Last updated: March 26th, 2020
This Notice covers both our online and offline data collection activities, including personal information that we collect through our various channels such as websites, applications, contracts, points of sale and events. As used in this Policy, CHS includes CHS Inc. and its subsidiaries and affiliates.
We collect personal information that you provide us voluntarily or consent to its collection. Personal information means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a consumer or household. We will process your personal information when one or more of the following conditions exist: (i) with your consent, or (ii) to perform or enter into contracts with you, or (iii) in conformance with our legitimate business interests (maintaining our books and records, maintaining the security and integrity of affiliated websites and our systems, enforcing the terms and conditions and Privacy Notice associated with affiliated websites and our systems, monitoring the use and performance of affiliated websites and our systems, quality assurance of our customer service operations, and product improvement and development), or (iv) to comply with legal obligations. Where processing is based on consent, you have the right to withdraw your consent at any time. To withdraw your consent, contact the CHS Privacy Office in writing per the ‘How to contact us with requests concerning your personal information’ section of this Notice.
This Notice is incorporated as part of the terms of any agreement that you have with CHS. When you use our services, you acknowledge this Notice and our privacy practices, including our use and disclosure of your personal information.
If you do not agree with the terms of this Notice, please do not use our services or provide any personal information.
If you decline to provide certain information when requested, we may not be able to provide the services for which you have contracted or requested.
What’s covered by this Notice
This Notice covers any CHS-affiliated site, product or service that links to this Notice and any collection, storage, transfer, sharing, disclosure or handling of your personal information when you use our services.
This Notice does not cover, and we are not responsible for, third-party websites or applications that may be linked from our affiliated websites; linking to them does not imply an endorsement. We are 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.
Personal information CHS collects
The following personal information is collected by CHS:
- Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers;
- Financial Information such as credit card number, debit card number CENEX Card numbers, income, transactions, credit information, taxation information, and other similar financial information;
Demographic information such as age, race, color, ancestry, national origin, citizenship, religion or creed, marital status, sex, veteran or military status;
- Health related information such as medical conditions, physical or mental disability, genetic information (including familial genetic information), pregnancy or childbirth and related medical conditions; and
- Commercial information such as records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Purpose of collecting personal information and data processing activities
Regardless of any opt-out you may have chosen, CHS may use your personal information for any of the following purposes:
We use personal information collected through affiliated websites for the purpose of:
- Processing feedback forms;
- Responding to requests for information, questions, or comments;
- Registering for industry events;
- Fulfilling subscription requests; and to
- Fulfill or process orders and invoices.
We use personal information to deliver services including, but not limited to:
- Processing transactions, fulfilling subscriptions, and processing credit applications;
- Administer and perform our services, including to carry out our obligations arising from any agreements entered between you and us;
- 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 our contract with you or your company;
- Enable us to perform our obligations and offer our services and provide communication with our clients, third party business partners and/or service providers; and
- Analyze with the intent to improve performance, services, and fix errors.
We use personal information to tailor advertisements, to include, but not limited to:
- Provide details about new services or products. We will always include an option for you to opt-out of such communications;
- Target marketing and advertising offers;
- Share and/or disclose information to prospective business partners and for other lawful purposes;
- Better understand you and our clients’ services and business requirements and to better understand our business and develop our products, services and offerings; and
- Request information or otherwise contact you regarding the business, products, services or affiliated websites.
Security We use personal information to provide necessary security controls including, but not limited to:
- Validate your personal information to verify your identity;
- Detecting, preventing or otherwise addressing fraud, security, or technical issues; and
- Otherwise protect our rights and the rights of other site users, third party business partners, clients or service providers.
Comply with legal requirements
We use personal information to comply with legal requirements including, but not limited to:
- Enable us to process applications for employment and to assess your suitability for any position for which you may apply;
- Fulfill our legal and regulatory or risk management obligations or to protect the rights of our company, business partners, service providers, clients and other website users.
- Complying with the law and/or legal process 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);
- Defending our rights and/or property or the rights and property of others;
- Responding to claims that the content(s) of a communication violates the rights of another.
Information about affiliated websites usage and electronic messages we send
To learn more about Google Analytics and how to opt out, please visit www.google.com/policies/privacy/partners/.
CHS does not use automatic decision-making or engage in profiling.
Third-party data sources
CHS may leverage external data sources in order to provide context and background on the users of its services in order to improve customer experience, mitigate fraud or malicious activity or comply with internal company and external regulatory requirements.
We also use the services of, and share your personal information with, third-party service providers to publicize and accept applications for available career and intern positions with CHS and member cooperatives.
Sharing personal information with Third Parties
CHS does not sell your personal information to third parties, but if we ever intend to, we will give you notice and you will have the opportunity to direct us not to sell your personal information. We will not sell personal information of minors under 16 years of age without affirmative authorization.
We share your personal information with non-affiliated third parties only as disclosed in this Notice. Regardless of any opt-out you may have chosen, CHS may transfer your personal information to:
- Worldwide CHS subsidiaries and non-affiliated partners and joint-venture companies to assist us in providing, maintaining and operating our services or marketing. These companies are required to comply with the principles set out in this Notice, and only use such information for the purposes for which it was provided to them;
- A third-party, in the event of a 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 our business or a division thereof in order for you to continue to receive the same or similar products and services from the third-party. In such an event, we will provide notice of any material change to this Notice or our products and services, in the manner described in this Notice. In these circumstances, personal information may be shared with the actual or prospective purchasers or assignees or with the newly-acquired business.
- While we do not provide your personal information to third parties for their use in marketing, California residents have the right to opt-out of such use of your personal information if it occurs.
Rights for residents of California
Under certain circumstances, and as required by law, you may have the right to:
Consumer right of disclosure and access.
Consumers have the right to request disclosure of their personal information and to receive additional details regarding their personal information collected, our purposes for such collection, and the categories of third parties with whom we have shared or sold their personal information. Consumers may only request twice a year such disclosures regarding their personal information that we collect and only for a 12 month look-back. Please see the next section for information on requesting your personal information.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights, including requests to delete your personal information). Identity verification is a necessary security measure to ensure personal information is not disclosed to any person who has no right to receive it. In addition, you may designate an authorized agent to make a request pursuant to your rights by contacting our Privacy Office.
Consumer data request process.
If we receive a verifiable request from you, we will promptly take steps to deliver a copy of the personal information that we have collected about the consumer. The information may be delivered by mail or electronically, and if provided electronically, the information shall be in a portable and, to the extent technically feasible, in a readily useable format that allows the consumer to easily transmit this information to another entity. Unless otherwise required by applicable law, the required information will be delivered within 45 days for California residents after the date of receiving the request from the consumer, unless we provide notice and a reason why more time is needed, in which case we will deliver the requested information no later than 90 days after your initial request for California residents.
Consumer right to be forgotten.
Consumers have the right to deletion of their personal information collected by us subject to the following exceptions:
- Information necessary to complete transactions or perform contract;
- Information used to detect data security incidents and protect against malicious, fraudulent or illegal activity;
- Information used to protect against illegal activity and/or comply with legal obligations and or applicable laws; or
- Information used to enable internal purposes that are reasonably aligned with the expectations of the consumer based upon the consumer’s relationship with us.
Your rights in connection with your personal information if you live in the European Economic Area, Switzerland, or the United Kingdom.
Under certain circumstances, and as required by law, you may have the right to:
- Request access to your personal information;
- Request correction of any incomplete or inaccurate personal information that we hold about you;
- Request erasure of your personal information when there is no need for us continuing to process it or you have exercised your right to object to processing (see below);
- Object to processing of your personal information or withdraw your consent to processing;
- Request the restriction of processing of your personal information to suspend the processing, for example if you want us to verify its accuracy or the reason for processing it; or
- Request the transfer of your personal information to another party.
If you want to exercise any of these rights, please contact the CHS Privacy Office in writing per the ‘How to contact us with requests concerning your personal information’ section of this Notice. Valid requests will be honored within 30 calendar days of request.
If you are located in the European Union (EU), you have the right to lodge a complaint with the EU Supervisory Authority in your country of residence. However, if you have a complaint regarding the processing of your personal information, we request that you first contact the CHS Privacy Office, and we will reply on a timely basis.
As it pertains to users of our services who are located in the EU, the controller of your personal information is CHS Inc., 5500 Cenex Drive, Inver Grove Heights MN 55077 USA.
How to contact us with requests concerning your personal information.
To request copies of or deletion of your personal information, or if you have any questions, comments or concerns about this Privacy Notice, please contact our Privacy Office by postal mail, email, telephone or online at:
Attn: Privacy Office
5500 Cenex Drive
Inver Grove Heights, MN 55077 USA
If you have a question or concern regarding your individual rights, email the CHS Privacy Team at:Contact CHS
You have a right not to receive discriminatory treatment by CHS for the exercise of the privacy rights contained in this Privacy Notice and as required by law.
How long we keep your personal information
To determine the appropriate retention period for information before we securely destroy it, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of your information, the purposes for which we process your information and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymize your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
How you are notified of changes to this Notice
We may change this Notice from time to time. If we do, we will post the updated Notice with the last revised date. A notice will be made through our affiliated websites via the contact information you provided to us whenever this Notice is changed in a material way. You acknowledge that your continued use of our services after we publish or send a notice about our changes to this Notice means that the collection, use and sharing of your personal information is subject to the updated Notice. You should periodically read the Notice to understand our privacy practices.
Security of your personal information
We have implemented technical and organizational measures designed to provide appropriate levels of security of your personal information.
International transfers of personal information
Please be aware that the personal information we collect 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. If you are located outside of the United States, please be advised that we process and store personal information in the United States. CHS has executed the EU Standard Contractual Clauses to safeguard your personal information if transferred outside of the EU.