Effective Date: 1 March 2024

FarmyHub OÜ (“FarmyHub”, “we”, “our”) processes personal data in strict compliance with all applicable data protection laws, including:

• The General Data Protection Regulation (GDPR) of the European Union

• The Philippines Data Privacy Act of 2012 (Republic Act No. 10173)

FarmyHub OÜ acts as the data controller responsible for the processing of your personal data as described in this Privacy Policy.

We process your personal data based on lawful bases for processing as defined under applicable data protection laws, including:

• The performance of a contract

• Our legitimate interests

• Compliance with legal obligations

• Your explicit consent (where required)

1. Purpose of this Privacy Policy

This Privacy Policy explains in detail how we collect, use, store, share, and protect your personal information during any interaction with us.

This includes, but is not limited to:

• Direct communications with FarmyHub (in-person meetings, email correspondence, telephone calls, contact forms, or other direct interactions).

• Use of our website and platform, where data may be collected both actively (information you submit) and passively (information collected automatically).

Automated data collection methods include, but are not limited to:

• Cookies

• Web Beacons / Pixel Tags / Clear GIFs

• Clickstream Data

• Device Fingerprinting

• Session Recording Tools (e.g., heatmaps, user flow tracking)

• Analytics Tools (e.g., Google Analytics)

• Advertising Pixels and Retargeting Tools

• Fraud Detection Scripts

This Privacy Policy applies regardless of your location or nationality at the time of using our platform.

However, please note:

• FarmyHub primarily targets users within the Philippine market, and our data processing activities are designed to comply with the legal frameworks stated above.

• If you are accessing or using our platform from outside the European Union or the Philippines, you acknowledge and agree that your personal data will be processed under these governing laws and that cross-border data transfers may occur as part of our operations.

2. Definition of Personal Data / Personal Information

For the purposes of this Privacy Policy, “personal data” or “personal information” refers to any information that identifies, relates to, describes, or could reasonably be used — either directly or indirectly — to identify an individual.

This includes, but is not limited to:

• Full name

• Email address

• Phone number

• City or location

• Usernames or account identifiers

• IP address and device identifiers

• Online identifiers (cookies, pixel tags, clickstream data)

• Communications or content exchanged via our platform

• Any other information that directly or indirectly identifies you

This definition also includes technical or behavioral data that can be linked to an individual, either alone or when combined with other information.

Special Categories of Personal Data

Also known as sensitive personal data, this refers to data revealing:

• Racial or ethnic origin

• Political opinions

• Religious or philosophical beliefs

• Trade union membership

• Genetic or biometric data

• Health information

• Sexual orientation

FarmyHub does not intentionally collect special categories of personal data. If you voluntarily provide such data in your content or communication, you do so at your own risk.

3. Collection of Personal Data

FarmyHub collects personal data directly from you, from your use of our platform, and from third parties, as described below:

3.1 Data You Provide Directly

We collect personal data when you:

• Register an account on our platform

  • We collect your full name and email address (including through Google or Facebook Login) for account creation and communication purposes.

  • Your email is never publicly displayed.

  • Providing your full name is voluntary. You may edit or change your displayed name within your profile at any time if you prefer to maintain anonymity toward other users.

• Create product listings or upload content

  • We collect any text, product details, photos, and, if you choose, your phone number for buyers to contact you directly.

  • You may also upload a profile picture or a company logo, but providing a photo is completely optional and not required.

  • Your city or general location is collected to display your approximate selling location (we do not collect detailed residential addresses).

• Submit information via forms, messages, or emails

  • This may include your contact details and any other information you choose to provide.

• Contact us via customer support (email, phone, or chat)

  • We collect necessary identifying information to assist you.

• Participate in surveys, promotional activities, or marketing campaigns (such as giveaways)

  • We may collect your name, email address, and any submitted content as part of participation requirements.

  • To ensure transparency in giveaway campaigns, FarmyHub may publish proof of the prize delivery (e.g., screenshots of the transaction or prize handover) on our official channels (such as our Facebook group).

  • We will not publicly disclose any participant’s personal data without their explicit consent.

• Subscribe to product catalogues, special offers, or marketing updates

  • We collect your email address to send weekly product catalogues and marketing information.

• Use our internal messaging system

  • Messages are collected and stored for fraud prevention, scam investigations, and user safety.

3.2 Data Collected Automatically

We collect certain information automatically when you interact with our platform, including:

• IP Address – used to identify your general location, ensure platform security, and prevent fraud.

• Device and Browser Information – including your device type, operating system, browser version, screen resolution, and device identifiers.

• Cookies and Similar Tracking Technologies – used for platform functionality, remembering user preferences, performing analytics, and delivering personalized advertisements.

• Clickstream and Usage Data – including pages visited, time spent on each page, links clicked, and navigation paths for improving user experience.

• Session Recordings – we may record user interactions (clicks, scrolls, movements) to analyze usability and detect technical issues.

• Location Data (based on IP) – approximate location (city or region) is collected to tailor content and listings geographically. We do not collect precise GPS-based location data.

3.3 Data Collected from Third Parties

We may also collect personal data about you from third-party sources, including:

• Third-party authentication services (Google, Facebook Login)

  • If you log in using these services, we collect personal information shared by the provider (e.g., name, email, profile picture, and other publicly available info based on your settings).

  • Once received, FarmyHub becomes the data controller of this data and uses it solely for account creation, authentication, and access.

  • Note: Your data may also be processed by the provider under their own policies:

    • [Google Privacy Policy]

    • [Facebook (Meta) Privacy Policy]

• Other users of the platform

  • Personal data may be collected when another user reports a listing, message, or interaction involving you (e.g., fraud, abuse, or violations).

  • This may include information you made public on the platform or details submitted in the report.

  • We do not intentionally collect sensitive data via reports unless legally required.

• Publicly available databases or records

  • Used for identity verification, confirming business legitimacy, or preventing fraudulent activities.

• Government agencies or regulatory authorities

  • We may receive data if required to cooperate with official investigations, law enforcement, or legal obligations.

FarmyHub collects this information solely to operate the platform, provide services, ensure safety, detect fraud, and comply with legal requirements.

4. Management, Use, and Retention of Personal Data

FarmyHub stores personal data securely in our databases and uses it only for the purposes outlined in this Privacy Policy.

We collect personal data:

• Directly – when you create an account, post listings, contact us, subscribe to newsletters, or join campaigns/giveaways.

• Indirectly – when we receive data from third-party logins, user reports, or official bodies.

We use your personal data for:

• Operating and managing our platform (account creation, security, maintenance)

• Facilitating buyer-seller interactions and transactions

• Investigating/preventing fraud, scams, spam, fake listings, or Terms violations

• Meeting legal and regulatory obligations

• Improving services and user experience

• Managing marketing communications, subscriptions, newsletters, giveaways, and contests

Legal bases for processing: contract performance, consent, legitimate interests, and legal compliance.

• Sensitive personal data is processed only if required by law (e.g., fraud investigations).

Account Deactivation and Deletion

• When you delete your account, it is marked as “inactive” or “deleted” for 1 month.

• During this time:

  • Your presence is hidden from the platform.

  • Chat records remain accessible (for fraud prevention and platform integrity).

• After 1 month:

  • All personal data is permanently deleted.

  • Chat records are anonymized and no longer linked to you.

We retain your data for up to 1 month after account closure, unless longer retention is legally required (e.g., disputes, fraud, compliance).

Data Storage and Cross-Border Transfers

• Data is stored on secure servers in the EU, Philippines, or cloud providers.

• If transferred outside the EU, appropriate safeguards are applied.

• Access is strictly limited to authorized personnel.

Marketing Consent

• We send marketing communications only with your explicit consent.

• You can withdraw consent or unsubscribe anytime (via email instructions or direct contact).

• If we need to use your data for a new purpose, we will notify you and seek consent when required by law.

5. Web Analytics and Tracking

FarmyHub uses analytics tools (including Google Analytics) to understand behavior, monitor performance, and improve services.

Data collected may include:

• Pages visited

• Time spent on pages

• Browser and device details (device type, OS, screen resolution)

• IP addresses (personal data under GDPR)

• Referring URLs and links clicked

Analytics data is processed in aggregate form (not tied to individual profiles).

Uses:

• Analyze usage patterns

• Detect technical issues

• Enhance user experience

• Where required by law, we rely on explicit consent for analytics/tracking cookies.

• Users can manage cookie preferences via our Cookie Banner or browser settings.

• See [Google Privacy Policy] for details on how Google processes data.

6. Cookies and Similar Technologies

FarmyHub uses cookies and similar tracking technologies for the following purposes:

• Ensure proper website functionality — Enable essential features such as login, account management, and secure browsing.

• Remember your preferences — Save language settings, location preferences, and other personalized choices.

• Perform analytics — Analyze user behavior, website traffic, and usage patterns to improve our platform and services.

• Provide personalized advertisements (with consent) — Display relevant ads and promotional content based on your interests and browsing history (this may apply if personalized advertising features are introduced in the future).

Cookies are small text files placed on your device. Some cookies may be placed by third-party service providers for analytics or advertising purposes. These third parties may collect information about your online activities over time and across different websites.

You can control or disable cookies through your browser settings or our Cookie Consent Banner. However, disabling certain cookies may impact your experience on our platform.

For details, see our Web Analytics and Tracking section.

7. Web Beacons / Pixel Tags / Clear GIFs

FarmyHub uses web beacons (also called pixel tags or clear GIFs) on our platform and in some email communications. These are small, transparent graphic images (typically 1x1 pixels) that work together with cookies and similar technologies.

Web beacons help us:

• Monitor user interactions (pages visited, links clicked, email open rates)

• Measure the effectiveness of marketing campaigns and newsletters

• Improve platform functionality and user experience

Third-party providers may also use web beacons on our behalf for analytics or advertising.

Where required by law, we rely on your explicit consent before deploying web beacons for analytics or marketing purposes.

You can control the use of web beacons by:

• Adjusting your cookie preferences through our Cookie Consent Banner

• Disabling cookies in your browser settings

• Managing email settings to block remote image loading (which prevents tracking pixels in emails)

See also: Cookies and Similar Technologies and Web Analytics and Tracking sections.

8. Clickstream Data

FarmyHub automatically collects clickstream data when you interact with our platform. This helps us monitor performance, improve usability, and ensure security.

We may collect:

• IP address or server address

• Domain name

• Date and time of your visit

• Pages accessed and files downloaded

• Referring website or link (if applicable)

• Operating system and browser type

• Device type and screen resolution

Clickstream data is used for:

• Statistical analysis and reporting

• System administration and platform maintenance

• Detecting and preventing fraud, abuse, or technical issues

• Improving user experience and platform functionality

We do not use clickstream data to identify individual users unless:

• Required by law or regulatory authorities, or

• Necessary to investigate suspected fraudulent, illegal, or harmful activities.

Where required by law, we rely on legitimate interests or your explicit consent as the legal basis for processing clickstream data.

You can manage clickstream data collection by adjusting cookie and tracking preferences through our Cookie Banner or browser settings.

9. External Links and Third-Party Websites

FarmyHub’s platform may contain links to third-party websites, services, or platforms.

• This Privacy Policy applies only to FarmyHub.

• Once you leave our platform, we have no control over how your personal data is collected, used, or protected by third parties.

We strongly recommend reviewing the privacy policies of external websites you visit.

FarmyHub is not responsible for the privacy practices or content of third-party websites.

10. Sharing and Disclosure of Personal Data

FarmyHub may share your personal data only when necessary for the purposes in this Privacy Policy and based on lawful bases (contract performance, legitimate interest, legal obligation, or explicit consent).

We share only the minimum data required, and all third parties are contractually obligated to protect your information.

Your personal data may be shared with:

• Internal staff of FarmyHub OÜ — on a strict need-to-know basis.

• Trusted service providers and partners, such as:

  • Hosting, cloud storage, IT support, cybersecurity providers

  • Marketing/communications agencies (only with your consent)

  • Analytics and research partners

  • Customer service providers (call centers, chat tools)

  • Payment or financial services providers (if applicable in the future)

  • Legal, auditing, and professional advisors

• Government authorities, law enforcement, or regulators — when required by law, court order, or valid legal request (including fraud investigations and compliance checks).

• Your authorized representatives — such as a lawyer or appointed agent, only with written request or documented consent.

• Other users of the platform — but only when strictly necessary during disputes or investigations, and limited to relevant data. Sensitive data is avoided unless required.

FarmyHub does not sell personal data to third parties.
Sensitive personal data is never shared unless legally required or with your explicit consent.

If service providers operate outside the EU or Philippines, FarmyHub ensures appropriate safeguards (e.g., Standard Contractual Clauses) are in place to protect your data in compliance with applicable laws.

11. Data Security and Protection Measures

FarmyHub implements strict technical, organizational, and contractual measures to protect your personal data from unauthorized access, loss, misuse, or disclosure. Our security practices are aligned with the General Data Protection Regulation (GDPR), the Philippines Data Privacy Act (RA 10173), and recognized industry standards.

Access Controls and Internal Security

• Personal data is accessible only to authorized personnel based on their job responsibilities.

• Role-based access controls are in place to restrict access to systems and databases.

• Systems require secure login credentials, with access rights assigned based on staff roles and responsibilities.

• All staff members undergo regular data protection training and are bound by internal confidentiality and data handling policies.

Data Encryption and Storage

We apply appropriate levels of encryption to protect different types of personal data:

• Passwords — Stored only in hashed and salted form; never stored or transmitted in plain text.

• Login Credentials / Session Tokens — Encrypted during transmission (SSL/TLS).

• Personal Identifiers (full names, email addresses, phone numbers) — Encrypted during transmission; securely stored with restricted access.

• Government IDs / Passport Numbers — If collected in the future, will be encrypted both in transit and at rest.

• Internal Messaging Content — Encrypted during transmission (SSL/TLS) and securely stored to protect confidentiality.

• Sensitive Personal Data (special categories as defined in Section 2) — Processed only if legally required or voluntarily provided. Such data is encrypted both in transit and at rest.

• IP Addresses / Device IDs (when linked to identity) — Encrypted during transmission and securely stored.

• Financial Data — FarmyHub does not store credit card numbers or bank details on its servers. If payment features are introduced, all financial data will be handled by PCI DSS-compliant third-party payment processors.

Network and System Security

• Our systems are protected by firewalls, intrusion detection systems, and routine network security monitoring.

• Regular vulnerability assessments and system audits are conducted to detect potential threats or weaknesses.

• Antivirus and malware protection tools are deployed and updated regularly.

Data Segregation and Retention

• Archived data and active data are stored separately to reduce exposure risk.

• Personal data is retained only for as long as necessary, as outlined in our Retention Policy.

Third-Party Service Providers and Contracts

All third-party service providers processing personal data on FarmyHub’s behalf are contractually obligated to maintain strict data security and confidentiality standards.

Contracts specify:

• Data processing purposes

• Security obligations

• Restrictions on data use

• Return or secure deletion of personal data upon contract termination

FarmyHub regularly monitors third-party compliance with these obligations.

Incident Response and Breach Notification

• FarmyHub maintains a documented incident response plan.

• In the event of a personal data breach, FarmyHub will assess the risk and notify affected users and relevant data protection authorities within the required legal timeframe (e.g., 72 hours under GDPR).

Ongoing Monitoring and Improvements

• FarmyHub reviews and updates its data security measures regularly to ensure continued compliance and protection against evolving threats.

Internet Transmission Risks

While FarmyHub implements strict technical and organizational security measures to protect your personal data, you acknowledge that the transmission of information over the internet is not entirely secure.

Although we do our best to protect your personal data, we cannot guarantee the security of your data transmitted to or through our platform. Any transmission of your personal data—whatever you decide to provide (including but not limited to your name, email address, phone number, listing details, photos, or any other information)—is done at your own risk.

Once we receive your data, we apply strict procedures and security features to prevent unauthorized access. If you prefer not to share sensitive information online, we encourage you to contact us directly through alternative secure channels.

12. Access to and Correction of Personal Data

You have the right to access and review your personal data stored by FarmyHub. Upon your request, we will provide access to the personal data we hold about you, free of charge, unless the request is excessive or repetitive.

You may also request the correction or completion of your personal data if you believe the information is inaccurate, incomplete, or outdated. We will assess your request and update our records accordingly, subject to verification.

Please note:

• We will not provide access to personal data that belongs to another individual unless legally authorized or required to do so.

• For security reasons, we may request additional information to verify your identity before processing access or correction requests.

• We will respond to access and correction requests within 30 days or as required by applicable data protection laws.

To submit a request, please contact us at: support@farmyhub.com

13. Privacy Complaints and Inquiries

If you have concerns or complaints regarding how FarmyHub manages your personal data or handles your privacy rights, you may contact us in writing or by email.

We take all privacy complaints seriously and commit to investigating your complaint promptly.

To file a privacy complaint, please contact us at:

support@farmyhub.com

Complaint Handling Process

• We will acknowledge receipt of your complaint within 7 business days.

• A full response will be provided within 30 business days or as required by applicable data protection laws.

• If necessary, we may request additional information to clarify your complaint or verify your identity.

Escalation

If you are not satisfied with our response, you have the right to lodge a complaint with the relevant Data Protection Authority:

• For EU residents (GDPR): Contact your local Data Protection Authority (DPA).

• For Philippine residents: Contact the National Privacy Commission (NPC) — www.privacy.gov.ph