Privacy Policy

1. Introduction and definitions

1. 1.1

   This Privacy Policy (“Policy”) applies to the Koshi mobile application (the “App”), which is owned and operated by 21 HECTARES AGROTECH PRIVATE LIMITED, which carries on business under the name “Bull Agritech” (“Bull Agritech”, the “Company”, “we”, “us” or “our”).

2. 1.2

   In this Policy, “you” or “User” means any shop owner or staff member who registers for or uses the App; “Farmer” means any customer of a User whose details are recorded by that User in the App; and “Personal Data”, “Data Principal” and “Data Fiduciary” shall have the meanings assigned to them under the Digital Personal Data Protection Act, 2023 (the “DPDP Act”).

3. 1.3

   The Company is the Data Fiduciary in respect of the Personal Data of Users processed under this Policy.

2. Personal data collected

1. 2.1

   We collect the following categories of Personal Data: (a) account and shop information, including mobile number, owner name, shop name, preferred language, shop location and such optional business details as you elect to provide; (b) records entered by you in the App, including Farmer names, mobile numbers, villages, landholding and crop details, bills, udhaar (credit) records, payments and product lists; (c) product pack photographs, logos and voice notes submitted by you; and (d) device and usage information, including device model, operating system, app version, notification token, features used and crash reports.

2. 2.2

   The App requests access to your device’s contacts, location, camera, microphone and notifications only with your permission. You may decline or revoke any such permission through your device settings, in which case the related features may be unavailable. Only those contacts that you expressly select are transmitted to us. We do not track your location in the background.

3. Purposes of processing

1. 3.1

   We process Personal Data for the following purposes: (a) authentication and account security; (b) provision of the App’s functionality, including billing, udhaar, farmer records, crop calendars, products and posters; (c) provision of artificial-intelligence features, including the reading of product packs and the conversion of voice notes into poster text; (d) sending notifications and, unless you disable them in the App’s Settings, news and offers relating to Koshi; (e) responding to support requests; (f) diagnosing crashes, improving the App and measuring the performance of our advertising; and (g) preventing misuse and complying with applicable law.

2. 3.2

   We do not sell Personal Data.

4. Farmer data

1. 4.1

   The User determines what Farmer data is recorded in the App and is solely responsible for obtaining the necessary permission from each Farmer.

2. 4.2

   We process Farmer data solely for the purpose of providing the App to the User. We do not message or call Farmers. Any communication to a Farmer is sent by the User from the User’s own WhatsApp account.

3. 4.3

   Farmer data recorded by a User is not made accessible to any other User or to any seed, fertiliser or pesticide company.

4. 4.4

   A Farmer may request the removal of their data from the relevant User or from our Grievance Officer.

5. Disclosure of personal data

1. 5.1

   We disclose Personal Data to service providers engaged by us for cloud hosting, analytics, crash reporting, notifications, artificial-intelligence processing, maps and SMS delivery of sign-in codes. Such disclosure is made under contract and is limited to what is necessary for each provider to perform its services. Certain providers may process Personal Data outside India, as permitted under applicable law.

2. 5.2

   The App uses the Meta (Facebook) software development kit to measure the performance of our advertisements on Facebook and Instagram. Through it, app events such as the installation and opening of the App, together with device information and your device’s advertising identifier, are shared with Meta Platforms, Inc. and its affiliates. We do not share Farmer data, bills or amounts with Meta. Such data is processed by Meta in accordance with the Meta Privacy Policy. You may reset or delete your advertising identifier through your device settings.

3. 5.3

   We may further disclose Personal Data: (a) at your direction, including bills and posters that you send through your own WhatsApp account, provided that any photograph attached to such a message is stored at a link that may be accessed by any person holding that link; (b) to a court, law enforcement agency or government authority pursuant to a valid legal request; and (c) to a successor entity in the event of a merger, acquisition or transfer of business, which shall be bound by the terms of this Policy.

6. Storage and security

1. 6.1

   Personal Data is stored on servers operated by Google Cloud in Mumbai, India.

2. 6.2

   We maintain reasonable security practices and procedures, including encryption of data in transit and at rest, logical separation of each User’s data, and access restricted to personnel who require it to provide support.

3. 6.3

   No method of transmission or storage is completely secure. You are responsible for securing your device, as any person with access to your device may be able to access the App.

4. 6.4

   In the event of a personal data breach affecting you, we shall notify you and the Data Protection Board of India as required by applicable law.

7. Retention and deletion

1. 7.1

   We retain Personal Data for so long as your account remains active.

2. 7.2

   You may request the deletion of your account and associated Personal Data through the delete-account option in the App’s Settings, under ખાતું (Account), or by written request by email to our Grievance Officer at info@koshi.ag. We may verify your registered mobile number before acting on such a request.

3. 7.3

   Upon a request for deletion of your account, your account, shop records and Farmer records shall be deleted within thirty (30) days, and from backups within one hundred and eighty (180) days. Usage analytics are retained for up to fourteen (14) months and crash reports for up to ninety (90) days.

4. 7.4

   Notwithstanding the foregoing, we may retain Personal Data for a longer period where required by applicable law, and may retain aggregated data from which no individual can be identified.

8. Rights of data principals

1. 8.1

   Subject to the DPDP Act, you have the right to: (a) obtain information about the Personal Data we hold about you; (b) seek correction, completion, updating or erasure of such Personal Data; (c) withdraw consent to any processing based on consent, without affecting the lawfulness of processing carried out before such withdrawal; (d) nominate another individual to exercise these rights in the event of your death or incapacity; and (e) seek redressal of grievances.

2. 8.2

   Requests may be made to our Grievance Officer and shall be responded to within thirty (30) days. If you are not satisfied with the response, you may file a complaint with the Data Protection Board of India.

9. Children

1. 9.1

   The App is intended for use by persons aged eighteen (18) years or older. We do not knowingly collect Personal Data of children. If you believe a child has provided Personal Data to us, please contact our Grievance Officer and such data shall be deleted.

10. Amendments

1. 10.1

   We may amend this Policy from time to time. The amended Policy shall be effective from the date stated above. Where an amendment materially affects the processing of your Personal Data, we shall notify you through the App before it takes effect.

11. Governing law and jurisdiction

1. 11.1

   This Policy shall be governed by and construed in accordance with the laws of India. Subject to your right to approach the Data Protection Board of India, the courts at Ahmedabad, Gujarat shall have exclusive jurisdiction over any dispute arising out of or in connection with this Policy.

12. Grievance Officer

1. 12.1

   In accordance with the DPDP Act and the Information Technology Act, 2000 and the rules made thereunder, the details of our Grievance Officer are as follows:

Email

info@koshi.ag

Phone / WhatsApp

+91 98700 62421

Hours

Monday to Saturday, 9:00 a.m. to 6:00 p.m.

Address

A-604, Ganesh Glory 11, Jagatpur Road, off S.G. Highway, Ahmedabad, Gujarat 382470, India