Privacy Policy and Terms & Conditions

1. Our approach to privacy

1.1 Apollo Agriculture ("Apollo", "we", "our", or "us") is committed to protecting and

respecting your privacy. This privacy policy sets out how we collect, store, process,

transfer, share and use data that identifies or is associated with you ("personal

information").

1.2 Before accessing or using our website at www.apolloagriculture.com (the "Apollo

Website") or our App (the "Apollo App"), or registering as a customer of Apollo, directly

or through our agents or employees, please ensure that you have read and understood

our collection, storage, use and disclosure of your personal information as described in

this privacy policy.

1.3 If you have any questions, comments and requests regarding this privacy policy, please

contact: privacy@apolloagriculture.com .

2. Who is responsible for your personal information

Apollo is the data controller of the personal information we hold about you. This means

that we determine and are responsible for how your personal information is used.

3. Personal information we collect about you and how we use it

Personal information you submit to us

3.1 We collect personal information that you submit directly to us, including information you

provide to our agents which is input into the Apollo App or on a phone call with an Apollo

agent or employee and input into our website platform. We may also use third party

credit bureau data about you where available.

3.2 We will indicate to you if the provision of certain personal information is mandatory or

optional. If you choose not to provide any personal information which is mandatory, we

may not be able to respond to you or provide our services to you.

3.3 The list below sets out the categories of personal information we collect about you, how

we use that information and the lawful basis we rely on to process that personal

information:

Personal and Contact information, such as your name, age, gender, family details,

address, telephone number, email address, national ID, location data (GPS outline of

field and/or home). We use this information to communicate with you about our products

and services, to enable you to utilize our products and services, and to respond to any

queries, issues or concerns you have. The lawful bases we rely on for processing this

personal information is i) that processing is necessary for our legitimate interests, namely

communicating with prospective customers and others about our products and services

and ii) the processing is necessary for the performance of a contract and to take steps

prior to entering into a contract.

Financial Information, such as your income, assets (home and farm) ownership, other

farming assets (such as type and number of livestock.) We use this information to

assess your suitability for and to allow you to access features in connection with your use

of the service. The lawful basis we rely on for processing this personal information is that

processing is necessary for the performance of a contract with you, namely our terms of

service. If you access the Apollo App, the lawful basis we rely on for processing this

personal information is that processing is necessary for your Apollo's legitimate interests,

namely providing you with access to Apollo’s services.

Agronomic and behavioural data, such as farming experience, recent performance,

quality of farm practices, crop sale prices and other indicators for future yields and

repayments. The lawful basis we rely on for processing this personal information is that

processing is necessary for our legitimate interests, namely ensuring that you are

suitable to receive our services.

Comments and opinions, when you contact us directly via our agents or call centre, we

will record your comments and opinions. We will use your comments and opinions to

respond to and address your queries, issues and concerns, improve our products and

services and to inform our marketing strategies. The lawful basis for processing this

personal information is that processing is necessary for our legitimate interests, namely

communicating with current or prospective customers and others about our products and

services.

Personal information we collect automatically

3.4 Information about your device: We also automatically collect personal information

about the device you use to access the Apollo Website or Apollo App, including your IP

address, details about the type of device and browser you use and device’s telephone

number (if applicable). We use this information as follows:

(a) To allow you to navigate around the Apollo Website or the Apollo App. The lawful

basis we rely on for processing personal information in this way is that processing

is necessary for the performance of a contract with you.

(b) For analytics purposes to measure site usage and performance to make

improvements as necessary. We will only use your personal information in this

way to the extent you give us your consent to do so.

4. Cookies and similar technologies

4.1 The Apollo Website uses cookies and similar tracking technologies. Cookies are pieces

of code that we transfer to your device for record-keeping purposes. This helps us to

provide certain functionalities on the Apollo Website as well as to monitor and improve

the Apollo Website.

4.2 We use the following types of cookies:

(a) Strictly necessary cookies. These are cookies that are required for the

operation of the Apollo Website such as cookies that allow you to log in to your

account on the Apollo Website. Without these cookies, certain elements of the

Apollo Website would not work.

(b) Analytical cookies. These allow us to recognise and count the number of

visitors, to see how visitors move around the Apollo Website and to monitor

performance of certain features on the Apollo Website. This helps us to improve

the Apollo Website.

the Apollo Website and to remember information that you enter on the site, such

as when you fill out a form.

4.3 Other than cookies that are required to operate the Apollo Website, we will only place

cookies on your device with your consent. if you would like to withdraw your consent to

non-essential cookies, you can do this by deleting the cookies for the Apollo Website

from your device through your browser settings or mobile device settings and rejecting

non-essential cookies the next time you access our website. The following links contain

further information about how to delete cookies from popular browsers:

(a) Delete cookies in Microsoft Edge;

(b) Delete cookies in Firefox;

(d) Delete cookies in Safari web;

(e) Delete cookies in iOS;

(f) Delete cookies in Chrome for Android.

4.4 Most browsers will also allow you to disable all cookies through your browser or mobile

settings. These settings will typically be found in the "options" or "preferences" menu of

your browser. Please note that if you choose to refuse cookies you may not be able to

use the full functionality of the Apollo Website.

5. How long we keep your personal information

5.1 We will store the personal information we collect for no longer than necessary for the

purposes set out and in accordance with our legal obligations and legitimate business

interests.

5.2 If you have signed up or attempted to sign up as a customer of Apollo Agriculture we will

delete or anonymise your personal information after seven (7) years, in order to comply

with our legal obligations.

5.3 If you have signed up or attempted to sign up as a customer of Apollo Agriculture, upon

your request, we will delete or anonymise your personal information (which we are

permitted to delete) within fourteen (14) days.

6. Recipients

6.1 As required in accordance with how we use your personal information, we may share

your personal information with the following:

(a) Companies in the same group as us: We may share personal information with

other entities owned by or under common ownership with Apollo. We do this to

coordinate our group-wide strategy for providing services and communicating

with prospective customers.

(b) Service providers and advisors. We may share your personal information with

third party vendors and other service providers that perform services for us or on

our behalf, which may include providing mailing, credit checks, messaging and

email services, fraud prevention, debt financing and web hosting.

share your personal information with third parties as required by law or if we

reasonably believe that such action is necessary to (i) comply with the law and

the reasonable requests of law enforcement; (ii) detect and investigate illegal

activities and breaches of agreements; and/or (iii) exercise or protect the rights,

property, or personal safety of Apollo, its users or others.

7. Storing and transferring your personal information

7.1 Security. We implement appropriate technical and organisational measures to protect

your personal information against accidental or unlawful destruction, loss, change or

damage. All personal information we collect will be stored on our secure servers.

7.2 International Transfers of your personal information. The personal information we

collect may be transferred to and stored in countries outside of the jurisdiction you are in

where we and our third-party service providers have operations. If you are located in the

United Kingdom ("UK") or European Economic Area ("EEA") or Kenya, your personal

information may be processed outside of the UK or EEA or Kenya, including in the United

States. We will ensure that these international transfers of your personal information are

made pursuant to appropriate safeguards, such as:

(a) ensuring that the personal information is only transferred to countries recognised

as offering an equivalent level of protection as compared to the level of protection

in the country you are located; or

(b) the transfer is made pursuant to appropriate safeguards of the relevant

jurisdiction , such as standard data protection clauses adopted by the European

Commission or UK Secretary of State or Kenyan Data Protection Commissioner

(as applicable).

7.3 We will take appropriate steps to ensure that your personal information is treated

securely and in accordance with applicable law and this privacy policy regardless of

where it is processed.

7.4 If you wish to enquire further about the safeguards we use, please contact us using the

details set out above.

8. Your rights in respect of your personal information

8.1 If you are resident in the UK or EEA, or Kenya, in accordance with applicable privacy law

you have the following rights in respect of your personal information that we hold:

(a) Right of access. You have the right to obtain:

(i) confirmation of whether, and where, we are processing your personal

information;

(ii) information about the categories of personal information we are

processing, the purposes for which we process your personal information

and information as to how we determine applicable retention periods;

(iii) information about the categories of recipients with whom we may share

your personal information; and

(iv) a copy of the personal information we hold about you.

(b) Right of portability. You have the right, in certain circumstances, to receive a

copy of the personal information you have provided to us in a structured,

commonly used, machine-readable format that supports re-use, or to request the

transfer of your personal data to another person.

or incomplete personal information we hold about you without undue delay.

(d) Right to erasure. You have the right, in some circumstances, to require us to

erase your personal information without undue delay if the continued processing

of that personal information is not justified.

(e) Right to restriction. You have the right, in some circumstances, to require us to

limit the purposes for which we process your personal information if the continued

processing of the personal information in this way is not justified, such as where

the accuracy of the personal information is contested by you.

(f) Right to object. You have the right to object to any processing based on our

legitimate interests. There may, depending on the particular circumstances, be

compelling reasons for continuing to process your personal information despite

your objection, and we will assess and inform you if that is the case. You can

object to marketing activities for any reason.

8.2 If you wish to exercise one of these rights, please contact us using the contact details at

the top of this privacy policy. We will not charge you a fee for complying with your request

to exercise one of these rights, other than where the request is manifestly unfounded or

excessive (such as if you submit a number of repeated requests), in which case we may

charge you a reasonable fee to cover our administrative costs.

8.3 You also have the right to lodge a complaint to your national data protection authority. If

you are in the EEA, further information about how to contact your local data protection

authority is available at https://edpb.europa.eu/about-edpb/about-edpb/members_en. If

you are in the UK, your local data protection authority is the Information Commissioner's

Office, which can be contacted using the details at https://ico.org.uk/global/contact-us/. In

the case of Kenya, the relevant authority is the Office of the Data Protection

Commissioner available at https://www.odpc.go.ke/

9. Links to third party sites

The Apollo Website may from time to time, contain links to and from third party websites,

including those of other users, our partner networks, advertisers, partner merchants,

news publications, retailers and affiliates. If you follow a link to any of these websites,

please note that these websites have their own privacy policies and that we do not

accept any responsibility or liability for their policies. Please check the individual policies

before you submit any information to those websites.

10. Our policy towards children

The Apollo Website is not directed at persons under 18 and we do not knowingly collect

personal information from children. If you become aware that your child has provided us

with personal information, without your consent, either directly or by other means, then

please contact us using the details below so that we can take steps to delete such

information and terminate any account your child has created with us.

11. Changes to this policy

We may update this privacy policy from time to time and so you should review this page

periodically. When we change this privacy policy in a material way, we will update the

"last modified" date at the end of this privacy policy. Changes to this privacy policy are

effective when they are posted on this page.

12. Notice to you

If we need to provide you with information about something, whether for legal, marketing

or other business-related purposes, we will select what we believe is the best way to get

in contact with you. We will usually do this through email or by placing a notice on the

Apollo Website.

13. Last modified

13.1 This privacy policy was last modified on 13 September,2022.