Privacy notice

Who we are

Mazrivo is operated by Lumifrik Technologies (Lumifrik Holdings, Ireland), “we” in this notice. You can write to us at hello@mazrivo.com.

Registered office and company number: to be added before this notice comes into force.

Our two roles

• For this website, and when you write to us, we decide how your data is used: we are the controller.
• For the records a company keeps in Mazrivo (its farmers, their farms, the inputs they receive, their deliveries and payments, and the company’s own staff accounts), that company is the controller. We process that data on its behalf and on its instructions, under a data processing agreement, and use it for nothing else.

If you are a farmer, the company you sell to decides how your data is used. Ask that company first. If you write to us, we pass your request on to it.

This website

mazrivo.com sets no cookies, runs no analytics and loads nothing from other companies’ servers: its fonts and images come from the site itself.

The sign-in form works in your browser. The company address you type is not sent to us: your browser goes straight to that company’s portal.

Our hosting provider, Vercel, keeps technical logs, including IP addresses, for a limited time, to deliver the site and protect it from abuse.

When you write to us

If you email us, we use your name, email address, company and what you tell us to answer you and to follow up on working together. We do so in our legitimate interest in answering enquiries or, when you ask us for an offer, to take steps before a contract.

We keep this correspondence for up to two years after our last exchange, unless it leads to a contract.

What Mazrivo records for companies

Depending on how it works, a company using Mazrivo records:

• about farmers: name, sex, year of birth, phone number if they have one, an identity document or the attestation or witness that confirms who they are, a photo, where they live (administrative areas and landmarks), their farms and plot boundaries, crops and field visits, the notice they heard and the basis for using their data, their signature, the inputs they received, their deliveries, weights and quality results, and what they were owed, recovered and paid;
• about the company’s staff: name, phone number, email address, roles, sites, phones and sign-in history;
• for every change: who made it and when, in an audit log that cannot be altered.

The company decides what it records, why, and on which legal basis. The app records the basis chosen for each farmer: an agreement with them, their consent (with their signature), or a legal obligation. Text messages go only to farmers who agreed to receive them.

How the data is protected

• Each company’s records are kept apart from every other company’s by the database itself (row level security), not only by the screens.
• Each person sees only what their roles and sites allow. Field staff never see farmers’ balances.
• Decisions on money, prices and quality need a second person, and every change is logged.
• Connections are encrypted. Passwords have at least 12 characters, and an account locks for 15 minutes after three failed sign-ins.
• Records captured without a network stay on the phone until they are sent. A phone that stays offline longer than the company allows (48 hours unless it sets otherwise) must sign in again.
• Our team works on each company’s set-up, not on its records. To see a company’s records, a person must be invited by that company’s administrator, like anyone else, and that access is recorded.

Where the data is kept

This website and the portal’s pages are served by Vercel. The records themselves are served by Mazrivo’s own servers, not by Vercel.

We plan to keep those servers and their backups in the European Union (with Hetzner, in Germany or Finland). Farmers’ personal data from Niger, Bénin, Togo, Burkina Faso and Mali would then be held outside their country. Before any real farmer data is collected, we are checking with counsel the conditions each country’s law sets for this, and the declarations or authorisations each requires.

The law in each country

Data recorded in Mazrivo is protected by the law of the country where the farmer lives and the company works:

• Niger: Law no. 2017-28 on the protection of personal data; authority: the HAPDP (Haute Autorité de protection des données à caractère personnel).
• Bénin: the Digital Code (Law no. 2017-20); authority: the APDP (Autorité de protection des données à caractère personnel).
• Togo: Law no. 2019-014 on the protection of personal data; authority: the IPDCP (Instance de protection des données à caractère personnel).
• Burkina Faso: Law no. 001-2021/AN on the protection of persons with regard to the processing of personal data; authority: the CIL (Commission de l’informatique et des libertés).
• Mali: Law no. 2013-015 on the protection of personal data; authority: the APDP (Autorité de protection des données à caractère personnel).
• Ireland and the European Union, for Lumifrik Holdings: the General Data Protection Regulation (GDPR); authority: the Data Protection Commission.

Each company declares its own processing to its country’s authority where the law requires it. Our own declarations are being prepared with counsel.

Your rights

Depending on the law that applies, you can ask to see the data held about you, to have it corrected or deleted, to restrict or object to its use, to receive a copy, and to withdraw your consent where the data is used on that basis, for example to stop text messages.

• Farmers and company staff: ask the company that keeps your record. It decides, and we help it answer.
• Anyone else, or if you are not sure whom to ask: write to us at hello@mazrivo.com. We answer within one month.

You can also complain to the data protection authority of your country.

How long data is kept

Each company decides how long its records are kept, within what the law allows and what it must keep for its accounts and for traceability.

When a company stops using Mazrivo, we return its data if it asks, then delete it from our servers, and from our backups as they expire.

Changes to this notice

We update this notice when the way we handle data changes, and date each version at the top of this page. The terms for using Mazrivo are in the terms of use.