Privacy Policy

Privacy Policy

Effective Date: August 23, 2026  ·  Last Updated: August 23, 2026

1. Introduction IMSA GROWERS' & EXPORTERS LTD ("IMSA GROWERS' & EXPORTERS LTD," "we," "us," or "our") respects your privacy and is committed to handling personal information in a lawful, fair, transparent, and secure manner. This Privacy Policy explains how we collect, use, disclose, store, transfer, and otherwise process personal information in connection with: Our websites, landing pages, and digital properties that link to this Privacy Policy, including imsagrowers.com and related pages (the "Website"); and Our software products, buyer/supplier portals, workflow tools, data rooms, document tools, communication features, and related trade-execution services, including IMSA GROWERS' & EXPORTERS LTD (the "Platform"). This Privacy Policy applies to visitors to our Website, prospective and current customers, users of the Platform, representatives of buyers, suppliers, exporters, importers, logistics providers, inspectors, financing partners, and other counterparties, and other individuals whose information we process in connection with our business. 2. Scope and Role of IMSA GROWERS' & EXPORTERS LTD In some circumstances, IMSA GROWERS' & EXPORTERS LTD acts as a data controller or business, meaning we decide why and how personal information is processed. This typically includes information processed for Website analytics, lead management, account registration, security, fraud prevention, customer support, product improvement, legal compliance, and commercial relationship management. In some circumstances, IMSA GROWERS' & EXPORTERS LTD may act as a service provider, processor, or similar role on behalf of a customer organization that uses the Platform. This may include certain customer-uploaded documents, trade records, workflow files, shipment materials, and related content processed within a business account or workspace. In those cases, the relevant customer organization may be responsible for certain notices, permissions, and instructions relating to that data. 3. Categories of Personal Information We Collect Depending on how you interact with us, we may collect the following categories of personal information: 3.1 Identity and contact information Name, business title, employer, company name, department, work email, business phone number, postal address, billing address, country, account profile details, and similar identifiers. 3.2 Account, authentication, and access information Usernames, encrypted passwords or password hashes, magic-link identifiers, authentication tokens, role permissions, account preferences, login history, session data, IP address, device identifiers, browser type, operating system, timestamps, and similar access/security data. 3.3 Commercial and transaction information Inquiry records, quotes, orders, counterparty profiles, purchase terms, pricing, shipment references, invoice references, order histories, relationship notes, negotiation records, audit trails, workflow actions, approvals, alerts, and platform activity tied to a person or business representative. 3.4 Payment, banking, and settlement information Payment instructions, remittance details, bank account holder name, bank name, branch, IBAN, SWIFT/BIC, account number or masked account number, proof of payment, beneficiary details, assignment/finance details, release confirmations, and related settlement records. 3.5 Trade, logistics, and document information Commercial invoices, packing lists, bills of lading, air waybills, phytosanitary certificates, certificates of origin, pre-shipment reports, QC evidence, arrival reports, dispute materials, container references, carrier data, route data, product data, shipment photos, workflow submissions, and supporting files uploaded to or generated through the Platform. 3.6 Compliance and diligence information Corporate registration records, tax/VAT numbers, licenses, certifications, sanctions/compliance screening inputs or outputs, business reputation signals, facility data, onboarding materials, and related due-diligence records. 3.7 Communications Emails, support requests, messages, commercial-desk inquiries, meeting notes, survey responses, chat submissions, call scheduling information, and any attachments or documents you send to us. 3.8 Usage, device, and analytics information Pages viewed, features used, clickstream data, referrers, approximate geolocation inferred from IP, browser events, crash logs, page performance data, cookie data, and similar diagnostic or analytics information. 3.9 Marketing and preference information Communication preferences, event participation, campaign attribution, newsletter subscriptions, and records of whether you opened or clicked communications from us. 3.10 Information from third parties and public sources We may receive business contact information, company profile information, sanctions/compliance information, logistics information, financial instructions, certification information, and other related business data from customers, counterparties, service providers, public registries, trade partners, or lawful third-party sources. 4. Information We Do Not Intend to Collect We do not intentionally seek to collect personal information from children. Our Website and Platform are intended for business and commercial use, not for use by minors. We also do not intentionally request special-category or sensitive personal information unrelated to business trade operations. If you choose to provide such information, or if it appears in documents you upload, you represent that you are authorized to provide it and that doing so is lawful. 5. How We Collect Information We collect information: directly from you, when you fill in forms, create an account, submit inquiries, upload documents, use the Platform, place or process orders, communicate with us, or otherwise interact with our services; automatically, through cookies, logs, analytics tools, and similar technologies; from your organization or counterparties, such as when an administrator creates an account for you or when a transaction counterparty uploads information associated with you; from service providers, integration partners, logistics providers, payment or finance partners, inspection/certification bodies, and lawful data sources; and from public sources, including government registries, professional networking sources, trade records, and corporate websites where permitted by law. 6. How We Use Personal Information We may use personal information for the following purposes: 6.1 To provide and operate the Website and Platform To create and manage accounts; authenticate users; manage roles and permissions; support buyer, supplier, and internal portals; host and store documents; run workflows; support search, onboarding, document generation, shipment tracking, payment coordination, and related commercial functions. 6.2 To manage business relationships and transactions To respond to inquiries; prepare proposals; evaluate counterparties; onboard organizations; support trade orders; coordinate shipments; generate and store documents; facilitate communication among transaction participants; support settlement and release workflows; and administer ongoing customer relationships. 6.3 To perform compliance, diligence, and security checks To verify identity or business information; perform risk scoring; support sanctions screening; review certifications or commercial credentials; detect suspicious activity; prevent fraud, abuse, or unauthorized use; maintain system integrity; and protect our rights, users, and business. 6.4 To improve and develop our services To understand usage patterns; analyze feature performance; diagnose technical issues; improve product design, reliability, and commercial workflows; test features; create aggregated or de-identified insights; and develop new offerings. 6.5 To communicate with you To provide notices, alerts, service messages, legal notices, account updates, commercial workflow prompts, marketing communications where permitted, support responses, and operational communications related to orders, documents, payments, or shipment status. 6.6 To enforce agreements and comply with law To investigate violations; protect our legal rights; defend claims; maintain records; satisfy audit, tax, accounting, customs, export-control, sanctions, anti-fraud, anti-money-laundering, financing, and other legal obligations; and respond to lawful requests from regulators, courts, or law-enforcement authorities. 6.7 For corporate transactions If we evaluate, negotiate, or complete a merger, acquisition, financing, reorganization, asset sale, or similar transaction, personal information may be reviewed or transferred as part of that process subject to appropriate confidentiality and legal safeguards. 7. Legal Bases for Processing Where the Data Protection Act 2019 or similar laws apply, we rely on one or more of the following legal bases: performance of a contract, or taking steps at your request before entering a contract; our legitimate interests, including operating and improving the Website and Platform, managing commercial relationships, protecting the security of our systems, preventing fraud, conducting business analytics, and defending legal claims; compliance with legal obligations; consent, where required or where we choose to rely on consent, including for certain cookies, marketing, or optional features; and where applicable, the establishment, exercise, or defense of legal claims. Where we rely on legitimate interests, we do so only where those interests are not overridden by your interests or fundamental rights and freedoms. 8. Cookies and Similar Technologies We and our service providers may use cookies, pixels, tags, SDKs, local storage, and similar technologies to operate the Website and Platform, remember settings, authenticate sessions, measure usage, improve performance, understand engagement, and support marketing or communications where permitted. Certain cookies or similar technologies are strictly necessary to provide requested services, including security, session continuity, and core site functionality. Other cookies or technologies may be optional and may be subject to consent where required by applicable law. You may manage cookies through your browser settings and, where available, through our consent tools. Blocking some technologies may affect the functionality of portions of the Website or Platform. 9. How We Disclose Personal Information We may disclose personal information to the following categories of recipients where reasonably necessary for the purposes described in this Privacy Policy: 9.1 Affiliates and related entities Our affiliates, parent entities, subsidiaries, or other related companies involved in our operations, services, governance, financing, compliance, or customer support. 9.2 Service providers and subprocessors Cloud hosting providers, database providers, email providers, analytics vendors, communication providers, identity/security vendors, infrastructure providers, document tools, product support providers, and professional service providers that assist us in operating the Website and Platform. 9.3 Transaction counterparties and workflow participants Buyers, suppliers, exporters, importers, logistics providers, carriers, warehouse operators, cold-chain providers, quality inspectors, customs brokers, certification bodies, banks, payment processors, financing counterparties, assignees, and similar parties involved in a transaction or workflow. 9.4 Professional advisers Lawyers, auditors, accountants, insurers, corporate advisers, compliance consultants, and similar advisers. 9.5 Authorities and legal recipients Courts, regulators, administrative bodies, law-enforcement agencies, customs authorities, tax authorities, export-control authorities, or other third parties where disclosure is required by law, legal process, or to protect rights, safety, property, or system integrity. 9.6 Corporate transaction recipients Parties involved in an actual or proposed merger, acquisition, financing, reorganization, sale of assets, or other business transaction. 10. Platform Collaboration and Shared Workspace Data The Platform is designed to support multi-party trade execution. As a result, information that is uploaded to the Platform or generated within the Platform may be visible to, shared with, or disclosed to authorized participants in a transaction workflow, including your organization, counterparties, carriers, inspection bodies, customs-related stakeholders, and financing or payment participants, to the extent necessary to perform the transaction, document compliance, coordinate shipment status, or process settlement. If you upload or submit documents, payment proofs, certificates, shipment records, or other content, you represent that you have the legal right and authority to upload, disclose, and share that content through the Platform. You are responsible for ensuring that your use of the Platform and your disclosures through it comply with applicable law, contractual obligations, and confidentiality commitments. Once information is intentionally shared with an independent third party through a transaction workflow, that third party's handling of the information is governed by its own practices, contracts, and legal obligations. Except to the extent required by law, we are not responsible for the independent privacy or security practices of third parties not under our control. 11. International Data Transfers Because we operate internationally and may use service providers or counterparties in multiple countries, personal information may be transferred to, stored in, or accessed from jurisdictions outside your country, state, province, or region of residence, including Kenya and other countries where we or our service providers operate. Where required by applicable law, we will implement appropriate safeguards for cross-border transfers, which may include contractual protections, transfer impact assessments, standard contractual clauses, adequacy mechanisms, or other lawful transfer tools. 12. Data Retention We retain personal information for as long as reasonably necessary for the purposes described in this Privacy Policy, including to: provide the Website and Platform; maintain accounts and commercial relationships; preserve transaction records, audit trails, and document histories; satisfy tax, accounting, customs, export, sanctions, anti-fraud, financing, dispute, and legal obligations; investigate incidents and defend legal claims; and enforce agreements. Retention periods may vary depending on the type of information, the sensitivity of the information, whether an account remains active, applicable limitations periods, legal obligations, regulatory expectations, dispute history, and whether the information is embedded in trade records or document archives. When we no longer need personal information, we will delete, anonymize, or de-identify it, unless continued retention is required or permitted by law. 13. Data Security We implement administrative, technical, organizational, and physical safeguards designed to protect personal information against unauthorized access, loss, misuse, alteration, or disclosure. These measures may include role-based access controls, authentication controls, encryption in transit and at rest where appropriate, logging and audit controls, restricted access environments, vendor diligence, and business continuity measures. However, no system, service, transmission, storage platform, or security control is completely secure. We cannot guarantee absolute security, uninterrupted availability, or that unauthorized access, disclosure, or misuse will never occur. You are responsible for maintaining the confidentiality of your credentials and for using appropriate care when uploading, sharing, or distributing documents through the Platform. 14. Data Accuracy and User Responsibilities You are responsible for ensuring that personal information and business information you provide to us is accurate, complete, and up to date. You are also responsible for ensuring that you have all necessary permissions, legal bases, and authority to submit personal information, financial details, commercial documents, shipping information, or other content relating to third parties. We may rely on the information provided by you, your organization, or transaction participants unless we have reason to believe it is inaccurate. 15. Your Privacy Rights Depending on where you are located and subject to applicable law, you may have rights relating to your personal information, including: access; correction or rectification; deletion; restriction of processing; objection to certain processing; withdrawal of consent, where consent is the basis; portability; opt-out rights relating to certain disclosures or targeted advertising, where applicable; and the right not to be discriminated against for exercising applicable privacy rights. If you want to exercise a privacy right, please contact us using the contact details below. We may need to verify your identity and authority before responding. We may deny or limit requests where permitted by law, including where the information is subject to legal privilege, relates to another person, is retained for legal compliance, is necessary to complete a transaction, or falls within another exemption. If we process information on behalf of a customer organization as a processor or service provider, we may direct your request to that organization or ask you to submit your request to them directly. 16. Region-Specific Notices 16.1 EEA, UK, and Switzerland If applicable law in the EEA, UK, or Switzerland applies, you may have the rights described above, including the right to lodge a complaint with your local supervisory authority or the UK Information Commissioner's Office, as applicable. You may also request information about the safeguards used for relevant international data transfers. 16.2 U.S. state privacy rights If you are a resident of a U.S. state that provides privacy rights and the relevant law applies to our processing, you may have rights such as access, deletion, correction, portability, and the right to opt out of certain uses or disclosures. We will honor such rights to the extent required by law. 16.3 Puerto Rico residents If a security incident involving certain unencrypted personal information occurs, we will provide notice in accordance with applicable Puerto Rico law. 17. Marketing Communications Where permitted by applicable law, we may send you marketing or commercial communications about our services, updates, events, or capabilities. You may opt out of marketing emails at any time by using the unsubscribe mechanism in the message or contacting us directly. Even if you opt out of marketing communications, we may still send you transactional, operational, legal, or account-related communications. 18. Third-Party Services and Links The Website and Platform may contain links to third-party websites, applications, services, or integrations. We are not responsible for the privacy, security, content, or practices of third parties that are not under our control. Your use of third-party services is subject to the terms and privacy policies of those third parties. 19. Confidential Business Records and Documents The Platform may host or process confidential trade, shipment, compliance, financing, and commercial records. While we take reasonable measures designed to protect such records, we do not represent that third-party systems, counterparties, carriers, authorities, certification bodies, or user-controlled environments will maintain the same level of confidentiality, privacy, or security. Users should avoid uploading unnecessary personal information and should limit uploaded documents to the minimum necessary for the relevant commercial or compliance purpose. 20. No Waiver of Non-Waivable Rights Nothing in this Privacy Policy is intended to waive, limit, or exclude any rights that cannot be waived, limited, or excluded under applicable law. 21. Changes to This Privacy Policy We may update this Privacy Policy from time to time to reflect changes in our business, services, data practices, legal requirements, or risk environment. If we make material changes, we will post the updated version with a revised effective date and may provide additional notice where required by law. 22. Contact Us If you have questions about this Privacy Policy or wish to submit a privacy request, contact: IMSA GROWERS' & EXPORTERS LTD Embakasi, North Airport Road Godown No 3 Nairobi Phone: 0758072019 Email: info@imsagrowers.com