CHS Global Privacy Notice

Last updated: December 03, 2024

This Privacy Notice covers both CHS online and offline data collection activities, including personal information that we collect through various channels such as websites, applications, contracts, points of sale, and events. As used in this Privacy Notice, CHS includes CHS Inc., CHS Hedging, LLC., CHS Market Advisors, LLC., as well as subsidiaries and affiliates.

Personal information means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked with you.

This Privacy Notice is incorporated as part of the terms of any agreement that you have with CHS. When you use CHS services or otherwise interact with CHS, you acknowledge this Privacy Notice and associated privacy practices, including the use and disclosure of your personal information.

If you do not agree with the terms of this Privacy Notice, please do not use CHS services or provide any personal information. If you decline to provide certain information when requested, CHS may not be able to provide the services for which you have contracted or requested.

Table of Contents

1. What's Covered by this Privacy Notice
2. What Personal Information CHS Collects
3. How CHS collects Personal Information
4. How CHS uses Personal Information
a. Web services
b. Deliver services
c. Marketing
d. Security
e. Comply with legal requirements

5. How CHS uses Cookies
6. How CHS Shares Personal Information with Third Parties
7. Specific Jurisdictions
   a. Brazil
   b. California
   c. China
   d. Colorado
   e. Europe
8. How to Contact CHS Concerning Your Personal Information
a. Shanghai data privacy contact
b. Brazil data privacy contact

9. How Long CHS Keeps Personal Information
10. How You Will be Notified of Changes to this Privacy Notice
11. How CHS Secures Your Personal Information
12. How CHS Handles International Transfers of Personal Information
13. How CHS Manages Children's Privacy

What’s Covered by this Privacy Notice

This Privacy Notice covers any CHS-affiliated website, product, service, or communication that links to it and any collection, storage, transfer, sharing, disclosure or handling of your personal information when you engage with CHS.

This Privacy Notice does not cover, and CHS is not responsible for, third party websites or applications that may be linked from CHS affiliated websites; linking to them does not imply an endorsement. CHS is not responsible for these websites or applications or any information they may collect. You should always review the privacy notice of any third party website or application.

What Personal Information CHS Collects

The following sensitive and non-sensitive personal information may be collected by CHS, depending on the services you requested:

• Identifiers which may include your real name, alias, contact information, video and image, IP address, online identifier, information sent to us by your web browser, email address, account name, website password and username, account registration information, usage data or other similar identifiers
• Background information which may include your professional associations, certifications, work history, and education history
• Financial Information which may include your credit card number, debit card number, corporate card numbers, income, transactions, credit information, taxation information, and other similar financial information
• Demographic information which may include your age, date of birth, race, color, ancestry, national origin, citizenship, religion or creed, marital status, sex, veteran or military status
• Health related information which may include medical conditions, physical or mental disability, genetic information (including familial genetic information), pregnancy or childbirth and related medical conditions
• Commercial information which may include voice recordings and data related to your purchasing, ownership percentage in business, consumer history, personal property and assets utilized for the consideration of a request to purchase products or services
• Information collected from or in connection with credit, know-your-client and other background verifications, including types and amounts of credit, payment history, negative banking items, collection actions, legal proceedings, previous bankruptcy and other credit-related information
• Information collected from or in connection with product/service orders, including proof of income (such as pay stubs or notices of assessment), bank account information, employment details (such as occupation and current or former employers)
• Information provided from or in connection with complaints, inquiries, surveys and customer research
• Information provided to or in connection with your interaction(s) or communication(s) with CHS employees

How CHS collects Personal Information

CHS collects information directly from you or those acting on your behalf when you populate and submit forms, request information, obtain services or products as well as information that is automatically collected from internet or other network activity regarding your interaction with our websites. In addition, CHS may also collect information from external data sources such as service providers, social media, joint ventures, government sources, operating systems and platforms, advertising networks, and data analytics providers.

How CHS uses Personal Information

CHS may retrieve, aggregate, alter or otherwise process your personal information with or without automated means when one or more of the following conditions exist:

• The personal information is provided voluntarily by you or with your consent to its processing. Should you wish to withdraw your consent at any time, contact the CHS Privacy Office.
• The processing is necessary for the performance of a contract with you or in order to take steps at your request prior to entering into a contract.
• The processing is necessary for credit services, including but not limited to, credit protection.
• The processing is necessary for our legitimate business interests which may include to:
  • Maintain books and records
  • Maintain the security and integrity of affiliated websites and systems
  • Enforce the terms and conditions of the Privacy Notice associated with affiliated websites and systems
  • Monitor the use and performance of affiliated websites and systems
  • Provide quality assurance of customer service operations
  • Make product improvements
  • Make product developments
  • Maintain health and safety
  • Continue providing the same or similar products and services during internal or external organizational changes.
• The processing is necessary for compliance with a legal obligation.
• The processing is necessary in order to protect your vital interest or the vital interests of others.
• The processing is necessary for the performance of a task carried out in the public interest.

CHS uses your personal information for the following purposes:

Web services

When we collect information through affiliated websites, CHS uses personal information to:

• Process feedback forms
• Respond to requests for information, questions, or comments
• Provide quality customer service
• Register for industry events
• Fulfill subscription requests
• Fulfill or process orders and invoices

Deliver services

When we deliver services, CHS uses personal information to:

• Process transactions, fulfilling subscriptions, and processing credit applications
• Administer and perform services, including to carry out obligations arising from any agreements entered between you and CHS
• Provide and deliver the information you request, process contributions and send confirmations, technical notices, updates, security alerts, support and administrative messages
• Enter in or perform a contract with you or your company
• Provide communication to customers, consultants, and third parties
• Analyze with the intent to improve performance, services, and fix errors

Marketing

When we tailor advertisements, CHS uses personal information to:

• Provide details about new services or products
• Target marketing and advertising offers to your preferences
• Share and/or disclose information to prospective business partners
• Assist in the development of products, services, and offerings that meet current and future business needs
• Request information or otherwise contact you regarding the business, products, services we offer through our affiliated websites

Security

When we provide necessary security controls, CHS uses personal information to:

• Verify your identity
• Provide physical protection of personnel, hardware, software, networks, and data from unauthorized physical access with video surveillance
• Detect and prevent fraud, security vulnerabilities, or technical issues
• Protect your rights, the rights of CHS, and the rights of others

Comply with legal requirements

While we comply with legal requirements, CHS uses personal information to:

• Enable CHS to process applications for employment to assess your suitability for any position for which you may apply
• Track and report on workplace illnesses and injuries
• Maintain crisis management plans
• Fulfill legal and regulatory or risk management obligations to protect your rights, the rights of CHS, and the rights of others
• To comply with the law and legal processes in which a formal request has been made (e.g., a request from an administrative oversight agency, civil suit, subpoena, court order or judicial or administrative proceeding)
• Defend your rights and property, the rights and property of CHS, and the rights and property of others
• Enforce published Terms of Use and this Privacy Notice
• Respond to claims that the content of a communication violates the rights of another

How CHS uses Cookies

To understand CHS use of Cookies on affiliated websites. See the CHS Cookie Notice.

How CHS Shares Personal Information with Third Parties

CHS may transfer your personal information to worldwide CHS subsidiaries and affiliates, service providers, non-affiliated partners, and joint-venture companies.

CHS shares your personal information with non-affiliated third parties only as disclosed in this Privacy Notice. CHS may share your personal data for the following business purposes to:

• Support internal audit functions with tools for analysis and coordinate with external auditors
• Include in meeting materials and managing reports of violations against CHS code of conduct standards provided to the Board of Directors
• Integrate data from multiple sources for analytics and reporting
• Track products in storage and product delivery via trucks, trains and barges
• Support general accounting purposes (accounts receivable, accounts payable, general ledger) as well as to invoice and process payments for transactions with third parties and required government reporting
• Track and report on workplace illnesses and injuries, for the protection of life, health, and the safety of property, and maintain crisis management plans
• Trade on the financial markets and provide market commentary to subscribers
• Provide remote IT support and workflow management between CHS systems
• Support enterprise-wide business activities and operations specifically as they relate to problem resolution, enterprise change management, ongoing hardware and software inventory, and to provide analytics related to customer service/satisfaction
• Provide office automation tools and other functions that aid and support the global CHS staff to optimized work activities
• Provide secure access to systems and networks
• Monitor network activity and system usage activity to maintain the confidentiality, integrity and availability ("CIA") of personal data
• Document, track and respond to company legal and compliance investigations, lawsuits, and compliance requirements
• Provide relevant information about CHS products and services based on individuals signing up to receive such information
• Provide physical protection of personnel, hardware, software, networks and data from unauthorized physical access and video surveillance
• Procure indirect goods and services for CHS
• Perform due diligence on third parties that CHS may do business with and to conduct business continuity planning
• Fulfill legal obligations as required by government and regulatory agencies
• Support the proposed or actual purchase, sale (including a liquidation, realization, foreclosure or repossession, or sale at bankruptcy), lease, merger, amalgamation or any other type of acquisition, disposal, transfer, conveyance or financing of all or any portion of its business or of any assets or shares of CHS or a division

See section on How CHS Secures Your Personal Information to understand how CHS third parties are required to safeguard personal data.

Specific Jurisdictions

In specific situations, you may be entitled to request the removal of your Personal Information or limit how it is used. You may also have the option to object to its use, receive a copy in a portable format, or request that it be transferred to another organization. If you'd like to explore any of these options, please contact us at privacy@xcslscl.com.

Below is additional information concerning the processing of personal information of prospective and current customers located in specific jurisdictions.

How to Contact CHS Concerning Your Personal Information

If you have any questions, comments, or concerns about this Privacy Notice, or to exercise your rights pertaining to your personal information, please contact the CHS Privacy Office by postal mail, email, telephone or via our online submission form at:

You may be asked to provide such information as name, relationship to CHS, contact information, and nature of the request. This information will only be used for the purpose of verifying your identity and responding to your request. This information will be deleted once your request is completed.

If you wish to appeal a previous refusal to act on a request under any of the data access rights provided, email privacy@xcslscl.com.

How Long CHS Keeps Personal Information

CHS determines the appropriate retention period for personal information before CHS securely destroys it. CHS considers the applicable legal requirements related to the amount, nature, and sensitivity of the information, the necessary purposes previously listed in this Privacy Notice, and the potential risk of harm from unauthorized use or disclosure of your personal information.

In some circumstances CHS may anonymize your personal information so it can no longer be associated with you, in which case CHS may use and share the information without further notice to you.

How You will be Notified of Changes to this Privacy Notice

CHS may change this Privacy Notice from time to time. The updated notice will be posted with the last revised date. You should periodically return to this Privacy Notice to understand current CHS privacy practices. You acknowledge your continued use of CHS services after the updated notice is published and the collection, use, and sharing of your personal information is subject to the updated Privacy Notice.

How CHS Secures Your Personal Information

CHS implements and maintains an information security program which includes technical and organizational measures based on international standards and generally accepted practices.

All CHS vendors who process personal information are required to safeguard data in accordance with the sensitivity of the data the vendor processes.

In the unfortunate event of a security breach involving your personal information, CHS will promptly take remedial actions to minimize any negative impacts to you. Where required by law we will notify you about the incident, potential impacts on you, remedial actions taken by CHS, and report such security breach to the competent government authorities.

CHS follows the Payment Card Industry Data Security Standard (PCI DSS) when handling credit card data.

How CHS Handles International Transfers of Personal Information

Please be aware CHS processes and stores personal information in the United States which may be transferred to and maintained on servers or databases located outside your state, province, country, or other jurisdiction, where the privacy laws may not be as protective as those in your location.

How CHS Manages Children’s Privacy

CHS may collect personal information from children under the age of 18 through affiliated websites, applications, contacts, or point of sale events for the purposes of employment, youth and scholarship programs, customer accounts, credit applications, and other requested services. This information may include name, contact information, family member names, education history, date of birth, demographic information, biometric, photo/video, or social security number depending on the requested services.

If you are a parent or guardian of a child under the age of 18 and would like to exercise their data subject rights on their behalf, please contact the CHS Privacy Office as identified earlier in this Privacy Notice. CHS will work in good faith to honor your request but may be required by law to retain some or all of a child’s personal information.