Privacy Policy
Last Updated: September 14th, 2026
ADA AGRODESK PRIVACY POLICY
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INTRODUCTION
Atlantus Digital Assets (“ADA,” “Company,” “we,” “us,” or “our”), a sales and asset-tokenization division of MOBI Automation – FZCO, a limited liability company duly incorporated under Dubai Law No. 16 of 2021 and regulated by the Dubai Integrated Economic Zones Authority (DIEZA), respects your privacy and is committed to protecting information processed in connection with your use of the AgroDesk platform and its related services (collectively, the “Platform”). This Privacy Policy (“Policy”) governs the collection, processing, storage, and protection of information obtained through your interaction with the Platform.
AgroDesk is a digital platform that allows a Farmer who owns qualifying farmland (“Farmland”) to register that Farmland, apply for participation in ADA's Farmland investment programme, and be connected with Investors, New Owners, or Leaseholders who acquire an interest in the Farmland or a Harvest Right over it. The Platform is designed to collect and process only the information necessary for account management, farmland verification, payment administration, security, and compliance purposes.
By accessing or using the Platform, you acknowledge that you have read, understood, and agreed to this Policy and the applicable Terms and Conditions [hyperlink]. Continued use of the Platform constitutes ongoing acceptance of this Policy, including any updates made to reflect regulatory, operational, or technological changes.
This Policy describes: (i) the categories of information processed in connection with the Platform; (ii) the lawful bases and purposes for such processing; (iii) technical and organisational safeguards applied to protect information; (iv) your rights as a data subject; and (v) the limited circumstances under which information may be disclosed to third parties.
We adhere to recognised data protection principles, including transparency, purpose limitation, data minimisation, and accountability. Information is processed lawfully and securely in accordance with the Nigeria Data Protection Act, 2023 (the “NDPA”) and the regulations, guidelines, and directives issued by the Nigeria Data Protection Commission (“NDPC”) from time to time.
ADA acts as the data controller for personal data processed in connection with the Platform. Where a Farmer or Investor completes identity verification through a designated onboarding process prior to accessing certain Platform features, information collected during that onboarding process is processed by ADA for the purposes described in this Policy.
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To provide secure access, verify Farmland and identity, process payments, and comply with applicable legal and operational standards, we collect and process the following categories of information:
2.1
Identity and Contact Information
2.2
Full name, date of birth, gender, nationality, phone number, email address, residential and business address, and signature.
2.3
Identity Verification (KYC) and Business Verification (KYB) Information
Full name, date of birth, gender, nationality, phone number, email address, National identification number (NIN), passport or other government-issued identification, proof of address, corporate registration documents (for corporate Users), tax identification number, and any other information reasonably required to verify your identity or the identity and standing of your business. and business address, and signature.
2.4
Farmland and Ownership Information
Certificate of Occupancy or other land title documents, survey plans, land registry records, Farmland location, size, boundaries, and agricultural use information submitted when registering Farmland on the Platform.
2.5
Financial and Payment Information
Bank account details, payment history, and information necessary to process payments in Naira or other currencies, including amounts due to you and amounts you are required to pay.
2.6
Farm and Cultivation Monitoring Information
Real-time and periodic updates on farming, cultivation, and development activities on registered Farmland, including planting and harvest dates, crop or livestock type, cultivation progress, site photographs, location data, harvest volumes and quantities, sales records, and other production data submitted by a Farmer or verified by us or our authorised representatives.
2.7
Survey and Usability Information
If you participate in a survey or usability study with us, we may record information you directly provide (for example, your name or email), your responses, and your interactions with the Platform.
2.8
Correspondence
Communications and information you provide directly to us via customer support, social media, or another support channel, or when you participate in a survey or questionnaire.
2.9
Information Automatically Collected
When you use the Platform, our servers automatically collect information about your activity, including your IP address, device and browser type, operating system, pages or features visited, time spent on those pages, usage frequency, search terms, clicked links, and related analytics data. We gather this information through server logs, cookies, and similar tracking technologies.
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Our primary purpose in collecting personal information is to provide you with a secure, smooth, efficient, and reliable platform experience. We generally use personal information to create, operate, deliver, and improve the Platform, and to prevent loss and combat fraud. We may use this information as follows:
3.1
To Provide and Maintain the Platform
We process your personal information to operate and deliver the Platform's services to you. When you create an Account and register Farmland or a payment arrangement, we collect certain details necessary to generate and manage your profile, verify your Farmland, and maintain accurate records of your activity. Without this information, we would be unable to create your Account, verify your Farmland, process payments, or provide core Platform services.
3.2
Facilitating Identity Verification and Payment Processing
We share relevant identity, KYC, and KYB information with licensed third-party verification providers, and relevant financial information with licensed third-party payment processors, to confirm your identity and eligibility, and to facilitate the disbursement of payments to you in Naira or another applicable currency. This processing is described further under “Who Do We Share Data With?” below.
3.3
Providing Farm and Development Updates
We use farm and cultivation monitoring information to provide Investors, New Owners, and Leaseholders with real-time or periodic updates on the progress of farming, cultivation, development, and harvest activities relating to Farmland in which they hold an interest.
3.4
Personalisation and User Experience
We use your information to understand your needs and interests and to tailor your experience so interactions with the Platform feel more relevant and intuitive.
3.5
Business and Analytics Activities
We process your information for business functions such as data analysis, audits, product development, performance reviews, tracking usage trends, evaluating promotional efforts, and supporting the growth of our operations.
3.6
To Protect Our Users
We use the information collected to protect the Platform and your Account, and to safeguard your interests, including detecting and preventing fraud and unauthorised access.
3.7
To Comply with Legal and Regulatory Requirements
We collect and use your personal information to comply with legal and regulatory obligations, including anti-money laundering (AML), counter-terrorism financing (CTF), and know-your-customer (KYC) requirements under applicable Nigerian law. We prioritise the privacy and security of your information and do not share it with third parties except as described in this Policy or where required by law, regulation, or legal process.
3.8
To Measure Platform Performance
We use personal information to analyse Platform usage and improve our offerings, including analysing and tracking data to determine the usefulness of certain content and to better understand how Users interact with the Platform.
3.9
To Enforce Our Terms and Other Agreements
We review, investigate, and take action to prevent activities that violate our Terms and Conditions. We reserve the right to suspend or terminate access for any User found engaging in activities that violate our Terms and Conditions.
3.10
To Facilitate Secure Third-Party Processing Services
We may use third-party tools to collect, process, and store your personal information. We take reasonable measures to ensure that these third-party providers handle your personal information securely and process it lawfully, in compliance with applicable data protection regulations.
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At ADA, user privacy and data protection are core design principles. We do not sell, rent, or broadly share your personal information with unrelated third parties. Data sharing is strictly limited to what is necessary for identity verification, payment processing, platform security, operational continuity, and a seamless user experience.
4.1
Identity Verification (KYC/KYB) Providers
We share identity, KYC, and KYB information with licensed third-party verification providers to confirm your identity, the identity of your business, and your eligibility to transact on the Platform, in compliance with applicable AML/CTF and know-your-customer requirements.
4.2
Payment Processors and Financial Institutions
We share financial and payment information, including bank account details and identification information, with licensed third-party payment processors and financial institutions to facilitate the disbursement of payments owed to you in Naira or other applicable currency.
4.3
Security Enhancement Partners
We may share minimal, strictly necessary information with trusted technology and security partners whose sole role is to help protect our systems from fraud, cyber threats, or data loss. These partners are contractually bound to process your data only under our instructions and cannot use it for unrelated commercial purposes.
4.4
Professional Advisors, Regulators, and Law Enforcement
We may share personal data with our lawyers, auditors, and other professional advisers where reasonably necessary, and may disclose personal data to the NDPC, the Central Bank of Nigeria, law enforcement agencies, courts, or other competent authorities, where required by law or in response to a valid legal request.
4.5
No Unnecessary Disclosure
We do not share your personal information with advertisers, brokers, or external analytics platforms beyond what is described in this Policy. Data is only shared when strictly necessary for technical operations, legal compliance, or security purposes.
4.6
User-Initiated Visibility
Where the Platform enables an Investor to view information about Farmland in which they hold an interest, certain non-sensitive information, such as Farmland location, crop type, and production status, may be visible to that Investor as a normal feature of the Platform. No sensitive personal information is disclosed to other Users unless you expressly choose to include it.
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5.1
We prioritise the security of your information and implement industry-standard security measures to protect your data. Our precautions include:
a.
Encryption Protocols:
All sensitive information is secured using advanced encryption standards (AES) and SSL/TLS protocols to protect your data during interactions with the Platform.
b.
Access Controls:
Access to personal information is restricted to authorised personnel and systems on a need-to-know basis.
c.
Secure Storage:
Personal information is stored on secure servers with appropriate technical and organisational safeguards.
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Continuous Monitoring:
We employ monitoring tools to detect and respond to suspicious activity, supporting a secure environment for all Users.
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Periodic Review:
Our security practices are periodically reviewed and updated to address emerging risks.
5.2
User Responsibility: While we implement robust security measures, the safety of your Account also depends on your actions. We strongly recommend keeping your login credentials secure and confidential, using trusted devices and networks to access the Platform, and staying vigilant against phishing attempts and unauthorised access.
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As a User of the Platform, you have important rights regarding your personal information, designed to give you greater control, transparency, and assurance over how your data is used, stored, and shared. We are committed to making it simple and transparent for you to exercise these rights. Please note that exercising some rights, such as deletion or restriction, may limit or remove your ability to use parts of the Platform that rely on that data.
6.1
Access Your Data
Request a copy of the personal information we hold about you, along with details about how and why it is processed.
6.2
Rectify Your Data
Ask us to correct or update any inaccurate or incomplete personal data, ensuring your records remain accurate and valid.
6.3
Request Erasure
In specific circumstances, such as where personal data is no longer necessary for the purposes for which it was collected, or where you withdraw consent (where applicable), you may request deletion of your personal information, subject to applicable legal and regulatory obligations. Please note that certain Farmland and transaction records are retained as part of our permanent record-keeping obligations and to maintain the integrity of ongoing payment and ownership arrangements, and cannot be deleted while such arrangements remain active. Requesting erasure of such data may result in the loss of access to certain features of the Platform, as the data is required to validate your Account status and maintain continuity of your Farmland or payment arrangements
6.4
Restrict Processing
Request that we limit the processing of your data if you contest its accuracy, object to its processing, or need it preserved for legal claims while your request is being reviewed. Restricting certain processing activities could affect your ability to fully use the Platform.
6.5
Object to Processing and Withdraw Consent
Withdraw consent where processing is based on consent, and object to certain uses of your data, such as for direct marketing.
6.6
Data Portability
Where technically feasible and legally required, request a copy of your personal data in a structured, commonly used, machine-readable format, or request that we transfer it to another service provider.
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7.1
We retain personal information only for as long as necessary for the smooth operation of the Platform, to meet legal or regulatory requirements, maintain security, resolve disputes, and enforce our agreements. Different categories of information are retained for different periods based on their purpose:
a.
Account and identification information is retained while your Account remains active, and for a limited period after closure to support record-keeping, fraud prevention, and compliance obligations.
b.
Usage, analytics, and technical data are retained for the time needed to operate, secure, and improve the Platform.
c.
Information collected during onboarding and verification is kept only for verification, audit, and fraud-prevention purposes.
7.2
If we are required to keep information for a longer period due to legal, regulatory, or operational requirements, we will retain it only for the duration of those obligations. After retention periods expire, we delete the information or de-identify it so it no longer identifies any User.
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8.1
Minors
The Platform is available only to Users eighteen (18) years of age or older. We do not knowingly collect or process personal data from minors. By using the Platform, you confirm that you meet this age requirement, as further stated in the Terms and Conditions. Any Account found to involve a minor may be suspended or terminated, and associated data removed, in accordance with applicable law.
8.2
Users Outside Our Jurisdiction
The Platform is operated in accordance with the laws and regulations applicable in Nigeria and the United Arab Emirates. Users who access the Platform from other jurisdictions do so at their own initiative and are solely responsible for ensuring compliance with all applicable local laws, regulations, and data protection requirements. We make no representation that the Platform is appropriate or lawful for use in all jurisdictions.
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9.1
Cookies are small data files stored in your browser by a website. They transmit information about your use of the Platform to its operator or to third parties that placed the cookie. Some cookies are “session cookies” that expire when you close your browser, and others are “persistent cookies” that stay on your device until you delete them.
9.2
The Platform uses both session and persistent cookies to enable you to sign in and use the Platform, store your preferences, analyse performance, personalise your experience, and for other lawful purposes.
9.3
Disabling Cookies
You can opt out of having your online activity and device data collected through these services, including by:
a.
Blocking cookies in your browser by following the instructions in your browser settings. For more information about cookies, visit www.allaboutcookies.org.
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Using privacy plug-ins or browsers that can be configured to block third-party cookies and trackers.
c.
Using the opt-out tools provided by analytics or advertising providers referenced above.
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As a result of the dynamic nature of law and platform policies, we may revise this Privacy Policy from time to time. Notice of any material change will be announced on the Platform, and, where required by law, your consent will be sought before using your information for any new purpose. It is at your sole discretion to provide such information; however, use of the Platform may be restricted or limited if you fail to provide information necessary for a particular feature.
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If you have any questions about this Policy, your data, or how we use it, please contact us at ADA
