Agrotunes (FZC) ("Agrotunes", "we", "us", "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, store, share, and protect personal data when you use our platform, website, and related services ("Services").
This policy applies to all users of Agrotunes Services globally, with specific provisions for users in the European Economic Area (EEA) under the General Data Protection Regulation (GDPR) and users in the United Arab Emirates under UAE data protection law.
1. Data Controller
Agrotunes (FZC)
Limited Liability Free Zone Company · SRTI Park, Sharjah, UAE
Email: info@agrotunes.com
Phone: +31 6 57 13 86 36
For GDPR purposes, Agrotunes (FZC) is the data controller responsible for your personal data.
2. Data We Collect
2.1 Information You Provide Directly
- Account data: name, email address, company name, password (hashed)
- Profile data: farm name, location, farm type, growing system, crop mix
- Payment data: billing address, payment method details (processed by our payment processors; we do not store full card numbers)
- Communications: messages sent through contact forms, support tickets, or lead forms
- Marketplace data: produce listings, order history, buyer-seller communications
2.2 Data Generated by Your Use of the Services
- Sensor data: temperature, humidity, CO₂, EC, pH, light intensity, soil moisture — collected from connected hardware
- Crop and production records: batch records, growth stages, harvest logs, recipe configurations
- Usage data: pages visited, features used, session duration, clicks, search queries within the Platform
- Device and technical data: IP address, browser type, operating system, device identifiers, time zone
- Log data: server logs, error reports, API request logs
2.3 Data from Third Parties
- IP geolocation: approximate city and country derived from IP address for currency display and localization
- Payment processors: transaction status and billing confirmations
- Analytics providers: aggregated usage metrics
3. Legal Bases for Processing (GDPR)
For users in the EEA, we process personal data under the following legal bases:
| Processing Activity | Legal Basis |
|---|
| Account creation and management | Contract (Art. 6(1)(b) GDPR) |
| Subscription billing and invoicing | Contract (Art. 6(1)(b) GDPR) |
| Providing Platform features and sensor data processing | Contract (Art. 6(1)(b) GDPR) |
| Security monitoring and fraud prevention | Legitimate interests (Art. 6(1)(f) GDPR) |
| Analytics and product improvement | Legitimate interests (Art. 6(1)(f) GDPR) |
| Marketing communications (where opted in) | Consent (Art. 6(1)(a) GDPR) |
| Cookie placement (non-essential) | Consent (Art. 6(1)(a) GDPR) |
| Legal obligation compliance | Legal obligation (Art. 6(1)(c) GDPR) |
| Responding to legal requests | Legal obligation (Art. 6(1)(c) GDPR) |
4. How We Use Your Data
- To create and manage your account and provide the Services you have subscribed to
- To process payments and send invoices
- To store, display, and analyze sensor data from your connected farm
- To operate the Agrotunes Marketplace and facilitate transactions between Farm Operators and Buyers
- To send transactional emails (account verification, alerts, invoices, password resets)
- To send product updates, newsletters, or marketing communications (only with your consent)
- To improve the Platform using aggregated and anonymized usage analytics
- To detect, investigate, and prevent fraudulent or unauthorized activity
- To comply with legal obligations, including tax and accounting requirements
- To respond to your inquiries, support requests, and feedback
5. Data Sharing and Disclosure
We do not sell your personal data. We share data only in the following circumstances:
5.1 Service Providers (Processors)
We engage trusted third-party processors who act on our instructions and are bound by data processing agreements, including:
- Cloud hosting and infrastructure providers
- Payment processors (e.g. Stripe)
- Email delivery services
- Analytics providers (with anonymized or pseudonymized data)
- Customer support tools
5.2 Marketplace Counterparties
When you transact through the Marketplace, relevant profile information (farm name, location, crop listings) is shared with counterparties as necessary to complete the transaction.
5.3 Legal Requirements
We may disclose personal data if required by law, court order, regulatory authority, or to protect the rights, property, or safety of Agrotunes, our users, or the public.
5.4 Business Transfers
In connection with a merger, acquisition, or sale of all or substantially all of our assets, personal data may be transferred as part of that transaction. We will notify you before your data is subject to a different privacy policy.
6. International Data Transfers
Agrotunes operates globally. Your personal data may be transferred to and processed in countries outside your country of residence, including countries outside the EEA. Where we transfer personal data from the EEA to third countries, we rely on appropriate safeguards including:
- Standard Contractual Clauses (SCCs) approved by the European Commission
- Adequacy decisions where applicable
- Binding Corporate Rules or other approved transfer mechanisms
7. Data Retention
We retain personal data for as long as necessary to provide the Services and fulfill the purposes described in this policy, or as required by applicable law:
- Account data: retained for the duration of the account plus 30 days after deletion request
- Sensor and crop data: retained for the life of the subscription; exported on request upon cancellation
- Billing records: retained for 7 years for tax and accounting compliance
- Marketing consent records: retained until consent is withdrawn plus 3 years
- Server logs: retained for up to 90 days for security purposes
8. Your Rights (GDPR)
If you are located in the EEA, you have the following rights regarding your personal data:
- Right of access: request a copy of the personal data we hold about you
- Right to rectification: request correction of inaccurate or incomplete data
- Right to erasure ("right to be forgotten"): request deletion of your data where no longer necessary or where consent is withdrawn
- Right to restriction: request that we limit processing of your data in certain circumstances
- Right to data portability: receive your data in a structured, machine-readable format
- Right to object: object to processing based on legitimate interests or for direct marketing
- Rights related to automated decision-making: not be subject to solely automated decisions that produce significant legal effects without human review
- Right to withdraw consent: where processing is based on consent, withdraw it at any time without affecting prior lawful processing
To exercise any of these rights, contact us at info@agrotunes.com. We will respond within 30 days. You also have the right to lodge a complaint with your national data protection authority in the United Arab Emirates or your local jurisdiction where applicable.
9. Security
We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, loss, alteration, or disclosure, including:
- Encryption of data in transit (TLS 1.2+) and at rest (AES-256)
- Password hashing using industry-standard algorithms
- Role-based access controls limiting data access to authorized personnel
- Regular security assessments and vulnerability monitoring
- Incident response procedures compliant with GDPR breach notification requirements (72-hour notification to supervisory authority)
10. Children's Privacy
Our Services are not directed at individuals under the age of 18. We do not knowingly collect personal data from minors. If we become aware that a minor has provided personal data, we will delete it promptly.
11. Cookies
We use cookies and similar tracking technologies on our website and Platform. For full details on what cookies we use, why, and how to control them, please see our Cookie Policy.
12. Changes to This Policy
We may update this Privacy Policy from time to time. We will notify you of material changes via email or in-platform notification before they take effect. The "last updated" date at the top of this policy reflects the most recent revision.
13. Contact and DPO
For privacy-related inquiries, requests, or complaints:
- Email: info@agrotunes.com
- Address: Sharjah Research, Technology & Innovation Park, UAE
- Phone: +31 6 57 13 86 36
If you are in the EEA and have concerns that we have not adequately addressed, you may contact your local data protection authority.
