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Legal

Terms

The agreement between Kaawa and the organisations that use it, including our promise never to sell farmer data.

Last updated 30 October 2026

Draft awaiting legal review
Passages marked [LEGAL REVIEW] are placeholders for counsel. Nothing here is final until they are resolved.

1. About these terms

These terms are an agreement between Kaawa [LEGAL REVIEW: registered legal name, Delaware entity number and address] and the organisation that signs up (“you”). They cover the Kaawa platform at kaawa.ug and the services we provide through it. Where your signed quote or order form says something different, the quote or order form wins.

The person accepting these terms confirms they may bind the organisation.

2. Words we use

  • Platform: the Kaawa web application and the services we run through it.
  • Your Data: everything you or your users put into the Platform, including Farmer Data.
  • Farmer Data: personal data about farmers and suppliers, their plots, documents, photographs, attestations and deliveries.
  • Statement: a Due Diligence Statement under Regulation (EU) 2023/1115 (the EUDR).
  • TRACES: the European Commission's information system for filing Statements.
  • Survey Partner: a vetted company we engage to map gardens and collect evidence for you.

3. The service

The Platform lets you register suppliers and gardens, check plot boundaries, screen plots against the 2020 forest baseline, prepare Contest Packs for plots we believe are wrongly flagged, keep a chain-of-custody ledger and prepare and file Statements. Survey Partners sign in on the web and upload boundary files; there is no field app. We may improve the Platform over time but will not remove a core function you rely on without telling you first.

4. Accounts and filing authority

You decide who in your organisation has access and what each person may do. Only your Org Admins can submit a Statement unless an Org Admin explicitly grants that permission to a named member. You keep your credentials secure and tell us promptly about any unauthorised use. Our staff may enter your account only to give support; every such session is logged and visible to your Org Admins.

5. Filing as your agent

When you ask us to, we submit Statements to TRACES as your agent, under your own TRACES credentials and never under our identity. You remain the operator or trader responsible for each Statement and for the accuracy of what it declares. The Platform refuses to file when traced volume is below the volume declared, and there is no override. We do not give legal advice; your counsel reviews your obligations [LEGAL REVIEW: agency wording and the EUDR's rules on authorised representatives].

6. Your data

You own Your Data. You give us the right to use it only to provide the Platform to you, to keep it secure and to meet our legal obligations. Our data processing agreement forms part of these terms and governs how we process personal data on your behalf.

You confirm that you have the right to give us Your Data, including any consent the law or free, prior and informed consent principles require from farmers.

7. Farmer data: no sale, no supply intelligence

Kaawa will never sell, rent or license Farmer Data, or otherwise make it available to buyers or any other third party in exchange for payment or other value.

Kaawa will not trade on, sell or publish supply intelligence derived from Your Data, whether about individual farmers or in aggregate. That includes volumes, prices, sourcing districts, supplier lists and screening outcomes.

We disclose Farmer Data only:

  • to the buyers you choose, at the disclosure tier you set, through share links you control, with every Tier 2 and Tier 3 access logged for you to read;
  • to TRACES, when we file a Statement for you;
  • to Survey Partners and other sub-processors, only as far as they need it to do work for you, under written terms at least as strict as these;
  • when the law requires it, in which case we tell you first unless the law forbids it.

This clause survives the end of these terms. A breach of it is a material breach [LEGAL REVIEW: remedies, and whether to exclude it from the liability cap].

8. Survey partners

If you order a managed survey, we assign vetted Survey Partners, check their work before it reaches you and pay them. They see only the farmer names, locations and job instructions for the gardens in their job, never your volumes, prices, buyers or other suppliers. We are responsible to you for their work as if it were our own [LEGAL REVIEW].

9. Fees and billing

Fees are set out in your written quote, in euros. Usage is charged per 60 kg bag of coffee in an accepted Statement and recorded when TRACES accepts the Statement. If you withdraw a Statement within its 72-hour amendment window, the usage line is reversed. Managed surveys and contest cases are charged as your quote sets out. Invoices are due within the period in your quote; fees are exclusive of taxes [LEGAL REVIEW: late payment and price-band adjustment terms].

10. Acceptable use

You will not use the Platform to make a declaration you know to be false, to break the law, to try to reach another organisation's data, to probe or overload the Platform, or to copy or reverse-engineer it.

11. Screening and contest results

Screening relies on public datasets, including the JRC Global Forest Cover 2020 map and Sentinel-2 imagery, which have known error rates. A Contest Pack sets out evidence and reasoning; it does not guarantee that an authority or a buyer will accept it. No flag is cleared automatically: a person reviews and signs every outcome, and the record shows who.

12. Confidentiality

Each of us keeps the other's confidential information confidential and uses it only for the purposes of these terms.

13. Warranties and liability

[LEGAL REVIEW: service levels, warranties and disclaimers, the liability cap and its exclusions, and indemnities.]

14. Suspension, termination and your data afterwards

Either of us may end these terms as your quote or order form allows, or straight away if the other materially breaches them and does not fix the breach within 30 days of notice. When the terms end you can export Your Data. Compliance records are kept for the five-year period the EUDR requires and then deleted; other data is deleted or returned as our data processing agreement sets out [LEGAL REVIEW].

15. Changes to these terms

We will give you at least 30 days' notice of a change that materially affects you. Changes do not apply to a term you have already paid for until it renews, unless the law requires them sooner.

16. Law and disputes

[LEGAL REVIEW: governing law, courts or arbitration, and the language of the agreement.]

17. Contact

Questions about these terms go to [email protected].

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