Privacy Policy

Farm + Farmer by Leadway Mobile Application

Last Updated: December 2025

1. Introduction

This Privacy Policy (“Policy”) describes how Farm + Farmer by Leadway (“the App”, “we”, “us”, “our”) collects, uses, stores, shares, and protects personal data of users (“you”, “your”).

This Policy must be read together with the Leadway Group Privacy Policy, available at:
https://www.leadway.com/privacy-policy/

This Policy is issued in compliance with the Nigeria Data Protection Act, 2023 (NDPA) and applicable subsidiary regulations, guidelines, and directives.

By installing or using the App, you confirm that you have read and understood this Policy.

2. Data Controller

The data controller is:

Leadway Assurance Company Limited
Lagos, Nigeria

As defined under Section 65 of the NDPA, Leadway determines the purposes and means of processing personal data within the App.

3. Categories of Personal Data Collected

We collect only personal data necessary for the operation of the App.

3.1 Contact and Account Data

  • Full name

  • Phone number

  • Email address

Used for account creation, authentication, and support.

3.2 Location Data

  • Approximate location

  • Precise GPS coordinates (foreground only)

Purpose:

  • Farm geolocation

  • Mapping farm boundaries

  • Associating farm activities with specific locations

Location data is collected only with your explicit consent and is not collected in the background.

3.3 Media Data

  • Photos or images you choose to upload or save

The App uses platform-approved system photo pickers.
We do not access your media library beyond the items you explicitly select.

Used for:

  • Farm documentation

  • Uploading reports or images

3.4 User-Provided Farm Data

  • Farm details

  • Crop or livestock information

  • Yields

  • Reports

  • Schedules

  • Notes

Used to enable farm management and record-keeping features.

3.5 Technical and Usage Data

  • App interactions

  • Feature usage

  • Crash logs

  • Device identifiers

Used to maintain, secure, and improve the App.

4. Legal Basis for Processing

In accordance with Section 25 of the NDPA, we process personal data on the following lawful bases:

  • Consent, where required (e.g. location data, media uploads)

  • Performance of a contract, to deliver App services

  • Legal obligation, where processing is required by law

  • Legitimate interests, limited to service improvement and security, provided such interests do not override your rights

5. Purposes of Processing

We process personal data to:

  • Provide farm setup, mapping, and tracking features

  • Enable farm record management

  • Improve app functionality and reliability

  • Respond to user support requests

  • Comply with legal and regulatory requirements

We do not use personal data for advertising.
We do not sell personal data.

6. Data Sharing and Disclosure

We may disclose personal data only where necessary to:

  • Leadway Group entities

  • Trusted service providers acting as data processors

  • Regulators, law enforcement, or courts where required by law

All processors are bound by contractual obligations consistent with Sections 39–41 of the NDPA.

7. International Data Transfers

Where personal data is transferred outside Nigeria, such transfers are conducted in accordance with Section 43 of the NDPA, using appropriate safeguards approved by Leadway.

8. Data Security

In line with Section 39 of the NDPA, we apply technical and organizational measures to protect personal data against:

  • Unauthorized access

  • Accidental loss

  • Alteration

  • Disclosure

These measures include access controls, encryption in transit, and restricted system access.

9. Data Retention

Personal data is retained only:

  • For as long as necessary to provide App services

  • To meet legal, regulatory, or audit requirements

When no longer required, data is securely deleted or anonymized.

10. Data Subject Rights

Under Sections 34–36 of the NDPA, you have the right to:

  • Access your personal data

  • Request correction of inaccurate data

  • Request deletion of personal data

  • Withdraw consent at any time for optional processing

  • Object to certain processing activities

Requests may be made through the App or via Leadway support channels.

11. Children’s Data

The App is not intended for children under the age of 13.
We do not knowingly collect personal data from children.

12. Video Demonstration

A demonstration of the App’s functionality is available at:
https://www.leadway.com/wp-content/uploads/2025/12/recod1_136Dz1vD.webm

This video is illustrative and does not modify data collection practices.

13. Policy Updates

This Policy may be updated to reflect changes in the App or legal requirements.
Updated versions will be published within the App or on our website.

14. Contact and Complaints

For privacy questions, data requests, or complaints, contact Leadway through the channels listed in the Leadway Group Privacy Policy:
https://www.leadway.com/privacy-policy/

You also have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC).