Privacy Notice
Draft — requires legal review before publication. This text has not yet been reviewed by a lawyer. Highlighted items are still to be confirmed.
Last updated: [To be confirmed: date of publication]
This notice explains how Wistelligence AS handles personal data on this website (wistelligence.com) and in the Wistelligence apps used by farms, including AquaFeed Pro.
1. Who we are
Wistelligence AS, organisation number 924 447 605, c/o Lillesand Regnskap og Økonomi, Storgata 2A, 4790 Lillesand, Norway.
[To be confirmed: Ari: confirm that the name change from ACR NORGE AS is registered, or add «registered as ACR NORGE AS, name change in progress».]
Contact about privacy: use the contact form at wistelligence.com/contact and choose the topic «Privacy», or write to the address above.
Part A – This website
A1. What we collect
| Data | When | Why | Legal basis (GDPR) |
|---|---|---|---|
| Name, e-mail, organisation (optional), country (optional), topic, your message | When you send the contact or partner form | To answer your enquiry | Your consent in the form (Art. 6(1)(a)); and steps at your request before a contract (Art. 6(1)(b)) [To be confirmed: lawyer: confirm basis] |
| Technical data such as IP address, browser type and time of request | Every visit, handled by our hosting provider to deliver and protect the site | Security and operation of the website | Legitimate interest (Art. 6(1)(f)) |
We do not use analytics, advertising tools or tracking cookies on this website (see «Cookies» below).
A2. How form messages are handled
Your message is sent to us by e-mail through our e-mail delivery provider and is not stored in a database on the website. Our server logs record only that a form was sent, a random reference and the time, not the content of your message or your contact details. We keep form e-mails for as long as needed to follow up your enquiry and for up to [To be confirmed: e.g. 24] months afterwards, unless the enquiry leads to a customer relationship.
A3. Cookies
This website does not set cookies and does not use local storage for tracking. If this changes, we will update this notice and ask for consent where required. The separate sign-in at wistelligence.com/login uses strictly necessary cookies to keep you signed in.
Part B – Wistelligence apps used by farms (including AquaFeed Pro)
B1. Roles
We are preparing to start production with farms in Nigeria, the Democratic Republic of the Congo, Burundi and Malawi. For the operational records a farm keeps in our apps, the farm organisation is normally the controller and Wistelligence AS is the processor, acting on the farm's instructions under a data processing agreement. Wistelligence AS is the controller for account administration, security logs and our own communication with users. [To be confirmed: lawyer: confirm roles and the data processing agreement template]
B2. What the apps process
- Account data: name, work e-mail or user name, role, language preference.
- Work records entered by staff: feeding, water quality, growth, mortality, harvests, tasks, photos and notes, linked to the user who entered them.
- Security and audit logs: sign-in events and changes to records.
- Accounting data, if the farm chooses to connect an accounting system when production starts.
The apps do not collect device location. If a location feature is switched on later, we will update this notice before it is used. [To be confirmed: Ari: confirm this variant (no location at launch)]
B3. Where data is stored and who helps us
| Provider | Purpose | Location |
|---|---|---|
| Supabase | Database and sign-in | Ireland (EU/EEA) |
| Vercel | Hosting of websites and web apps | United States and global edge network |
| Fly.io | Background data processing | Sweden (EU/EEA) |
| Resend | E-mail delivery | [To be confirmed: Ari: confirm region] |
[To be confirmed: Ari: confirm each provider and region in the provider's dashboard; lawyer: confirm the transfer mechanism for each US provider]
We do not sell personal data, and we do not share farm data with feed suppliers, partners or other third parties unless the farm asks us to.
B4. Transfers from Nigeria, the DR Congo, Burundi and Malawi
Data entered on a farm in these countries is transferred to and stored with the providers above, mainly in the EU/EEA. Before the first farm starts we will confirm, for each country, what the local law requires for such transfers and document the safeguards used:
- Nigeria: Nigeria Data Protection Act 2023 and the rules of the Nigeria Data Protection Commission. [To be confirmed: lawyer: registration, transfer conditions, local representative]
- Malawi: Data Protection Act 2024. [To be confirmed: lawyer: confirm status, transfer conditions and registration]
- DR Congo: data protection provisions in the Digital Code (2023). [To be confirmed: lawyer: confirm provisions and authority]
- Burundi: [To be confirmed: lawyer: confirm applicable rules]
Where local law gives you more rights than this notice describes, local law applies.
B5. Your rights – farms and farm staff
You can ask for access to your personal data, correction, deletion, restriction, objection and a copy in a portable format. Farm staff should first contact their own farm administrator, since the farm decides how its records are used; we help the farm answer. You can also contact us directly (section 1). You may complain to the Norwegian Data Protection Authority (Datatilsynet) or to the data protection authority in your own country.
B6. How long we keep data
The farm decides how long its records are kept while it uses the apps. When a farm stops using a service, we delete or return its data within [To be confirmed: e.g. 90] days, except what we must keep by law (for example accounting rules).
B7. Security
Data is encrypted in transit. [To be confirmed: Ari: confirm encryption at rest per provider] Access is limited by role, and changes are logged.
Changes
We will publish changes on this page with a new date. For material changes to Part B we will inform farm administrators in advance.