Bushel Inc. – Privacy Notice
(June 2026)
App name: Inco Grain
Your privacy is important to us. We have created this Privacy Notice to explain, in plain English, how we collect, use, share, retain, and protect information that can directly or indirectly identify you (“Personal Data”). This Notice also explains your privacy rights and how to exercise them.
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, where we act as a service provider, processor, or similar service role for another organization, that organization is generally responsible for responding to rights requests relating to the personal data it controls, unless applicable law or our contract says otherwise. Please direct those requests to the organization in control of your personal data.
Bushel Inc. (“Bushel”) is a software company headquartered at 118 Broadway North, Suite 600, Fargo, North Dakota 58102 USA.
Bushel operates through its subsidiaries, including 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”
We are committed to data minimization. We collect and use only the personal information that is reasonably necessary and proportionate to the purposes described in this Notice. We do not collect more data than we need, and we will not use your data for purposes that are incompatible with those disclosed here. Where required by law, we also provide a notice at or before collection describing the categories of personal information we collect, the purposes for which we use it, and the categories of retention and sharing that apply.
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:
You may exercise any of these rights by contacting us via email at [email protected]. Where applicable law requires, you may also exercise opt-out rights through your browser’s privacy controls or a recognized Universal Opt-Out Mechanism, and we will treat that signal as a valid opt-out request. If we cannot verify your identity or confirm your request, we may not be able to respond to some requests.
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.
Where we collect sensitive personal information (such as government-issued ID numbers, financial account details, or precise geolocation), we will collect and use it only when we have a lawful reason to do so and only for the purposes described in this Notice. Where required by law, we will obtain your consent before collecting or using sensitive personal information, except where another legal basis applies or the law allows us to do so without consent.
IF YOU ARE AN AFFILIATED USER, CUSTOMER, OR BUSINESS PARTNER, OR EXPRESS INTEREST IN OUR SOLUTIONS:
Learning about our company and our solutions:
As an agribusiness, if you request or indicate an interest in the Bushel Platform, we process information such as 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 agribusiness using the Bushel Platform, we process information such as 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 the Bushel App (formerly Bushel Farm):
If you are a Grower using the Bushel App, we process information such as 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.
Agricultural and Farm Data:
Some data you share through Bushel Farm (such as field boundaries, crop information, yield data, and agronomic records) may be considered agricultural business data under applicable state or industry standards. We treat this information with heightened care, use it only to provide the services you have requested, and do not sell or license it to third parties for purposes unrelated to your farm operation without your explicit consent. We may disclose this information only as needed to provide the service, comply with law, or support the farm operation you requested.
Using Bushel Wallet:
If you are a Grower using Bushel Wallet, we process information such as 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, any beneficial owner information (such as, job title, date of birth, SSN), and line of credit information or loan information.
The sensitive categories of personal information listed above (Social Security Number, passport, government ID, financial account details) are processed only on the basis of your explicit consent or as required by law and financial regulation. You have the right to limit our use and disclosure of sensitive personal information as described in Your Rights above. We use this information only to provide the Bushel Wallet services, meet legal and financial compliance obligations, and prevent fraud.
Negotiating and entering into a contract with us and relationship management during the contract term:
If you are an agribusiness entering into an agreement with us related to the licensing or purchase of our solutions, we process information such as 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 information such as 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 information such as 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 information such as 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:
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 https://www.allaboutcookies.org or https://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.
We honor recognized Universal Opt-Out Mechanisms (UOOMs), including the Global Privacy Control (GPC) browser signal, where we are required to do so under applicable law (including California, Colorado, Connecticut, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Texas, and other states). If your browser or device sends a recognized opt-out preference signal, we will treat it as a valid request to opt out of the sale or sharing of your personal information and of targeted advertising. We do not currently honor the older “Do Not Track” (DNT) browser header as it lacks a uniform technical standard; however, we will update this Notice if that changes. Visit www.allaboutdnt.org to learn more about DNT, and https://globalprivacycontrol.org to learn more about GPC. Where applicable law requires, we will provide a clear confirmation that your opt-out signal has been honored.
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, driver and driver’s license status, 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.We use this information to administer employment or contractor relationships, payroll, benefits, compliance, security, and performance management.
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.
The reasons that we process about you depend on who you are and how we interact with you.
IF YOU ARE AN AFFILIATED USER, CUSTOMER, OR 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:
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:
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 ONLINE PROPERTIES WE PROVIDE:
We process personal information about you to:
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:
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:
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”).
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 https://www.allaboutcookies.org or https://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 and, where required by applicable law (including California), any opt-out choices you have previously exercised will be honored by the acquiring organization with respect to your personal information.
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.
Where required by law (including under California’s CPPA regulations effective January 1, 2026), we conduct or commission periodic cybersecurity audits of our data processing activities. The results of such audits are used to continuously improve our security posture. We keep different categories of personal information for different periods based on the purpose for which it was collected and any legal retention requirement
Where we are subject to certain privacy requirements in the United States, the following applies:
We do not knowingly collect the personal data of children under the age of 16 (or under 18 where required by applicable state law, including Maryland and New Jersey). We do not knowingly sell or share that information either, except as permitted by law. If you are a parent or guardian and believe we have collected information about a child, please contact us at [email protected] with sufficient detail to enable us to delete that information.
This section for California residents supplements the information contained in Our Privacy Notice and it applies solely to all visitors, users, and others who reside in the State of California. It is intended to describe our practices under California law, including categories collected, purposes, retention, and rights.
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 California Consumer Privacy Act and the California Privacy Rights Act (“CPRA”). 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.The specific categories we collect or disclose may vary depending on how you interact with us.
For details about types of information collected or disclosed, please see the “What Personal Information?” section above.
Sources of Personal Information
We obtain the categories of personal information listed above from the following categories of sources:
Use of Personal Information for Business Purposes or Commercial Purposes
We may use or disclose personal information and sensitive personal information we collect for “business purposes” or “commercial purposes” (as defined under the CPRA), which may include the following examples:
Retention of Personal Information
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.
Sale or Share of Personal Information
As defined in the CPRA, “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.
As defined in the CPRA, “share” and “sharing” mean sharing, 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 cross-context behavioral advertising, whether or not for monetary or other valuable consideration, including transactions between a business and a third party for cross-context behavioral advertising for the benefit of a business in which no money is exchanged.
We do not sell or share the personal information of any Consumers.
Personal Information of Minors
We do not knowingly sell or share the personal information of any Consumers under the age of 16.
If you have reason to believe that a child under the age of 16 has provided us with personal information, please contact us at [email protected] with sufficient detail to enable us to delete that information.
Do Not Track
Please see the “Universal Opt-Out Mechanisms (Global Privacy Control)” section above for our current approach to browser-based opt-out signals.
Your Rights under the CPRA
The CPRA provides California residents with specific rights regarding their personal information. If you are a resident of California, you have the following rights:
Exercising Your CPRA Data Protection Rights
In order to exercise any of your rights under the CPRA, and if you are a California resident, you can contact us:
We will verify your request before responding where required by law.
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. If you use an authorized agent to submit a request on your behalf, you must provide the authorized agent signed permission to do so, verify your own identity directly with us, and directly confirm with us that you provided the authorized agent permission to submit the request.
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. We will acknowledge the request no later than 10 days after receiving the 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 usable and should allow you to transmit the information from one entity to another entity without hindrance.
Agricultural Data Consent. If you are an agricultural producer under Nebraska law, by signing or otherwise affirmatively consenting to this notice, you authorize Bushel to collect, process, use, disclose, and share the your agricultural data, including, without limitation, production, cultivation, yield, GPS, irrigation, financial, marketing, equipment, livestock, and land-related information, for the purposes described in this notice and any related services, analytics, recordkeeping, support, compliance, or business operations.
Withdrawal of Consent; Deletion. You may withdraw this consent at any time by providing written notice to Bushel at [email protected] or by phone at 701-212-1422 Upon receipt of a valid withdrawal request, Bushel will cease processing and sharing your identifiable agricultural data to the extent reasonably practicable, subject to applicable legal, contractual, archival, security, and compliance obligations. You may also request deletion of your identifiable agricultural data, and Bushel will delete such data to the extent required and permitted by applicable law, subject to any information that must be retained for legal, regulatory, fraud-prevention, dispute-resolution, or legitimate business recordkeeping purposes. This does not affect Buushel’s right to use non-identifiable and anonymized data for any legal purpose.
In addition to California, residents of many other U.S. states have rights over their personal data. These include, but may not be limited to: Virginia, Colorado, Connecticut, Iowa, Montana, Oregon, Texas, New Jersey, New Hampshire, Nebraska, Tennessee, Minnesota, Maryland, Delaware, Indiana, Kentucky, Rhode Island, and others as laws come into effect. Although the specific rights and procedures may differ slightly by state, they generally include the rights to access, correct, delete, and obtain a portable copy of your personal data, and to opt out of the sale of personal data, targeted advertising, and in some states, profiling for significant decisions. To exercise your rights under any applicable state law, please contact us at [email protected] or by phone at 701-212-1422. We will respond to your request within the timeframe required by the applicable law and at no charge to you.
The specific rights and procedures may differ by state and may depend on the role Bushel plays in the relevant processing.
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:
We cannot respond to your request or provide you with the required information if we cannot:
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:
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.
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. The updated version will always be the most recent Notice.
If you have any questions or complaints related to our practices with respect to the collection, use, or disclosure of personal information, please contact the Data Privacy team and our General Counsel at [email protected].