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Bushel Privacy Notice

06/29/2022

Scope of this Notice

This Notice applies only to the practices, technologies, and services of Bushel Inc. and its subsidiaries. If you provide or submit personal information to those websites or online services, the privacy notices on those websites or online services apply to your personal information. We encourage you to carefully read the privacy notices of any website you visit.

Furthermore, in all situations where we are the processor, all of your Data Subject Rights requests must be directed to the organization in control of your personal data. 

Our Data Values

Your privacy is important to us. 

We have created this Privacy Notice to demonstrate our commitment to the individual’s right to data protection and privacy. 

This Privacy Notice outlines how we handle information that can be used to directly or indirectly identify an individual “Personal Data”.

Who We Are

Bushel Inc. (“Bushel”) is a software company headquartered at 503 7th St N, Fargo, ND 58102. 

Bushel operates through its subsidiaries, including Bushel Brokerage LLC, Bushel IS LLC, Bushel Farm Inc., and Bushel Exchange LLC in the USA. 

If you have a privacy question, you may contact the Data Privacy team at Bushel and our General Counsel at [email protected]

Full contact information of our privacy team, including of our representatives where this is legally required, is available via this page.

If you have concerns about how we handle your information, you have the right to make a complaint about us to the privacy regulator in your country, state, or province. 

Most privacy regulators can be contacted online using the resources provided at https://globalprivacyassembly.org/participation-in-the-assembly/members-online/ More information is included under “International Data Transfers”

Your Rights

You have rights under privacy and data protection laws related to the data we process about you. 

You do not have to pay a fee, and we will respond to your request within the specific timeframe required by the laws applicable to you. We will honor the requests you make related to your rights as the law allows, which means in some cases there may be legal or other official reasons that we may not be able to address the specific request you make related to your rights. You may:

    • request access to the Personal Data we hold about you;
    • block or suppress further use of your Personal Data;
    • object to certain types of processing;
    • request deletion or removal of your Personal Data;
    • lodge a complaint with the competent data protection supervisory authority about the way we handle or process your Personal Data;
    • withdraw consent at any time if our processing of your Personal Data is based specifically on your consent;
    • have inaccuracies related to your personal data corrected;
    • obtain the Personal Data that we hold about you so you can reuse it for your own purposes across different services.

You may exercise any of these rights by contacting us via email at [email protected]
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What personal information?

The data we process (collect, use, and share) about you depends on who you are and how we interact with you. Personal information is data that identifies you or that makes you identifiable. It includes data that could be used to identify, locate, track or contact you.

If you are an affiliated user,  customer, business partner, or express interest in our solutions:

Learning about our company and our solutions: As a Grain Purchasing Entity, if you request or indicate an interest in the Bushel Platform, we process your name, email address, phone number, job title, information about the company where you work, including its website address, and any comments you provide. We maintain and update this information as we continue to engage with you.

Using the Bushel Platform: If you are a Grower with an affiliated  Grain Purchasing Entity or Entities’  using the Bushel Platform, we process your name, email address, scale ticket information, prepaids & bookings, contracts information, cash bids, settlements information, delivery tickets, outbound tickets, work orders, phone number, information about the company where you work, actions you have taken in the applications on the platform, signature, and usage/user activity analysis.

Using Farmlogs: If you are a Grower using the Farmlogs Platform, we process your name, email address, postal code, phone number, actions you have taken in the applications on the platform, signature, geolocation information, usage/user activity analysis, and if you choose to upgrade to a paid subscription/plan, your credit card information. 

Using Bushel Wallet: If you are a Grower using Bushel Wallet, we process your name, email address, postal address, and phone number. If applicable, we may also process date of birth, SSN, passport information, drivers license information, ID card information, US Visa information, Federal Employment Authorization Card information, EIN, public records information (such as, FBN, Certificate of Assumed Name, Business License, Sales/Use Tax License, Registration of Trade Name), controller information and any beneficial owner information (such as, job title, date of birth, SSN). 

Negotiating and entering into a contract with us and relationship management during the contract term: If you are a Grain Purchasing Entity entering into an agreement with us related to the licensing or purchase of our solutions, we process your name, email address, postal address, company name, billing information (e.g., purchase order number, bank wire information, credit card number), company size, company financial information, signature, and if applicable EIN, public records information (such as, FBN, Certificate of Assumed Name, Business License, Sales/Use Tax License, Registration of Trade Name), controller information and any beneficial owner information (such as, job title, date of birth, SSN).

Receiving marketing, sales-related and business development communications from us: If our marketing team or a member of our sales or business development teams sends communications to you, we process your name, phone number, email address, postal address, job title, job function, company name, company size, company financial information, device type, email view information including IP address and associated city, and information about which of our solutions you use or which may be of interest to you.

Market research and surveys: If you participate in our market research and surveys, we process your email address, job title, phone number, survey responses, company name, job function, state, country, and any comments you provide.

Participation on a recorded telephone call or video conference with Bushel: If you have consented to a recorded telephone call or video conference with Bushel, we may process your name, email address, job title and voice for analytical purposes to improve our training and customer relationship management. For any such telephone calls or video conferences, notice of the recording will be provided in advance and during the meeting. You may decline recording at any time before or during the meeting, and you may request deletion of the recording at any time. All such recorded meetings will be automatically deleted within 180 days.

If you visit the websites and online properties we provide:

Our website: We process personal information about you that we collect either directly, through forms or data entry fields on our website, or through passive collection by cookies and other data collection technologies. The types of personal data we process in each of these contexts is further explained below:

    • Contact us and Request a demo: we process your name, email address, phone number, description of your current job role, business/company name, business/operation, what Bushel product/service you’d like to learn more about, what topics would be most helpful to include in your demo and any comments you provide.
    • Contact us and Let’s chat: we process your name, email address, phone number, description of your current job role, business/company name, if you are a current Bushel customer, business/operation, what Bushel product/service you are interested in, and any questions/feedback you provide.
    • Contact us and signup for Newsletter: we process your name and email address. 
    • Consumer opinion surveys: we process your survey responses to questions like how satisfied are you with our support team, how satisfied are you with your Customer Success Manager, how likely are you to recommend Bushel to a friend or colleague, etc. Additionally, after our closing support tickets, we request feedback from you to understand your experience with our support team. 
    • Cookies and other data collection technologies: we use browser session cookies, which are temporary cookies that are erased from your device’s memory when you close your Internet browser or turn your computer off, and persistent cookies, which are stored on your device until they expire, unless you delete them before that time. We group browser cookies on our site into four categories:
        • Required cookies: These cookies are necessary to enable the basic features of this site to function, such as allowing images to load or allowing you to select your cookie preferences.
        • Performance cookies: These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site.    All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site, and will not be able to monitor its performance.
        • Functional cookies: These cookies allow us to analyze your use of the site to evaluate and improve our performance. They may also be used to provide a better customer experience on this site. For example, remembering your log-in details or providing us information about how our site is used.
        • Advertising cookies: These cookies may be used to share data with advertisers so that the ads you see are more relevant to you, allow you to share certain pages with social networks, or allow you to post comments on our site.
        • Videos and other features on our site use Flash cookies to collect and store your preferences, such as volume. Flash cookies are different from browser cookies because of the amount of, type of, and way that data is stored. Cookie management tools provided by your browser will not remove Flash cookies. To learn how to manage privacy and storage settings for Flash cookies click here.
          Some cookies may be placed by third party service providers who perform some of these functions for us.
        • Server log files: We automatically gather server log file information when you visit our websites. This includes IP address, browser type, referring and exit web pages, and your operating system.

Cookie Preference: Some of these uses may involve the use of “third party cookies”; those are cookies that are set by software used by third parties, such as to carry out statistical analysis of page use, page interactions and paths through the site, or for the purposes of serving internet advertisements using an online advertising supplier. Third party cookies may collect information about your online activities over time and across different websites following your visit to our Sites.  

Generally, the information collected using these Web technologies does not identify you by name. If, however, you have created a user identity, for example, by signing up to use a password-protected area on one of our Sites, we may link the information we collect using Web technologies to other information that identifies you personally.

If you do not wish to receive cookies, you may set your browser to reject cookies or to alert you when a cookie is placed on your computer. You may also delete our cookies as soon as you leave a Site. For more information on how to do so, please refer to your browser ‘help’ section or see http://www.allaboutcookies.org or http://www.aboutcookies.org. Although you are not required to accept our cookies when you visit our Sites, if you set your browser to reject cookies, you will not be able to use all of the features and functionality of our Sites.

Except as otherwise disclosed in this notice, we do not currently respond to web browser “do not track” signals or other mechanisms that indicate your preference for not having information collected over time and across different Web sites or digital apps following your visit to our websites. If we do so in the future, we will describe how we do so in this Privacy Notice. Visit www.allaboutdnt.org to learn more.

If you are an employee, contractor, job applicant, or former employee:

Applying to work at Bushel: If you apply to work at Bushel, we process personal information about you and your professional experience, education and training such as your application, your name (and any former names), postal address, email address, phone number, universities attended, academic degrees obtained, grades, professional certifications and licenses, employment history, and curriculum vitae or resume.

Offer of employment or contractor position: Prior to making an offer of employment or a contractor position, we may process personal information to conduct professional reference checks in accordance with applicable laws. If we extend an offer of employment or a contractor position at Bushel to you, we will process personal information about the position to which you have been appointed, your job title at Bushel, the compensation or project-based contractor rate we offer to you, whether you accept the offer, your signature, and your starting compensation or project-based contractor rate, and your start date at Bushel.

Employment-Related Background checks: Prior to commencement of your employment with us, we may engage service providers to conduct background checks that involve the necessary personal information processing as permitted by the laws in the location in which you reside and/or work. More details are provided to you in the context of our request to you to complete these checks.

As an employee or contractor of Bushel: we may process personal information about your benefits, nationality, residency status, disability status, email address, office or other workplace location, work phone number, mobile phone number, photographs, passport, visas, marital status, beneficiaries, emergency contact details, financial account information, social security number or other government-issued identification number, holiday and paid time off days, salary, incentive compensation, Bushel stock options granted, Bushel stock ownership, assigned projects, performance against your assigned goals, training completed, any performance improvement plans, any disciplinary actions taken, system accounts, technology and physical assets provided to you, your role and actions taken in connection with Bushel projects and processes.

If your employment with Bushel ends, we process personal information necessary to offboard you from Bushel, including deactivation of your access to our systems, fulfilling our financial, benefits, and related obligations with respect to the end of your employment with Bushel.

In certain countries, supplemental privacy notices will be provided to Bushel employees and contractors, and where applicable, consent will be obtained, to ensure compliance with local requirements.

What personal information?

The data we process (collect, use, and share) about you depends on who you are and how we interact with you. Personal information is data that identifies you or that makes you identifiable. It includes data that could be used to identify, locate, track or contact you.

If you are an affiliated user,  customer, business partner, or express interest in our solutions:

Learning about our company and our solutions: As a Grain Purchasing Entity, if you request or indicate an interest in the Bushel Platform, we process your name, email address, phone number, job title, information about the company where you work, including its website address, and any comments you provide. We maintain and update this information as we continue to engage with you.

Using the Bushel Platform: If you are a Grower with an affiliated  Grain Purchasing Entity or Entities’  using the Bushel Platform, we process your name, email address, scale ticket information, prepaids & bookings, contracts information, cash bids, settlements information, delivery tickets, outbound tickets, work orders, phone number, information about the company where you work, actions you have taken in the applications on the platform, signature, and usage/user activity analysis.

Using Farmlogs: If you are a Grower using the Farmlogs Platform, we process your name, email address, postal code, phone number, actions you have taken in the applications on the platform, signature, geolocation information, usage/user activity analysis, and if you choose to upgrade to a paid subscription/plan, your credit card information. 

Using Bushel Wallet: If you are a Grower using Bushel Wallet, we process your name, email address, postal address, and phone number. If applicable, we may also process date of birth, SSN, passport information, drivers license information, ID card information, US Visa information, Federal Employment Authorization Card information, EIN, public records information (such as, FBN, Certificate of Assumed Name, Business License, Sales/Use Tax License, Registration of Trade Name), controller information and any beneficial owner information (such as, job title, date of birth, SSN). 

Negotiating and entering into a contract with us and relationship management during the contract term: If you are a Grain Purchasing Entity entering into an agreement with us related to the licensing or purchase of our solutions, we process your name, email address, postal address, company name, billing information (e.g., purchase order number, bank wire information, credit card number), company size, company financial information, signature, and if applicable EIN, public records information (such as, FBN, Certificate of Assumed Name, Business License, Sales/Use Tax License, Registration of Trade Name), controller information and any beneficial owner information (such as, job title, date of birth, SSN).

Receiving marketing, sales-related and business development communications from us: If our marketing team or a member of our sales or business development teams sends communications to you, we process your name, phone number, email address, postal address, job title, job function, company name, company size, company financial information, device type, email view information including IP address and associated city, and information about which of our solutions you use or which may be of interest to you.

Market research and surveys: If you participate in our market research and surveys, we process your email address, job title, phone number, survey responses, company name, job function, state, country, and any comments you provide.

Participation on a recorded telephone call or video conference with Bushel: If you have consented to a recorded telephone call or video conference with Bushel, we may process your name, email address, job title and voice for analytical purposes to improve our training and customer relationship management. For any such telephone calls or video conferences, notice of the recording will be provided in advance and during the meeting. You may decline recording at any time before or during the meeting, and you may request deletion of the recording at any time. All such recorded meetings will be automatically deleted within 180 days.

If you visit the websites and online properties we provide:

Our website: We process personal information about you that we collect either directly, through forms or data entry fields on our website, or through passive collection by cookies and other data collection technologies. The types of personal data we process in each of these contexts is further explained below:

    • Contact us and Request a demo: we process your name, email address, phone number, description of your current job role, business/company name, business/operation, what Bushel product/service you’d like to learn more about, what topics would be most helpful to include in your demo and any comments you provide.
    • Contact us and Let’s chat: we process your name, email address, phone number, description of your current job role, business/company name, if you are a current Bushel customer, business/operation, what Bushel product/service you are interested in, and any questions/feedback you provide.
    • Contact us and signup for Newsletter: we process your name and email address. 
    • Consumer opinion surveys: we process your survey responses to questions like how satisfied are you with our support team, how satisfied are you with your Customer Success Manager, how likely are you to recommend Bushel to a friend or colleague, etc. Additionally, after our closing support tickets, we request feedback from you to understand your experience with our support team. 
    • Cookies and other data collection technologies: we use browser session cookies, which are temporary cookies that are erased from your device’s memory when you close your Internet browser or turn your computer off, and persistent cookies, which are stored on your device until they expire, unless you delete them before that time. We group browser cookies on our site into four categories:
        • Required cookies: These cookies are necessary to enable the basic features of this site to function, such as allowing images to load or allowing you to select your cookie preferences.
        • Performance cookies: These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site.    All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site, and will not be able to monitor its performance.
        • Functional cookies: These cookies allow us to analyze your use of the site to evaluate and improve our performance. They may also be used to provide a better customer experience on this site. For example, remembering your log-in details or providing us information about how our site is used.
        • Advertising cookies: These cookies may be used to share data with advertisers so that the ads you see are more relevant to you, allow you to share certain pages with social networks, or allow you to post comments on our site.
        • Videos and other features on our site use Flash cookies to collect and store your preferences, such as volume. Flash cookies are different from browser cookies because of the amount of, type of, and way that data is stored. Cookie management tools provided by your browser will not remove Flash cookies. To learn how to manage privacy and storage settings for Flash cookies click here.
          Some cookies may be placed by third party service providers who perform some of these functions for us.
        • Server log files: We automatically gather server log file information when you visit our websites. This includes IP address, browser type, referring and exit web pages, and your operating system.

Cookie Preference: Some of these uses may involve the use of “third party cookies”; those are cookies that are set by software used by third parties, such as to carry out statistical analysis of page use, page interactions and paths through the site, or for the purposes of serving internet advertisements using an online advertising supplier. Third party cookies may collect information about your online activities over time and across different websites following your visit to our Sites.  

Generally, the information collected using these Web technologies does not identify you by name. If, however, you have created a user identity, for example, by signing up to use a password-protected area on one of our Sites, we may link the information we collect using Web technologies to other information that identifies you personally.

If you do not wish to receive cookies, you may set your browser to reject cookies or to alert you when a cookie is placed on your computer. You may also delete our cookies as soon as you leave a Site. For more information on how to do so, please refer to your browser ‘help’ section or see http://www.allaboutcookies.org or http://www.aboutcookies.org. Although you are not required to accept our cookies when you visit our Sites, if you set your browser to reject cookies, you will not be able to use all of the features and functionality of our Sites.

Except as otherwise disclosed in this notice, we do not currently respond to web browser “do not track” signals or other mechanisms that indicate your preference for not having information collected over time and across different Web sites or digital apps following your visit to our websites. If we do so in the future, we will describe how we do so in this Privacy Notice. Visit www.allaboutdnt.org to learn more.

If you are an employee, contractor, job applicant, or former employee:

Applying to work at Bushel: If you apply to work at Bushel, we process personal information about you and your professional experience, education and training such as your application, your name (and any former names), postal address, email address, phone number, universities attended, academic degrees obtained, grades, professional certifications and licenses, employment history, and curriculum vitae or resume.

Offer of employment or contractor position: Prior to making an offer of employment or a contractor position, we may process personal information to conduct professional reference checks in accordance with applicable laws. If we extend an offer of employment or a contractor position at Bushel to you, we will process personal information about the position to which you have been appointed, your job title at Bushel, the compensation or project-based contractor rate we offer to you, whether you accept the offer, your signature, and your starting compensation or project-based contractor rate, and your start date at Bushel.

Employment-Related Background checks: Prior to commencement of your employment with us, we may engage service providers to conduct background checks that involve the necessary personal information processing as permitted by the laws in the location in which you reside and/or work. More details are provided to you in the context of our request to you to complete these checks.

As an employee or contractor of Bushel: we may process personal information about your benefits, nationality, residency status, disability status, email address, office or other workplace location, work phone number, mobile phone number, photographs, passport, visas, marital status, beneficiaries, emergency contact details, financial account information, social security number or other government-issued identification number, holiday and paid time off days, salary, incentive compensation, Bushel stock options granted, Bushel stock ownership, assigned projects, performance against your assigned goals, training completed, any performance improvement plans, any disciplinary actions taken, system accounts, technology and physical assets provided to you, your role and actions taken in connection with Bushel projects and processes.

If your employment with Bushel ends, we process personal information necessary to offboard you from Bushel, including deactivation of your access to our systems, fulfilling our financial, benefits, and related obligations with respect to the end of your employment with Bushel.

In certain countries, supplemental privacy notices will be provided to Bushel employees and contractors, and where applicable, consent will be obtained, to ensure compliance with local requirements.

Why do we process personal information?

The reasons that we process about you depend on who you are and how we interact with you.

If you are a customer, business partner, or express interest in our solutions:

If you have a formal contract or other type of agreement in place with us, we process personal information about you in order to fulfill the following obligations to you under that contract or agreement to:

    • Provision your account on our platform;
    • Authenticate you to enable you to access your account on our platform, including additional users of the solution;
    • Provide customer service and support, and investigate issues that you raise;
    • Deliver our saas solutions to you, 
    • Communicate with you, including via email, about your use of our solutions, obtain your input on new features, functionality, and content, and to provide information about updates to our solutions;
    • Communicate with you about Bushel events, agriculture industry or related news; and
    • Deprovision your account on our platform.

We process personal information about you to send direct email marketing communications about our solutions. You may withdraw your consent at any time by clicking the “unsubscribe” link in the email communications we send to you. You may also withdraw consent by exercising Your Rights as described above.

If you have consented to our recording a telephone call or video conference, we process this information for analytical purposes to improve our training and customer relationship management. For any such telephone calls or video conferences, notice of the recording will be provided in advance and during the meeting. You may decline recording at any time before or during the meeting, and you may request deletion of the recording at any time. All such recorded meetings will be automatically deleted within 180 days.

We process personal information about you based on business purposes as follows, to which you may exercise Your Rights to object as described above:

    • To renew subscription-based solutions you have licensed;
    • To provide additional solutions you request 
    • To retain you as a customer or partner;
    • To better understand the needs of the agriculture and business communities we aim to serve, we analyze our interactions with you online and offline and store that information in a quantitative way. This helps us continue to improve how we provide information and engage specifically with you, including to help us determine when you might be ready to make a purchase based on repeated interactions with Bushel. We do not make any automated decisions about you that would result in legal or other similarly significant effects on you;
    • To determine whether, when, and the IP address and associated city of, a marketing, sales, or business development email communication we sent was viewed and to effectively manage and improve upon such communications with you;
    • To understand the business that you work for and to tailor our communications with you to improve our engagement with you;
    • To understand your business requirements 
    • To develop and enhance our solutions to address your needs and to make them more relevant to you; and
    • To manage our legal, financial, policy and regulatory compliance responsibilities and to demonstrate our compliance upon request.

Statistical and research purposes: We may further analyze use of our solutions, and characteristics of the companies that use our solutions (e.g., by size and industry sector) to help us understand and make decisions about customer and market needs, to improve our solutions, to design new solutions, and to inform partnership and business development decisions.

If you visit the websites and Apps we provide:

We process personal information about you to:

    • Deliver the resources and information you have requested online.
    • Send direct email marketing communications about our solutions, events and related resources that may be of interest to you.
    • Use cookies and other data collection technologies to help you navigate our website or technical solutions, personalize and provide a more convenient experience to you, analyze which pages you visit, which features you use in our technical solutions, and which consumer privacy tools you use, provide features such as social sharing widgets and videos, measure advertising and promotional effectiveness, assess which areas of our site you visit to remarket to you after you visit our site, and to provide content to you from our third party content partners.

You may withdraw your consent at any time by clicking the “unsubscribe” link in the email communications we send to you. You may also withdraw consent by exercising Your Rights as described above. 

We process personal information about you based on business purposes as follows, to which you may exercise Your Rights to object as described above:

    • To evaluate the characteristics and needs of our customers;
    • To communicate with you about Bushel events, agriculture industry or related news;
    • To conduct online consumer surveys to learn about your business requirements; we do not directly collect any personal information about you when we conduct these surveys, however cookies and data collection technologies may be used to manage the delivery of the surveys; and
    • To administer our website and our technical solutions and to understand how our website visitors navigate through our websites and technical solutions.

Statistical and research purposes: We may further analyze information we gather online to improve the online experience, resources and tools we provide to our users.

If you are an employee, contractor, job applicant, or former employee:

If you have a formal contract or other type of agreement with us, we process personal information about you to fulfill the specific obligations we have to you under the applicable contract or agreement such as:

    • Payment of project fees to contractors;
    • Managing performance obligations under employment contracts, where applicable;
    • Management of Bushel stock options pursuant to stock option agreements; and
    • Management of stock ownership pursuant to stock purchase and related agreements.

We process personal information about you to establish and manage our relationship with and responsibilities to you and for effective operation of our business, such as to:

    • Recruit new talent to join Bushel;
    • Onboard employees and contractors to Bushel;
    • Grant and ensure appropriate access to Bushel systems and facilities;
    • Ensure the security and safety of the workplace and the tangible and intangible assets for which we are responsible;
    • Assign roles and responsibilities;
    • Manage team and cross-functional communications and collaboration;
    • Promote a positive workplace culture;
    • Administer payroll;
    • Benefits administration;
    • Award and pay incentive compensation;
    • Invoice payments;
    • Managing Bushel projects and processes;
    • Maintaining corporate, financial and other essential business records and reporting;
    • Evaluating financial and operational ;performance; and
    • Managing compliance, including, but not limited to our privacy, security, accounting, labor and employment, and other legal and regulatory obligations.

Statistical and research purposes: We may further analyze information to evaluate and understand employee engagement and to develop plans to continuously improve our workplace culture.

International Data Transfers

We may transfer, access, or store personal information about you outside of your country of residence that requires legal protections for international data transfer. When we do, we will ensure that an adequate level of protection is provided for the information by using one or more of the following approaches:

    • We may transfer personal information to countries that have privacy laws that have been recognized by the country from which the data are transferred as providing similar protections for the data (“adequacy”).
    • We may enter into written agreements, such as standard contractual clauses and other data transfer agreements, with recipients that require them to provide the same level of protection for the data.
    • We may seek your consent for transfers of your personal information for specific purposes.
    • We may rely on other transfer mechanisms approved by authorities in the country from which the data are transferred.

How do we share data about you?

At Bushel, we only share personal information in ways that we tell you about. We do not sell personal information to third parties and we do not share personal information with third parties that are not owned by us or under our control or direction except as described in this Notice.

Service providers. We share personal information with service providers that help us with our business activities. Service providers support us in processing the types of personal information described above in the section “What personal information” and for the purposes described in the section “Why do we process personal information.” They only are authorized to process that information as necessary and as directed by us.

Third party cookies and similar technologies. While Bushel does not sell personal information to third parties, Bushel does share data related to cookies and similar technologies with third parties to evaluate and optimize the performance of and analyze your use of our online services and for advertising purposes. You may choose to opt out of our use of these technologies or reject non-essential technologies by setting your browser to reject cookies or to alert you when a cookie is placed on your computer. You may also delete our cookies as soon as you leave a Site. For more information on how to do so, please refer to your browser ‘help’ section or see http://www.allaboutcookies.org or http://www.aboutcookies.org. Although you are not required to accept our cookies when you visit our Sites, if you set your browser to reject cookies, you will not be able to use all of the features and functionality of our Sites.

Required by law. If we are required to disclose personal information as part of a legal process, we will take commercially reasonable steps to inform you as part of that process. We may also be required to disclose personal information in response to lawful requests by government authorities, including requests from national security agencies or law enforcement.

Safety, system security and integrity, fraud prevention, government requests and protection of our rights are all reasons where we may share personal information where we believe in good faith it is necessary.

Mergers, acquisitions, divestitures, or asset sales but only if the acquiring organization agrees to this Notice’s protections.

Keeping and Securing Your Data

We will keep personal information about you for as long as we provide solutions to you, as long as you work for or with us, or request you have made to us, as applicable to our interactions with you. If we have a contract or other agreement with you, we will follow the retention obligations of that agreement. We may keep data longer if we have a legal obligation to keep it or to maintain necessary records for legal, financial, compliance, or other reporting obligations, and to enforce our rights and agreements. 

We take appropriate security measures to protect personal information against loss, misuse, and unauthorized access, alteration, disclosure or destruction. We also have implemented measures to maintain the ongoing confidentiality, integrity and availability of the systems and services that process personal information, and will restore the availability and access to data in a timely manner in the event of a physical or technical incident.

Personal Information of Minors

We do not sell the personal information of any Consumers. We would require authorization from the parent or guardian of a Consumer who is less than 13 years of age. 

If You have reason to believe that a child under the age of 13 (or 16) has provided Us with personal information, please contact Us with sufficient detail to enable Us to delete that information.

CCPA Privacy

This privacy notice section for California residents supplements the information contained in Our Privacy Policy and it applies solely to all visitors, users, and others who reside in the State of California.

Categories of Personal Information Collected and/ or Disclosed for Business or Commercial Purposes 

We collect, use or disclose information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or Device. The following is a list of categories of personal information which we may collect or may have disclosed from California residents within the last twelve (12) months.  

Please note that the categories provided in the list below are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact collected by Us, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been collected.

When We disclose personal information for a business purpose or a commercial 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.

For details about types of information collected or disclosed, please see the “What personal information?” section above.

Category A: Identifiers, such as your name, email address, etc

Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), such as signature, telephone number, etc

Category D: Commercial information, such as records, history of services purchased, etc

Category F: Internet or other similar network activity, such as interaction with our service, etc

Category G: Geolocation data, such as approximate physical location

Sources of Personal Information

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

    • Directly from You. For example, from the forms You complete on our Service, preferences You express or provide through our Service, or from Your purchases on our Service.
    • Indirectly from You. For example, from observing Your activity on our Service.
    • Automatically from You. For example, through cookies We or our Service Providers set on Your Device as You navigate through our Service.
    • From Service Providers. For example, third-party vendors to monitor and analyze the use of our Service, third-party vendors to deliver targeted advertising to You, third-party vendors for payment processing, or other third-party vendors that We use to provide the Service to You.

Use of Personal Information for Business Purposes or Commercial Purposes

We may use or disclose personal information We collect for “business purposes” or “commercial purposes” (as defined under the CCPA), which may include the following examples:

    • To operate our Service and provide You with our Service.
    • To provide You with support and to respond to Your inquiries, including to investigate and address Your concerns and monitor and improve our Service.
    • To fulfill or meet the reason You provided the information. For example, if You share Your contact information to ask a question about our Service, We will use that personal information to respond to Your inquiry. If You provide Your personal information to purchase a product or service, We will use that information to process Your payment and facilitate delivery.
    • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
    • As described to You when collecting Your personal information or as otherwise set forth in the CCPA.
    • For internal administrative and auditing purposes.
    • To detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity, including, when necessary, to prosecute those responsible for such activities.

Please note that the examples provided above are illustrative and not intended to be exhaustive. For more details on how we use this information, please refer to the “Use of Your Personal Data” section.

If We decide to collect additional categories of personal information or use the personal information We collected for materially different, unrelated, or incompatible purposes We will update this Privacy Policy.

Sale of Personal Information

As defined in the CCPA, “sell” and “sale” mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to a third party for valuable consideration. This includes benefits received in return for sharing personal information, but not necessarily a monetary benefit.

We do not sell the personal information of any Consumers, and we do not share personal information with third parties that are not owned by us or under our control or direction except as described in this Notice.

Share of Personal Information

We may share Your personal information identified in the above categories with the following categories of third parties:

    • Service Providers
    • Payment processors
    • Our affiliates
    • Our business partners
    • Third party vendors to whom You or Your agents authorize Us to disclose Your personal information in connection with products or services We provide to You

Your Rights under the CCPA

The CCPA provides California residents with specific rights regarding their personal information. If You are a resident of California, You have the following rights:

    • The right to notice. You have the right to be notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.
    • The right to request. Under CCPA, You have the right to request that We disclose information to You about Our collection, use, sale, disclosure for business purposes and share of personal information. 
    • The right to say no to the sale of Personal Data (opt-out). We do not sell the personal information of any Consumers, and we do not share personal information with third parties that are not owned by us or under our control or direction except as described in this Notice.
    • The right to delete Personal Data. You have the right to request the deletion of Your Personal Data, subject to certain exceptions. Once We receive and confirm Your 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 comply with legal obligations.
    • The right not to be discriminated against. You will not receive discriminatory treatment from us for exercising your rights. 

Exercising Your CCPA Data Protection Rights

In order to exercise any of Your rights under the CCPA, and if You are a California resident, You can contact Us:

Only You, or a person registered with the California Secretary of State that You authorize to act on Your behalf, may make a verifiable request related to Your personal information. We cannot respond to your request if we cannot verify your identity.

We will disclose and deliver the required information free of charge within 45 days of receiving Your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice.

Any disclosures We provide will only cover the 12-month period preceding the verifiable request’s receipt.

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.

“Do Not Track” Policy as Required by California Online Privacy Protection Act (CalOPPA)

Some third party websites do keep track of Your browsing activities. If You are visiting such websites, You can set Your preferences in Your web browser to inform websites that You do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of Your web browser.  For additional information please see cookie preferences in the “Cookie Preference?” section above.

Your Canada Privacy Rights (Personal Information Protection and Electronic Documents Act, aka “PIPEDA” & Personal Information Protection Act, aka “PIPA”)

PIPEDA

Generally speaking, individuals have a right to access the personal information that an organization holds about them. They also have the right to challenge the accuracy and completeness of the information, and have that information amended as appropriate.

In order to exercise any of Your rights under the PIPEDA, and if You are a Canada resident, You can contact Us:

Your request to Us 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 the required information if We cannot:

    • Verify Your identity or authority to make the request
    • And confirm that the personal information relates to You

We will disclose and deliver the required information free of charge within 30 days of receiving Your verifiable request. The time period to provide the required information may be extended once by an additional 30 days when reasonably necessary and with prior notice.

Any disclosures We provide will only cover the 12-month period preceding the verifiable request’s receipt.

PIPA

An individual has the right to ask for access to his or her own personal information contained in a record that is in the custody or under the control of an organization.

In order to exercise any of Your rights under the PIPA, and if You are an Alberta resident, You can contact Us:

Your request to Us 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 the required information if We cannot:

    • Verify Your identity or authority to make the request
    • And confirm that the personal information relates to You

We will disclose and deliver the required information free of charge within 45 days of receiving Your verifiable request. The time period to provide the required information may be extended once by an additional 30 days when reasonably necessary and with prior notice.

Any disclosures We provide will only cover the 12-month period preceding the verifiable request’s receipt.

Changes to this Notice

We may make changes to this Notice from time to time based on changes to applicable laws and regulations or other requirements applicable to us, changes in technology, or changes to our business. Any changes we make to the Notice in the future will be posted on this page, and where we change this Notice in ways that also affect how we process personal information about you, where appropriate, we will notify you directly via email or other direct contact with you, and we also will post a notice on our homepage that this Notice has changed.