SOIL AND WATER OUTCOMES FUND DATA PRIVACY POLICY
The Soil and Water Outcomes Fund and its managing organizations ReHarvest Partners and AgOutcomes (collectively, the “Soil and Water Outcomes Fund”, “we”, “us”, “our”) are committed to safeguarding your personal and on-farm information. We understand that you care about how your data is used and shared, and that you expect us to protect your data and take your privacy seriously. This Privacy Policy (“Policy”) describes the data that we collect, what we do with it, who we share it with, how it is stored and the rights available to you. The Policy covers our treatment of the data you provide to us as part of your enrollment in or prospective enrollment in the Soil and Water Outcomes Fund, and the resulting transfer of data to us. It does not cover the practices of companies and or people that we do not own, control or manage.
By providing data to or participating in the Soil and Water Outcomes Fund, and in any other interactions you may have with us in any manner, you acknowledge that you accept the practices and policies outlined in this Policy, and you hereby consent, to the fullest extent permitted in your jurisdiction, that we will collect, use, and share your Data in the following ways.
WHAT WE COLLECT
We gather and analyze various types of data from our users or prospective users, including Personal Data, and on-farm Agricultural, Environmental and Financial Data (“Data”). We collect this Data in order to establish eligibility of prospective participants, manage our relationship with our users, conduct analysis in order to provide payment estimates and quantify environmental outcomes, contract with participating farmers, and provide payments per the terms of our contracts.
Depending on the nature of the relationship you have with us, where you are located, and the products and services you utilize, we may collect and otherwise process the following Data and information:
- Personal Data: authentication details, including user ID, password and memorable information used to access our services; Communication records, including records of any communications between you and us via email, our website, telephone, social media and letter; Contact details, including your name, title, home address, company name, company address, phone number, email address, and mobile number; Device and electronic information when you access our services, including IP address, cookies, activity logs related to interactions with our systems, online identifiers, device type, operating system, browser, unique device identifiers, and geo-location data; Identification information used to verify your identity, including social security number and/or Employer Identification Number, date of birth, place of birth, passport, driver’s license, and proof of address; and Service usage, including when you are operating and accessing our services, the transactions you undertake, information you select, logs of when you access the services and for how long, and any information that you choose to download.
- Agricultural Data: farm names, field names, field acreages, digitized field boundaries or maps, and crop and field information such as planting date, crop rotations, fertilization rates, seeding type and rates, row spacing, yield goal, tillage type, residue management, manure applications and other field level operational data necessary to compute environmental outcomes.
- Environmental Data: locations of soil and water sampling, results of soil sampling, results of water sampling
- Financial Data: credit/debit card details, bank information and or payment information that may be used to determine credit worthiness.
HOW YOUR DATA IS COLLECTED
In addition to any personal information that you provide to us directly, we may also collect and derive data about you through the following means:
- Cookies and similar technologies: when you visit our website or use any of our mobile applications, we may employ cookies and similar technologies.
- Monitoring of platforms and services: if you use any of our platforms then we may collect data on your usage of these platforms
- Third party sources: other organizations may provide us with access to certain data that they have collected from you on our behalf, and or if you are a customer of a third party and we have a relationship with that third party, we may receive information from them. See ‘Use of Data by Third Parties’ section
- Outcomes Customers: as needed to facilitate our operations business, services and products.
HOW WE USE YOUR DATA
Depending on the nature of the relationship that we have with you, where you are located, the purposes for which we may use your data are as follows:
- Processing enrollment applications for the Soil and Water Outcomes Fund
- Provide standard and or personalized services to you and perform on our contracts with you and outcomes customers
- Verifying your identity
- Performing Know Your Customer (KYC), Anti-Money Laundering (AML) reviews, and assessing your creditworthiness
- Provide information about our services and activities, including marketing information, to you and otherwise advertising our products and services
- Operate, personalize, maintain and improve our products, services, apps and website
- Run models that allow us to quantify the environmental outcomes resulting from the implementation of certain on-farm practices you implement as part of your participation in the Soil and Water Outcomes Fund
- Estimate payments based on these environmental outcomes
- Communicate and assist you in relation to any services that we provide to you
- Administration of our business
- Compliance with laws that are applicable to us and any other related lawful and legitimate interests
- Defending ourselves and bringing claims in relation to legal proceedings
- Safeguarding our environments
- Security and protecting our systems
To provide our services, some personal information is necessary so we can provide you with the required access to our platforms, services, information and products. We also require personal information to authenticate you so that we know it is you and not someone else. Should you choose not to provide the necessary personal information, we may be unable to facilitate your services and access.
We are committed to only using your personal data to the extent relevant, necessary and permitted by applicable local law. We may combine the various types of data we collect and use it as described in this Policy. We may also anonymize and aggregate any data collected and use and transfer any such anonymized data without notice, consent or limitation, so long as such data does not and cannot be used to identify you. We will not use your Data to engage in a conflict of interest or illegal activity.
OWNERSHIP OF DATA AND YOUR RIGHTS
We believe that you are the owner of the Data that originates from your farm, device, or equipment. We believe that ownership should give you the right to share, download, and delete your Data. You shall not provide data to the Soil and Water Outcomes Fund unless you are the owner or authorized to do so by the owner. You shall indemnify the Soil and Water Outcomes Fund from any claims that someone else owns the Data uploaded to your account. We will provide a copy of your Data to you upon request, or when your contract ends.
Subject to local law, you may have certain rights regarding your personal information.
For example, if you are based in the European Union and certain other countries, you may have the following rights:
- Access: request a copy of your data and information relating to how it is processed
- Rectify: request any inaccuracies in the data we hold about you be corrected
- Erasure: request that we erase your data from our records
- Restrict: request that your data is no longer processed by us
- Object: object to certain ways that we process your data
- Transfer: request that your data be shared with a third party
- Withdraw your consent: where we are relying on your consent to process your data, then you can withdraw your consent at any time
- Lodge a complaint: you may be entitled to lodge a complaint with your local data protection authority.
If you reside in California, you may have certain rights with respect to your personal information, including the right to access the personal information we hold about you and the right to opt out of the sharing of your personal information in certain circumstances.
To exercise any of your rights, please contact us on the details set out in the 'Contact Us' section of this Policy below.
Please note that some of your rights are not absolute and there may be certain circumstances where we are unable to fulfil a request that you have made. In some circumstances we may also require that you provide additional personal information to confirm your identity.
YOUR RESPONSIBILITIES
You shall not allow any unauthorized person to access your login information, password, account or Data. You are responsible for any loss of data or other damage that occurs to the Soil and Water Outcomes Fund as a result of any unauthorized access with your account. If your account with the Soil and Water Outcomes Fund terminates, you have the responsibility to delete your Data, or the Soil and Water Outcomes Fund will assume you have abandoned all ownership claims. Once abandoned, the Soil and Water Outcomes Fund may delete your Data or anonymize and aggregate your Data according to this Agreement.
USE OF DATA BY THIRD PARTIES
We grant some third-parties access to your Data to help us provide certain aspects of our services to you. These may include our third-party monitoring and verification partners that use your Data to run models that calculate the volume of environmental outcomes (for example, carbon sequestration and water quality improvements) that result from your participation in the Soil and Water Outcomes Fund. This may also include our third-party IT, data processing, payment processing or other technology providers that we use to help us provide our services to you. For third-party partners and technology providers, the terms their own specific privacy policy will apply to their protection of your Data, but we will only engage with such service providers if their terms of protection for your Farm Data are materially consistent with the terms and protections of this policy.
We do not reveal personally identifiable Data to parties outside our third-party monitoring and verification partners 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.
DATA SECURITY
We use technical, administrative, and physical security safeguards and other reasonable security measures to protect your Data against loss, misuse, interference, unauthorized access, modification or disclosure. We seek to provide a secure online environmental for your Data, but please be aware that, despite our ongoing efforts, no security measures are perfect or impenetrable. Moreover, we are not responsible for the security of information that you transmit to us over networks that we do not control, including internet and wireless networks. We therefore cannot warrant the security of any information you provide to us over the internet and you do so at your own risk, and we cannot be responsible for theft, loss, destruction or inadvertent disclosure of personal data.
We encourage you to play an important role in keeping your Data secure, by maintaining the confidentiality of any passwords and account details used on our Site. It is your sole responsibility to maintain such confidentiality and we will not be liable for any damage, loss or expense suffered due to such disclosure.
We will notify you in not more than forty-eight (48) hours after we learn of any security breach that may result in the loss or destruction or unauthorized access, use, disclosure, transfer, or alteration of your Data, and work with you to respond to and do damage limitation with respect to any such breach.
PRIVACY POLICY UPDATES
From time to time, we may change and post revisions to this Policy and such changes to this Policy will become effective upon the posting of the revised Policy on our Site. Any information we hold about you will be governed by our most current policy. We recommend that you periodically review this policy for any changes.
CONTACT US
If you have any questions or complaints about this Policy or our treatment of your Data, or if you would like to access or amend your Data, please contact us at privacy@reharvestpartners.com.
Last Updated: April 12, 2021