In the course of serving or otherwise interacting with our current, former and prospective clients and other individuals who visit our website (the “Website”) or otherwise communicate or engage with us (“you” or “your”), Farmland LP may obtain personal information about such individuals. Obtaining this information is important to our ability to deliver the highest level of service to you, but we also recognize that you expect us to treat this information appropriately.
This policy describes the types of personal information we may collect about you, the purposes for which we use and otherwise process the information, the circumstances in which we may share the information and the steps that we take to safeguard the information to protect your privacy. As used throughout this policy, the terms “Farmland LP,” “we,” “us” and “our” refer to Vital Farmland Holdings, LLC and its affiliates. For purposes of this policy, “personal information” has the meaning given to such term (or to terms of similar intent, such as “personal data”) under applicable law, as and to the extent applicable to your rights and our obligations with respect to such information.
The Sources of Personal Information
The personal information we collect about you comes primarily from the account applications or other forms and materials you submit to Farmland LP during the course of your relationship with us. We may also collect information about your transactions and experiences with Farmland LP relating to the services Farmland LP provides. In addition, depending on the services you require, Farmland LP may obtain additional information about you, such as your credit history, from consumer reporting agencies or other third parties such as service providers, advisers (including, but not limited to, independent financial advisers), vendors and publicly available sources such as company websites. We may also collect personal information about individuals who visit our Website or otherwise communicate or engage with us and through the use of cookies on our Website. Additional information on how we use cookies on our Website is provided below, under the section entitled “Cookies.”
Finally, in the provision of financial services to you, and subject to compliance with all applicable laws and regulations, information may be collected about you indirectly from monitoring or other means (e.g., archived email monitoring). In these circumstances, the information is not accessed on a continuous or routine basis, but it may be used for compliance or security purposes.
The Personal Information We Have about You
If you deal with Farmland LP in your individual capacity (e.g., as a private client), as a settlor/trustee/beneficiary of a trust, or as an owner or principal of a company or other investment vehicle established to invest on your behalf or on behalf of your family, etc., the typical information we collect about you may include (in addition to any other information as may be determined on a case-by-case basis):
Of the above categories of personal information that we may collect about you, the following may be considered “sensitive” categories under certain applicable laws: (A) social security number, driver’s license number, state identification card, and passport number; (B) account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to your account; and (C) your biometric information for the purpose of uniquely identifying you. This policy, and the practices described herein, applies equally to our collection, use, disclosure and other processing of such “sensitive” personal information.
Of course, you are not required to supply any of the personal information that we may request. However, failure to do so may result in our being unable to open or maintain your account or to provide services to you. While we endeavor to ensure that all information we hold about our clients is accurate, complete and up to date, we rely on our clients promptly notifying us if there are any changes to their personal information.
We may also collect certain additional personal information through the use of cookies on our Website. Additional information on how we use cookies on our Website is provided below, under the section entitled “Cookies.”
Our Website is not intended for children and we do not knowingly collect personal information relating to children (including any minors under the age of 16).
Our Use of Your Personal Information
We may use your personal information to:
If your relationship with Farmland LP ends, Farmland LP will continue to treat your personal information, to the extent we retain it, as described in this policy.
You may opt out of receiving promotional communications at any time by following the “unsubscribe” instructions found within Farmland LP email updates or changing your contact preferences. Please note, you will continue to receive essential account-related information, even if you unsubscribe from promotional emails.
We may process some of your personal information, including “sensitive” personal information, for purposes of automated decision-making and profiling. For example, in connection with our entering into, or the performance of, our contracts with you, we may collect your investor preferences and use that information to profile you for specific assets based on your investment objectives, time horizon, risk tolerance, etc.
We do not use or otherwise process your “sensitive” personal information other than as described herein.
Disclosures of Your Personal Information within Farmland LP
In order to provide efficient and reliable services and to improve product and service options available to you, more than one entity within Farmland LP may be given, or given access to, your personal information. For example, one Farmland LP entity might share your information with another in order to facilitate settlement of your transactions or the maintenance of your accounts, or as part of its arranging for the performance of specialized services such as US and international brokerage, asset management and advisory services. When so sharing your personal information, we adhere to applicable legal and industry standards regarding the protection of personal information. Additional information on how your personal information is protected while within Farmland LP is provided below, under the section entitled “Information Security: How We Protect Your Privacy.”
Disclosures of Your Personal Information to Third Parties
Farmland LP does not disclose your personal information to third parties, except as described in this policy. We may disclose your personal information as follows:
Farmland LP has relationships with certain service providers to provide its services to you. Farmland LP has contracted with Juniper Square, HubSpot, and North Capital. Among other services, these technologies assist Farmland LP with investor onboarding, fund communications, quarterly reporting, and “Know Your Customer” requirements and other obligations. For purposes of satisfying “Know Your Customer” requirements, Farmland LP asks for your identifying information, such as your name, email address, tax identification number, address, telephone number, date of birth, gender, videos, and photographs that may contain images of your face, including your driver’s license or government-issued identification number or card. Farmland LP will also collect information pertaining to your account transactions. Your personal information will be shared with Juniper Square, HubSpot, and North Capital and will be subject to their privacy policies. Farmland LP may contract with other or alternate providers of such services in the future.
Data Retention
We will keep your personal information only for as long as necessary depending on the purpose for which it was provided. Details of retention periods for different aspects of your personal information are available in our retention policy, information about which you can request by contacting us. When determining the relevant retention periods, we take into account a variety of factors, including, but not limited to, the following:
Information Security: How We Protect Your Privacy
Farmland LP is committed to protecting the privacy and confidentiality of your personal information. We limit access to your personal information to authorized Farmland LP employees or agents and, as described above in Disclosures of Your Personal Information to Third Parties, third parties are held to appropriate standards of privacy. We also maintain physical, electronic and procedural safeguards designed to protect the information against loss, misuse, damage or modification and unauthorized access or disclosure.
Unfortunately, the storage and transmission of electronic information is not completely secure. Although we strive to protect your personal information, we cannot guarantee the security of information stored on our or our service providers’ servers or transmitted via email or through the Website; you transmit personal information to us at your own risk. In addition, links on the Website may take you to third-party websites over which we have no control. While such links are provided for your convenience, you should be aware that the information handling practices of the linked websites might not be the same as ours. You should review any privacy policies and cookie policies on those linked websites. We are not responsible for any linked websites.
Privacy and the Internet
The following additional information will be of interest to you as a visitor to this Website:
Cross-Border Data Transfers
The recipients of your personal information pursuant to this policy may be located in the United States or elsewhere, and certain of such recipients’ respective countries may have different data privacy laws and protections than your home country. We may transfer your personal information outside of your home country, including to our affiliates in other countries, for the purposes set out in this policy. Any transfer of your personal information to recipients in a third country will be made subject to appropriate safeguards or applicable derogations provided for under applicable law.
Information For EEA (EU plus Iceland, Norway and Liechtenstein) and UK Residents
What Rights Do I Have?
Under the EU’s General Data Protection Regulation “GDPR” and the UK General Data Protection Regulation (i.e., the GDPR as implemented into UK law, the “UK GDPR”), individuals located in the European Economic Area (“EEA”) or the UK, as applicable, have certain additional rights with respect to their personal data. For purposes of this section, “personal data” has the meaning given to such term in the GDPR or UK GDPR, as applicable. For the purposes of applicable data privacy legislation, Farmland LP is a “controller” of such individuals’ personal data.
Under certain conditions, you may have the right to:
Where possible, we obtain and rely on user consent as a lawful basis for processing personal data. In some cases, Farmland LP may process and retain personal data pursuant to a legal obligation or another legitimate interest under the GDPR or UK GDPR, to protect your vital interests, the interests of Farmland LP, or those of another person, or where necessary for the performance of a contract with you for provision of our services. If we have obtained your consent, then you may withdraw it any time by contacting us.
These rights are not absolute and each is subject to certain exceptions or qualifications.
Information For California Residents
What Rights Do I Have?
Under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, the “CCPA”), residents of the state of California have certain rights with respect to their personal information. For purposes of this section, “personal information” has the meaning given to such term under the CCPA. Please note that the rights under the CCPA do not apply to personal information collected, processed, sold or disclosed subject to the Gramm-Leach-Bliley Act (Public Law 106-102), the Fair Credit Reporting Act (12 CFR 1022) and/or the California Financial Information Privacy Act. Under the CCPA you may have the right to:
We will not discriminate against any California resident who exercises the rights set forth in this section.
These rights are not absolute and each is subject to certain exceptions or qualifications.
How May I Exercise My Individual Rights?
You have the right to appoint an authorized agent to exercise these rights on your behalf. If you want to exercise any of these rights, or have your authorized agent exercise any of these rights on your behalf, you may contact us. Please note that Farmland LP may request additional information from you to verify your identity before we disclose any personal or account information.
Other Privacy Policies or Statements; Changes to Policy; Contact
This policy provides a general statement of the ways in which Farmland LP processes and protects your personal information. You may, however, in connection with specific products or services offered by Farmland LP, be provided with privacy policies or statements that supplement this policy. In the event of a conflict between the terms of this policy and such supplemental privacy policies or statements, such supplemental privacy policies or statements will govern in relation to your use of such products or services. This policy may be changed from time to time to reflect changes in our practices concerning the collection and use of personal information. The revised policy will be effective immediately upon posting to our Website.
Cookies
Statement on Cookies
By using our Website with your browser settings adjusted to accept cookies, you consent to Farmland LP’s use of cookies and other tools to provide the products and services available on our Website. If you would like to modify your browser to notify you when you receive a new cookie or to disable cookies altogether, please refer to Managing Cookies below. Remember, though, without cookies, you may not be able to take full advantage of all of our Website features.
Cookies at Farmland LP and How We Use Them
Cookies are small text files that may be placed on your Web browser when you visit our Website or when you view advertisements we have placed on other websites. Cookies allow your browser to remember some specific information which the web server can later retrieve and use. Cookies may enhance your online experience by saving your preferences while you are visiting a particular website. Farmland LP does not use cookies to store any personal information that could be read or understood by others. When you quit your browser, some cookies are stored in your computer’s memory, while some expire or disappear.
Cookies are used primarily for administrative purposes, to improve your experience with our Website. Examples of this include the use of cookies:
In addition to administrative uses, Farmland LP may also use cookies in one or more of the following ways:
We may use cookie technology to collect certain aggregate and non-personal information when you visit our Website. “Clickstream” data (e.g., information regarding which of our Website pages you access, the frequency of such access, and your product and service preferences) may be collected by Farmland LP itself, or by our service providers, using cookies, Web beacons, page tags, or similar tools that are set when you visit our Website or when you view an advertisement we have placed on another Website. Clickstream data and similar information may be shared internally within Farmland LP and used: for administrative purposes; to assess the usage, value and performance of our online products and services; to improve your experience with our Website; and as otherwise permitted by applicable law or regulation. If you are a Farmland LP client, this information helps us suggest products or service offerings that may be of interest to you. This information may be processed by us for the purposes described above, or on our behalf by third parties, solely in accordance with our instructions.
Managing Cookies
The Help menu on the menu bar of most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie and how to disable cookies altogether. Additionally, you can disable or delete similar data used by browser add-ons, such as Flash cookies, by changing the add-on’s settings or visiting the Website of its manufacturer. Some of our Website pages employ “functionality cookies” that help the Website remember your settings and preferences for use when you visit the Website in the future. This provides a more tailored and pleasant user experience. These cookies store information in multiple places. On those Website pages using functionality cookies, you will find a “Delete Cookies” feature on every page that will allow you to delete these cookies completely from your device. Please note that, if you decline to use cookies, you may experience reduced functionality and, for websites using authentication-related cookies, declining cookies will prevent you from using the website altogether. To learn more about what cookies are set on your computer as you browse the Web and how to manage or delete them, visit allaboutcookies.org.