Gradable Privacy Policy

Effective November 6, 2020

Gradable (“us”, “our”, or “we”) appreciates that you have trusted us with your Personal Information; protecting that information is an important part of how we conduct our business. We believe it is important for you to know how we treat Personal Information that we may have about you.
This Privacy Policy explains our information practices, the kinds of information we may collect, how we use and share that information, and how you can opt-out of a use or correct or change that information but not to the information practices of companies we don’t own or control, or people that we don’t manage. This Privacy Policy is incorporated by reference into Gradable’s Terms of Use (the “Terms”). All other terms not defined in this Privacy Policy will have the meanings set forth in the Terms.

 

Who Does this Privacy Policy Apply To?

This Privacy Policy describes the rights you have concerning the Personal Information we collect about you.  This Privacy Policy is applicable to U.S. residents and other clients of Gradable’s services about whom we have Personal Information.

 

What Are the Sources of Your Personal Information?

 

We may obtain Personal Information from the following sources:

  1. you;
     

  2. our clients, their agents or representatives, applications, forms, or other documents, or from your dealings and transactions with us and other sources;
     

  3. our Affiliates;
     

  4. consumer reporting agencies;
     

  5. service providers;
     

  6. joint marketing vendors;
     

  7. websites or mobile applications owned or operated by us or our Affiliates; and
     

  8. sources that are publicly available.

What Personal Information Do We Process?

The type of Personal Information we process may vary depending on whether you deal with us as an individual or in connection with one of our corporate or institutional clients, as well as the jurisdiction where you reside. We may process the following categories of information, among others:

  1. Account Information such as your full name, company or organization name, phone number, postal address, email address, and your personal and/or work-related contact information;
     

  2. Agricultural Data, as broadly understood in the agricultural industry, including, but not limited to, agronomic data, application data, climate data, harvest data, invoice data, planting data, land data, machine data, pricing data, weather data, and the type of agricultural products or services you use and purchase from us or other parties.
     

  3. Commercial and financial information, such as your source of wealth/income, assets and liabilities, investment experience and objectives, ownership structure, bank account numbers, credit card numbers, payment preferences, social security/social insurance number, creditworthiness and credit history, and risk tolerance;
     

  4. Professional or employment related information, such as current or past job history; 
     

  5. Internet or other electronic network activity information, to the extent you access and use one of our websites or mobile applications; and
     

  6. Information Related to Data Collected for our Clients, we provide customer relationship management services to our clients, and collect and process information under the direction of its clients. Often times, we have no direct relationship with the individuals whose Personal information we process.

How Do We Use Personal Information?

We use personal information to better tailor and personalize our services and communications to you and for any other purpose permitted by applicable law, including the following purposes:

  1. to provide and operate services, including, without limitation, maintaining or servicing accounts, verifying customer information, fulfilling requests for products or services, retaining records of transactions, and for billing purposes;
     

  2. to provide operational and technical support and development of our businesses, including to improve or enhance our services, evaluate customer service, efficiency and cost, as well as for risk management purposes;
     

  3. to carry out credit checks (where applicable), money laundering, conflict checks, for fraud and financial crime prevention purposes, or other activity required under applicable laws;
     

  4. to detect security incidents and protect against malicious, deceptive, fraudulent, or illegal activity;
     

  5. in order to comply with legal and regulatory requests made to us or any Affiliates anywhere in the world, and to assist with law enforcement, investigations, complaints, regulatory requests, litigation, arbitration, mediation, and other legal processes;
     

  6. for monitoring purposes, such as to establish the existence of facts (e.g., keeping records of transactions), to maintain compliance with regulatory or self-regulatory practices, to comply with applicable laws, and for other purposes permissible under applicable law; and
     

  7. to conduct research and analytics, and for marketing purposes in accordance with applicable law. 

When Do We Share Personal Information?

We may share Personal Information at your request or to complete a transaction for which the Personal Information was collected, provide a service to you, assist you in exercising your rights with respect to your information, detect security incidents or illegal activity, conduct our regular business activity including quality assurance and marketing to you, and as required by law (for instance with regulators and law enforcement agencies).

We may share Personal Information for the purposes listed within this Privacy Policy to the following categories of recipients:

  1. our Affiliates and business partners with whom we may jointly offer products or services, or whose products or services we believe may be of interest to you. In such cases, our business partner's name will appear, along with Gradable. We require our affiliates and business partners to maintain the confidentiality and security of Personal Information they maintain on our behalf and not to use it for any purpose other than the purpose for which we provided them;
     

  2. your agents, representatives, and other persons acting on your behalf or to whom you instruct or authorize us to disclose your Personal Information;
     

  3. if you are a representative of an entity or institution, to the entity or institution you represent;
     

  4. third parties that are necessary to administer services to you or the client you represent or are associated with, such as third-party IT, data processing and payment processing service providers we utilize so that we can operate our business;
     

  5. our agents and representatives, such as attorneys, auditors, and other professionals;
     

  6. government, legal regulatory, supervisory, or other authorities under applicable laws;
     

  7. prospective purchasers and assignees in the event our business, or a portion thereof, is sold or assigned; and
     

  8. other third parties as may be required for the purposes set forth within this Privacy Policy, or where we have obtained the appropriate authorization if required.

We may also use and share Personal Information on an aggregate or deidentified basis (such that it does not identify individuals) for various business purposes, where permissible under applicable laws.

We do not sell Personal Information.

What Additional Privacy Rights May You Have?

California Residents

For California residents, the California Consumer Privacy Act (“CCPA”) provides certain rights regarding the information that we collect. In particular, you may have the following rights:

Notification of Personal Information Collection

We collect, use, and process your Personal Information, as described within this Privacy Policy, for expected internal reasons, Legal obligations, and servicing a transaction or providing a service. In addition, we may use your information to detect security and fraud as well as technical support functions. If we plan to use or disclose your Personal Information for a purpose not previously identified (either in this Policy, our Terms of Use or separately), we will endeavor to advise you of that purpose before such use or disclosure.

 

Further detail on categories of and Personal Information collected about you, sources of Personal Information, purposes for collecting Personal Information, as well as Third Parties to whom we disclose Personal Information, are described within this Privacy Policy.

 

Access to Specific Pieces of Information

Under California Civil Code Sections 1798.83-1798.84, you may request that we disclose certain information to you about our collection and use of your Personal Information.

 

Upon your valid request, we will provide a report outlining specific pieces of Personal Information collected about you. You may make this request a maximum of two times within a twelve-month period.

 

Deletion of Personal Information

You may request that we and our service providers delete any Personal Information that we collect from you. Our obligation to comply with this request is subject to exemptions. If you are interested in requesting deletion of your Personal Information, please note we may have a legal reason to retain your information, as permitted by the CCPA, in accordance with the original reason provided for collecting and processing Personal Information as described within this document.

 

We retain Personal Information in accordance with our information management policies, which establishes general standards and procedures regarding the retention, handling, and disposition of our records, including Personal Information. Personal Information is retained as long as necessary to meet legal and regulatory requirements. Retention may be extended if we are required to preserve Personal Information in connection with litigation, investigations, and proceedings. 

 

Opt Out of Sale

While, under the CCPA, you may request that we do not sell your Personal Information, because we do not sell any Personal Information, there is no need to opt out of sales. 

 

Anti-Discrimination

We will not discriminate against you for exercising your CCPA rights. 

 

In order to provide a response, Gradable may ask that you provide clarifying or identifying information to verify your request. We cannot respond to your request or provide you with Personal Information if we cannot verify your identity and confirm that the Personal Information relates to you.

 

Agents who make requests on behalf of individuals will be required to verify their authority to make the request by submitting written authorization from the individual. We will not honor any requests from agents until authorization is verified.

 

To allow us to process your CCPA request, please submit your request to: legal@farmersbusinessnetwork.com.

 

Contact.  If you have any questions or concerns regarding this Privacy Policy, please contact our Privacy Officer and we will endeavor to answer your questions and advise you of any steps taken to address the issues raised by you. If you are dissatisfied with our response, you may be entitled to make a written submission to the Privacy Commissioner in your jurisdiction. The contact information for our Privacy Officer is as follows:

 

FBN Grain LLC

Attn: Privacy Officer

388 El Camino Real

San Carlos, CA 94070

Email: legal@farmersbusinessnetwork.com