Privacy Policy

Effective 14 October 2026

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 with the field agents of a participating agribusiness (your "agribusiness"). It also holds what the agribusiness tells us about the agents' supervisors, and it is managed by our own team.

You only receive AgentBI messages after you have agreed to them. A member of our team reads you what AgentBI does, on the phone or in person, and records your answer. If you message the AgentBI number without having agreed, we keep your message, but AgentBI does not message you.

What we collect

• Contact details: your mobile number and your WhatsApp id. WhatsApp also sends us the profile name you set there; we do not read it or keep it.
• Messages: the words of every message you send to AgentBI and that AgentBI sends you, when each was sent, and whether it was delivered and read. A location you share is kept. For a voice note we keep only WhatsApp's reference to it, never the recording.
• Your answers: your answers to the onboarding questions, for example your nearest town, how you travel, your home location and the name on your M-Pesa account, and your ID number or next of kin where the questions ask for them.
• Information from your agribusiness: your full name, phone number, region and territory, hire date, whether you are active, and your supervisor. For agents, also your sales (product, quantity, value and date, with a code for the farmer instead of their name or number) and counts of your activity. For supervisors, your name, phone number and region.
• What we work out: whether an agent may need support, for example after no sale for some time, under rules a person sets; the messages our system suggests sending; and, where a research experiment is running, which group an agent is in.
• Technical data: records of message delivery, and logs of our systems, which name messages and people by our own ids and never by your number or your words.
• On this website: the site sets no cookies of its own, and runs scripts of its own only to play example conversations: one on the home page, and a demo with made-up agents and data. They send nothing anywhere, and anything typed into the demo stays on the page. Cloudflare, which serves it, receives your IP address with each visit, as any web host does.
• Our own team: when one of us signs in to manage AgentBI, Google tells us their email address. We check it and do not keep it.

Why we use it

• To send you onboarding questions, reminders, coaching and program information, and to answer your replies. Messages go between 7am and 7pm Kenya time, except the reply confirming that you asked us to stop or to delete your data.
• To read what you type, and your voice notes if you agreed to that, so that you can answer in your own words instead of tapping a button. An AI model does the reading (see "Who we share it with").
• To show our team which agents may need support, so that a person can decide whether to send a message. A person sets the rules and sends the message; the system only suggests.
• To measure whether the program works, including by comparing groups of agents in research experiments. An experiment starts only after a named person approves it and its ethics review is recorded.
• To keep the service safe, find and fix faults, 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 a member of our team reads you what AgentBI does and records your answer, and which you can withdraw at any time by sending 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

• Your agribusiness sends us the information about you listed above. Today nobody at your agribusiness signs in to AgentBI, and AgentBI sends it nothing. If you ask us to erase your data, we may tell it that you asked (see data deletion).
• Our research partner, Busara, designs how the program is measured. AgentBI's systems send it nothing today.
• Google Cloud stores everything AgentBI holds, in its Johannesburg, South Africa region (africa-south1).
• Meta Platforms, which operates WhatsApp, carries every message between you and AgentBI, so it has their words, your number and any voice note you send. For these, Meta works on our behalf, as our "processor", under its WhatsApp Cloud API terms and its data processing terms (the Meta Global Processor Terms). Those terms also let Meta combine or anonymise what it carries to improve and measure its services, and use it for itself to keep WhatsApp safe and secure. WhatsApp also holds information about your own WhatsApp account, including when you message a business. What Meta and WhatsApp hold for themselves falls under their own privacy policies; we have not established everything that includes, or how long they keep it.
• Google's Gemini API, an AI model, reads each message you type while you answer the onboarding questions, and your voice notes if the wording you agreed to covered voice notes. It is sent your message and the question you were answering; never your number, your name or your earlier messages, and private answers we already hold are blanked out of your message first. Your typed reply to a question that asks for a private detail, such as your ID number, is never sent to it, but a private detail you type in any other message, or say in a voice note, is. We keep no recording of a voice note.
• Sentry reports faults in our software to our engineers. Its reports name messages and people only by our own ids, never by number, name or words.
• Slack is where our team receives alerts. An alert carries no more than a Sentry report does.
• Cloudflare carries the traffic to our web address and serves this website. The messages WhatsApp delivers to us pass through Cloudflare, which can read them.
• Authorities, where the law requires it.

We do not sell personal data, and we do not share it with other agribusinesses.

International transfers

AgentBI is hosted in South Africa, so storing your data at all sends it out of Kenya. Some of the services above process it elsewhere, and for several we have not yet established where:

• Google keeps the daily backups of our database, and our system logs, in its Johannesburg region too. Backups and logs made before we set that stay where Google first put them, which may be outside Africa, until they expire: logs within 30 days, and backups, we expect, within 14. Google keeps its record of administrative actions on our systems in a location it chooses.
• Google does not say where its Gemini API processes a request.
• Meta processes WhatsApp messages in its own data centres. Its contract names the companies running those data centres in the United States, Denmark, Sweden and Ireland. Our WhatsApp number uses Meta's "local storage" in South Africa (Meta does not offer Kenya): Meta may process a message in any of its data centres for up to 60 minutes, and after that keeps its words, any voice note or file, and our template messages only in South Africa. That promise is in Meta's documentation, not its contract, and the documentation does not say whether it also covers button taps, lists, shared locations or delivery reports. Meta's documentation also says it keeps messages for at most 30 days.
• Sentry keeps its reports in the United States or the European Union; we have not confirmed which. Where Slack keeps alerts we have not confirmed.
• Cloudflare handles each request at whichever of its data centres receives it, which is not necessarily in Kenya.

We keep a record of every flow of personal data out of AgentBI: who receives it, where, what is sent and for how long. Which safeguards under the Data Protection Act, 2019 apply to each transfer, including our contract with each provider, we are confirming with our lawyers.

How long we keep it

We have not yet set a fixed period, and nothing deletes your data on a schedule yet. We keep what we hold until you ask us to erase it (see data deletion). That includes the information your agribusiness sends us, which we keep as it arrived. Some things have fixed periods today:

• our system logs, which name people by our own ids: 30 days; Google's record of administrative actions on our systems: 400 days;
• backups of our database: one a day, and the 14 most recent are kept.

We keep a record of your consent and of any request to stop or to be erased for as long as needed to honour it.

Your rights

You can ask us what data we hold about you, for a copy of it, to correct it, to erase it, or to restrict or object to how we use it, and you can withdraw your consent at any time. Three of these work by sending a word on WhatsApp, as a message on its own:

• Stop messages: send STOP (or ACHA). This takes effect straight away. See our data deletion instructions for other words that work.
• A copy of your data: send MY DATA (or NIPE DATA YANGU). It does not stop your messages. We record the request and, if we may message you, reply to say so. A member of our team then calls you on that number. Because phone numbers are passed on to new people, we check it is you before we send anything: if we hold your ID number, you tell us your full name and ID number on the call; otherwise you show your national ID card in person. Then we email you the copy as an encrypted file and tell you its password on the call, or hand you a printed copy. We never send it over WhatsApp, and if we cannot confirm it is you, we send nothing. The law gives us seven days from your message, and that is the deadline we work to. If you ask by email instead, we will ask you to send MY DATA from the number you use with AgentBI, and count the seven days from your email.
• Erase your data: send DELETE (or FUTA DATA YANGU). This also stops your messages. We act on it within 14 days, after checking the number is still yours. Our data deletion instructions say what is erased and what is kept.

To correct an answer while you are answering the onboarding questions, wait for Aggie to read back what it recorded and tap Change something. For anything else, email admin@agentbi.org; other requests sent over WhatsApp are read to run the program, not as an inbox. We respond to email within 30 days. If you are in Kenya, you may also complain to the Office of the Data Protection Commissioner.

Security

We limit access to personal data to people who need it. Data is encrypted on its way to and from our systems and where Google stores it, though Meta and Cloudflare handle messages unencrypted while they process them, as described above. Meta stores messages encrypted, under keys Meta itself holds. Our system keeps an audit trail of what it does, which names people by id and never by number or words. 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.