Privacy Policy

1. About this policy

This Privacy Policy explains how [Legal Entity Name] (ABN [ABN]), trading as Cotton IQ (“Cotton IQ”, “we”, “us” or “our”), collects, holds, uses and discloses personal information. We are bound by the Privacy Act 1988 (Cth) (“Privacy Act”) and the Australian Privacy Principles (“APPs”).

It applies to the Cotton IQ website (cottoniq.app), the Cotton IQ portal and IQ1 platform (portal.cottoniq.app), and any related products, services and communications (together, the “Services”).

For information about how we handle the agronomic, quality and financial data you upload to the platform, please also read our Data & Security Policy, which forms part of this policy.

2. What is personal information

“Personal information” means information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether true or not and whether recorded in a material form or not. Information about a business or a paddock is generally not personal information, but it can become personal information where it is linked to an identifiable individual (for example, a sole-trader grower).

3. The personal information we collect

Depending on how you interact with us, we may collect:

• Contact and identity information — name, business/farm name, email address, phone number, postal or property address, and job role.
• Account information — login credentials, user preferences, and records of your access to and use of the portal.
• Enquiry and demo information — the details you provide when you request a demo, contact us, or correspond with our team.
• Operational data you upload — HVI classing data, harvester and picker records, agronomic inputs, RCTIs and financial returns. This data relates primarily to your business and fields, but may include or be linked to personal information. It is dealt with in detail in our Data & Security Policy.
• Technical information — IP address, device and browser type, and usage data collected through cookies and similar technologies (see our Cookie Policy).

We generally do not collect sensitive information (as defined in the Privacy Act). If we ever need to, we will only do so with your consent or as otherwise permitted by law.

4. How we collect personal information

We collect personal information:

• directly from you — when you contact us, request a demo, create an account, or use the Services;
• from your authorised representatives, such as a farm manager, agronomist or consultant acting on your behalf;
• from third parties you direct us to (for example, your gin or a data provider), where you have authorised that disclosure; and
• automatically, through cookies and analytics when you use our website and portal.

Where it is reasonable and practicable, we collect personal information directly from you. If we receive information about you that we did not solicit, we will deal with it in accordance with the APPs.

5. Why we collect, hold, use and disclose personal information

We use personal information to:

• provide, operate, maintain and improve the Services;
• set up and administer your account and authenticate users;
• respond to enquiries, provide support, and arrange demonstrations;
• process the operational data you upload to generate your analysis and insights;
• communicate with you about the Services, including service and security notices;
• send you marketing communications where permitted (see section 8);
• maintain the security and integrity of our systems; and
• comply with our legal obligations.

We will only use or disclose your personal information for the purpose it was collected, for a related purpose you would reasonably expect, or as otherwise permitted or required by law.

6. Who we disclose personal information to

We may disclose personal information to:

• our personnel and contractors who need it to perform their roles;
• service providers who support the Services — including cloud hosting, data storage, analytics, email and customer-support providers — under obligations of confidentiality and security;
• your own authorised users and representatives that you invite to your account; and
• government agencies, regulators or law enforcement where required or authorised by law.

We do not sell your personal information. We do not disclose individual grower results to other growers, merchants or third parties for their own purposes. How we handle aggregation and de-identification of platform data is explained in our Data & Security Policy.

7. Overseas disclosure

We aim to store personal information in Australia. Some of our service providers (for example, cloud infrastructure or support tools) may store or process data outside Australia. Where this occurs, we take reasonable steps to ensure the recipient handles your personal information consistently with the APPs. If we disclose personal information to overseas recipients, the countries in which they are likely to be located are set out here: [list of countries, e.g. United States]. This section will be kept current as our providers change.

8. Marketing communications

We may send you information about our products and services where you have consented or where it is otherwise permitted under the Privacy Act and the Spam Act 2003 (Cth). Every commercial electronic message we send will include a way to unsubscribe. You can opt out at any time by using the unsubscribe link or contacting us at privacy@cottoniq.app.

9. Automated processing and decision-making

The Cotton IQ platform uses analytics to map, visualise and generate insights and recommendations from the data you provide — for example, highlighting quality patterns or indicating which merchant schedule may pay most for a field's cotton. These insights are decision-support tools: they are provided to you to inform your own commercial decisions and those of your advisers. Cotton IQ does not use your personal information to make automated decisions that produce legal or similarly significant effects about you without human involvement.

10. Security of your information

We take reasonable steps to protect personal information from misuse, interference and loss, and from unauthorised access, modification or disclosure. Our technical and organisational measures are described in our Data & Security Policy. No method of transmission or storage is completely secure, but we work to protect your information and to respond appropriately to any incident.

11. Data breaches

We comply with the Notifiable Data Breaches scheme under the Privacy Act. If we become aware of an eligible data breach that is likely to result in serious harm, we will notify affected individuals and the Office of the Australian Information Commissioner (OAIC) as required by law.

12. Retention

We keep personal information only for as long as it is needed for the purposes described in this policy, or as required by law. When it is no longer required, we will take reasonable steps to destroy or de-identify it.

13. Accessing and correcting your information

You may request access to the personal information we hold about you, and ask us to correct it if it is inaccurate, out of date, incomplete, irrelevant or misleading. To make a request, contact us using the details below. We will respond within a reasonable period. There is no fee to make a request, though we may charge a reasonable cost for providing access in some cases. If we refuse access or correction, we will tell you why in writing.

14. Complaints

If you believe we have breached the APPs or mishandled your personal information, please contact our Privacy Officer at privacy@cottoniq.app. We will acknowledge your complaint and aim to resolve it promptly. If you are not satisfied with our response, you may complain to the OAIC at www.oaic.gov.au or by phone on 1300 363 992.

15. Changes to this policy

We may update this Privacy Policy from time to time. The current version will always be available at cottoniq.app/privacy, with the “last updated” date shown above. Significant changes will be communicated through the Services or by email where appropriate.

16. Contact us

Privacy Officer — Cotton IQ
[Legal Entity Name] (ABN [ABN])
[Registered Address]
Email: privacy@cottoniq.app