Dimitra Incorporated
At Dimitra, we understand that your privacy is important to you and that we care about how your information is used and shared online. We respect and value the privacy of everyone who uses our mobile apps and/or visits our web sites and will only collect and use information in ways that are useful to you and in a manner consistent with your rights and our obligations under the law.
This policy applies to our use of any and all data collected by us in relation to your use of our mobile apps and our web sites. Please read this privacy policy carefully and ensure that you understand it. (Your acceptance of our privacy policy is deemed to occur upon your first use of our mobile apps or our website.) If you do not accept and agree with this privacy policy, you must stop using our mobile apps or our web sites immediately and contact us at privacy@dimitra.io
1. Definitions and Interpretation
In this policy, the following terms shall have the following meanings:
“Account”
means an account required to access and/or use certain areas and features of our mobile apps or our web sites;
“Cookie”
means a small text file placed on your computer or device by our web sites when you visit certain parts of our web sites and/or when you use certain features of our web sites. Details of the cookies used by our web sites are set out in section 12 below:
“our mobile apps and our website”
mobile apps, including Connected Farmer, Connected Coffee, Livestock Guru, Deforestation, Real World Assets, Carbon, and ESG, and our website, http://dimitra.io;
“UK and EU Cookie Law”
means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended in 2004, 2011 and 2015;
“We/Us/Our”
means Dimitra Incorporated
2. Information About Us
3. Scope – What Does This Policy Cover?
This privacy policy applies only to your use of our mobile apps and our web sites. It does not extend to external websites that are linked to from our mobile apps and our web sites (whether we provide those links or whether they are shared by other users). We have no control over how your data is collected, stored, or used by external websites, and we advise you to check the privacy policies of any such websites before providing any data to them. We comply with the following privacy and environmental regulations:
- General Data Protection Regulation (GDPR) (EU)
We comply with the GDPR to ensure the privacy and protection of personal data for individuals within the European Union. Your personal data is processed transparently, securely, and with your consent where necessary. The immutable nature of blockchain technology, including the Dimitra blockchain environment, ensures that data recorded on the blockchain cannot be altered or deleted. To comply with GDPR principles, we take all reasonable measures to protect personal data. This includes storing personal data off-chain or encrypting/hashing it, ensuring data privacy and security while leveraging blockchain's benefits. These measures enable us to align with regulatory requirements such as the 'right to be forgotten..
- California Consumer Privacy Act (CCPA) (California, USA)
We are committed to protecting the privacy of California residents in accordance with the CCPA. This law provides rights regarding access to, deletion, and sharing of personal data.
- California Online Privacy Protection Act (CalOPPA) (California, USA)
As part of CalOPPA, we ensure transparency regarding the collection and use of personal data on our platform, including maintaining a privacy policy that is regularly updated.
- Personal Information Protection and Electronic Documents Act (PIPEDA) (Canada)
We comply with PIPEDA in Canada, ensuring that any personal information we collect is handled responsibly, securely, and with full respect for your privacy rights.
- Australia’s Privacy Act (Australia)
We adhere to Australia’s Privacy Act to ensure the protection of personal data and respect individuals' rights to privacy in Australia.
4. What Data Do We Collect?
PII stands for Personally Identifiable Information. It refers to any data that can be used to uniquely identify an individual, either on its own or when combined with other information. Examples of PII are:
- Full name
- Government issued ID
- Passport number
- Driver's license number
- Email address
- Phone number
- Physical address
- Date of birth
- Gender
- Zip code
- IP address
- Cookies or device identifiers
- Geo-location data (Dimitra only uses Geo-location data to identify farm land plots, not users)
Dimitra limits user supplied data in the following ways:
- Dimitra acknowledges you as the data owner of your own PII data that you submit into the Dimitra infrastructure.
- Dimitra only acts as a host and data processor of your PII data, which you can delete upon request.
- Dimitra anonymizes all user data (i.e. all PII data is removed) before being used to train any of our AI models.
- Dimitra anonymizes all user data (PII is removed) before being used for any commercial purposes.
- Dimitra may monetize or train AI models on user supplied non-PII data and share that data with third parties if authorized by the user.
- Dimitra requests user authorization to monetize and/or train machine learning models on submitted non-PII user data. If the user does not authorize data usage, the application is not made available to the user.
- Dimitra minimizes data collection to only what is necessary for the purposes of providing user-oriented application functionality.
- Dimitra uses encryption and secure access controls to protect user submitted data.
- Dimitra allows users to manage and control their submitted PII data (e.g., request access, deletion, or corrections).
- Dimitra notifies users in case of PII related data breaches.
Some data will be collected automatically by our mobile apps and our web sites, other data will only be collected if you voluntarily submit it and consent to us using it for the purposes set out in section 5. Depending upon your use of our mobile apps and our web sites, we may collect some or all of the following data:
Personal Data
- Name
- Business/company name
- Contact information such as email addresses and telephone numbers
Farm Data
- Crop types
- Production data
- Geospatial information (including satellite images)
Usage Data
- IP address (automatically collected)
- Web browser type and version (automatically collected)
- Operating system (automatically collected)
- A list of URLs starting with a referring site, your activity on our mobile apps and our web sites, and the site you exit to (automatically collected)
5. How Do We Use Your Data?
- All personal data is stored securely in accordance with the EU General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR). For more details on security see section 6, below.
- We use your data to provide the best possible services to you using Google Analytics as a tool. This includes:
- Supplying our services to you
- Personalising and tailoring our services for you
- Responding to communications from you
- Supplying you with email newsletters, alerts etc. that you have subscribed to (you may unsubscribe or opt-out at any time by unsubscribing from our newsletters)
- Market research
- Analysing your use of our mobile apps and our web sites/product to enable us to continually improve our mobile apps and our web sites and your user experience
- In some cases, the collection of data may be a statutory or contractual requirement, and we will be limited in the services we can provide you without your consent for us to be able to use such data.
- With your permission and/or where permitted by law, we may also use your data for marketing purposes which may include contacting you by email with information, news and offers on our services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that we fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended in 2004, 2011 and 2015.
- Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis:
- 1. you have given consent to the processing of your personal data for one or more specific purposes;
- 2. processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
- 3. processing is necessary for compliance with a legal obligation to which we are subject;
- 4. processing is necessary to protect the vital interests of you or of another natural person;
- 5. processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or;
- 6. processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject, which require protection of personal data, in particular where the data subject is a child.
6. How and Where Do We Store Your Data?
- We only keep your data for as long as we need to in order to use it as described above in Section 5 and/or for as long as we have your permission to keep it. In any event, we will conduct a periodic review to ascertain whether we need to keep your data. Your data will be deleted if we no longer need it in accordance with the terms of our Data Retention Policy.
- Some or all of your data may be stored or transferred outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland and Liechtenstein). You are deemed to accept and agree to this by using our mobile apps and our web sites and submitting information to us. If we do store or transfer data outside the EEA, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the EEA and under the GDPR, See Section 3 . Such steps may include, but not be limited to, the use of legally binding contractual terms between us and any third parties we engage and the use of the EU-approved Model Contractual Arrangements.
- Data security is of great importance to us, and to protect your data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through our mobile apps and our web sites.
- Notwithstanding the security measures that we take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to us data via the internet.
7. Do We Share Your Data?
- We may contract with third parties to supply services to you on our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under the law.
- We may compile statistics about the use of our mobile apps and our web sites including data on traffic, usage patterns, user numbers, sales and other information. All such data will be anonymised and will not include any personally identifying information.
- In certain circumstances we may be legally required to share certain data held by us, which may include your personal information, for example, where we are involved in legal proceedings, where we are complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from you in order to share your data in such circumstances and will comply as required with any legally binding request that is made of us.
8. What Happens If Our Business Changes Hands?
- We may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of our business. Data provided by users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use the data for the purposes for which it was originally collected by us.
- In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes. When contacted you will be given the choice to have your data deleted or withheld from the new owner or controller.
9. How Can You Control Your Data?
- When you submit information via our mobile apps and our web sites, you may be given options to restrict our use of your data. We aim to give you strong controls on our use of your data (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails.)
10. Your Right to Withhold Information and Your Right to Withdraw Information After You Have Given it
- You may access our mobile apps and our web sites without providing any data at all. However, to use all features and functions available on our mobile apps and our web sites you may be required to submit or allow for the collection of certain data.
- You may restrict your internet browser’s use of cookies. For more information, see section 12.
- You may withdraw your consent for us to use your personal data as set out in section 5 at any time by contacting us using the details set out in section 15, and we will delete your data from our systems. However, you acknowledge this may limit our ability to provide the best possible services to you.
11. How Can You Access Your Data?
You have the legal right to ask for a copy of any of your personal data held by us (where such data is held). Please contact us for more details at info@dimitra.io or using the contact details below in section 14.
12. What Cookies Do We Use and What For?
- Our web sites may place and access certain first party cookies on your computer or device. First party cookies are those placed directly by us and are used only by Us. We use cookies to facilitate and improve your experience of our web sites and to provide and improve our services. For more details, please refer to section 5, above. We have carefully chosen these cookies and have taken steps to ensure that your privacy is protected and respected at all times.
- By using our web sites you may also receive certain third party cookies on your computer or device. Third party cookies are those placed by websites, services, and/or parties other than us. For more details, please refer to section 5. These cookies are not integral to the functioning of our web sites.
- All cookies used by and on our web sites are used in accordance with current UK and EU cookie laws.
- Before cookies are placed on your computer or device you will be shown a message requesting your consent to set those cookies. By giving your consent to the placing of cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of cookies; however certain features of our web sites may not function fully or as intended.
- Our web sites use analytics services provided by Google Analytics. Website analytics refers to a set of tools used to collect and analyse usage statistics, enabling us to better understand how people use our mobile apps and our web sites. This, in turn, enables us to improve our mobile apps and our web sites and the services offered through it. You do not have to allow us to use these cookies, as detailed below, however whilst our use of them does not pose any risk to your privacy or your safe use of our web sites, it does enable us to continually improve our web sites, making it a better and more useful experience for you.
- The analytics service(s) used by our web sites use(s) cookies to gather the required information. Certain of these cookies may be placed immediately when you first visit our mobile apps and our web sites and it may not be possible for us to obtain your prior consent. You may remove these cookies and prevent future use of them by following the steps set out below.
- You can choose to enable or disable cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party cookies. By default, most internet browsers accept cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
- You can choose to delete cookies at any time however you may lose any information that enables you to access our mobile apps and our web sites more quickly and efficiently including, but not limited to, login and personalisation settings.
- It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
13. Summary of Your Rights under GDPR
Under the GDPR, you have:
- the right to request access to, deletion of or correction of, your personal data held by us;
- the right to complain to a supervisory authority;
- be informed of what data processing is taking place;
- the right to restrict processing;
- the right to data portability;
- object to processing of your personal data;
- rights with respect to automated decision-making and profiling (see section 14 below).
To enforce any of the foregoing rights or if you have any other questions about our mobile apps and our web sites or this Privacy Policy, please contact us using the details set out in section 15 below.
14. Automated Decision-Making and Profiling
14.1 In the event that we use personal data for the purposes of automated decision-making and those decisions have a legal (or similarly significant effect) on you, you have the right to challenge to such decisions under GDPR, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from us.
14.2 The right described in section 14.1 does not apply in the following circumstances:
- 1. The decision is necessary for the entry into, or performance of, a contract between you and Us;
- 2. The decision is authorised by law; or
- 3. You have given your explicit consent.
- Where We use your personal data for profiling purposes, the following shall apply:
- Clear information explaining the profiling will be provided, including its significance and the likely consequences;
- Appropriate mathematical or statistical procedures will be used;
- Technical and organisational measures necessary to minimise the risk of errors and to enable such errors to be easily corrected shall be implemented; and
- All personal data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling.
15. Children’s Personal Information
We do not knowingly collect personal information from children under 13 without prior verifiable parental consent. If we learn that a child under the age of 13 has submitted personally identifiable information online without parental consent, we will take all reasonable measures to delete such information from our databases and to not use such information for any purpose (except where necessary to protect the safety of the child or others).
If you believe that a child under the age of 13 has provided us with personal information without verification of parental consent, please contact our data protection officer at privacy@dimitra.io.
16. Contacting Us
If you have any questions about our mobile apps and our web sites or this Privacy Policy, please contact us by email at info@dimitra.io or our data protection officer at privacy@dimitra.io Please ensure that your query is clear, particularly if it is a request for information about the data we hold about you (as under section 11, above).
17. Changes to Our Privacy Policy
We may change this Privacy Policy as we may deem necessary from time to time, or as may be required by law. Any changes will be immediately posted on our mobile apps and our web sites and you will be deemed to have accepted the terms of the Privacy Policy on your first use of our mobile apps and our web sites following the alterations. We recommend that you check this page regularly to keep up-to-date.