Ag Exchange Group (AGEX) Data Policy

Update History

March 3, 2019 - Converted Bid and Ask terminology to Offer and Target

July 10, 2021 - Clarified existing policy and added explicit sections on data visibility, ownership, portability and security. Also added a section on what happens during a change in ownership.

Data Collected

Some or all of the following data may be collected during your use of the CXN360 service.

Land Data is captured at the resolution of Legal Land Descriptions (LLDs) (e.g. at a resolution of a quarter-section in the Public Land Survey System (PLSS, USA) or Dominion Land Survey (DLS, Canada)). Users are required to provide a “Home LLD”, a.k.a. Home Quarter, and this geolocation is used to identify your primary shipping location. Users can (optionally) identify the LLDs that they farm, indicating whether those LLDs are owned or rented/leased. Inventory Management users can use their land data for tracking and traceability of their crops, from field to storage unit to sale.

Farm Management Data may include information regarding offers received, offers accepted, targets made, and targets accepted. Users can also record the commodity grown and yield quantity by LLD, the storage unit identifier and storage unit location where the commodity is stored. Inventory Management users can also keep detailed time-based records for their commodity inventory. All grower license levels can also record Points of Interest (e.g. storage facilities) on the maps.

Agronomic Data is captured for record management for tracking and traceability of crops grown, at the resolution of the Legal Land Descriptions for their farm. Agronomic data is currently limited to the commodity grown, location, seeding date and harvest date.

Data Retention

You have control over the data that you enter into the CXN360 service (operated by Ag Exchange Group Inc. and referred to as CXN360 hereafter) via your CXN360 member account. You can add data to your member account, delete data from your member account or close your member account at any time.

Once you have deleted any data (or your member account), your deleted data will not appear in any searches on CXN360 after that time. However, there are places where there are still elements of your data left on CXN360, even after you delete the data or your member account. These include, but may not be limited to, the following cases:

a) If you have ever attempted to buy (Offer) or sell (Target) on CXN360, or completed a transaction on CXN360 using either or both of the Offer and Target features, then there is an audit trail created. This audit trail cannot be deleted because the audit trail is the final authority in case there is ever a dispute between CXN360 members over the terms of a negotiation and it must remain on CXN360 to protect both parties if there is a disputed negotiation.

b) Your data will be present in the backup copies of the database. The backup copies of the database are not in active use and the data cannot be accessed by anyone other than one of our system administrators. These backup copies exist to protect you (and Ag Exchange Group) from disaster and your data must remain intact to ensure that we can protect the integrity of the database for you and all of the other CXN360 members. In the unlikely event that we must restore the CXN360 database from backups, we shall follow generally accepted disaster recovery principles and techniques to ensure that the database is correctly restored. However, no disaster recovery plan is perfect and, in the event of a disaster, we may need to contact you to ensure that your data is correctly restored, or deleted, as appropriate.

Data Analysis and Privacy

CXN360 members are not anonymous. CXN360 members use the system for mutual economic benefit and, to be able to conclude negotiations on CXN360; members must know the identity of the person with whom they are negotiating. In general, Growers can see the identity of the Buyers but not the identities of the other Growers, and Buyers can see the identities of the Growers but not the identities of the other Buyers.

All data on CXN360 is analyzed to provide value-added capabilities such as the reports that are available from the CXN360 dashboard.

Reports that are generated from data that is uniquely identifiable as belonging to you, such as land use reports, are only available to you - no other CXN360 member can access those reports.

Reports on system activity are based on data accumulated across all CXN360 members. For example, summary Grower reports are available to CXN360 Buyers and summary Buyer reports are available to CXN360 Growers. In these summary reports, personal identifiers are never included but your data may contribute to these reports. The way in which your data contributes to these reports is governed by the analysis that we perform upon the data to generate the reports and the techniques that we use for data analysis may change at any time.

Data Ownership

You have control over the personal data that you submit to CXN360 via your member account. You can add data to, or modify, the personal data associated with your member account, or close your member account, at any time. However, CXN360 is not an anonymous service. By interacting with CXN360, you explicitly grant Ag Exchange Group Inc. the right to record (also known as logging, including the internet address (IP address) from which you accessed CXN360) your data and your interactions with CXN360 services and other CXN360 members. Ag Exchange Group Inc. may analyze this data and these interactions for any purpose, including the provision of the value-added service that CXN360 provides to you. Please note that these interactions include all personal information related to you, as a user, and any information that you may submit to CXN360. These recorded interactions with CXN360 services and other CXN360 members are the property of Ag Exchange Group Inc. and are not considered to be part of your personal data.

Due to regulatory compliance for audit trails for transactions executed within CXN360, all user interaction records are maintained for the mandated regulatory compliance period. For Canadian customers, the current regulatory compliance period is seven years.

When you close your member account, these interaction records (a.k.a. audit trails) are maintained for the regulatory compliance period. Within 30 days of your closing of your account, the data associated with your account is no longer considered as input to any of our ongoing analyses. Any analyses that may have occurred while your account was active may have used data associated with your account as part of those analyses and the results will remain part of the permanent record at Ag Exchange Group Inc.

In the event that ownership of the CXN360 service, or Ag Exchange Group Inc., are transferred to a third party, these records will be preserved as part of the transfer of ownership.

Data Visibility

CXN360 operates under a “community membership” model. Members may be individuals and/or businesses of any kind. Community memberships are of different “types” such as free and paid, commodity buyer and commodity grower. For both buyers and growers, there exist multiple levels of paid service whereby members pay incremental fees to access further system capabilities.

Real identities are required to become a community member. There is no support for anonymity within CXN360 and the use of a false identity will result in the associated user account being disabled. One of the primary goals of CXN360 is to promote business relationship development between members, this business relationship is predominantly that of vendor and purchaser: buyers make offers to purchase commodities from growers and growers make offers to sell commodities to buyers. Analyses of specific transactions are private to a user and not shared, unless aggregated, to preserve confidentiality within the service.

By becoming a member of the CXN360 community, you explicitly agree to allow other members to access certain elements of your data. In particular, you agree to share sufficient personal contact information with counterparties within CXN360, and only within CXN360, such that they are able to uniquely identify you and to contact you, both within CXN360 and without.

Ag Exchange Group will disclose your personal information when we are required or authorized by law to do so; for example, if a court issues a subpoena or in the defence of, or pursuit of, legal claim

Ag Exchange Group does not share data from CXN360 with parties that are not members of the CXN360 community.

Data Portability

CXN360 provides only minimal data upload capabilities (business name and contact information, legal land descriptions, storage unit characteristics, harvest and inventory records and document storage associated with current inventory, grading reports, etc.). Business name and contact information is mandatory, CXN360 neither supports nor allows anonymity within the community. Legal land descriptions (other than the location of the primary shipping or receiving point), storage unit characteristics, harvest and inventory records are all optional, but any data entered by you, via the provided user interface tools, can be retrieved via the corresponding reports. Use of the document storage capability is optional and is not intended to act as a long-term, large-scale personal document repository. You can add, retrieve and delete documents at any time, as long as your account remains active.

You can interact with CXN360 using a variety of user interfaces and the records that you create through those user interfaces or explicitly enter using the presented forms can be retrieved using the integrated reporting tools. However, the underlying data is, and remains, the property of Ag Exchange Group Inc.

Once you have deleted any data (or your member account), your deleted data will not appear in any future interactions (e.g. you will not appear as a potential recipient of an offer to purchase) on the Ag Exchange system after that time. Records of your interactions with CXN360 are the property of Ag Exchange Group Inc. and will be retained for 7 years as per regulatory requirements. At the end of the required retention period, the records of your interactions will also be deleted.

Any data that has been anonymized and integrated into our analytics warehouse cannot be deleted – the anonymization process ensures that any data in the analytics warehouse cannot be traced back to a specific user and, therefore, cannot be deleted.

Data Security

CXN360 uses industry-standard, commercially reasonable security practices such as firewalls, SSL (Secure Socket Layers) communication channels, and storing backups in encrypted form. However, no security system is perfect and we cannot guarantee the security of our databases or communications channels.

We will inform you, via email or as otherwise required by law, of any data or security breach.

Vendor Access to Data

When contracting with third parties having access to any Ag Exchange Group Inc. information or systems, Ag Exchange Group Inc. ensures that the contracts clearly obligate vendors to privacy, security and confidentiality provisions at least as rigorous as Ag Exchange Group Inc.’s own obligations in respect thereof. Further, we would expect all potential third-party integration partners to abide by the Ag Data Transparency policies and/or follow a substantially similar set of Ag Data Transparency rules and/or protocols.

Change in Ownership

In the event that ownership of CXN360, or Ag Exchange Group Inc., are transferred to a third party, all members will be informed of the upcoming change of ownership, as required in the operating jurisdiction(s). This notice will take the form of email communications and messages within CXN360.

In the event that ownership of CXN360, or Ag Exchange Group Inc., are transferred to a third party, the user accounts will remain active (unless otherwise specified in the transfer of ownership agreement) and the records of all user interactions with CXN360 will be preserved as part of the transfer of ownership.

The new owners of CXN360, or Ag Exchange Group Inc., or both, may post new data and privacy policies. Members are strongly advised to review any new data and privacy policies if such a transfer of ownership occurs.

Notice

We will inform you, via email or as otherwise required by law, of any changes in our data agreements.

Contact Details

You may direct any enquiries regarding these policies via email to admin@cxn360.com.