Privacy Policy
This policy explains how Burgeon Strategy LLC ("Burgeon", "we") handles personal data when you use AgentBI, our WhatsApp-based service for field agents, or visit agentbi.org. Burgeon Strategy LLC is the data controller. You can reach us at admin@agentbi.org.
Who this applies to
AgentBI is used by field agents who work with a participating agribusiness (your "agribusiness"), and by staff of that agribusiness. You only receive AgentBI messages after you have opted in.
What we collect
- Contact and identity: your mobile phone number, your name, and the profile name shown on WhatsApp.
- Messages: the content of messages you send to and receive from AgentBI, when they were sent, and whether they were delivered or read.
- Your answers: responses to onboarding, comprehension and coaching questions, and any sale or activity you choose to report to us.
- Information from your agribusiness: your role, start date, supervisor, location and activity or sales records that your agribusiness shares with us under a written agreement, so that we can support you and measure the program.
- Technical data: message delivery logs and, on this website, standard server logs.
Why we use it
- To send you onboarding steps, reminders, coaching and program information, and to answer your replies.
- To give your agribusiness a view of how its agent network is doing, including onboarding progress and activity.
- To measure whether the program works. This is done with a research partner and uses aggregated or pseudonymised data wherever possible.
- To keep the service safe, prevent misuse, and meet legal obligations.
Anything you report to AgentBI yourself, such as a sale, is used for coaching and support only. Your agribusiness's own records remain the record of what was sold.
Legal basis
We rely on your consent, which you give when you opt in on WhatsApp and can withdraw at any time by replying STOP; on our legitimate interest in running and improving the program; and on legal obligations. Where the Kenya Data Protection Act, 2019 applies, we process your data in accordance with it.
Who we share it with
- Meta Platforms, which operates WhatsApp. Messages travel through WhatsApp under Meta's own terms and privacy policy.
- Your agribusiness, which sees your onboarding progress, activity and coaching status, but not the full text of your conversations unless you ask us to share it.
- Our research partner, under a written agreement, for program evaluation.
- Service providers that host our systems and deliver messages, bound by contract to protect your data.
- Authorities, where the law requires it.
We do not sell personal data, and we do not share it with other agribusinesses.
International transfers
Our systems are hosted outside Kenya, including in the United States and the European Union. When we transfer personal data out of Kenya we use safeguards recognised under the Data Protection Act, 2019, including contractual protections, and we keep records of those transfers.
How long we keep it
We keep your data for the duration of the program you take part in and for up to 24 months afterwards, then delete or anonymise it. We keep a record of your consent and of any opt-out for as long as needed to honour it, and we keep data longer only where the law requires.
Your rights
You can ask us to tell you what data we hold about you, correct it, delete it, restrict or object to how we use it, or give you a copy. You can withdraw consent at any time by replying STOP, which stops all AgentBI messages. To exercise any right, message us on WhatsApp or email admin@agentbi.org. We respond within 30 days. If you are in Kenya, you may also complain to the Office of the Data Protection Commissioner.
See our data deletion instructions for the exact steps.
Security
We limit access to personal data to people who need it, encrypt data in transit and at rest, and keep access logs. No system is perfectly secure, and if a breach affects you we will tell you and the relevant authority as the law requires.
Children
AgentBI is for adults working with a participating agribusiness. We do not knowingly collect data from anyone under 18.
Changes
If we change this policy in a way that matters to you, we will tell you on WhatsApp or on this page before the change takes effect.