Privacy Policy

Last updated: July 13, 2026
This Privacy Policy explains how Plotra (a Terraxis SRL product; “Plotra”, “we”, “us”, or “our”)
collects, uses, protects, and governs personal and operational data when you use the Plotra platform
for coffee farming, traceability, human rights due diligence, compliance, and cooperative
management.
Plotra is built as a cooperative workstation: information is captured at the point a real operational
event happens — a delivery, a screening visit, a quality check — rather than through repeated,
disconnected forms. This keeps what we hold tied to what an actual event generated, which
underpins the purpose-limitation and minimisation commitments below.
Our data processing practices align with the principles of the EU General Data Protection Regulation
(GDPR), the Kenya Data Protection Act 2019, and other applicable data protection laws.
1. Information We Collect
Personal Information — provided when creating or using an account: name, email, telephone
number, account credentials, cooperative membership, user preferences, and communications with
our support team.
Farm and Operational Data — farm boundaries and GPS coordinates, parcel mapping, production
and yield records, delivery and inventory records, certification and compliance records,
environmental and satellite-derived indicators, and audit and traceability records.
Human Rights Due Diligence and Safeguarding Data — where applicable, information about
children and young workers connected to a farm, including age, schooling, farm tasks performed,
hours, and indicators of unsafe or exploitative conditions (see Section 13, which sets out how this
category is handled — it is treated differently from the categories above, not folded into them).
Technical Information — device and browser information, IP address, login activity, usage analytics,
performance logs, and security/audit logs.
2. How We Use Your Information
We process information only for legitimate agricultural, operational, and human rights due diligence
purposes, including: providing and maintaining the platform; supporting coffee traceability and farm
management; facilitating compliance with regulatory frameworks including the EU Deforestation
Regulation (EUDR) and human rights due diligence frameworks aligned with the OECD Guidelines
and CSDDD; identifying and responding to child labour and safeguarding risks; managing cooperative
operations; generating reports and compliance documentation; improving platform performance;
protecting platform security; and complying with applicable legal obligations.
We do not use personal data for advertising, behavioural profiling, or unrelated commercial
purposes.

3. Legal Basis for Processing
We match legal basis to purpose rather than relying on one blanket justification:
Purpose Legal basis
Account operation, platform access Performance of a contract
Farm registration, delivery, batch, traceability
records Contract / legitimate interest
EUDR due diligence statements and
geolocation evidence Legal obligation
Human rights due diligence, child labour and
young-worker screening

Legal obligation / legitimate interest, supported by a
documented balancing assessment

Safeguarding indicators suggestive of forced
labour, trafficking, debt bondage, or coercion

Legal obligation, or an equivalent lawful basis
appropriate to data touching on potential criminal
conduct

Optional value-added services (Section 6) Consent, requested separately from core

compliance processing

Where processing relies on consent, you may withdraw it at any time without affecting the
lawfulness of prior processing. Withdrawing consent does not stop processing that rests on a legal
obligation or contractual basis — including safeguarding referrals, which are never consent-gated.
4. Purpose Limitation
We collect and process data only for clearly defined purposes related to agricultural production,
traceability, certification, regulatory compliance, human rights due diligence, and supply-chain
management. Information is never repurposed for unrelated activities without an appropriate legal
basis.
5. Data Ownership, Sovereignty, and Controller/Processor Roles
You retain ownership of the operational information you submit to Plotra. Farmers and cooperatives
maintain access to their operational records, including parcel information, production history, and
compliance documentation, and may export information in interoperable formats (PDF, CSV, XLSX,
GeoJSON) where permitted by applicable agreements and law.
For most producer and household data, the cooperative acts as data controller for its member
network, with Plotra acting as processor under a data processing agreement. For platform-level
compliance outputs shared with buyers, certifiers, or regulators (such as Due Diligence Statements
or aggregated traceability records), Plotra and the relevant cooperative or exporter may act as joint
controllers, with responsibilities set out in the applicable data processing agreement.
6. Information Sharing and Commercial Services
We do not sell your personal information. Information may be shared only when necessary with:
your cooperative or authorised supply-chain partners; regulatory authorities where required by law;

certification bodies where authorised; competent child-protection or labour authorities where a
safeguarding referral obligation applies (Section 13); trusted infrastructure and cloud service
providers; professional service providers under confidentiality obligations; and law enforcement or
courts where legally required. Any third-party processing is governed by appropriate contractual and
legal safeguards.
Plotra generates regulatory documents, compliance reports, traceability records, and due diligence
information — including Due Diligence Statements, traceability documentation, and parcel
verification records — from operational data provided by authorised supply-chain participants.
Optional value-added services (enhanced traceability, quality/lab results, cup scoring, sustainability
metrics, sourcing intelligence) are offered on top of core compliance services and rely on separately
requested consent where they go beyond standard compliance requirements. Plotra does not sell
identifiable personal information or farmer/worker records as standalone datasets.
7. Aggregated and Anonymised Data
We may generate aggregated or anonymised datasets to improve our platform, develop compliance
tools, produce industry insights, and enhance supply-chain services. These datasets do not identify
individual farmers, workers, or users, and safeguarding-related data is never included in aggregated
outputs used for general analytics.
8. Automated Decision-Making and Human Review
Plotra’s risk engines generate automated indicators and risk ratings from submitted human rights
due diligence data. These outputs support human review; they do not replace it. No enforcement
action, escalation, or decision producing a legal or similarly significant effect on an individual is taken
purely by automated means. Where you are affected by an automated outcome, you may request
human review and an explanation of how it was reached.
9. Data Security
We implement technical and organisational measures including encryption of data in transit and at
rest, role-based access controls, secure authentication, audit logging, regular backups, disaster
recovery procedures, infrastructure security monitoring, and periodic security reviews. Human rights
due diligence and safeguarding data are subject to additional access restriction beyond these
baseline measures (Section 13).
10. Data Protection Impact Assessment
Where processing is likely to result in higher risk to individuals — including automated risk screening
and processing involving children — Terraxis conducts a Data Protection Impact Assessment as part
of its ongoing compliance programme. This is treated as a prerequisite before scaling that processing
further, not a retrospective exercise.
11. Data Retention
We retain information only as long as necessary to provide our services, comply with legal
obligations, support traceability, resolve disputes, and maintain legitimate business records.
 Account information: during account activity and up to three (3) years after account closure,
unless a longer period is legally required.

 Operational and compliance records: retained as long as necessary to satisfy regulatory,
certification, contractual, or traceability requirements (including EUDR record-keeping
periods).
 Security and audit logs: generally up to two (2) years, unless longer retention is required for
security investigations or legal obligations.
 Human rights due diligence and safeguarding records: generally retained for a shorter
period than routine operational data, except where an open referral, investigation, or legal
obligation requires longer retention (Section 13).
12. Your Rights
Subject to applicable law, you may have the right to: access your personal information; correct
inaccurate information; request deletion; restrict certain processing; object to specific processing;
receive your information in a portable format; withdraw consent where processing is based on
consent; and lodge a complaint with a supervisory authority — including Kenya’s Office of the Data
Protection Commissioner or, where applicable, an EU supervisory authority. Requests may be
submitted using the contact details below.
13. Children’s Data and Safeguarding
Plotra’s core services are provided to coffee producers, cooperatives, and other authorised business
users, and account holders must be adults. However, as part of human rights due diligence, Plotra
does knowingly and deliberately process information about children and young workers connected
to participating farms, specifically to identify and respond to child labour and safeguarding risk —
this is a core compliance function of the platform, not an incidental data collection we seek to avoid.
Because of this, children’s data is handled under distinct rules, not the general terms above:
 It is collected under a legal obligation / legitimate interest basis, not a general consent
checkbox signed by an adult on the child’s behalf (see the Privacy and Consent Notice).
 Where age-appropriate, the young person themselves — not only a guardian — is informed
in plain, locally appropriate language that information about them is being collected and
why, at the point of screening.
 Access is restricted to designated, trained personnel; it is not visible on general cooperative
or buyer dashboards.
 Automated risk indicators generated from this data always require human review before any
consequential action (Section 8).
 Where findings suggest forced labour, trafficking, debt bondage, or coercion, referral to
competent child-protection or labour authorities follows a defined, tracked process.
 Retention is generally shorter than for routine operational data, except where an open case
or legal obligation requires otherwise.
14. Cross-Border Data Transfers
Where information is transferred outside its country of origin — including between Kenya, Belgium,
and other EU jurisdictions — Plotra implements appropriate safeguards consistent with applicable

data protection law, including GDPR Chapter V mechanisms such as standard contractual clauses
where required.
15. Cookies
We use cookies and similar technologies to improve platform functionality, security, and user
experience. See our Cookie Policy for details.
16. Changes to this Policy
We may update this Privacy Policy periodically. Where material changes occur, we will notify users
through the platform or by email before those changes become effective.

Contact Us
For general privacy questions: privacy@plotra.eu For data protection queries and rights requests:
dpo@plotra.eu Website: https://plotra.eu Registered address: Brussels, Belgium — operations
address: Nairobi, Kenya
Plotra by Terraxis — https://terraxis.eu Coffee Traceability • Farm Management • EUDR Compliance
• Human Rights Due Diligence