Jigawa El-Meena Farms Limited ("JEFs", "we", "our", or "us") is a Special Purpose Vehicle (SPV) established to develop, operate, and manage export-oriented alfalfa production, processing, and logistics activities in Jigawa State, Nigeria.
JEFs is committed to safeguarding the privacy and personal data of its employees, contractors, farmers, partners, financiers, buyers, regulators, and digital platform users. This Policy sets out how we collect, process, store, share, and protect personal data in compliance with the Nigeria Data Protection Act (NDPA) 2023 and applicable regulations.
1. Scope of This Policy
This Policy applies to personal data processed by JEFs in connection with:
- Project development and operations
- Digital farm management and traceability systems
- Employment, contracting, and service provision
- Producer and cluster onboarding
- Export, quality assurance, and compliance activities
- Interactions with lenders, regulators, and partners
2. Legal Basis for Processing
JEFs processes personal data lawfully under one or more of the following grounds:
- Consent of the data subject
- Performance of a contract or pre-contractual obligations
- Compliance with legal or regulatory requirements
- Legitimate operational and commercial interests, provided such interests do not override individual rights
3. Categories of Personal Data Collected
Depending on engagement with JEFs, we may collect:
- Identification data: names, job titles, contact details
- Employment & contractor data: CVs, credentials, payroll information
- Producer & cluster data: farm location, production records, compliance documentation
- Operational & platform data: login credentials, system activity logs
- Technical data: IP address, device type, cookies
- Compliance data: export, audit, ESG, and certification documentation
JEFs does not knowingly process data relating to minors.
4. Purpose of Data Processing
Personal data may be used to:
- Operate and manage alfalfa production and processing activities
- Enable digital farm management, traceability, and reporting
- Facilitate employment, contracting, and service delivery
- Support export documentation and regulatory compliance
- Meet lender, audit, and reporting requirements
- Maintain operational security, integrity, and accountability
5. Data Sharing & Disclosure
JEFs does not sell personal data.
Data may be shared strictly on a need-to-know basis with:
- El-Meena Farms Ltd (technical, digital, and market platform support)
- Financial institutions and escrow managers (e.g. JAIZ Bank)
- Export logistics providers and quality inspectors
- Regulators and public authorities where legally required
All third parties must comply with applicable data protection obligations.
6. Data Security Measures
JEFs implements proportionate technical and organisational safeguards, including:
- Role-based access controls
- Secure digital storage and encryption where applicable
- Audit logs and monitoring systems
- Confidentiality obligations for staff and contractors
Security controls are reviewed periodically to address emerging risks.
7. Data Retention
Personal data is retained only for:
- Operational necessity
- Legal, regulatory, or contractual compliance
Data no longer required is securely deleted or anonymised.
8. Rights of Data Subjects
In accordance with the NDPA, data subjects have the right to:
- Access personal data held by JEFs
- Request correction or update of inaccurate data
- Withdraw consent (where applicable)
- Request erasure where legally permissible
- Object to or restrict certain processing
- Lodge a complaint with the Nigeria Data Protection Commission (NDPC)
9. Cookies & Digital Tracking
JEFs digital platforms may use cookies to:
- Improve functionality
- Monitor system performance
- Enhance user experience
Users may manage cookie preferences through browser settings.
10. International Data Transfers
Where data is transferred outside Nigeria, JEFs ensures appropriate safeguards consistent with NDPA requirements and contractual protections.
11. Policy Updates
This Policy may be updated periodically to reflect legal, operational, or regulatory changes. Updates will be communicated through official channels.
12. Contact Information
For all privacy-related enquiries, requests, or complaints:
Data subjects may also lodge complaints with the Nigeria Data Protection Commission (NDPC).
Closing Statement
JEFs is committed to responsible data stewardship, transparency, and trust across its agricultural, digital, financial, and export operations. Personal data protection is integral to our governance, ESG, and compliance framework.