Privacy Policy

1. Introduction

Kusini Lab, Ltd. (“Kusini Labs,” “we,” “us”) is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our platform and services.

2. Information We Collect

We may collect the following types of information:

• Account information: Name, email address, company name, and role when you create an account
• Batch data: Commodity type, weight, grade, GPS coordinates, photographs, and farmer identification submitted through the platform
• Transaction data: Records of compliance documents generated, verification scans, and shipment tracking
• Device information: Browser type, IP address, device identifiers, and usage patterns collected automatically

3. How We Use Your Information

We use collected information to:

• Provide, operate, and maintain our Services
• Generate tamper-proof hashes of batch events for traceability
• Auto-generate compliance documents (EUDR declarations, certificates of analysis, phytosanitary certificates)
• Enable buyers and regulators to verify commodity provenance
• Improve and develop new features
• Communicate with you about your account and our Services
• Comply with legal obligations

4. Data Hashing and Integrity

Batch event data submitted to our platform is hashed to create immutable, tamper-proof records. These hashes are anchored to a public ledger for independent verification. The underlying data remains in our systems and is not stored on any blockchain. Hashed records cannot be altered, deleted, or backdated once created.

5. Information Sharing

We may share your information with:

• Supply chain participants: Buyers, importers, and regulators who scan or verify shipments through VerifyPortal will see batch provenance data
• Regulatory authorities: When required by law or to facilitate compliance with EUDR and other applicable regulations
• Service providers: Third-party vendors who assist us in operating the platform, subject to confidentiality obligations

We do not sell your personal information to third parties.

6. Data Retention

We retain your information for as long as your account is active or as needed to provide the Services. Hashed records are retained indefinitely as they form part of the immutable traceability chain. We may also retain information as required by law or for legitimate business purposes.

7. Data Security

We implement appropriate technical and organizational measures to protect your information against unauthorized access, alteration, disclosure, or destruction. However, no method of transmission over the Internet or electronic storage is completely secure.

8. Your Rights

Depending on your jurisdiction, you may have the right to access, correct, delete, or port your personal data. You may also have the right to object to or restrict certain processing activities. Please note that hashed batch records cannot be modified or deleted due to their immutable nature.

9. International Transfers

Your information may be transferred to and processed in countries other than your country of residence. We ensure appropriate safeguards are in place for such transfers in accordance with applicable data protection laws.

10. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the updated policy on the platform. Your continued use of the Services after changes are posted constitutes acceptance of the revised policy.

11. Contact

For questions about this Privacy Policy or to exercise your data rights, contact us at hello@kusinilabs.com.