Grain Basis, LLC

Privacy Policy

In the United States of America there are regulations which impose various requirements the treatment of customer information. These regulations require that firms develop privacy policies and disclose these policies to its customers. Grain Basis, LLC (“Grain”) considers your privacy one of our utmost concerns. This Privacy Notice outlines our current policies and practices regarding how information about individual customers is collected and used.

Personal Account Information

In order to provide you with individualized service, Grain collects information about you from your account application and other forms that you may deliver to us. Grain also collects information about your transactions with us and our affiliates. We may use this information to open an account for you, process your requests and transactions and to provide you with additional information about our products and services. In order to service your account and mail correspondence to you, we provide your personal information to other affiliated independent firms that specialize in providing these services. These firms may include brokerage firms, clearing firm(s), consulting firms, and also our printing/mailing vendors. We require these other independent firms to protect the confidentiality of your information and to use the information only for the limited purpose for which the disclosure is made. We do not disclose any nonpublic personal information about our customers to other independent firms, organizations or individuals except in furtherance of our business relationship with you, or as otherwise permitted or required by law. In addition, if you decide at some point to terminate your service agreement with Grain, we will continue to adhere to the privacy policies and practices described in this notice. We restrict access to nonpublic personal information about you to those employees who need to know that information to provide products or services to you. We maintain physical, electronic and procedural safeguards that comply with US federal standards to guard your personal information. Use of Website and Electronic Systems This Privacy Policy (this “Policy”) details our commitment to protecting the privacy of individuals who visit our website and register to use the products and services that we market (the “Service”). For the purposes of this Policy, the term, “website” shall refer collectively to www.grainbasis.com.

PRIVACY NOTICE

Grain has always been committed to maintaining the confidentiality, integrity and security of personal information about our current and prospective customers. We understand that privacy is an important issue for you, and we want you to understand how we work to protect your privacy when we collect information about you.

HOW WE OBTAIN PERSONAL INFORMATION

In providing you with products and services, or information about such products and services, Grain may collect public and non-public personal information about you from the following sources: Your Service agreements and other related documents and forms (for example, name, address, social security number, birth date and financial information)Transactions with Grain, Outside entities, including credit reporting agencies, to obtain information (such as verification of identity, credit-worthiness, and credit history, purchasing and investment preferences).

HOW WE PROTECT YOUR INFORMATION

It is our policy not to release your personal information except as permitted by law, requested by you or set forth below. Within Grain, we restrict access to your personal information to those who require it to provide products or services to you. We maintain physical, electronic and procedural safeguards to protect your personal information. These safeguards include limiting access to data and periodically testing our security technology. Within Grain we may share information about you for several reasons, including: to assist us in providing services to help design and improve products to offer products and services that may be of interest to you In the course of doing business, we may share information with third parties, which could include personal information about you. Personal information may be shared with others for the following reasons: in response to a subpoena to prevent fraud to comply with inquiries from government agencies or other regulators for other legal purposes. We also may share personal information: with others that service your accounts, or that perform services on our behalf with others with whom we may have joint marketing agreements. These include financial services companies financial services providers, such as introducing brokers, broker/dealers, futures commission merchants, investment companies, investment advisers, commodity trading advisers and commodity pool operators publishers and other direct marketers of products related to the agricultural industry, such as newsletter or book publishers and software or system developers to other non-affiliated third parties with your consent, at your request or as permitted or required by law. The security of your personally identifiable information is very important to us. When we collect your personally identifiable information online, we use reasonable efforts to protect it from unauthorized access. However, due to the inherent open nature of the Internet, we cannot guarantee that your personally identifiable information will be completely free from unauthorized access by third parties such as hackers and your use of our Service demonstrates your assumption of this risk. We have put in place reasonable physical, electronic, and managerial procedures to safeguard the information we collect. Only those employees who need access to your information to perform their duties are authorized to have access to your personally identifiable information. For more information on protecting your privacy, please visit www.ftc.gov/privacy.

OUR COOKIE POLICY

Cookies and Similar Technologies: “Cookies” are pieces of information that may be placed on your computer by a service for the purpose of facilitating and enhancing your communication and interaction with that service. Many services use cookies for these purposes. We may use cookies (and similar items such as clear gifs, web beacons, tags, etc.) on our website to customize your visit and for other purposes to make your visit more convenient or to enable us to enhance our Service. We may also use and place cookies (and similar items) on your computer from our third-party service providers in connection with the Service, such as an analytics provider that helps us manage and analyze Service usage, as described more fully below. In addition, our advertisers and business partners may set cookies and similar items on your computer when you use our Service. You may stop or restrict the placement of cookies on your computer or flush them from your browser by adjusting your web browser preferences, in which case you may still use our Service, but it may interfere with some of its functionality. Cookies and similar items are not used by us to automatically retrieve personally identifiable information from your computer without your knowledge. If you delete your cookies, change browsers or use a different cookie, our cookie (or an opt-out cookie) may no longer work, and you will have to reinput (or opt-out) again. Analytics and Conversion Tracking: We may use analytics services that use cookies, JavaScript and similar technologies to help us analyze how users use our website. The information generated by these services about your use of the Service (including your IP address or a truncated version of your IP address) is transmitted to and stored by analytics service providers on their servers. Those service providers will use this information for the purpose of evaluating your, and other users’, use of the Service, compiling reports for us on website activity and providing other services relating to website activity and Internet usage. We may collect information about your computer, including your IP address, operating system and browser type, for system administration and in order to create reports. This is statistical data about our users’ browsing actions and patterns and does not identify any individual. For example, we use cookies on our site for Google Analytics (the “Analytics Service”). The Analytics Service is a web-based analytics tool that helps website owners understand how visitors engage with their website. The Analytics Service customers can view a variety of reports about how visitors interact with their website so that they can improve it. Like many services, the Analytics Service uses first-party cookies to track visitor interactions as in our case, where they are used to collect information about how visitors use our site. We then use the information to compile reports and to help us improve our site. Cookies contain information that is transferred to your computer’s hard drive. These cookies are used to store information, such as the time that the current visit occurred, whether the visitor has been to the site before and what site referred the visitor to the web page. The Analytics Service collects information anonymously. They report website trends without identifying individual visitors. You can opt out of the Analytics Service without affecting how you visit our site. For more information on opting out of being tracked by Google Analytics across all websites you use, visit https://tools.google.com/dlpage/gaoptout.We may also use Google conversion tracking and/or similar services to help us understand your and other users’ use of the Service. Automatically Collected Information: When you access the Service or open one of our HTML emails, we may automatically record certain information from your system by using cookies and other types of tracking technologies. This “automatically collected” information may include Internet Protocol address (“IP Address”), a unique user ID, device type, device identifiers, browser types and language, referring and exit pages, platform type, version of software installed, system type, the content and pages that you access on the Service, the number of clicks, the amount of time spent on pages, the dates and times that you visit the Service, and other similar information. Depending on the law of your country of residence, your IP address may legally be considered personally identifiable information. Communications with Grain By providing your contact information to us (including, without limitation, your email address, physical address, and phone number) (collectively the “Channels”) to us, you expressly consent to receive communications from us. We may use the Channels to communicate with you, to send information that you have requested or to send information about other products or services developed or provided by us or our business partners, provided that, we will not give your contact information to another outside party to promote their products or services directly to you without your consent or as set forth in this Privacy Policy. By using the Service, you expressly consent to receive in-product communications from us. By providing your phone number to us, you expressly consent to receive phone calls and/or text messages from us. We will not give your phone number to another party to promote their products or services directly to you without your consent or as set forth in this Privacy Policy. Any phone calls and/or text messages delivered to your phone or device may cause you to incur extra data, text messaging, or other charges from your wireless carrier. MESSAGE AND DATA RATES MAY APPLY. You are solely responsible for any carrier charges incurred as a result of phone and/or text communications from Grain. Any communication or material you transmit to us by email or otherwise, including any data, questions, comments, suggestions, or the like is, and will be treated as, non-confidential and nonproprietary. Except to the extent expressly covered by this Privacy Policy, anything you transmit, or post may be used by us for any purpose, including but not limited to, reproduction, disclosure, transmission, publication, broadcast and posting. Furthermore, you expressly agree that we are free to use any ideas, concepts, know-how, or techniques contained in any communication you send to us, as well as any data developed using the content of such communication, without compensation and for any purpose whatsoever, including but not limited to, developing, manufacturing and marketing products and services using such information.

OPT OUT NOTICE

All unsubscribe or opt-out requests may be made by clicking the “unsubscribe” link at the bottom of the relevant email. We will process your request within a reasonable time after receipt. However, we are not responsible for, and in some cases, we are incapable of, removing your personally identifiable information from the lists of any third party who has previously been provided your information in accordance with this Privacy Policy or your consent. You should contact such third parties directly. If you would like to update or correct any personally identifiable information that you have provided to us, please email us at support@grainbasis.com and once we confirm your information, we will update such information within a reasonable amount of time. If you prefer that Grain not disclose non-public personal information about you to non-affiliated third parties, you may opt out of those disclosures. That is, you may direct Grain not to make those disclosures, other than disclosures permitted or required by law. Any customer who decides to opt out of these disclosures to non-affiliated third parties must notify us by sending an e-mail to support@grainbasis.com. Grain regularly provides notices to its customers regarding its privacy policy. Grain reserves the right to change this policy, and to apply changes to information previously collected, as permitted by law. If there is any change to this policy, Grain will provide its customers with a revised privacy notice. To obtain further information, please call our Customer Service Team at 800.771-6748.

LEGAL WEBSITE USER AGREEMENT

Grain makes available information, materials, products and services on this website subject to the following terms and conditions and the terms and conditions of all applicable account and other 3rd party vendor agreements, disclaimers and the legal notices that appear on this website and/or must be agreed by you in the grain marketing services contract. By accessing this site, you agree to the terms and conditions as outlined below, in addition to those contained in such agreements, disclaimers and legal notices. Grain and the vendors offered retain the right to change these terms and conditions from time to time at its sole discretion. The prices, fees, costs and other terms of all products and services offered on this website are subject to change at any time and from time to time without notice. This site is presented solely for informational purposes and to provide access to certain electronic products or services. No offer to buy or sell futures, securities derivative products or foreign exchange of any kind, or any type of investment or trading advice or strategy is made, given or in any manner endorsed by Grain. You are fully responsible for any investment or trading decisions you make, and such decisions should be based solely on your evaluation of your financial circumstances, investment or trading objectives, risk tolerance and liquidity needs.

WEBSITE LINKS

This website contains or may contain references and links to other companies and/or their websites, none of which is under the control of Grain. Grain makes no representations, warranties or endorsements whatever about any other websites to which you may have access through the Grain website or any products or services of those other companies even if the products or services of those other companies or their websites are described or offered on Grain website or integrated with any of the products or services offered by Grain.

DISCLAIMERS

All products, services, information, software and system performance offered or provided in this site are offered and/or provided “as is” without warranty of any kind, either express or implied, including but not limited to the implied warranties of merchantability and fitness for a particular use or purpose. You use this site and all products and services at your own risk. In no event shall Grain be liable for any special, incidental, indirect or consequential damages of any kind, or any financial losses or damages whatever, including, without limitation, those resulting from loss of (or errors in) service, software, data, whether or not we have been advised of the possibility of such damages and regardless of the theory of liability.