Right to Object
Object to processing of your data based on legitimate interests, including profiling. We will cease processing unless we can demonstrate compelling legitimate grounds.
Right to Portability
Receive your personal data in a structured, commonly used, machine-readable format where processing is based on consent or contract.
Right to Withdraw Consent
Withdraw consent at any time where processing is based on consent. Withdrawal does not affect the lawfulness of processing prior to withdrawal.

To exercise any of these rights, contact our data team at hello@kilimora.africa. We will respond within 30 days. We may need to verify your identity before fulfilling a request. There is no charge for exercising your rights.

If you believe we have not handled your data lawfully, you have the right to lodge a complaint with the Office of the Data Protection Commissioner (ODPC) of Kenya at www.odpc.go.ke.

10

Cookies

Our website kilimora.africa uses cookies and similar tracking technologies to provide basic website functionality and understand how visitors use the site.

Essential cookies
Required for the website to function correctly. These include session cookies that maintain your session while you browse. These cannot be disabled without breaking site functionality.
Analytics cookies
Used to understand aggregate visitor behaviour on our website. We use privacy-respecting analytics that do not track you across other websites. These are set only with your consent.
Functional cookies
Used to remember preferences such as language settings. These are set only where you have made a specific choice that requires a preference to be stored.

We do not use advertising cookies, third-party tracking pixels, or any cookie that follows you across other websites. You can manage cookies in your browser settings at any time. Disabling analytics cookies will not affect your ability to use the site.

11

Children

Kilimora's services are not directed at children under 18 years of age. We do not knowingly collect personal data from anyone under 18 without the consent of a parent or legal guardian.

Where Kilimora's programmes operate in community settings that involve young people in educational or observational roles (such as a child of an enrolled farmer attending a training session), any data recorded about those young people is limited to anonymised programme participation records and is subject to our enhanced safeguarding standards as described in our Safeguarding and Protection Framework.

If you believe that we have inadvertently collected personal data from a child, please contact us immediately at hello@kilimora.africa and we will take steps to delete it.

12

International Transfers

Kilimora primarily stores and processes data within Kenya and East Africa. In some cases, however, data may be transferred to or processed by service providers located outside Kenya — for example, cloud infrastructure providers or carbon registry platforms operating internationally.

Where international transfers occur, we ensure adequate safeguards are in place, including:

  • Data processing agreements with standard contractual clauses
  • Transfers only to jurisdictions that provide an adequate level of data protection as assessed under the KDPA
  • Assessment of the recipient's data protection framework before any transfer takes place

You may request information about the safeguards governing any specific international transfer of your data by contacting us at hello@kilimora.africa.

13

Updates to This Policy

We review and update this Privacy Policy periodically to reflect changes in our services, applicable law, or best practices in data protection. The current version is always available at kilimora.africa/privacy-policy.

When we make material changes to this policy, we will:

  • Update the effective date at the top of this page
  • Where possible, notify enrolled programme participants via USSD or SMS
  • Post a notice on our website for a period of at least 30 days following any material change

Continued use of AgriKonnekt or our website after an updated policy has been published constitutes acceptance of the revised terms. If you do not accept a material change, you may withdraw from our services in accordance with Section 09.

This policy was last updated and became effective in January 2026.

14

Contact Us

For any question, concern, or request relating to this Privacy Policy or the processing of your personal data, please contact us:

Kilimora CLG — Data Enquiries
Baraza Media Lab, Keystone Park, 95 Riverside Drive, Nairobi, Kenya

If you are not satisfied with our response, you have the right to escalate your complaint to the Office of the Data Protection Commissioner (ODPC) of Kenya: