Last Updated: 03 August 2026

This Privacy Policy governs your ("you" or "your") access to and use of the Greenda® platform, including the website greenda.ai, the Greenda® mobile application (available on iOS and Android), and the web-based expert dashboard, all operated by GreendaAI GmbH ("Greenda", "we", "our" or "us").

This Privacy Policy explains how we collect, use, store, and share your personal data, in compliance with the General Data Protection Regulation (GDPR) and applicable German data protection laws.

Our platform can be used in two ways: (i) directly, where a farmer or agricultural professional registers with Greenda and receives treatment plans validated by Greenda's own agronomists; and (ii) through a cooperative ("Coop"), where an agricultural cooperative or similar organisation onboards its own farmers and its own agronomist experts onto the platform. This Policy applies to both models. Where you use the platform through a Coop, please read Section 5 carefully, the Coop is a separate, independent data controller for its own purposes, and this Policy covers only Greenda's processing.

1. Who We Are (Data Controller)

GreendaAI GmbH

c/o Design Offices München Macherei

Weihenstephaner Str. 12

81673 Munich

Germany

Email: contact@greenda.ai

We act as the data controller for personal data collected and processed by Greenda via our website, mobile application, and expert dashboard, for our own purposes as described in this Policy. We do not have a designated Data Protection Officer (DPO), as we do not meet the thresholds requiring appointment under Art. 37 GDPR. For all data protection enquiries relating to Greenda's processing, please contact us at contact@greenda.ai.

Where you access the platform through a Cooperative, that Cooperative is a separate and independent controller in respect of the personal data it processes for its own purposes (for example, managing its membership and providing agronomic advice to its members through its own experts). Greenda is not responsible for the Cooperative's own data processing, and the Cooperative must provide you with its own privacy information. See Section 5.

2. Who This Policy Applies To

Our platform serves the following categories of users, each of whom we process data for differently:

Direct Users (independent farmers and experts): individuals who register directly with Greenda through the mobile app to submit crop assessments for their own farms and receive treatment plans validated by Greenda's agronomists. This includes both independent farmers and independent agricultural experts (agronomists) who use the app for their own farms; both are treated the same way for the purposes of this Policy. Both business (B2B) and individual users may register (see Section 2.1 on consumers).
Coop-Affiliated Farmer Users: farmers who are onboarded onto the platform by a Cooperative and whose crop assessments are validated by that Cooperative's own experts.
Greenda Expert Users: certified agronomists engaged by Greenda under contract who are given web dashboard access to review AI pre-diagnoses and author treatment plans for Direct Users. Dashboard access is provisioned under contract and is not available through online self-service registration.
Coop Expert Users: agronomists engaged by a Cooperative under contract who are given web dashboard access to review AI pre-diagnoses and author treatment plans for that Cooperative's own farmers.
Cooperative Administrators: staff of a Cooperative who manage the Cooperative's workspace, seats, and users on the platform.
Website visitors: individuals who visit greenda.ai.

Access channels. The mobile application is the only self-service channel and is used by individual users (independent farmers and independent experts using it for their own farms). The web dashboard is not self-service: access is provisioned only under contract, to Greenda's own contracted experts and to Cooperatives' experts.

2.1 Note on Consumers

The platform is designed for farmers and agricultural professionals acting in a professional or business capacity. Where an individual user nonetheless qualifies as a consumer under applicable law, mandatory statutory consumer-protection rights are unaffected by this Policy or by our Terms of Use.

3. Personal Data We Collect and Process

3.1 Website, greenda.ai

3.1.1 Data Collected

Web forms: first name, last name, email address, phone number, and (for cooperative enquiries) organisation name and role.
Analytics (GA4, HubSpot tracking): IP address, device type, browser type, operating system, referring URLs, pages visited, session duration.

3.1.2 Purpose and Legal Basis

Responding to enquiries and providing requested materials, Legitimate Interests (Art. 6(1)(f) GDPR).
Sending newsletters and marketing communications, Consent (Art. 6(1)(a) GDPR).
Website analytics and performance optimisation, Consent (Art. 6(1)(a) GDPR) for non-essential cookies; Legitimate Interests (Art. 6(1)(f) GDPR) for technically necessary operations.
Protection against fraud and security threats, Legitimate Interests (Art. 6(1)(f) GDPR).

3.2 Mobile Application, Individual and Coop-Affiliated Users

This section applies to individual mobile-app users (independent farmers and independent experts using the app for their own farms) and to Coop-Affiliated Farmers.

3.2.1 Data Collected

Account data: first name, last name, email address, phone number.
Cooperative affiliation data (Coop-Affiliated Farmers only): the identity of the Cooperative you belong to, your membership or seat reference within that Cooperative, and the assignment of your assessments to that Cooperative's experts.
Authentication data: one-time password (OTP) delivered by email and, optionally, Google Sign-In (OAuth) where you choose to sign in with a Google account. No permanent password is stored by us; where you use Google Sign-In, Google acts as the identity provider for the sign-in.
GPS location and geo-tagged coordinates: precise farm location captured at the time of each crop assessment submission, including reverse-geocoded address fields (country, locality, street).
Crop assessment data: photographs of crops and plants, voice notes (transcoded via FFmpeg and transcribed to text by a third-party speech-to-text provider, Deepgram), written observations, pest descriptions, growth phase, yield phase, pest counts and intensity.
Farm profile data: farm name, farm area (hectares), crop cultivar, irrigation type, farming type (organic / conventional / zero-residues), pesticide use history, estimated yield, estimated market price.
Weather data: temperature, humidity, precipitation, wind speed, and cloud cover fetched automatically at the time of assessment submission based on GPS coordinates (via OpenWeatherMap API).
Behavioural data: submission frequency, offline submission flags, app usage patterns, timestamps.
Device data: device ID, operating system, app version, Firebase Cloud Messaging push notification token.
Attribution and marketing analytics data: device and advertising identifiers (e.g. Google Advertising ID or Apple IDFA, where permitted), app install and campaign attribution, and in-app events, collected via the AppsFlyer SDK where you have consented (and, on iOS, permitted tracking).

3.2.2 Purpose and Legal Basis

Delivering AI-powered crop health pre-diagnosis (Google Gemini) and expert-validated treatment plans, Contractual Necessity (Art. 6(1)(b) GDPR), based on the Terms of Use you accept when using the app.
Routing Coop-Affiliated Farmers' assessments to their Cooperative's experts for validation, and disclosing the necessary data to that Cooperative, Contractual Necessity (Art. 6(1)(b) GDPR) and Legitimate Interests (Art. 6(1)(f) GDPR).
Managing farm profiles and assessment history, Contractual Necessity (Art. 6(1)(b) GDPR).
Sending push notifications (treatment plan delivery, service updates), Contractual Necessity (Art. 6(1)(b) GDPR).
Sending service notifications and messages via WhatsApp (WhatsApp Cloud API, Meta) where you have provided your phone number for this purpose, Contractual Necessity (Art. 6(1)(b) GDPR) and, for non-essential messages, Consent (Art. 6(1)(a) GDPR).
Measuring app installs and marketing campaign attribution via the AppsFlyer SDK, Consent (Art. 6(1)(a) GDPR).
Generating anonymised regional pest trend insights and agricultural risk reports, Legitimate Interests (Art. 6(1)(f) GDPR).
Improving AI models, expert advisory pipeline, and platform features using anonymised data, Legitimate Interests (Art. 6(1)(f) GDPR).
Sending marketing communications and newsletters, Consent (Art. 6(1)(a) GDPR).
Compliance with legal and regulatory obligations, Legal Obligations (Art. 6(1)(c) GDPR).

3.3 Expert Dashboard, Greenda Experts and Coop Experts

Web dashboard access is provisioned only under contract (to Greenda's contracted experts and to Cooperatives' experts) and is not available through online self-service registration.

3.3.1 Data Collected

Account data: name, email address, professional credentials.
Cooperative affiliation data (Coop Experts only): the identity of the Cooperative that added you and the scope of farmers assigned to you within that Cooperative's workspace.
Activity data: crop assessments reviewed, AI diagnoses corrected or validated, treatment plans authored, timestamps of all expert actions.
Authentication data: one-time password (OTP) delivered by email and, optionally, Google Sign-In (OAuth) where you choose to sign in with a Google account. No permanent password is stored by us; where you use Google Sign-In, Google acts as the identity provider for the sign-in.
Product usage analytics: feature interactions and usage patterns within the dashboard (Mixpanel), collected only with your consent, see our Cookie Policy.
Technical error data: application error logs with a pseudonymous user reference (Sentry), used for error monitoring; no assessment content is included.

3.3.2 Purpose and Legal Basis

Providing access to the agronomist review queue and enabling expert validation of AI diagnoses, Contractual Necessity (Art. 6(1)(b) GDPR).
Restricting each expert's access to the appropriate scope of farmers (Greenda Experts to Direct Farmers; Coop Experts to their own Cooperative's farmers only), Legitimate Interests (Art. 6(1)(f) GDPR) and security by design.
Retaining expert correction events and validated treatment plans as part of our IP and patent audit trail, Legitimate Interests (Art. 6(1)(f) GDPR).
Quality assurance and accountability in the human-AI advisory pipeline, Legitimate Interests (Art. 6(1)(f) GDPR).

4. AI Processing and Human Expert Review

Greenda® uses Google Gemini (a third-party AI service operated by Google LLC) to generate an automatic pre-diagnosis of crop health issues based on submitted photographs, notes, and farm parameters. This pre-diagnosis is not a final recommendation and is not communicated to farmers until it has been reviewed by a certified agronomist.

Every AI pre-diagnosis is reviewed, validated, and where necessary corrected by a certified agronomist before a treatment plan is issued to the farmer:

For Direct Users, this validation is performed by Greenda's own agronomists.
For Coop-Affiliated Farmer Users, this validation is performed by the Cooperative's own experts. Greenda provides the platform and the AI pre-diagnosis; the Cooperative's expert is responsible for reviewing, validating, and authoring the treatment plan. Coop Experts can only access the farmers of their own Cooperative.

The complete AI pipeline log, including system prompts, AI outputs in JSON format, and expert corrections, is stored per assessment for transparency, IP protection, and patent audit purposes.

Farmers are notified of completed treatment plans via push notification. Our target validation response time is 48 hours from submission; for Coop-Affiliated Farmers, response times depend on the Cooperative's own experts.

No fully automated decision-making with legal or similarly significant effect on users takes place. All treatment recommendations are validated by a qualified human agronomist before delivery (Art. 22 GDPR).

5. The Cooperative Model, Separate Controllers

Where you use the platform through a Cooperative, Greenda and the Cooperative each act as independent (separate) data controllers, each determining the purposes and means of the processing it carries out for its own ends. This is not a joint-controller arrangement under Art. 26 GDPR, and the Cooperative is not Greenda's processor.

Greenda's role and purposes: operating the platform, generating the AI pre-diagnosis, hosting and securing the data, maintaining the assessment and audit logs, and improving the service using anonymised data. Greenda is the controller for these purposes, and this Policy describes that processing.
The Cooperative's role and purposes: onboarding and managing its own farmers and experts, validating assessments through its own experts, and providing agronomic advice to its members. The Cooperative is the controller for these purposes and is responsible for having its own lawful basis and for providing its members and experts with its own privacy information. Greenda is not responsible for, and does not control, the Cooperative's own processing.
Controller-to-controller disclosures: to enable validation, Greenda discloses the relevant assessment data (including farmer identity, GPS coordinates, and crop photographs) to the Cooperative and its assigned experts. Each party is independently responsible for its own compliance with the GDPR in respect of that data.
Segregation between Cooperatives: a Cooperative and its experts can only access the data of that Cooperative's own farmers. Data is logically segregated so that one Cooperative cannot access another Cooperative's or Greenda's direct farmers' data.

If you have questions about how your Cooperative uses your data, or wish to exercise your rights in respect of the Cooperative's processing, please contact your Cooperative directly.

6. Anonymisation and Use of Aggregated Data

Where personal data are no longer required for operational purposes, they are deleted or irreversibly anonymised in accordance with this Policy. Once anonymised, data cannot be used to identify any individual and falls outside the scope of GDPR.

Crop photographs are retained linked to your farmer account for the duration of your active account. Upon account deletion, photographs are anonymised and retained indefinitely for AI model training and agricultural research purposes. Once anonymised, they cannot be linked back to you or your farm.

Location and assessment data are aggregated to a non-identifiable regional level for pest trend analysis. Anonymised and aggregated datasets may be made available through our Data-as-a-Service (DaaS) offering to government bodies and agribusinesses. This applies across both the direct and cooperative models.

7. Data Sharing and Recipients

We do not sell your personal data. We share personal data only with the following categories of recipients, all of whom are bound by appropriate data processing agreements, controller-to-controller arrangements, or other contractual protections.

7.1 Cooperatives (Separate Controllers)

For Coop-Affiliated Farmers and Coop Experts, Greenda discloses the necessary personal data to the relevant Cooperative and its assigned experts so that they can validate assessments and provide advice. As explained in Section 5, each Cooperative is a separate, independent controller, not a subprocessor of Greenda.

7.2 Technology Subprocessors

Scaleway SAS (EU): primary cloud infrastructure. All primary data storage, farm data, crop assessments, farmer PII, GPS coordinates, and the PostgreSQL database, is hosted exclusively on Scaleway's EU-region infrastructure. Crop photographs are stored in Scaleway Object Storage with no public direct URLs, served via imgproxy.
BunnyWay d.o.o. (Slovenia, EU — bunny.net): content delivery and security layer in front of our application services. bunny.net processes your IP address and technical request metadata in transit in order to deliver the application and to protect it against attacks (web application firewall, rate limiting, and DDoS filtering). Traffic is served exclusively from points of presence located in the EU (EU-only routing). bunny.net does not permanently store access logs of your requests; security event logs, which include the IP addresses of suspicious requests, are retained for up to 30 days on the basis of our legitimate interests in securing the platform (Art. 6(1)(f) GDPR).
Google LLC (USA, Google Gemini API): crop assessment data (photographs, notes, farm parameters) is transmitted to Google Gemini for AI pre-diagnosis processing. Google acts as a data processor under a data processing agreement including Standard Contractual Clauses (SCCs).
Google LLC (USA, Firebase Cloud Messaging): push notification tokens are shared with Firebase to deliver treatment plan notifications and service alerts to farmers.
Scaleway SAS (EU, Transactional Email): OTP login codes and expert notification emails are sent via Scaleway's email service, within the EU cloud boundary.
HubSpot, Inc. (USA, EU instance): registration data (name, email address, phone number, farm/organisation metadata) is synchronised to HubSpot CRM for account management and customer support. Data is processed on HubSpot's EU instance (app-eu1.hubspot.com); transfers to HubSpot's US entity are governed by SCCs.
Sentry (Functional Software Inc., USA): application error logs and performance data from our backend, the web dashboard, and the mobile application are transmitted to Sentry for error monitoring. Data is minimised and does not include full assessment content. Transfers are governed by SCCs.
OpenWeatherMap (OpenWeather Ltd., UK): GPS coordinates are transmitted to fetch weather data at the time of assessment submission. No personal identifiers beyond coordinates are shared.
Google LLC (USA, Firebase Remote Config): a Firebase installation identifier and, for signed-in users, a pseudonymous account identifier (sent as a configuration signal) are used to deliver feature configuration and manage the rollout of app features. Transfers are governed by SCCs.
Google LLC (USA, Google Sign-In / OAuth): where you choose to sign in with a Google account, Google processes your authentication as an identity provider. Transfers are governed by SCCs.
Deepgram, Inc. (USA): voice notes submitted with a crop assessment are transmitted to Deepgram for speech-to-text transcription. Transfers to the USA are governed by SCCs.
Meta Platforms Ireland Ltd. (WhatsApp Cloud API): where you provide a phone number for WhatsApp, your phone number and message content are processed to deliver service notifications and messages via WhatsApp. Transfers outside the EU/EEA are governed by SCCs.
AppsFlyer Ltd.: mobile attribution and marketing analytics. Device and advertising identifiers and in-app event data are processed to measure installs and campaign attribution, only where you have consented. International transfers are governed by appropriate Chapter V safeguards (adequacy decision and/or SCCs).
Founder Blocks (development partner): our contracted development partner has access to system data under a signed Data Processing Agreement (DPA) for the purpose of platform development and maintenance.

7.3 Analytics and Marketing

Google Analytics 4 (Google LLC, USA): website visitor analytics (IP address, device type, behaviour). Governed by SCCs and active only with your cookie consent.
Google Tag Manager (Google LLC, USA): deploys and manages the consent-gated loading of website tags (container GTM-NJ5333R4). Governed by SCCs.
AppsFlyer Ltd.: mobile install attribution and marketing analytics SDK, active only with your consent. See Section 7.2.
Mixpanel Inc. (USA): product usage analytics within the mobile application and the web dashboard (feature interactions, submission patterns). Pseudonymised; active only with your consent. Data is ingested via Mixpanel's EU data-residency endpoint. Governed by SCCs.
HubSpot Inc. (USA, tracking): HubSpot tracking cookies may be active on greenda.ai subject to your cookie consent.

7.4 Legal and Regulatory

Government authorities, courts, and law enforcement agencies: where required by applicable law, court order, or regulatory obligation.
Professional advisors: legal, financial, and tax advisors bound by professional confidentiality obligations.

8. International Data Transfers

Some of our subprocessors, including Google LLC (Gemini AI, Firebase, Firebase Remote Config, Google Sign-In, GA4, Google Tag Manager), HubSpot Inc., Sentry, Mixpanel, and Deepgram Inc., are based in the United States and may process personal data outside the EU/EEA. AppsFlyer Ltd. and Meta (WhatsApp Cloud API) may also process certain data outside the EU/EEA. We ensure that all such transfers comply with GDPR Chapter V through:

Standard Contractual Clauses (SCCs) adopted by the European Commission (Art. 46(2)(c) GDPR), incorporated into our data processing agreements with each US-based subprocessor.
Adequacy Decisions by the European Commission, where applicable.

All primary data storage remains within the EU on Scaleway's EU-region infrastructure.

9. Data Retention

We retain personal data only as long as necessary for the purposes described in this Policy, or as required by applicable law. The following retention periods apply to Greenda's processing.

9.1 Farmer Account and Operational Data

Farmer account, profile, farm data, and assessment history: duration of active account + 3 years after account closure.
Crop photographs: retained linked to your farmer identity for the duration of your active account. Upon account deletion, photographs are anonymised and retained indefinitely for AI model training purposes.
AI pipeline logs and expert correction records (assessment logs): retained on the basis of legitimate interests (IP and patent protection) for as long as necessary. You may request erasure of assessment logs at any time (see Section 11); we will erase them unless a legal obligation or legitimate interest override applies.
Support and communication records: 3 years from last interaction.

9.2 Cooperative Workspace Data

Coop-Affiliated Farmer and Coop Expert account data held by Greenda: for the duration of the Cooperative's active use of the platform, plus up to 3 years, subject to the Cooperative's own instructions and applicable statutory periods. On termination of a Cooperative's engagement, Greenda ceases to make that Cooperative's workspace data available and deletes or anonymises it within a reasonable period, save for data Greenda must retain by law or on the basis of its own legitimate interests (e.g., anonymised assessment logs).

9.3 Financial Data

Financial and accounting records: Invoices, billing documents, payment receipts, and accounting vouchers are retained for 8 years after the end of the relevant calendar year, in accordance with § 257 (1) No. 4, (4) HGB and § 147 (3) AO as amended by the Fourth Bureaucracy Relief Act (BEG IV, BGBl. 2024 I Nr. 323), effective 1 January 2025. Core financial statements, trading books, inventories, opening balance sheets, and annual financial statements are retained for 10 years in accordance with § 257 (1) No. 1, (4) HGB and § 147 (1) No. 1 AO.
Payment transaction data (Stripe, when integrated): Retained for 8 years from the date of transaction, in accordance with the above statutory requirements.

9.4 Marketing and Analytics

Marketing consent records: duration of relationship + 3 years.
Website analytics (GA4): 14 months from collection.
Product usage analytics (Mixpanel): 2 years from collection.
CRM data (HubSpot, contact records): duration of active relationship + 3 years.
Sales pipeline records (HubSpot): duration of active opportunity + 3 years.

9.5 Expert User Data

Greenda Expert and Coop Expert account and activity data: duration of active engagement + 3 years.

10. Security of Your Data

We implement the following technical and organisational measures to protect your personal data:

All API and application traffic is served exclusively over HTTPS/TLS.
Application traffic passes through an edge security layer (bunny.net) providing a web application firewall, rate limiting, and DDoS filtering, served exclusively from EU points of presence.
Crop photographs are stored in Scaleway Object Storage with no public direct URLs, served via imgproxy with on-the-fly compression and resizing.
All primary personal data (GPS coordinates, farmer PII, assessment data) is stored within EU-based Scaleway infrastructure.
Data segregation between Cooperatives: access controls ensure that each Cooperative and its experts can only access their own Cooperative's farmers, and cannot access other Cooperatives' or Greenda's direct farmers' data.
OTP login codes are single-use and expire immediately after use.
Access to personal data is restricted on a strict need-to-know basis across internal admin, operations, and development roles.
Application errors and anomalies are monitored in real time via Sentry.
A penetration test is planned prior to our public launch.

11. Your Rights under GDPR

As a data subject, you have the following rights under GDPR (Arts. 15–21):

Right of access (Art. 15): obtain confirmation of whether we process your data and receive a copy.
Right to rectification (Art. 16): correct inaccurate or incomplete personal data.
Right to erasure (Art. 17): request deletion of your personal data ("Right to be Forgotten"). This right may be limited where retention is required by law or legitimate interest (e.g. statutory retention periods, IP audit trail). Upon confirming your deletion request, we will action it within 30 days and send you a written response confirming: (a) which data has been immediately deleted or irreversibly anonymised; (b) which data is being retained in restricted access for the applicable statutory period, together with the legal basis and duration; and (c) your right to lodge a complaint with the BayLDA if you disagree with any retention decision. Where your request is complex or we are processing a high volume of requests, we may extend our response by a further two months under Art. 12(3) GDPR, in which case we will notify you of the extension and the reason before the initial 30-day period expires.
Right to data portability (Art. 20): receive your personal data in a structured, machine-readable format.
Right to object (Art. 21): object to processing carried out on the basis of legitimate interests. We will cease processing unless we can demonstrate compelling legitimate grounds.
Right to restriction of processing (Art. 18): request that we limit how we use your data in certain circumstances.
Right to withdraw consent (Art. 7(3)): withdraw consent at any time for consent-based processing, without affecting the lawfulness of prior processing.

To exercise any of these rights in respect of Greenda's processing, email contact@greenda.ai. We will respond within one month of receipt (Art. 12 GDPR).

If you use the platform through a Cooperative and your request concerns the Cooperative's own processing (for example, its management of your membership or its experts' advice), please contact your Cooperative, which is the responsible controller for those purposes. Where a request reaches the wrong party, we will endeavour to direct you to the appropriate controller.

You also have the right to lodge a complaint with the competent supervisory authority. In Bavaria, Germany, this is:

Bayerisches Landesamt für Datenschutzaufsicht (BayLDA)

Promenade 18, 91522 Ansbach, Germany

Website: www.lda.bayern.de

12. Consent and Withdrawal

Where we rely on consent as the legal basis for processing (e.g. marketing communications, non-essential cookies), we will obtain your consent before processing begins. You may withdraw consent at any time by emailing contact@greenda.ai or using the unsubscribe link in any marketing email. Withdrawal does not affect the lawfulness of processing carried out prior to withdrawal.

13. Cookies and Tracking Technologies

We use cookies and similar technologies across our platform:

Website (greenda.ai): strictly necessary cookies (no consent required), analytics cookies (GA4, HubSpot tracking, Mixpanel), and marketing/advertising cookies (HubSpot, Meta), the latter two categories active only with your consent.
Web application (app.greenda.ai): strictly necessary sign-in and security cookies and a consent cookie (no consent required), interface preferences stored in your browser's local storage, and product usage analytics (Mixpanel) active only with your consent.
Mobile application: device identifiers and SDKs as described in our Cookie Policy, with analytics and attribution active only with your consent.

You can manage or withdraw consent at any time: for the website via our cookie preference centre at greenda.ai/updatecookies, for the web application via its cookie settings, and for the mobile application via your device settings and the app's privacy settings. For full details, see our Cookie Policy.

14. Updates to This Policy

We may update this Privacy Policy periodically to reflect changes to our services, data practices, or applicable law. The date of the latest revision is shown at the top of this document. We will notify users of material changes via email or in-app notification prior to the change taking effect. Previous versions may be requested at contact@greenda.ai.