EFFECTIVE DATE: March 8, 2021

Your privacy is important to Tecsoil USA, Inc., dba Solinftec (thereafter “We, “ Our,” “Us”.) We developed this Privacy Policy so you know how we collect, use, disclose, share, store, and protect your personal information, how you can control your personal information, and what rights you have with respect to the personal information we collect in connection with our commodity application, as detailed below.

The term “Personal Information” can have different meanings depending on applicable law, and generally it has the same meaning as personal data or personal identifiable information (PII). Personal Information is defined in the data privacy laws applicable in your country. Personal Information is information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household—this includes a specific identifier (for example, name, address, phone number, identification number, location data, online identifiers (such as, IP addresses) or a combination of an identifier with one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of a natural person. Some personal information can be regarded as sensitive information, depending on applicable data privacy laws.

In this Privacy Policy, we define “Personal Information” as information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you. Personal Information does not include information that is aggregated or information that cannot be reasonably linked to you.

This Privacy Policy applies only to our actions with respect to our “Solinftec Commodity” Mobile Application (the “App”). It does not extend to our website, other applications, any websites that can be accessed from the App, including but not limited to, any links we may provide to social media websites.

ACKNOWLEDGEMENT AND ACCEPTANCE OF TERMS

By accepting this Privacy Policy during the App installation process, you expressly consent to our collection, use, disclosure, and sharing of your personal information in accordance with this Privacy Policy. If you do not agree to these terms, please do not access or use the App.

INFORMATION WE COLLECT FROM YOU

We collect Personal Information only as necessary to deliver the App and provide services associated with the App, to fulfill legal and regulatory requirements, and for the other purposes set forth in this Privacy Policy.

We may collect the following information, which may include Personal Information, from you:

• First name and Last name
• Email
• Location (e.g., GPS) in connection with your use of the App
• Digital photos that you capture in connection with your use of the App
• Phone number
• IP address

HOW WE COLLECT INFORMATION FROM YOU

We collect this information in the following ways:

1. Information you provide.

We may collect your first name, last name, email, phone number, and digital photos captured by your camera-equipped mobile computing device, and other information about you that you may voluntarily send to us through the use of the App.

1. Information automatically collected through your use of the App.

To the extent that you use the App, we collect your location (GPS) automatically.

We may also automatically collect certain information based upon your use of the App, such as IP address.

GEOLOCATION INFORMATION

As you use the App, we collect your geolocation information through your device’s GPS, Wi-Fi, or Bluetooth. We use this information in order to provide our services in connection with the App. For example, collecting geolocation information allows us to make agronomic recommendations to you for optimizing your fleet of agriculture machines including recommending drive routes, drive speeds, and vehicle dispatch schedules.

You may disable geolocation collection by adjusting the settings on your device. However, if you disable geolocation collection you may not be able to use our services and the App effectively.

HOW WE USE YOUR INFORMATION

We use information we collect about you, including your Personal Information, for the following purposes, including, but not limited to:

• facilitate and enable delivery of our services;
• provide support to you in connection with the use of the App;
• for our general administrative purposes;
• resolve disputes; troubleshoot problems;
• communicate with you about our services in connection with the App;
• detect and protect us against error, fraud, and other criminal activity;
• provide product and services to you, and to respond to your inquiries about our services and the App;
• improvement of our existing product and services;
• improve our ability to address your needs;
• to make agronomic recommendations and product tips;
• cooperate with government officials or parties in litigation under process of law or regulation, or as otherwise required or permitted by law;
• protect the security or integrity of the products or services, and/or to enforce the terms governing their use;
• and as otherwise described to you at the time of collection.

HOW WE SHARE YOUR PERSONAL INFORMATION

In connection with your use of the App, we may share the following information about you with our grain elevator operator customers for the purposes stated above:

• First name and Last name
• Email
• Location (e.g., GPS) in connection with your use of the App
• Digital photos that you capture in connection with your use of the App
• Phone number

The following describes additional ways we may disclose and share information that we collect about you, which may include Personal Information:

• Third-Parties. We may provide your information to third-parties to whom you request that we provide the information.

• Business Partners. We may share your Personal Information, such as location (GPS), first and last name, with our partnering grain elevator operator customers.
• Legal Requests. In response to a verified request by law enforcement or other government officials relating to a criminal investigation or alleged illegal activity, or if we believe there has been a violation of this Privacy Policy, or if we believe that someone may be causing injury to our rights or property, to other users, or to anyone else, or as required by law we can disclose your Personal Information, including first and last name, phone number, email, digital photos.
• Business Transactions. In the event we go through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its assets, your personal information, including your email, will likely be among the assets transferred. If that happens, we will use reasonable efforts to make sure the transferee uses your information in a manner consistent with this Privacy Policy.
• Aggregate and De-Identified Information. We may disclose aggregate, anonymous, or de-identified information about users for compliance, or other purposes.

We will not sell, rent, or share any of your Personal Information, including your email address, to non-affiliated third party vendors or website owners for their marketing or advertising purposes without your consent.

HOW WE RETAIN YOUR PERSONAL INFORMATION

In general, we keep information about you for as long as we need it to carry out the purposes described above, and as necessary to comply with our records-management policies. We also keep your personal data as we reasonably determine to be necessary to exercise or preserve our legal rights, or comply with other legal obligations we might have, such as in connection with litigation.

We may retain some information about you, as required for our own internal purposes, such as for legal compliance and operational purposes.  We will not use this information to market products or services to you, unless you subsequently agree to receive such marketing.

We may also retain some information that has been aggregated, anonymized or put through another technical process that reduces our ability to attribute such information to you for our internal operations and research and development purposes, but we will no longer link this information with you individually.

YOUR CHOICES—HOW YOU CAN CONTROL YOUR PERSONAL INFORMATION

You may update, make changes to the Personal Information, or request that we delete Personal Information we collected and/or hold for you by contacting us as at the address provided below, or electronically at [email protected].

Where you have provided your consent for us to use information about you, you may request to withdraw that consent for future uses of such information by contacting, as specified above.

If you are a California resident, please consult the relevant section below.

PROVISION OF PERSONAL INFORMATION / AUTOMATED DECISION MAKING

Personal Information we collect from you is necessary to provide the services related to the use of the App. Failure to provide such information and pertaining data may not enable us to provide our services to you or make the App accessible. We do not use automatic decision-making or profiling of individuals.

MARKETING OR ADVERTISING PRACTICE

We don’t collect or use Personal Information for marketing purposes.

SECURITY MEASURES WE HAVE IN PLACE

The security of your Personal Information is important to us. We have taken steps to help protect the personal information we collect. We have implemented commercially reasonable technical, administrative, and physical security measures designed to protect your personal data from unauthorized access, disclosure, use, and modification. However, no data security measures can guarantee 100% security. You should take steps to protect against unauthorized access to your device.

The Personal Information we collect for the use of the App is encrypted in transit.

CHILDREN’S PRIVACY

The App is not directed to individuals under the age of thirteen (13), and we do not collect, process, or use information relating to individuals who we know to be  under the age of 13. A legal representative of an individual under 13 years old has the right, upon request, to view the information provided by the child or to require that it be deleted. Please contact our privacy representative at the address provided below.

CHANGES IN THIS PRIVACY POLICY

We reserve the right to modify this Privacy Policy at any time, so please review it frequently. If we make material changes to this Privacy Policy, we will notify you by posting the revised version of this Privacy Policy as required by law.

CONTACT US   

Tecsoil USA, Inc. (dba Solinftec)

Customer Operations Team

3000 Kent Ave Suite 2130

West Lafayette, Indiana 47906

Email: [email protected]

CALIFORNIA PRIVACY NOTICE

This California Privacy Notice (“Notice”) is for California residents and supplements our Privacy Policy. It explains how we collect, use, and share your Personal Information and how to exercise your rights under the California Consumer Privacy Act of 2018 (“CCPA”).

We define “Personal Information” as information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you. Personal Information does not include information that is aggregated or information that cannot be reasonably linked to you.

How We Collect, Use, and Share Your Personal Information

We collect various types of Personal Information about you when we provide our service associated with the App.

To provide our services and the App to you, we must process information about you, including Personal Information. We may share your personal information for business purposes and only to the extent necessary to provide our services in connection with the App, and with strict restrictions on how our partners can use and disclose the data we provide, in accordance with the CCPA.

The best way to learn about the kinds of information we collect and how we use it is to review our Privacy Policy.

Here is a summary of the CCPA-related categories of Personal Information we may have collected about you over the past twelve (12) months, depending on how you use our Services, as well as how we use it and with whom we may shave shared it:

We may obtain the categories of personal information listed above from the following categories of sources:

• Directly from you
• Collected automatically during the use of the App.

Use of Personal Information

We may use or disclose personal information we collect for one or more of the following business purposes:

• facilitate and enable delivery of our services;
• provide support to you in connection with the use of the App;
• for our general administrative purposes;
• resolve disputes; troubleshoot problems;
• communicate with you about our services in connection with the App;
• detect and protect us against error, fraud, and other criminal activity;
• provide product and services to you, and to respond to your inquiries about our services and the App;
• improvement of our existing product and services;
• improve our ability to address your needs;
• to make agronomic recommendations and product tips;
• cooperate with government officials or parties in litigation under process of law or regulation, or as otherwise required or permitted by law;
• protect the security or integrity of the products or services, and/or to enforce the terms governing their use;
• as otherwise described to you at the time of collection;
• as described to you when collecting your personal information or as otherwise set forth in the CCPA;
• to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing of Personal Information

We may disclose your personal information to a third party for a business purpose.  When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

We may disclose your personal information for a business purpose to grain elevator operator customers in connection with your use of the App, as detailed in our Privacy Policy.

Your Rights and Choices

The CCPA provides California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, if specified, we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
  • sales, identifying the personal information categories that each category of recipient purchased; and

disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

3.   Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

• Mail:

Tecsoil USA, Inc. (dba Solinftec)

Customer Operations Team

3000 Kent Ave Suite 2130

West Lafayette, Indiana 47906, USA

OR

• Email: [email protected]

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.  Making a verifiable consumer request does not require you to create an account with us.  We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

1. Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.  If you have an account with us, we will deliver our written response to that account.  If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.  Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt.  The response we provide will also explain the reasons we cannot comply with a request, if applicable.  For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.  If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.