Verdex · Privacy

Privacy policy

Version 2026-09-11 · effective from that date

This notice explains what personal data Verdex processes when you visit verdex.spatialsusty.com or use the service, on what legal basis, where it is kept, for how long, and how to exercise your rights. It is written for the EU General Data Protection Regulation (GDPR) and Ghana's Data Protection Act, 2012 (Act 843); where other national laws apply to you, the stricter rule is followed.

1. Who is responsible

The controller for account, usage and website data is:

Spatial Sustainability Hub
[to be completed — VERDEX_LEGAL_ADDRESS]
Data-protection contact — privacy@spatialsusty.com (fallback support@spatialsusty.com)

Farmer and plot data is different. When an operator (a cooperative, trader or exporter) uploads plot geometries, supplier records or farmer identifiers, that operator decides why and how the data is used and is the controller for it; Spatial Sustainability Hub processes it only on the operator's instructions as a processor (GDPR Art. 28; Act 843 s.30). We are controller only for platform security, account administration and our own compliance records. Operators must have a lawful basis to share the data, should upload it pseudonymised — plot and supplier codes, not farmer names — and must not upload more than the EUDR requires. Our data-processing terms form part of the Terms of service; a signed Data Processing Agreement is available from privacy@spatialsusty.com.

Sensitive and children's data are not accepted. If a file contains them we quarantine it, tell the operator the same day and do not process it further.

2. What we collect and why

DataPurposeLegal basis
Account: operator id, display name, e-mail, password (stored only as a hash), tier, terms-acceptance date and versionCreate and secure your account; contract recordsContract (Art. 6(1)(b))
Single sign-on identifiers (IdP subject id) when your organisation uses SSO/SCIMLog you in via your identity providerContract; your organisation's instructions
Plot geometries, supplier and farmer identifiers, shipment data you uploadRun the EUDR risk analysis you request and produce the evidence packetProcessed for the operator as controller
Usage metering (plots analysed per month, features used)Enforce plan limits; billing; understanding what worksContract; legitimate interest (Art. 6(1)(f))
Audit log: action, time, IP address, browser user-agentSecurity, tamper-evident record of who did what — the EUDR evidence must be defensibleLegitimate interest; legal obligation (EUDR Art. 31 record-keeping)
Support e-mails and feedback you send usAnswer you; improve the productLegitimate interest
Page views (cookieless, aggregated — path, referrer, country, device class)Understand how the site is usedConsent — only if you choose “Allow analytics”
Server and proxy logs (IP, request path, status)Operate and defend the serviceLegitimate interest

We do not sell personal data, do not build advertising profiles, do not send direct marketing without your prior consent, and do not use your plot data to train models for other customers.

Risk verdicts are decision support. A Verdex result must not be used as the sole automated basis for a decision that significantly affects a farmer, cooperative member, worker or supplier — a human must review it and there must be a route to correction. Operators accept this in the Terms; affected people may ask for human review through the operator or through us.

3. Where data is kept

  • Application database and processing: a virtual machine operated by the provider named in the Legal notice.
  • Uploaded files, evidence packets and backups: Google Cloud Storage, region europe-west3 (Frankfurt, Germany).
  • Reference satellite data (public, no personal data) is stored separately from operator data with separate access controls.

Personal data may therefore be processed outside your country. Transfers out of the EU/EEA rely on an adequacy decision or the EU Standard Contractual Clauses with a transfer risk assessment; Ghana-origin data is transferred only under the safeguards Act 843 requires and the operator's data-processing agreement. Every vendor and country is recorded in our vendor and transfer register before any data moves.

4. Who else sees it (sub-processors)

  • Google Cloud — object storage and, where enabled, Earth Engine analysis (Google Ireland Ltd / Google LLC).
  • E-mail delivery provider for transactional and support mail.
  • Plausible Analytics (Plausible Insights OÜ, Estonia) — only if analytics is enabled on this deployment and you consent; receives no cookies and no identifiers.
  • Your own identity provider, if your organisation uses SSO.

Professional advisers, and regulators, courts or authorities where the law requires, may also receive data. Authorities receive nothing from us about your plots directly: operators submit their own Due Diligence Statements. We give 30 days' notice before adding a sub-processor.

5. How long we keep it

Account (operator id, display name, e-mail, password hash, terms acceptance)Life of the account, then deleted on closure or erasure request
Due-diligence evidence: analysis results, verdicts, evidence packets5 years from the verdict (EUDR Art. 31), capped by your plan; archived or deleted securely after
Raw plot uploads (input files)Kept with the analysis record for the same period; deleted earlier on request or when the job or account is deleted. Policy target: contract end + 90 days
Watchlist entries and TRACES submission history5 years
Monitoring snapshots2 years
Supplier magic links1 year after revocation
Audit log (who did what, when, from which IP)5 years — tamper-evident; archived, not deleted, on erasure so the record of handling survives
Security logsUp to 12 months
Application, server and proxy logs30–90 days
Support requests and feedback24 months after closure

Retention is also capped by plan (Free 30 days, Starter 1 year, Growth and Enterprise the full period). Operators may agree shorter periods or earlier return/deletion by contract; on termination we return or delete within 30 days except evidence under the 5-year rule. Backups expire on their normal rotation.

6. Your rights

You can ask for access to, a copy of, correction of, or erasure of your personal data; restriction of or objection to processing; and portability. Where processing rests on consent you may withdraw it at any time (analytics: use “Cookie settings” in the footer). You may also object to direct marketing and ask for human review of a decision based on an automated risk verdict. Write to privacy@spatialsusty.com (or support@spatialsusty.com); we may need to verify your identity, ask only for what that requires, and answer within one month (extendable for complex requests, with notice). Operators can also export or erase their whole account through the API (POST /v1/operators/{id}/data-export, DELETE /v1/operators/{id}); erasure archives the tamper-evident audit trail before deleting, because the law requires us to be able to show what happened.

If you are a farmer whose plot was uploaded by a cooperative or buyer, that organisation is the controller: make your request to it, or to us and we will route it to them without delay. You may complain to us first, and to your supervisory authority — in Ghana the Data Protection Commission, in the EU the authority of your member state.

7. Security

Transport encryption everywhere; passwords hashed; tenant isolation enforced at the application, database-row and object-store layers; per-tenant provisioning tokens; append-only audit chain; least-privilege containers; encrypted, verified, off-site backups. No system is perfect. If we learn of a breach affecting personal data we assess it immediately; where we are processor we notify the operator without undue delay, where the GDPR applies we notify the supervisory authority within 72 hours and affected people where the risk is high, and under Act 843 we notify the Ghana Data Protection Commission and affected people as soon as reasonably practicable.

8. Children

The service is for businesses and their staff. We do not knowingly collect data from anyone under 18.

9. Marketing

We do not send direct marketing to individuals without prior consent (Act 843 s.40) and never reuse plot, supplier or analysis data for marketing. Any product-update e-mail has a one-click unsubscribe.

10. Changes

We will post changes here with a new version date and, for material changes, tell account holders by e-mail before they take effect.