Privacy Policy

(Effective January 25, 2022)

We at Cattler Corporation know you care about how Your Data is used and shared, and we take your privacy seriously. We believe helping you to power your prosperity includes keeping the data you share with us safe. We promise to never sell your personal information, and to give you transparency and control over how your data is used and shared. We understand there is a significant responsibility that comes with you entrusting your data with us and protecting that information is an important part of how we conduct our business.

Please read the following to learn more about our Privacy Policy ("Policy").

Scope

This Policy explains our information practices, the kinds of information we may collect, how we protect that information, how we use and share that information, and how you can opt-out of a use or correct or change that information. This Policy does not apply to the information practices of companies we don't own or control, or people that we do not manage.

We update this Policy from time to time and we encourage you to periodically review this Policy. We will post any Policy changes on this page and if the changes are material, we will provide you with a more prominent notice by email, push notification, and/or by other means. This Policy is incorporated by reference into Cattler's Terms of Service (the "Terms"). All other terms not defined in this Policy will have the meanings set forth in the Terms.

This Policy is global in nature, meaning that it is applicable to all websites, mobile applications, services and offerings of Cattler, and it describes our privacy practices as they relate to:

1. "Farm Data" means any farming data, as broadly understood in the cattle industry, including, but not limited to, your feed inputs data, application data, cattle data, invoice data, forage data, land data, machinery data, pricing data, grain purchases data, cattle sales data, feedyard fees data, weather data, and the type of products or services you use and purchase from us or other parties.
2. "Economic Data" means any cost, price, financial or payment information, including, but not limited to, assets and liabilities, income sources, payment history, payment preferences, and tax id number. Note: Economic Data provided by you or gathered about you by us from third parties in connection with a credit application or for other purposes may be subject to and protected by additional terms and conditions listed therein.
3. "Personal Data" means any information other than Farm Data, Economic Data or Member Content, including, but not limited to: (a) Company name, points of contact, account users, employees, agents, responsible parties, etc., (b) contact information including, but not limited to, email address, business phone numbers, address, etc., (c) your pictures and likeness, (d) communications, information or other materials that you provide us, and (e) business relationship information, including information relating to your agreements with us, preferences, etc.
4. "Member Content" means any and all text, graphics, logos, tools, photographs, images, illustrations, software or source code, audio and video and product feedback that you provide through the Cattler Platform service. You choose whether Member Content will be personally identified to you.

When we refer to "Data" we mean all four types of data defined above, and when we refer to "Your Data" we mean Data you own and have granted us a license to use.

By using or accessing the Services (as defined in the Terms of Service) and by interacting with us in any other manner, you acknowledge and accept the practices and policies outlined in this Policy. You hereby consent, to the fullest extent permitted in your jurisdiction, that we will collect, use, and share Your Data in the following ways, which are essential to providing you the Services.

Disputes About This Policy Or Relating To The Services Generally Must Be Resolved By Binding Arbitration And On An Individual Basis Only As Specifically Set Forth In The Terms Of Service.

Information We Collect

Information we receive from you

When you interact with the Cattler Platform via our websites and mobile application or use our Services, we may collect Data and other information from you. The Data that we receive about you depends on the context of your interactions with the Cattler Platform, how you configure your Cattler account and the choices that you make – including what products you purchase. The Data you provide may also depend upon what Services you use, your location, and applicable law. Access to some Services in the Cattler Platform require you to provide information for it to function. If you do not wish to provide the required information you may not be able to use certain features of the Cattler Platform.

• Creating a Cattler Account. We collect Your Data when you create or modify your Cattler account, set preferences, use Cattler services, or provide any other Data to access or utilize the Cattler Platform. For example, through the account registration process and/or through your account settings, we may collect Personal Data. We may also collect Financial Data in order to process a loan application. Certain information may be required to register with us, to take advantage of some of our features, or to order products from us.
• Commercial and Financial Information. We may collect payment and billing information, data from purchases and sales, transactions, prices and costs when you use our Administration section of the platform.
• Customer Support, Product Research and Feedback. We may collect Your Data when you reach out to us for support, give us feedback, participate in optional surveys, product research or training and you choose to share.
• Usage Data. We may collect usage information such as the pages you viewed, the features you use, your browser type and details about any links with which you interact.
• Location information. We may collect precise location information to provide you with personalized, location-based services and content if you grant permission to do so in your device settings. Such location-based technology is integral to the functionality of the Cattler mobile application.
• Mobile Information. We may collect information about your device such as Internet Protocol ("IP") addresses, log information, error messages, device type, and unique device identifiers. For example, we may collect IP addresses from you as part of our sign-in and security features.
• Live Communications. If you communicate with us via telephone, online conference or other electronic means of communication, we may record that communication in accordance with applicable laws.
• Information Collected Automatically; Cookies. Whenever you interact with our Services, we may use commonly used tools such as cookies, web beacons, pixels, local shared objects and similar technologies (collectively "cookies") to collect information about you so we can provide the experiences you request, recognize your visit, track your interactions, and improve your and other customers' experience. You may be able to change the preferences on your browser or device to prevent or limit your device's acceptance of cookies, but this may prevent you from taking advantage of some of our features.

Information We Collect From Other Sources

We may also get information about you from others where permitted by applicable law. In most circumstances, where the information we collect about you is held by a third party, we will obtain your permission before we seek out this information from such sources (such permission may be given directly by you or implied). From time to time, we may utilize the services of third parties and may also receive data collected by those third parties in the course of the performance of their services for us or otherwise. Where this is the case, we will take reasonable steps to ensure such third parties have represented to us that they have the right to disclose your information to us. When permitted by applicable law or regulatory requirements, we may collect information about you from other sources without your knowledge or consent.

We may also collect market-related information, which may include information concerning market trends and activities impacting our business or your business. This information may include contract terms, financial information and other information for the purpose of market analysis and strategic planning. In addition, we may also collect information related to our media, investor and public relations activities and information related to our interactions with financial and other advisors. We collect information from publicly available sources, such as open government databases.

We may use third-party service providers in connection with collecting Usage Data, including but not limited to Google Analytics. Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. This helps us conduct research and analytics, and for marketing purposes in accordance with applicable law. You can prevent Google Analytics from recognizing you on return visits to this site by disabling cookies on your browser. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy

We may also use a third-party marketing software from a company called Hubspot to send promotional emails. As mentioned above, we use cookies as part of tracking so we have information on email open rates and click-through rates, as well as to track activity on our website. For example, we use Hubspot cookies to see if an individual who opens an email then visits other parts of our website. This helps us update, expand, and analyze our records, identify new customers, and create more tailored advertising to provide services that may be of interest to you. For more information on Marketo's privacy and cookie policy, please see Hubspot's privacy policy and other disclosures: https://legal.hubspot.com/privacy-policy.

How Do We Use Your Data?

We collect and process Your Data from you only where:

• we have your consent;
• we need Your Data to perform a contract with you or provide a service for you;
• provide you with the benefits of the Cattler Platform and operate our business;
• where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms; or
• we need to comply with legal requirements, including applicable laws and regulations.

We collect and process Your Data in order to:

• establish and manage our relationship with you, including providing you with the Cattler Platform, setting up your user account, verifying Your Data, performing our contract with you for the use of our services and to fulfill our obligations under the applicable terms of service contacting you about our Services, etc;
• analyze, improve and update our Services;
• send you marketing materials and information that we believe may be of interest to you;
• personalize your experience and tailor recommendations and offers to you, including through the development of insights about you and your operation's needs to help you make better decisions on your farm;
• provide you with support and resolve disputes;
• protect the rights, property, safety or security of the Cattler Platform, our Cattler Members, employees or others and prevent errors, fraud or illegal activity;
• enable us to comply with applicable laws or regulatory requirements;
• enforce or apply our Terms of Service;
• for debt collection; and
• for any other permitted business purposes.

Because we only work with businesses and their authorized representatives, we do not knowingly collect or solicit Data from anyone under the age of 13. If you are under the age of 13, please do not attempt to register for the Services or send any Data. If we learn we have collected Data from a child under the age of 13, we will delete that information as quickly as possible. If you believe a child under the age of 13 may have provided us Data, please contact us at support@cattler.farm.

How Do We Share Your Data?

We believe farmers own the information generated by their farming operations. Cattler will never sell your data. Except as outlined below, we will never provide Your Data to another party without explicit consent from you.

We may share Your Data in the following circumstances:

• at your request or to complete a transaction for which Your Data was collected;
• provide a service to you;
• assist you in exercising your rights with respect to Your Data;
• detect security incidents or illegal activity;
• conduct our regular business activity including quality assurance and marketing to you; and
• as permitted or required by applicable laws or regulatory requirements, including, but not limited to, comply with search warrants, subpoenas or court orders.

We may share Your Data for the purposes listed within this Policy to the following categories of recipients:

• internally across Cattler Corporation with whom we may jointly offer products or services, or whose products or services we believe may be of interest to you. We require our affiliates to maintain the confidentiality and security of Your Data they maintain on our behalf;
• your agents, representatives, and other persons acting on your behalf or to whom you instruct or authorize us to disclose Your Data with;
• third parties that are necessary to administer services to you or the entity you represent or are associated with, such as third-party IT, data processing, and payment processing service providers we utilize so we can operate our business. We do not reveal personally identifiable Data to parties outside our affiliates for their independent use unless: (1) you request or authorize it; (2) the information is provided to help complete a transaction initiated by you; (3) the Financial Data is provided to a credit bureau or similar information reporting agency; or (4) the disclosure otherwise is lawfully permitted or required. Any third-party service providers which are engaged by us must agree to follow the privacy standards set by this Policy or similar standards;
• our agents and representatives, such as attorneys, auditors, and other professionals;
• government, legal regulatory, supervisory, or other authorities under applicable laws;
• prospective purchasers and assignees in the event our business, or a portion thereof, is sold or assigned; and
• 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.

Your Data may be transmitted to/from and stored by us or third-party service providers in the U.S., Canada, Australia, Brazil, and other countries such as Argentina where we conduct engineering and software development. As such, Your Data may potentially be accessible to the law enforcement and national security authorities of those jurisdictions.

Sharing Your Data with Other Cattler Members and Professionals

Please note that the Cattler Platform allows you to share Your Data with other parties, including other Cattler Members and individuals or businesses with professional accounts, such as agronomists, applicators, experts, consultants, etc. (collectively, "Professionals"). To the extent you share Your Data with others, you grant them a license to use and exercise all rights in Your Data, as permitted by the functionality of the Services. We are not responsible for how others use Your Data, or the advice or information they provide you when you share Your Data.

We may also use and share Data on an aggregate or anonymized basis (such that it does not identify individuals) for various business purposes, where permissible under applicable laws. We own the Cattler Platform services and content, including aggregated and/or anonymized data, analytics, benchmarking, etc.

We do not and will not sell Your Data.

Security of Personal Information

Your account is protected by a password for your privacy and security. You must prevent unauthorized access to your account and Your Data by selecting and protecting your password appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account.

We endeavor to protect the privacy of your account and Your Data, but unfortunately, we cannot guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time. In the event of a breach of Your Data by an unauthorized person, we will investigate and if necessary, provide notice to you by email or upon your next log in.

Your Data Rights and Choices

Access

Through your account settings or if requested in writing, you may access, and, in some cases, edit certain types of Your Data, which may change as our Services and the Cattler Platform change. If you have any questions about viewing or editing Your Data, please contact us at support@cattler.farm. When you update Your Data, however, we may maintain a copy of the unrevised Data in our records. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the Data we have about you. In addition, Data may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices. In the event that we cannot provide you with access to Your Data, we will endeavor to inform you of the reasons why, subject to any legal or regulatory restrictions.

IMPORTANT NOTICE: THIS POLICY FORMS A PART OF AND IS GOVERNED BY OUR TERMS OF SERVICE. DISPUTES ABOUT THIS POLICY OR RELATING TO THE SERVICES GENERALLY MUST BE RESOLVED BY BINDING ARBITRATION AND ON AN INDIVIDUAL BASIS ONLY AS SPECIFICALLY SET FORTH IN THE TERMS OF SERVICE.