1.Personal information we collect
We collect personal information about you from different sources listed below.

Personal information you provide to us

• Account information: When you register for the BX Hub ( for example as a grower, exporter, produce partner, retailer or brand) and create an account, we collect your first and last name, username, email address, password, phone number, farm name, farm address and/or location and job role.
• Profile details and farm information: we may collect additional details about the farm, including information about field and farming practices (including current and historical practices) which you provide through the App. You may provide this information directly or through other tools such as an API connecting with our App.
• Marketing information: When you register your choices for receiving communications about our activities and publications, we store this information.

  Information Collected via automated means

• Device data: We collect information about your device such as your mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, and general location information such as city, state or geographic area.
• Usage data: When you access and use the App, we receive and store information about interactions with our App, including pages or screens you viewed, how long you spent on a page or screen, browsing history, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access, and whether you have opened our marketing emails or clicked links within them.

  We collect personal information automatically via cookies or similar technologies on our App (collectively referred to as “Cookies”), including for conducting analytics. For more information on our use of Cookies, please read our Cookie Policy.

  Information We Receive from Third Parties

  We may receive information about your farm, including personal information, from third parties such as exporters or produce partners. They process your personal information in accordance with their own privacy policies. Please review these policies carefully before using their services.

  2. How we use your personal information?

  We will use your personal information for one or more of the purposes set out below.

   

• Providing you with the BX Hub. We use your personal information to operate, maintain and provide you with the BX Hub. In particular, BX provides you with the BX Hub to enable you to capture data to plot and track your farm’s regenerative journey and share this information with your partners. The personal information we process when doing so includes your account information and profile details.

   

• Providing you with support and to respond to your requests and complaints. If you reach out to us for support, we use your personal information to respond and resolve your queries and facilitate support. The personal information we process when doing so includes your correspondence with us, your contact details, and to the extent applicable other personal information processed about you when you use our App. We use this information to perform our contract with you or when it is in our legitimate business interests to do so.

   

• Communicate with you about the BX Hub. When we need to perform our contract with you or when it is in our legitimate interests, we will communicate with you about the BX Hub including by sending you announcements, automated reminders, updates, security alerts, and support and administrative messages. The personal information we process when doing so includes your account information and usage data.

   

• To administer surveys. We may also use your personal information to administer a contest, survey or other feature we offer on our App.

   

• Improve or monitor usage of our App and to protect, investigate and deter against fraudulent, harmful, unauthorised or illegal activity. It is in our legitimate interests to improve our App and customer service and to keep our App safe for our users, which includes conducting troubleshooting, testing and research and to keep the App secure. When doing so we may use personal information that we automatically collect about you such as usage and device information.

   

• To measure performance of our App. When it is in our legitimate interests to do so, we use your personal information that we automatically collect about you or that is generated about you when you use the App for analytics and measurement to understand how our services are used, such as analysing data about your visits to the BX Hub to optimise product design.

   

• To personalise your experience and use of the BX Hub. When it is in our legitimate interests to do so, we use your personal information to provide you with tailored advice for your farm and fields on regenerative practices which may benefit you, your farm and the environment. When doing so, we will process personal information your account information, as well as personal information that we automatically collect about you.

   

• Direct marketing. Except where consent is required, unless you have opted out of receiving marketing communications, it is in our legitimate interests to use your personal information to communicate with you regarding our BX Hub, promotions, events, and other news, products or services we think will be of interest to you. You can opt out of such communications by following the unsubscribe mechanism on any communication, or by otherwise emailing us at optout@bx.tech.

   

• To enforce the Terms and Conditions, to comply with legal obligations and to defend BX against legal claims or disputes. To comply with our legal obligations and to enforce our terms and policies, to ensure the integrity of our App and to defend ourselves against legal claims or disputes, we will use the personal information relevant to such a case. Some processing may also be necessary to comply with a legal obligation placed on BX, for example to keep records of transactions, or as requested by any judicial process or governmental agency. In these circumstances, we will process your personal information to either perform our contract with you, to comply with a legal obligation or when it is in our legitimate business interests.

   

• For anonymization and aggregation. It is in our legitimate interests to aggregate or anonymize personal information in a form that does not allow you to be personally identified and use the resulting information for statistical analysis regarding the use of the BX Hub, such as to better understand our customer base, or for other purposes.

  We only rely on legitimate interest as a legal basis when such legitimate interests are not overridden by your interests or your fundamental rights and freedoms and we ensure we comply with any request you make to exercise your rights.

  If, where we are processing your personal information to perform our contract with you, you do not provide the personal information, we may not be able to conclude or fulfill such contract.

  3. Do we disclose your information to third parties?

  We do not sell, trade, or otherwise transfer to third parties, your personal information, unless to the following recipients and in the following circumstances:

• Other users. We may share your personal information with other users of the App, such as retailers. Our App allows you to control who your data is shared with.

   

• Service Providers: We rely on trusted third parties who assist us in providing the BX Hub and for the purposes as set out above, such as providers of website analytics, hosting and cloud computing services, marketing and other administrative services.

   

• Advisors: We work with various advisors, including tax consultants and legal advisors, with whom we may share your personal information.

   

• Legal: We may also disclose your personal information to law enforcement agencies, regulatory bodies, public authorities or pursuant to the exercise of legal proceedings if we are legally required to do so, or if we believe, in good faith, that such disclosure is necessary to comply with the law, enforce our polices, the Terms & Conditions, to protect our or others’ rights, property or safety or for the purposes of preventing or detecting an unlawful act.

   

• Business Transaction: if BX is involved in a merger, acquisition or asset sale, financing due diligence, reorganisation, bankruptcy, receivership, sale of company assets, or transition of service to another provider, your personal information may be sold, transferred or otherwise shared including as part of any due diligence process.

  4. Your rights and choices

  Depending on your location you may have the following rights, as provided under applicable law and subject to any limitations in such law:

• access the personal information we hold about you;
• request we correct any inaccurate personal information we hold about you;
• request we delete any personal information we hold about you;
• restrict the processing of personal information we hold about you;
• object to the processing of personal information we hold about you;
• withdraw your consent to the processing of personal information we hold about you, when we have relied on consent as the legal basis to process your personal information; and/or
• receive any personal information we hold about you in a structured and commonly used machine-readable format or have such personal information transmitted to another company.

  Please note that, prior to any response to the exercise of such rights, we will require you to verify your identity. Depending on where you reside, you may be entitled to empower an “authorized agent” to submit requests on your behalf. We will require authorised agents to confirm their identity and authority, in accordance with applicable laws.

  You are entitled to exercise the rights described above free from discrimination. In addition, we may have valid legal reasons to refuse your request, and will inform you if that is the case. For more information on your rights, please contact us using the details in the “Contact Us” section below.

  5. International data transfers

  We may transfer your personal information to our service providers who are located outside of the United Kingdom (“UK”) and the European Economic Area (“EEA”), such as to the United States which may not provide the same protections as the data protection laws where you are based. When we do so, we will ensure that relevant safeguards are in place to afford adequate protection for your personal information and we will comply with applicable data protection laws, in particular if you reside in the UK or the EEA by relying on a UK government adequacy regulation or adequacy decision by the European Commission, on contractual protections for the transfer of your personal information or a derogation if available. For more information about how we transfer personal information internationally, please contact us as set out in the “Contact Us” section below.

  6. Children’s privacy

  Our App is not directed to children, and we do not knowingly collect personal information from anyone under the age of 18. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us as set out in the “Contact Us” section below. If we become aware that we have collected personal information from children without verification of parental consent, we take steps to remove that information from our servers.

  7. Retention of personal information

  We retain your personal information only for as long as is necessary to fulfil the purposes for which it was collected and processed, in accordance with our retention procedures, and in accordance with applicable laws or until you withdraw your consent (where applicable).

  To determine the appropriate retention period for your personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we use your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements. Generally, we retain your account information for 2 years after you close your account.

  8. Security of personal information

  We use reasonable organizational, technical and administrative measures, including password and two-factor authentication, designed to protect against unauthorised access, misuse, loss, disclosure, alteration and destruction of personal information we process. Unfortunately, data transmission over the internet cannot be guaranteed as completely secure. Therefore, while we strive to protect your personal information, we cannot guarantee its security.

  9. Do Not Track

  Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

  10. Links to Other Sites

  The App may contain links to other sites that are not operated by us. If you click a third party link, you will be directed to that third party’s site. We strongly advise you to review the privacy policy of every site you visit.

  We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

  11. Changes and Updates to this Policy

  We will update this Policy from time to time. You are advised to review this Policy periodically for any changes. Changes to this Policy are effective when they are posted on this page.

  If we make material changes, we will let you know.

  12. Complaints

  If you have a concern about our privacy practices, including the way we handled your personal information, please contact us at privacy@privacy@bx.tech . We will endeavour to respond to your complaint as soon as possible. You can also report it to your local data protection authority that is authorised to hear those concerns

  13. Contact Us

  BX Technologies Limited is the entity responsible for the processing of your personal information in connection with the App, and is the controller in respect of such processing in connection with UK and EEA data protection laws.
  If you have any questions or comments about this Policy, our privacy practices, or if you would like to exercise your rights with respect to your personal information, please contact us by email at privacy@bx.tech or at Runway East Borough Market, 20 St. Thomas Street, London, SE1 9RS.