Privacy Policy and Ag Data Use Agreement

1. Introduction and Acceptance

CattleOS Inc. ("CattleOS," "we," "our," or "us") is committed to protecting the privacy and security of your personal information and agricultural data. This Privacy Policy and Ag Data Use Agreement ("Policy") describes how we collect, use, disclose, and protect information when you access or use the CattleOS platform, including our web application, mobile applications, APIs, and all associated services (collectively, the "Platform").

BY ACCESSING OR USING THE CATTLEOS PLATFORM, CREATING AN ACCOUNT, OR CLICKING "I AGREE" OR ANY SIMILAR ACCEPTANCE MECHANISM, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO BE BOUND BY THIS POLICY IN ITS ENTIRETY.

If you do not agree with this Policy, you must immediately discontinue use of the Platform. Your continued use of the Platform following any modifications to this Policy constitutes your acceptance of those changes.

This Policy applies to all users of the Platform, including individual users, business clients, and enterprise partners. It is intended to comply with applicable privacy legislation including Canada's Personal Information Protection and Electronic Documents Act (PIPEDA), Alberta's Personal Information Protection Act (PIPA), and other applicable provincial and international privacy frameworks. This Policy also aligns with the Ag Data Transparent evaluation criteria established by the Ag Data Transparency Evaluator, Inc.

2. Information We Collect

2.1 Account Registration Information

To create and maintain an account on the Platform, we collect the following personal information:

• First name and last name
• Email address
• Phone number

This information is used solely for the purposes of account creation and authentication, and for our team to contact you in connection with your account, including in the event of service disruptions, security incidents, or technical issues affecting your use of the Platform.

2.2 Agricultural Data (Ag Data)

When using the Platform, you have the ability to upload, enter, and manage agricultural data. In this Policy, "Ag Data" refers to the following categories of data that originate from your operation, farm, device, or equipment:

• Livestock Data: animal identification and pedigree, genetic and genomic information, feed consumption, health records, weight measurements, breeding records, calving data, death loss records, and other data related to livestock management.
• Farm Management Data: information related to financial records, regulatory compliance, supply chain, inventory, and other operational management data.
• Land Data: soil and fertility data, topographical data, geospatial information, pasture management data, and conservation data.
• Climate and Weather Data: precipitation, wind speed and direction, temperature, and other weather information relevant to your operation.

These categories are illustrative but not exhaustive of the types of agricultural information the Platform may collect from you. Some types of Ag Data may link to personal information, such as your name, address, or email address. Protection of personal information is addressed throughout this Policy and is subject to applicable privacy laws and regulations.

2.3 Anonymous Usage Data

We collect anonymized, non-personally identifiable data about how users interact with the Platform. This data cannot reasonably be used to identify you and includes:

• Feature usage patterns and navigation flows
• Session duration and frequency of use
• Performance metrics, error logs, and crash reports
• Device type, operating system, and browser type (without identifiers)
• Aggregate behavioral analytics used to improve Platform functionality

This anonymous usage data is collected automatically as part of your use of the Platform for the sole purpose of improving the user experience, optimizing performance, and identifying areas for product development.

2.4 Marketing Communications (Consent-Based)

Where you have expressly opted in to receive marketing communications, we will use your email address to send promotional materials, product updates, agricultural industry insights, and other marketing content from CattleOS. Marketing communications are only sent on the basis of your explicit, freely given, and specific consent as described in Section 5 of this Policy.

2.5 Information We Do Not Collect

CattleOS does not collect the following categories of information unless you explicitly provide them for a specific purpose:

• Payment or financial information (processed directly through third-party payment processors)
• Government-issued identification numbers
• Sensitive personal characteristics or biometric data
• Location data beyond what you voluntarily provide
• Information from minors under the age of 18

3. Ownership of Ag Data

CattleOS believes that you are the owner of Ag Data that originates from your farm, operation, device, or equipment. Ownership gives you the right to control, share, download, and delete your Ag Data at any time while you maintain an active account on the Platform.

You shall not upload data to the Platform unless you are the owner of such data or are authorized to do so. You shall indemnify CattleOS from any claims that someone else owns the Ag Data uploaded to your account.

In order to perform the services provided through the Platform, you grant CattleOS a limited license to use your Ag Data as follows: (1) to clean your Ag Data by removing perceived errors and omissions; (2) to store your Ag Data on servers owned or leased by CattleOS; (3) to share your Ag Data with others as authorized by you; and (4) to use your Ag Data to provide the Platform services to you. This license does not transfer ownership of your Ag Data to CattleOS.

4. How We Use Your Information

We use the personal information and Ag Data we collect only for the following purposes:

• Account creation, authentication, and management
• Providing, maintaining, and improving the Platform and its features
• Delivering agricultural data management, analytics, and benchmarking services to you
• Communicating with you regarding your account, technical issues, or Platform updates
• Responding to your support requests, inquiries, and feedback
• Sending transactional and service-related communications necessary to fulfill our obligations to you
• Sending marketing and promotional communications where you have given explicit consent
• Monitoring Platform performance, identifying bugs, and conducting internal analytics to enhance user experience
• Ensuring Platform security, preventing fraud, and protecting the rights and safety of our users
• Complying with applicable legal obligations

We do not use your personal information or Ag Data for any purpose that is incompatible with the purposes listed above without your prior consent.

5. Consent

5.1 Consent to Data Collection and Platform Use

By accessing or using the CattleOS Platform, you expressly consent to the collection of anonymous usage data as described in Section 2.3. This data is non-identifiable and is collected automatically to improve the quality, reliability, and performance of the Platform on your behalf.

By creating an account, you consent to the collection and use of your account registration information (name, email address, phone number) for account administration and for CattleOS to contact you regarding matters related to your account and the Platform.

5.2 Consent to Marketing Communications

We will only send you marketing emails if you have provided separate, explicit, and freely given consent by checking the marketing opt-in box during registration or by subsequently opting in through your account settings. Your consent to marketing communications is:

• Separate and distinct from your consent to account registration and Platform use
• Entirely voluntary. Declining will not affect your access to the Platform
• Revocable at any time by clicking "Unsubscribe" in any marketing email, or by updating your notification preferences in your account settings
• Subject to applicable anti-spam legislation, including Canada's Anti-Spam Legislation (CASL)

5.3 Withdrawal of Consent

You may withdraw any consent provided under this Policy at any time by contacting us at support@cattleos.com or through the account settings on the Platform. Please note that withdrawal of consent to the collection of account registration information will result in the termination of your account, as this information is necessary for account functionality. Withdrawal of consent to anonymous usage data collection may be requested; however, as this data is non-identifiable, retroactive deletion is not technically feasible.

6. Aggregated Data and Transparency

CattleOS may anonymize and aggregate your Ag Data with data from other users to create aggregated datasets ("Aggregated Data"). Aggregated Data does not contain your personal information and is provided in datasets that are large enough to prevent identification of any individual user or operation.

Opt-Out Right: Aggregated Data sharing is enabled by default. However, you have the option to opt out of inclusion in anonymized and aggregated datasets at any time through your account settings or by contacting support@cattleos.com. Aggregated datasets created prior to your opting out cannot be retroactively modified or deleted. If you opt out, you may lose access to certain benchmarking or comparative features of the Platform that rely on aggregated datasets.

No Sale of Aggregated Data: CattleOS does not sell Aggregated Data to third parties. Aggregated Data may be used by CattleOS for internal research, product improvement, and to provide benchmarking features within the Platform. By signing up for the Platform, you do not give CattleOS the right to sell aggregated data to third parties without obtaining your further consent.

7. Data Sharing and Disclosure

CattleOS does not sell, rent, trade, or otherwise transfer your personal information or Ag Data to third parties for their own commercial purposes.

CattleOS will obtain your consent prior to sharing your Ag Data with any third party, including integrations, government agencies, and others. We may share your information in the following limited circumstances:

• Service Providers and Subcontractors: With trusted third-party service providers who assist us in operating the Platform (e.g., cloud hosting, email delivery, analytics), solely to the extent necessary for them to perform their services. All third-party contractors and subcontractors that have access to user data are required to follow CattleOS's data policies, including the terms of this Policy, and are subject to confidentiality obligations.
• Legal Requirements: Where required by applicable law, court order, or governmental authority, or where we believe disclosure is necessary to protect the rights, property, or safety of CattleOS, our users, or the public. CattleOS will not share your Ag Data with government agencies unless you provide your consent, except where legally compelled. CattleOS shall notify you of any government request to obtain your Ag Data.
• Trusted Advisors: You may grant designated third parties ("Trusted Advisors") access to view, edit, or download your Ag Data. Examples include veterinarians, nutritionists, breed associations, consultants, lenders, and others designated by you. You may revoke their access at any time through the Platform.
• Integrations: With your consent and direction, CattleOS may provide you with the ability to share your Ag Data with other technology providers through integrations. When your Ag Data is transferred or shared with a third party, your use is subject to that third party's policies and contract terms.
• Business Transfers: In connection with a merger, acquisition, financing, or sale of all or a portion of CattleOS's assets, provided the acquirer agrees to honour this Policy. See Section 14 for details.
• With Your Consent: For any other purpose with your prior written consent.

Once Ag Data has been shared outside of the Platform at your direction, CattleOS no longer has control over how a third party may use your Ag Data. CattleOS is not responsible for what a third party does with your Ag Data after you provide your consent to share.

8. Data Portability

CattleOS maintains an original copy of your Ag Data and personal data that can be retrieved or deleted upon your request. You can download your Ag Data at any time as long as you maintain an active account with the Platform. You may also request a copy of your data in a commonly used, machine-readable format by contacting support@cattleos.com. In some circumstances, your Ag Data may not be retrievable in its original format, but CattleOS will make reasonable efforts to provide it in a usable format.

You may delete your Ag Data at any time while you have an active account, and for thirty (30) days after termination of your account. Requests to delete your Ag Data after your account terminates may be made by email request to support@cattleos.com. Deletion of Ag Data will not cause any Aggregated Data to be deleted.

9. Data Storage and Security

CattleOS implements commercially reasonable technical, administrative, and organizational security measures designed to protect your personal information and Ag Data from unauthorized access, use, disclosure, alteration, or destruction. These measures include:

• Encryption of data in transit using TLS/HTTPS protocols
• Encryption of data at rest using industry-standard encryption
• Access controls limiting staff access to personal information and Ag Data on a need-to-know basis
• Regular security assessments and vulnerability monitoring
• Secure cloud infrastructure hosted with reputable, enterprise-grade service providers

While we take reasonable steps to protect your information, no security system is impenetrable. We cannot guarantee the absolute security of your data.

Breach Notification: In the event of a data breach, natural disaster, or other unforeseen event that causes your Ag Data or personal information to be deleted or compromised, CattleOS will notify you by email, by notification when you log in, or by other method required by law. We will also notify applicable regulatory authorities in accordance with our legal obligations.

10. Data Retention

We retain your personal information and Ag Data only for as long as is necessary to fulfill the purposes for which it was collected, including to satisfy legal, accounting, or reporting obligations.

• Account Information: Retained for the duration of your account and for a period of up to 2 years following account closure, unless a longer retention period is required by law.
• Ag Data: Stored as long as you have an active account with CattleOS, and for a period of thirty (30) days after termination. After thirty (30) days following termination of your account, CattleOS will no longer have any obligation to retain your Ag Data.
• Marketing Consent Records: Retained for a minimum of 3 years from the date of consent in accordance with CASL requirements.
• Anonymous Usage Data: May be retained indefinitely as it cannot be linked to any individual.

Upon request for deletion of your account and personal data, we will take reasonable steps to delete or de-identify your personal information in accordance with our legal obligations. If your account with CattleOS terminates and you do not request deletion within thirty (30) days, CattleOS will assume you have abandoned all ownership claims, and may delete your Ag Data or anonymize and aggregate it according to this Policy.

11. Your Privacy Rights

Subject to applicable law, you have the following rights with respect to your personal information and Ag Data:

• Right of Access: You may request a copy of the personal information and Ag Data we hold about you.
• Right to Rectification: You may request that we correct any inaccurate or incomplete personal information.
• Right to Erasure: You may request deletion of your personal information and Ag Data, subject to our legal retention obligations.
• Right to Withdraw Consent: You may withdraw any consent you have provided at any time, as described in Section 5.3.
• Right to Opt Out of Marketing: You may opt out of marketing emails at any time by following the unsubscribe instructions or contacting us directly.
• Right to Opt Out of Aggregation: You may opt out of inclusion in anonymized and aggregated datasets, as described in Section 6.
• Right to Data Portability: You may request your account data and Ag Data in a commonly used, machine-readable format, as described in Section 8.
• Right to Lodge a Complaint: You have the right to lodge a complaint with the applicable privacy regulatory authority in your jurisdiction.

To exercise any of these rights, please contact us at support@cattleos.com. We will respond to your request within 30 days and may require verification of your identity before processing your request.

12. Cookies and Tracking Technologies

The Platform may use cookies, web beacons, and similar tracking technologies to collect anonymous usage information as described in Section 2.3. These technologies help us understand how the Platform is used, remember user preferences, and improve functionality.

You may configure your browser to reject cookies; however, doing so may affect certain features of the Platform. We do not use third-party advertising cookies or sell cookie data to any third party.

13. Notice of Changes

We reserve the right to update or modify this Policy at any time. If we make material changes, we will notify you by:

• Posting the revised Policy on the Platform with an updated "Last Updated" date
• Sending an email notification to the address associated with your account
• Displaying a prominent notice on the Platform at your next login
• Providing a summary of the changes made to this Policy

Your continued use of the Platform following notice of material changes constitutes your acceptance of the revised Policy. If you do not agree to the revised Policy, you must discontinue use of the Platform.

14. Changes in Company Ownership

In the event CattleOS is sold or acquired by another company (meaning at least 51% of company ownership interest is transferred in a single calendar year), you will be notified and have the option of downloading or deleting your Ag Data for at least thirty (30) days after the transfer. This Policy will continue to apply to your Ag Data until the new owner provides you notice of a new data use agreement. The acquiring company must agree to honour the terms of this Policy with respect to your existing Ag Data until such new agreement is in place.

15. Third-Party Links and Integrations

The Platform may contain links to third-party websites or integrations with third-party services. This Policy applies solely to information collected by CattleOS through the Platform. We are not responsible for the privacy practices or content of third-party services. We encourage you to review the privacy policies of any third-party services you access through or in connection with the Platform.

16. International Data Transfers

CattleOS is headquartered in Canada. Your information may be stored and processed on servers located in Canada or other jurisdictions. By using the Platform, you acknowledge and consent to the transfer of your information to jurisdictions that may have different data protection laws than your country of residence. We take appropriate safeguards to ensure your information remains protected in accordance with this Policy wherever it is processed.

17. Children's Privacy

The Platform is not directed to individuals under the age of 18. We do not knowingly collect personal information from minors. If you believe we have inadvertently collected information from a person under the age of 18, please contact us at support@cattleos.com and we will take immediate steps to delete such information.

18. Contact Us

If you have any questions, concerns, or requests regarding this Policy or the handling of your personal information or Ag Data, please contact our Privacy Officer:

We are committed to working with you to resolve any concerns about our privacy practices promptly and fairly.