- the types of personal information we collect about you;
- the purposes for which we collect that information;
- how we use that information;
- with whom we share that information;
- how we safeguard that information;
- the choices available to you regarding how we use your personal information; and
- how you can contact us about our privacy practices.
- What personal information do we collect?
- What is the purpose of the collection and use of your personal information?
- To whom do we disclose your personal information?
- What if there is a change in the initial purpose of collection of your personal information?
- Do we knowingly collect personal information about children?
- How do we safeguard your personal information?
- Do we transfer your personal information to third parties for storage or processing?
- How long do we retain your personal information?
- Do we collect, use, and disclose non-personal information about you?
- How do we ensure the accuracy of your personal information?
- How can you access your personal information?
- What types of “cookies” and/or other technologies do we use and how can you manage “cookies”?
- Do you use third party advertising partners? If so, how can I opt out of targeted advertising?
- What type of analytics services do we use and for what purpose? How can you disable analytics?
- What do you need to know about the basis for collection, using, and processing your personal information and your associated personal information rights if you are located within the European Union (“EU”) or the European Economic Area (“EEA”)?
- Who do you contact if you have an inquiry, complaint, or want to request a review of your personal information?
- How do we handle complaints?
- How do you withdraw your consent to the collection, use or disclosure of your personal information?
- How can you unsubscribe from our commercial electronic messages such as messages regarding new products or services?
“collection” means the act of gathering, acquiring, recording or obtaining personal information from any source, including third parties, by any means.
“consent” means voluntary agreement with the collection, use and disclosure of personal information for defined purposes. Consent can be either express or implied and can be provided directly by the individual or by an authorized representative, such as a parent or guardian. Express consent is permission that is granted by an individual taking a positive step to signify consent and may be given orally, electronically or in writing. Implied consent is the assumption of consent that can reasonably be inferred from a user's action or inaction.
“user” means an individual, such as a student, tutor or mentor, who uses the Service provided by FarmLink, including anyone else who accesses or visits the Sites.
“disclosure” means making personal information available to a third party.
“personal information” means information about an identifiable individual, but not aggregated information that cannot be associated with a specific individual.
“registered user” means a user who has created and registered an account with FarmLink on the Site, as well as a Subscribing Organization that has created and registered an account or accounts with FarmLink on the Site.
“Subscribing Organization” means a company, entity or organization, including any business that has subscribed to the Service.
“third party” means an individual other than the user, or the user's agent, or an organization other than FarmLink or a Subscribing Organization.
“use” means the treatment, handling and management of personal information by and within FarmLink.
When you interact with us through the Service, we may collect or receive the following types of information.
Personal Information You Provide To Us
You may provide us with your personal information in different ways. For example, we may collect any or all of the following personal information if the information is reasonably required to provide the Service to you:
- ainformation that you provide when you become a registered user or otherwise complete forms on the Service, such as your name, postal address, telephone number, and email address;
- information about your farm operation including, but not limited to, farm location, acreage, crop yield, crop sales, and budget information.
- your log-in and password details in connection with your account(s), including your username;
- your correspondence with FarmLink employees and independent contractors, including any questions, concerns or comments you may have about the Service or problems that you report;
- comments, videos, photographs, and any other content or information that you may submit to the Service;
- your location information, including IP address, via your mobile device, desktop application or web browser; and/or
- details of your requests made through the Service.
FarmLink does not collect information related to method of payment such as a credit or debit card number. All purchases of FarmLink products and services will be directed to and handled by third parties such as Moneris. You will be bound by the privacy policies of these third party sites.
Technical Information We Collect Automatically
When you visit the Sites and/or use any of our mobile applications, we may collect, using electronic means, technical information. This information may include:
- the IP address of your computer and which browser you used to view our Sites;
- operating system;
- resolution of screen;
- language settings in browsers;
- the site you came from and searched for keywords if arriving from a search engine and/or
- unique mobile device identifiers.
This technical information (some of which in certain instances may be considered personal information) is aggregated and used to measure and improve effectiveness of our Sites. We do not attempt to combine this technical information with other personal information we collect on our Sites.
FarmLink collects your personal information and will use your personal information as is reasonably required for the following purposes:
- if you are a registered user, to establish and maintain your Grain Fox account;
- to provide web applications, mobile applications, the Service, and/or the other services or information that you request;
- to provide mobile device notifications;
- to provide mobile device security;
- to verify your identity if you submit comments, videos, photographs, opinions, or any other content or information to the Service;
- to respond to questions, comments, requests, job applications, or complaints that you submit to FarmLink;
- to collect amounts owing from you to the FarmLink, if applicable;
- to track communications with you;
- to analyze use of the Service and to improve the Service;
- to send emails, newsletters, regular mail or other communications you have consented to receive from the FarmLink;
- to provide Service-related announcements or notifications to you;
- to fulfill a purpose that we disclose to you when we request your personal information;
- to aggregate your personal information resulting from the combination and/or aggregation of certain raw personal information collected from you with other data in a way that no longer personally identifies you;
- to aggregate information about your farm operation resulting from the combination and/or aggregation of certain raw farm operation information collected from you with other data in a way that no longer identifies your farm operation;
- to process payments made by you; and/or
- to meet legal and regulatory requirements.
Your personal information will only be collected and used by FarmLink and its employees, agents, partners, independent contractors, and service providers in a manner consistent with the activities of the Service. Access to your personal information by FarmLink employees, agents, partners, independent contractors, and service providers is limited only to those authorized, based on their need to deal with your personal information for the reason(s) for which it was obtained, including to enable them to perform a business, professional or technical support function for FarmLink.
FarmLink may disclose your personal information to:
- its employees, agents, partners, licensees, independent contractors, and service providers as is reasonably necessary to enable these parties to perform a business, professional or technical support function for FarmLink.
- a person who, in the reasonable judgment of FarmLink, is seeking the information as your agent; and
- a third party or parties, where you consent to such disclosure or the disclosure is permitted or required by law.
Corporate Reorganization and Business Transfers
FarmLink will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and obtain your express consent to do so pursuant to Section 22.
Please note that we may process your personal data without your knowledge or consent where this is required by law.
The Service is intended for general audiences and is not directed to children under the age of 13. We do not knowingly collect personal information from children under 13. In the event that we learn that we have collected personal information from a child under the age of 13, we will take appropriate steps to delete that personal information. If you become aware or believe that a child has provided us with personal information, please contact us as provided in Section 18.
FarmLink is committed to safeguarding your personal information. FarmLink uses appropriate security measures to protect personal information against risks such as loss or theft, unauthorized access, disclosure, copying, misuse, modification or destruction, and any other unlawful form of processing of the personal information in our possession regardless of the format in which it is held. The methods of protection and safeguards used by FarmLink include, but are not limited to:
- Administrative safeguards such as privacy and security policies and procedures, privacy and data protection training for FarmLink staff;
- Technical safeguards such as security testing, vulnerability scans, and technological measures, including the use of passwords, encryption, firewalls, and secure coding frameworks;
- Physical safeguards such as locked filing cabinets, and need-to-know access for FarmLink employees.
FarmLink also ensures that its employees with access to personal information are made aware of the importance of maintaining the confidentiality of personal information.
FarmLink takes care in disposing of or destroying personal information to prevent unauthorized parties from gaining access to the information.
While FarmLink is committed to safeguarding your personal information, we cannot ensure or warrant the security of any personal information we collect either directly or automatically from you, and you do so at your own risk.
FarmLink cannot guarantee that such personal information may not be accessed, disclosed, altered, or destroyed by breach of any of our security safeguards. To the degree that personal information is of a sensitive nature, in the event of a breach, there may be a risk of significant harm to you which includes bodily harm, humiliation, damage to reputation or relationships, loss of employment, business or professional opportunities, financial loss, identity theft, negative effects on the credit record and damage to or loss of property.
FarmLink also cannot guarantee that information sent or received over the Internet is secure and does not make any representation or warranty concerning the security of personal information communicated to or from FarmLink via the Internet or regarding the interception by third parties.
Your personal information may be stored and processed in any country where we engage third party service providers (e.g. United States). While such information is outside of your country of residence, it is subject to the law of the country in which it is held, and may be subject to disclosure to the governments, courts, or law enforcement or regulatory agencies of such other country, pursuant to the laws of such country. For example, personal information stored in the United States is subject to the US PATRIOT ACT.
Where and when appropriate, we will transmit amended personal information to third parties having access to the personal information in question.
FarmLink will only keep personal information for as long as reasonably necessary to fulfil the relevant purposes set out in the Policy Privacy and in order to comply with our legal and regulatory obligations. To determine the appropriate retention period for your information, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of your information, the purposes for which we process your information and whether we can achieve those purposes through other means, and the applicable legal requirements.
Please note, if you are a registered user and your FarmLink account becomes inactive, FarmLink may choose not to retain your personal information associated with your FarmLink account, or any other records associated with your FarmLink account, for a period longer than three years after your FarmLink account becomes inactive, in which case such information will be obfuscated (i.e. masking our or redacting information) and anonymized prior to deletion.
We may collect, use and disclose non-personal information, including aggregated data resulting from the combination and/or aggregation or certain raw data collected from you with other data in a way that no longer personally identifies you or your farm operation. We make no attempt to link this non-personal information with the identity of individuals or their respective farm operations. We may permanently archive non-personal information about you or your farm operation for future use in any manner whatsoever.
You are responsible for keep your personal information complete, up-to-date and accurate as is necessary when directly using and interacting with the Service. Where required, FarmLink will promptly assist you in correcting or completing any personal information found to be inaccurate or incomplete. Where appropriate, FarmLink will transmit amended information to third parties having access to the personal information in question.
Upon request, FarmLink will provide you with a reasonable opportunity to review the accuracy of your personal information. Such personal information will be provided within a reasonable time of the request and at a minimal or no cost to you.
Also upon request, FarmLink will provide an account of the use and disclosure of your personal information and, where reasonably possible, will state the source of the information. In providing an account of disclosure, FarmLink will provide a list of organizations to which it may have disclosed personal information about you when it is not possible to provide an actual list.
In certain situations, FarmLink may not be able to provide access to all of the personal information we hold about you. In such a case, we will provide the reasons for denying access upon request. Such reasons may include:
- if doing so would likely reveal personal information about another individual that cannot be severed or the information could reasonably be expected to threaten the life or security of another individual;
- if doing so would reveal any of our confidential information;
- if the information is protected by solicitor-client privilege;
- if the information was generated in the course of a formal dispute resolution process; or
- if the information was collected in relation to the investigation of a breach of an agreement or a contravention of a federal or provincial law, or that of a foreign jurisdiction.
The Sites use “cookies”, which are small text files placed on your computer or other device when you visit a website. When you visit the site again, the cookie allows that site to recognize your browser. Cookies may store user preferences and other information.
There are three main types of cookies:
- Session cookies are specific to a particular visit and limited to sending session identifiers (random numbers generated by the server) so you don't have to re-enter information when you navigate to a new page or check out. Session cookies are not permanently stored on your device and are deleted when the browser closes;
- Persistent cookies record information about your preferences and are stored in your browser cache or mobile device and remain on your device between browsing sessions. For example, a persistent cookie may be used on a website to remember your log-in details so you will not need to enter those details each time you visit that website; and
- Third party cookies placed by someone other than us which may gather data across multiple websites or sessions.
We use the below listed cookies to perform the following functions:
- Strictly necessary / technical cookies that are essential to enable you to move around a website and use its features. You cannot withdraw your consent to the use of these types of cookies because without them, the Service cannot be provided.
- Analytical / performance cookies that collect information in aggregated form about how users interact with the Sites so that we may improve functionality. These cookies are sometimes placed by third party providers which enable features or functionality provided by third parties in connection with the Service. For example, advertising, interactive content, and analytics (see Section 16 below). The parties that set these third-party cookies can recognize your device both when it visits the website in question and also when it visits certain other websites.
- Functional cookies that allow a website to remember choices you make, recognize you when you return and to personalize content.
- Targeting / advertising cookies that track browser habits and used to deliver targeted (interest-based) advertising based on your browsing activities and interests. See Section 15 on how you may opt out of targeting advertising.
You can manage website cookies in your browser settings, and you always have the choice to change these settings by accepting, rejecting, or deleting cookies. If you choose to change your settings, you may find that certain functions and features will not work as intended on the Service. All browser settings are slightly different, so to manage cookies, you should refer to the relevant settings within your browser.
We may use other technologies similar to cookies like web beacons, which are sometimes called "tracking pixels" or "clear gifs". These are tiny graphics files that contain a unique identifier that enable us to recognize when someone has visited the Sites or opened an email that we have sent them. In many instances, these technologies are reliant on cookies to function properly, and so declining cookies will impair their functioning.
We may use third party advertising partners such as advertising networks, exchanges, and social media platforms to display advertising on the Sites or to manage and serve our advertising on other sites. You have a variety of options to opt out of interest based advertising ranging from browser controls, add on utilities such as ad blockers, and other opt out tools. Other opt out tools may include organizations, such as the Network Advertising Initiative, whose members agree to provide a means for consumers to opt out of the members’ targeted advertising on websites.
The Sites employ Google Analytics, a web analysis service from Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google"). Google Analytics uses "cookies," which are text files placed on your computer, to help the website analyze how users use the Sites, compiling reports on the Sites’ activity for the Sites’ operators and providing other services relating to website activity and Internet usage. The information generated by the cookie (including the IP address) is transferred and stored on a Google server located in the United States.
Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other information held by Google.
We may also use additional analytics programs from time to time to process non-personal information about you.
We make no attempt to link this non-personal information with the identity of individuals using the Service. Non-personal information may be permanently archived for future use in any manner whatsoever by FarmLink.
Disable Google Analytics
You can prevent the collection and processing of cookie created data relating to your utilization of the Sites (including your IP) via Google by downloading and installing the browser-plugin available under the following link (https://tools.google.com/dlpage/gaoptout?hl=en).
Google currently offers this opt-out tool for Internet Explorer 11, Google Chrome, Mozilla Firefox, Apple Safari and Opera.
Legal Basis for Processing Your Personal Information
Below are the types of lawful basis that, depending on the circumstances, we may rely on to process your personal information:
|Legal Basis for Processing||Explanation of Legal Basis|
|Consent||You have given consent to us for the processing of your personal information for one or more specific purposes.|
|Legitimate Interest||Processing your personal information to enable us to provide and improve the Service to you, administer our relationship with you and our business, for marketing and in order to exercise our rights and responsibilities. Where we rely on legitimate interests as a lawful ground for processing your personal information, we balance those interests against your interests, fundamental rights and freedoms. You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at as provided under Section 18.|
|Performance of a Contract||Processing your personal information where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.|
|Comply with a legal or regulatory obligation||Processing your personal information where it is necessary for compliance with a legal or regulatory obligation that we are subject.
Change of Purpose
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent where this is required or permitted by law.
Your Personal Information Rights
Under certain circumstances and in accordance with EU/EEA applicable data protection laws, you have the following rights:
|Right||Explanation of Right|
|Right of Access||The right to make a written request for details of your personal information and a copy of that personal information.|
|Right to Rectification||The right to have inaccurate information about you corrected or removed.
|Right to Erasure
(‘Right to be Forgotten’)
|The right to have some or all of your personal information erased.
|Right to Restriction of Processing||The right to request that your personal information is only used for restricted purposes.
|Right to Automated Decisions||The right to contest any automated decision made where such a decision is based solely on automated processing, including profiling, which produces legal effect concerning you or similarly significantly affects you, unless you have expressly consented to it or it is necessary for entering into, or performance of, a contract for the provision of services to you or otherwise authorized by applicable law.|
|Right to Object||The right to object to processing of your personal information in cases where our processing is based on the performance of a task carried out in the public interest or we have let you know the processing is necessary for our or a third party’s legitimate interests.|
|Right to Data Portability||The right to ask for the personal information you have made available to us to be transferred to you or a third party in machine-readable format.|
|Right to Withdraw Consent||The right to withdraw any consent you have previously given us to handle your personal information. If you withdraw your consent, this will not affect the lawfulness of our use of your personal information prior to the withdrawal of your consent.|
To exercise any of these rights, please contact us as provided in Section 18. These rights are not absolute and they do not always apply in all cases.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request in order to help us respond efficiently to your request.
You will not have to pay a fee to access your personal information (or to exercise any of the above rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
If you have any complaints regarding our privacy practices as data controller, you have the right to make a complaint at any time to your local Supervisory Authority. We would, however, appreciate the chance to deal with your concerns before you approach your Supervisory Authority so please contact us as provided under Section 18.
FarmLink Privacy Officer
Mailing Address: 110-93 Lombard Ave., Winnipeg, Manitoba R3B 3B1
Telephone No.: 204-832-2133
You may withdraw your consent to the collection, use or disclosure of your personal information by FarmLink at any time, subject to legal or contractual restrictions and reasonable notice. In certain circumstances, your withdrawal of consent may result in the inability of FarmLink to continue providing aspects or optimization of the Service to you. Please contact FarmLink for more information regarding the implications of withdrawing consent.
If you no longer wish to receive commercial electronic messages from FarmLink regarding our new products or services, promotions or other similar communications, you may unsubscribe here [Insert link to unsubscribe mechanism]. Please note that, after you unsubscribe, FarmLink may still send electronic communications to you in certain limited circumstances, such as to provide you with Service notifications and billing information, or to provide information that FarmLink is legally obligated to provide you.
Date: November 20, 2020