Privacy Policy & Data Sovereignty
Last updated: October 2026 • Effective across all 54 African Union jurisdictions
1. Commitment to African Data Sovereignty
Stratum Platform Ltd. ("STRATUM", "we", "us", or "our") operates a high-precision market intelligence and commercial intermediation ecosystem across Africa. We are committed to safeguarding the privacy, dignity, and rights of our 190,000+ consumer panelists, informal retail merchants, and institutional client partners.
Our data processing operations are strictly benchmarked against the continent's leading regulatory standards: the Nigeria Data Protection Act (NDPA 2023 / NDPR), the South Africa Protection of Personal Information Act (POPIA 2013), the Kenya Data Protection Act (KDPA 2019), Egypt's Law No. 151/2020, and the European Union General Data Protection Regulation (GDPR) for cross-border bilateral flows.
2. Information We Collect and Process
Consumer Panelist Telemetry
Demographic indicators, purchase frequency, FMCG brand sentiment, localized survey responses, and verified audio/video focus group recordings captured strictly under prior written or recorded biometric consent.
Informal Kiosk & Merchant Audits
Point-of-sale SKU velocity, off-shelf availability, price point resistance, and wholesale restock cycles. All merchant data is aggregated and anonymized; individual spaza shops or kiosks are never identified by owner names.
Institutional & Deal Room Inquiries
Corporate names, executive emails, targeted commercial corridors, and distributor matching briefs submitted via our intake portal under bilateral Non-Disclosure Agreements (NDAs).
Sensor & Geofencing Verifications
GPS metadata used solely to certify that field enumerators were physically inside retail clusters. Coordinates are permanently truncated into 500-meter cluster centroids to guarantee individual household anonymity.
3. Legal Basis for Processing
We process personal information under the following recognized legal grounds:
- Explicit Informed Consent: All panelists opt into research panels with full transparency regarding survey objectives and digital honoraria compensation.
- Contractual Performance: Processing required to provide intelligence feeds and execute bilateral deal room intermediation agreements.
- Legitimate Commercial Interest: Publishing anonymized, macro-economic, and sectoral market intelligence indexes across the AfCFTA zone.
- Statutory Compliance: Compliance with trade, tax, and anti-money laundering regulations across member states.
4. Anonymization & Machine Learning Protections
When consumer feedback is synthesized into the Stratum Intelligence Graph, differential privacy algorithms are applied. Personal identifiers (names, phone numbers, precise geocodes) are permanently uncoupled and replaced by cryptographic hash tokens.
Synthetic consumer twins generated for category concept testing are mathematically derived from macro distributions; they cannot be reverse-engineered to reconstruct any individual citizen's identity.
5. In-Continent Data Residency & Cross-Border Transfers
Primary consumer telemetry is stored on certified tier-3 data infrastructure within Africa (including South Africa, Kenya, and Nigeria). Where data is transferred cross-border for institutional client reporting, transfers are governed by Standard Contractual Clauses (SCCs) and Pan-African data protection authority authorizations.
6. Your Rights as a Data Subject
Under NDPR, POPIA, KDPA, and GDPR, all participants possess inviolable rights to:
- Request access to all personal data held concerning them.
- Request immediate rectification of inaccurate demographic or commercial records.
- Withdraw consent and request erasure ("Right to be Forgotten") from our active panel database.
- Lodge a complaint with their national supervisory authority (e.g., NDPC Nigeria, Information Regulator South Africa, ODPC Kenya).
Contact the STRATUM Data Protection Officer (DPO)
For regulatory inquiries, rights requests, or verification of mutual NDA protocols, please contact our Office of Data Governance: