Privacy Policy

1. About Agrii

“Agrii” is a trading name  (“Agrii,” “we,” or “us”), for Masstock Arable (UK) Limited, registration number 02387531, having their registered offices Station Road, Andoversford, Cheltenham, GL54 4LZ and United Agri Products Limited, registration number 02798041, having their registered offices Station Road, Andoversford, Cheltenham, GL54 4LZ and their associated subsidiaries.

Agrii is a leading provider of Agronomy services, Technology and Strategic advice to support sustainable and profitable farming solutions in the UK.

This Privacy Policy outlines what personal data we collect, how we use that information and other information about how we protect your privacy.

2. Purpose

Agrii recognises the need to maintain the confidentiality of private, sensitive, and proprietary information. This Data Privacy Policy (“Policy”) sets our Agrii’s overarching approach to data privacy, including how the  company protects the confidentiality of private, sensitive and proprietary information (“Company Confidential” or “Client Confidential” information). This Policy is designed to foster compliance with all applicable  laws, directives, and regulations and other Agrii policies governing the security and confidentiality of all types of information – paper, electronic and verbal. Agrii do not sell, transfer, lease or share your information with 3rd parties other than described here in this policy. In circumstances where we do share information it is only in what would reasonable be expected to support Order Fulfilment, provision of services and product or service enhancements.

3. Scope and Application of Law

A.  Scope

This Policy covers all sensitive, private, and proprietary information that is both internally and externally transmitted, irrespective of the medium of storage or transfer. Types of data covered by this Policy may include but are not limited to, client data, personal information, confidential legal data, confidential client data, non-public financial data and proprietary research data. Collectively, these data types are referred to as “confidential data.” This Policy applies to all  Agrii employees and others performing work for the Company who may handle and store confidential data on behalf of Agrii, its Customers or Suppliers.

B.  Application of Laws

This Policy comprises the internationally accepted data privacy principles without replacing the existing national  laws. It supplements the national data privacy laws. The relevant national law will take precedence if it conflicts with this Policy, or it has stricter requirements than this Policy. The content of this  Policy must also be observed in the absence of corresponding national legislation. The reporting requirements for data processing under national laws must be observed.

4. Principles

At a high level, data processing principles that Agrii will comply with include:

4.1. Fairness  and lawfulness:  When  processing  personal data,  the individual rights  of the data subjects must  be protected. Personal data  must be collected and processed  in a legal and fair manner.

4.2. Restriction to a specific purpose: Personal data can be processed only for the purpose that was defined before the data was collected. Subsequent changes to the purpose are only possible to a limited extent and require substantiation.

4.3.  Transparency: The data subject must be informed of how his/her data are being handled. In general, personal data must be collected directly from the individual concerned. When the data are collected, the data subject must either be aware of, or informed of: the identity of the Data Controller; the purpose of data processing; and third parties or categories of third parties to whom the data might be transmitted.

4.4.  Data reduction  and data economy:  Before  processing  personal data,  you must determine whether and to what extent the processing of personal data is necessary to achieve the purpose for  which it is undertaken. Where the purpose allows and where the expense involved is in proportion with the goal being pursued, anonymised or statistical data must be used. Personal data may  not be collected in advance and stored for potential future purposes unless required or permitted by national law.

4.5.  Deletion: Personal data that is no longer needed after the expiration of legal or business process- related periods must be deleted. In some cases, there may be an indication of interests that merit protection or historical significance of this data in individual cases. Please see Data Retention police for further information.

4.6.  Factual accuracy: Personal data on file must be correct, complete, and (if necessary) kept up to date. Suitable steps must be taken to ensure that inaccurate or incomplete data are  deleted, corrected, supplemented or updated.

4.7.  Confidentiality and data security: Personal data are subject to data secrecy. It must be treated as  confidential on a personal level and secured with suitable organizational  and technical measures to prevent unauthorised access, illegal processing or distribution, as well as accidental loss, modification or destruction.

5. Reliability of Data Processing

Collecting, processing and using personal data is permitted only under the following legal basis.

A.  Consent given to process data

Data can be processed following consent by the data subject. Before giving consent, the data subject must be informed in accordance with this Policy. The declaration of consent must be obtained in writing or electronically for the purposes of documentation. In some circumstances, such as telephone conversations, consent can be given verbally. The granting of consent must be documented.

B.  Data processing pursuant to legal authorisation

The processing of personal data is also permitted if national legislation requests, requires or allows this. The  type and extent of data processing must be necessary for the legally authorized data processing activity, and must comply with the relevant statutory provisions.

C.  Processing of sensitive data

Sensitive personal data  can be processed only if the law requires this or if the data subject has given consent  for the same. This data can also be processed if it is mandatory for asserting,  exercising or defending legal claims regarding the data subject. If there are plans to process sensitive data, the CRCO or the Corporate Data Protection Officer (DPO) must be informed in advance.

D.  Legitimate Interest

In  some  circumstances  Agrii will rely  on the legitimate  interest concept to  justify our processing of personal data but only in circumstances where such processing should be reasonably expected by the Data Owner. The below Section is not exhaustive list of these circumstances and therefore we suggest you consult your Agrii representative in case of doubt.

6. Customer Data

A.  Processing of an Order

Agrii will process a farmer’s order and personal data with the intention of fulfilling the order management process. Specific examples of data processed are as follows:

• Farmer’s personal and financial data to set them up as a customer on the order management system
• Farm location and GPS data to enable the delivery of the product to the correct location
• Farmer’s personal data to process an invoice related to the order
• Farmer’s financial data to process payment for the order
• Farmers premises access information where provided

B.  Satellite Imagery for Provision of Digital Services and Trials Research

Agrii processes satellite imagery and use image data to enhance their digital products and services with the  intention of improving capacity management for agronomists and optimising the process for conducting agronomy field trials. Specific examples of this are:

• Satellite  data assessing  the growth stage  and development of  the crop with the intention  of identifying requirement for application of product
• Satellite data assessing the growth stage of a crop with the intention of identifying optimum time for harvesting
• Using satellite data to optimise the research trails process providing additional data that enriches research

C.  Processing of GPS Data for provision of Digital and Technology Services

Agrii will process GPS data for customers using their digital products and services with the intention of supporting  agronomists with additional information to help manage their capacity. Specific examples include:

• Mapping boundaries of fields using GPS data so as satellite, weather, OS and soil data can be applied to algorithms that serve up relevant information to the agronomist
• Using GPS data to capture the exact location of a specific soil sample
• Using GPS data to capture the exact location of an agronomist inspection

D.  Business Development

Agrii will store business network contact information, with the intention of engaging the network with information about Agrii’s products and services. Examples of such engagements include:

• Technical  marketing teams  managing a list of  agronomists and farmers  for dissemination of technical information bulletins relating to research trials and agronomic products
• Technical marketing team managing a list of agronomists and farmers in their local region for invitation to iFarms and other similar education and marketing forums
• Agrii  employees  managing their  own personal contact  list with the intention  of engaging the contact to develop business for Agrii enterprises
• Agrii marketing teams  making direct contact with customers whom have provided  consent, to inform them of products and services that may be of interest to them

E.  Profiling of Customers

Agrii  will process  customer data and  profile customer segments  with the intention of enhancing  the relevance of Agriis products and services to the agronomist network.  Specific examples of this include the following:

• Analysis  of trends  in ordering  of specific products  against specific farms  or agronomists, and identifying opportunities to alternative product or service for farmer
• Analysis of ordering data to identify opportunity to offer complimentary products or services to agronomist or farmer

F.   Research Trails

In some cases, farmer data is used as part of R&D trials process.  Outputs from R&D trials enable Agrii to provide relevant information to farmers that promotes enhanced farming practices. Specific examples of data that is used in in research trials are:

• Data sets being categorised against a specific farmers address and GPS location
• Research reports being categorised against a specific farm address and GPS location, including farmer name and contact information

G.  Third Parties

From time to time Agrii may share data with 3rd parties with the intention of enhancing capacity for the agronomists  and increasing profit for the farmer and enhancing our products and services. Specific examples include:

• Sharing anonymised farm planning data with Farm Management Systems providers that we use to support them in testing of product enhancements
• Sharing of agronomist and farm data to enable a 3rd party to fulfil an order of product
• Sharing of anonymised cookies data for the purpose of web analytics

7. Rights of the Data Subject

Every data subject has the following rights

7.1. The data subject may request information on which personal data relating to him/her has been stored, how the data was collected, and for what purpose. If there are further rights to view the employer’s documents (e.g. personnel file) for the employment relationship under the relevant employment laws, these will remain unaffected.

7.2. If Personal Data are transmitted to third parties, information must be given about the identity of the recipient or the categories of recipients.

7.3. If Personal Data are incorrect or incomplete, the data subject can demand that it be corrected or supplemented.

7.4. The data subject can object to the processing of his or her data for purposes of advertising or market research. The data must be blocked from these types of use.

7.5. The data subject may request his/her data to be deleted if the processing of such data has no legal basis, or if the legal basis has ceased to apply. The same applies if the purpose behind the data processing has lapsed or ceased to be applicable for other reasons. Existing retention periods and conflicting interests meriting protection must be observed.

7.6. The data subject generally has a right to object to his/her data being processed, and this must be considered  if the protection of his/her interests takes precedence over the interest of the data controller owing to a particular personal situation. This does not apply if a legal provision requires the data to be processed.

7.7. Additionally, every data subject can assert the rights as per national privacy laws.

7.8. When a data subject makes an application to exercise his/her data subject rights, the application must be handled immediately by the Corporate Data Protection Officer.

8. Appendix A: Terms and Definitions

1. Personal Information is information that can be used to distinguish or trace an individual’s identity, such as name, social security number, or biometric records, either alone or when combined with other personal or identifying information that is linked or linkable to a specific individual, such as date and place of birth, mother’s maiden name, etc.
2. Data are anonymised if personal identity can never be traced by anyone, or if the personal identity could be recreated only with an unreasonable amount of time, expense and labour.
3. Consent is the voluntary, legally binding agreement to data processing.
4. Data breach incidents are events where there is justified suspicion that  Personal Data are being illegally captured, collected, modified, copied, transmitted or used.
5. Data subject under this Policy is a natural person whose data can be processed. In some countries, legal entities can be data subjects as well.
6. Sensitive data are data about racial and ethnic Agrii, political opinions, religious or philosophical beliefs, union membership or the health and sexual life of the data subject. Under certain national laws, other data categories can be considered sensitive or the content of the data categories can be structured differently.
7. Personal Data are all information about certain or definable natural persons. A person is definable for instance if the personal relationship can be determined using a combination of information with even incidental additional knowledge.
8. Processing  personal data  means  any process, with or without the use of automated  systems, to collect, store, organise, retain, modify, query, use, forward, transmit, disseminate or combine and compare data. This also includes disposing of, deleting and blocking data and data storage media. Processing personal data is required if the permitted purpose or justified interest could not be achieved without the personal data, or only with exceptionally high expense.
9. Data Controller is a natural or legal person, alone or jointly with others, who determine the purposes and means of the processing.
10. Data  Processor  is  a natural  or legal person,  who processes personal  data on behalf of the data controller.

9. Privacy Policy

A. INCORPORATION OF PRIVACY POLICY

9.1. Agrii (UK) (‘Company’) is committed to ensuring that your privacy is protected and the Company is compliant with the Data Protection Act 1998. This privacy policy (‘Privacy Policy’) explains how the Company uses the information the Company collects about you and the procedures that the Company has in place to safeguard your privacy. Agrii is a trading name of Masstock Arable (UK) Ltd and United Agri Products Ltd.

9.2. By using the Company website www.agrii.co.uk (‘Website’), purchasing and/or utilising any services provided by the Company(‘Services’) via the Website, you consent to the Company using the information the Company collects about you. If you do not agree with the terms and conditions set out in this Privacy Policy, do not continue to use the Website.

B. THE INFORMATION THE COMPANY COLLECTS AND HOW THE COMPANY USES IT

9.3. When you visit the Website or obtain any Services offered on the Website, the Company may collect information including your name, postal address, e-mail address, telephone number, credit card number and expiry date, type of Services obtained and such other relevant information which the Company deems necessary to process your order in respect of the Services. Where necessary, the information collected is transmitted in a secure manner to third parties to assist the Company to provide you with the Services requested by you and to maintain the support services of the Company. Information collected under this clause 2.1 is collected is processed by us.

9.4. Subject to the terms and conditions of this Privacy Policy, the Company protects all personal and financial data from being disclosed to any third parties except when required by law. In addition, the Company may use your information to assist in the prevention of unlawful activities e.g. money laundering or activities which threaten the Company’s Website or is adverse to you or the Company’s interest.

9.5. The Company may also use aggregate information and statistics, (but, which will not contain your identifying information) for the purposes of monitoring your usage of the Website in order to help the Company develop the Website and the Services offered by the Company. The Company may provide such aggregate information to third parties.

9.6. The Company may collect information which is based upon your behaviour and navigation on the Website. This information allows the Company to carry out internal research on the users’ interest, demographics and behavior so that the Company can better understand, and in turn provide better information, products and services to you and other customers.

9.7. The Company may also wish to provide you with information about special features featured on the Website or any other service or products the Company thinks may be of interest to you.

9.8. The Company may also want to provide you with related information from third parties which it thinks may be of interest to you.

If you do not wish the Company to send you any information set out in Clauses 2.5 to 2.6 above, please send an e-mail to info@agrii.co.uk.

9.9. If you contact the Company, the Company may keep record of that correspondence.

Subject to the other provisions of this Privacy Policy and such other provisions specified on the Website, the Company will not provide your information to other companies or organisations without your consent.

C. USE OF COOKIES AND OTHER INFORMATION GATHERING TECHNOLOGIES

9.10. The Company uses ‘cookies’ and other technologies to collect information on site to assist the Company in monitoring the Company’s web page flow, promotional effectiveness as well as to promote trust and safety.

9.11. Certain features on the Website are only available if you enable the cookie. The Company also uses a cookie to assist it to provide information which is relevant to your interest.

9.12. You are free to decline the Company’s cookies although that may impair certain features on the Website.

9.13. You can delete any cookies from your computer – refer to your internet browser’s help files.

9.14. The Company may also track certain information through the use of JavaScript code and third party web site analytics providers.

9.15. Please note that the advertisers on the Company website may also use cookies which the Company have no control over.

D. PROTECTING YOUR INFORMATION

9.16. The internet is not a secure medium. However, the Company has put in place various security procedures and strict policy rules to safeguard and protect your information from unauthorised and unlawful access and use. These security procedures and policy which are of the highest standards are continuously improved.

9.17. Notwithstanding the above, it should be appreciated that no system is entirely fool-proof and you should be careful when you reveal any confidential information to any third party.

E. SECURITY AND WHERE WE STORE YOUR PERSONAL DATA

9.18. We are committed to protecting the security of your Data. We use a variety of security technologies and procedures to help protect your Data from unauthorised access and use. We have implemented strict internal guidelines to ensure that your privacy is safeguarded at every level of our organisation. We will continue to update policies and implement additional security features as new technologies become available.Although we will do our best to protect your Data, we cannot guarantee the security of your Data transmitted to our Site. Any transmission of Data is at your own risk. Once we receive your Data, we will use appropriate security measures to seek to prevent unauthorised access or disclosure.

F. RETENTION PERIOD(S)

9.19. The retention period for your data depends on the relationship with us, we need to retain customer and client data for a period of 7 years, for non customer / client data we retain this information for a period of 30 months. We will respond to your request in writing as soon as practicable and in any event within one month of receipt of your request. We may request proof of identification to verify your request. All requests should be addressed through our Personal Data Request form. You may also use the above contact information if you think any information about you is inaccurate, incomplete, or if you want to change the sort of information about you that AEI may have collected.You have the right to lodge a complaint with the Data Protection Commissioner if you are unhappy with how we are processing your Data.

G. SALE OF COMPANY

9.20. If the Company and/or this part of its business is sold or integrated with another business, your details may be disclosed to the Company’s advisers and any prospective purchasers and their advisers and will be passed on to the new owners of the Company or this part of its business (as the case may be).

H. UPDATING YOUR DETAILS

9.21. If any of the information that you have provided to the Company changes, for example if you change your e-mail address, name or payment details or if you wish to cancel your order, please let the Company know the correct details by sending an e-mail to info@agrii.co.uk.

I. YOUR PRIVACY

9.22. As an existing or potential client of Agrii, we believe you to have a legitimate interest in receiving information about our products, services and events. You have the option to opt-out or unsubscribe from this marketing at any time by sending an e-mail to info@agrii.co.uk.

9.23. We will never knowingly sell your data to any third-party supplier without your consent.

J. OTHER TERMS

9.24. Owing to the global nature of the Internet infrastructure, the information you provide may be transferred in transit to countries outside the European Economic Area that do not have similar protections in place regarding your data and its use as set out in this Privacy Policy. However, the Company has taken the steps outlined above to try to improve the security of your information. By using the Website, you consent to these transfers.

9.25. The Company supplies links to other websites. If you click on a link, you are not protected by this Privacy Policy and you are advised to read the privacy policy of the other website as they may differ from this Privacy Policy.

9.26. The Company reserves the right to amend this Privacy Policy from time to time as it deems necessary. In such event, the Company will post such changes on the Website.

9.27. You have the right at any time to ask the Company not to process your personal data for marketing purposes.

9.28. The Company welcomes your views about the Website and its privacy policy. If you would like to contact the Company with any queries or comments please send an e-mail to info@agrii.co.uk

K. CHANGES TO THIS PRIVACY STATEMENT

9.29. We reserve the right to change this Privacy Statement from time to time at our sole discretion. If we make material changes to our privacy policy, these changes will be posted to our privacy policy page. You should review this page regularly for updates. If you have comments or questions about our privacy or terms of use, please email info@agrii.co.uk