Privacy Policy

Atlas Agri Solutions Pty Ltd (ACN 637 187 716), a Corporate Authorised Representative (number 001310912) of Balmedie Financial Pty Ltd (ACN 159 803 415, AFS Licence No 434899), and its related bodies corporate, including Maia Technology Pty Ltd (ACN 19 605 252 042) (collectively referred to as “Atlas Ag”, “we”, “our”, or “us”), recognise the importance of protecting the privacy and rights of individuals in relation to their personal information.

This Privacy Policy outlines how we collect, use, store, disclose, and manage your personal information in connection with your interactions with our new consolidated website and our product offerings, including Atlas Carbon, MaiaGrazing, and our upcoming Atlas Grazing product.

We are committed to protecting your privacy and handling your personal information in accordance with the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (the "Act") and other applicable Australian privacy laws. We encourage you to read this policy carefully to understand our practices regarding your personal information.

What is your personal information?

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When used in this Privacy Policy, the term “personal information” has the meaning given to it in the Act. In general terms, it is any information that can be used to personally identify you. This may include your name, address, telephone number, email address, and profession or occupation. If the information we collect personally identifies you, or you are reasonably identifiable from it, the information will be considered personal information.

What personal information do we collect and hold?

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We may collect the following types of personal information:

• Identity and Contact Data: Name, date of birth, gender, profession or occupation, mailing or street address, email address, telephone number, and other identification details (e.g., driver's license number if required for specific services or verification purposes).
• Property and Farm Data: Your property name and address, Property Identification Number (PIN/PIC), farm and business name, property size, farm map information (e.g., paddock layouts, boundaries), and farm operation type.
• Financial and Transaction Data: Your credit card information (processed securely by third-party payment providers; we do not store full credit card numbers on our systems) and account details, subscription information, and purchase history when you sign up for or use an Atlas Carbon, MaiaGrazing, or Atlas Grazing service.
• Product Usage Data (Atlas Carbon, MaiaGrazing & Atlas Grazing):
  • Agricultural Operations Data: Soil data, water usage, photographs taken on your property which contain geo-location data, precise mapping data on your property, land title and company documents (where relevant).
  • Livestock and Grazing Data (MaiaGrazing & Atlas Grazing): Individual animal identification (e.g., ear tag numbers), animal movements, grazing records, health records (e.g., vaccination, medication logs), breeding records, weight data, and other performance metrics.
  • Sensor and IoT Data (Atlas Grazing): Data from on-farm sensors or Internet of Things (IoT) devices integrated with the platform (e.g., weather stations, soil moisture sensors, animal collars, remote feeder data).
  • User-generated Content: Information you upload, post, or input into our services.
  • Third-Party Integration Data: Data received from third-party services or government systems with which you integrate your account (e.g., National Livestock Identification System (NLIS), accounting software, market platforms).
• Communication Data: Information from your interactions with our customer support, including communication content, support ticket details, and feedback from customer surveys and enquiries.
• Technical and Usage Data (collected automatically): IP address, device ID, device type, operating system, browser type, geo-location information, browsing behaviour (e.g., pages visited, features used), error logs, debugging information, and system performance data.
• Other Information: Any additional information relating to you that you provide to us directly through our websites and app, during conversations with our representatives (e.g., over the phone, videoconferences, farm visits), or indirectly through your use of our services.

We may also collect aggregated and anonymised information that does not personally identify you. This includes performance metrics, debugging and device usage information, and generalised grazing data, which we use for service delivery, product development, maintenance, and operational and reporting purposes.

How do we collect your personal information?

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We collect your personal information directly from you unless it is unreasonable or impracticable to do so. This occurs:

• When you register for and use our Atlas Carbon, MaiaGrazing, or Atlas Grazing services, including via our websites, software platforms, or mobile applications.
• During conversations and interactions with our representatives, whether over the phone, via videoconference, at live events, or during farm visits by our specialists.
• When you provide feedback, participate in surveys, or engage in our live webinars.
• When you contact us for support, inquiries, or provide other information directly.

We also collect personal information indirectly from other sources, including:

• Automatically: Through your use of our websites and apps via cookies and similar technologies (as further detailed in our Cookie Policy and the "Cookies" section below), which collect technical and usage data.
• From Third-Party Integrations: When you link your Atlas Ag account with third-party services, applications, or government systems (e.g., NLIS, accounting software, weather data providers), or when data is provided by our business partners.
• From Publicly Available Sources: Such as public registers (e.g., for property title information) or professional profiles, where relevant to our services or for purposes like verifying identity.

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What happens if we can’t collect your personal information?

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If you do not provide us with the personal information described above, some or all of the following may happen:

• You may not be able to access or use the functions of our websites, software platforms and mobile apps, either to the same standard or at all.
• We may not be able to onboard you, or provide the requested services to you.
• We may be unable to tailor the content of our websites or software platform to your preferences, and your experiences of our websites or software platform may not be as enjoyable or useful.

Cookies and similar technologies

In some cases, we collect your personal information and other data through the use of cookies and similar tracking technologies (e.g., pixel tags, web beacons) when you access and use our websites and apps. These technologies enable us to recognise your device, track service usage patterns, and collect technical information for various purposes.

For a more detailed explanation of the types of cookies we use, their purposes, and how you can manage your cookie preferences, please refer to our dedicated Cookie Policy

For what purposes do we collect, hold, use and disclose your personal information?

We collect personal information about you so that we can perform our business activities and functions and to provide the best possible quality of customer service.

We collect, hold, use, and disclose your personal information for the following purposes:

• To provide, operate, maintain, and improve our websites, software platforms, and mobile applications, and to deliver associated services to our customers (e.g., providing you access to our software).
• To facilitate the transition of customers from MaiaGrazing to Atlas Grazing, including managing discounts and data migration processes, and providing ongoing support during the sun-setting period of MaiaGrazing.
• To track eligible activities for Atlas Carbon services to enable submission of your audit, where relevant to our services.
• To answer queries, provide information or advice, and otherwise perform our contractual obligations to our customers.
• To analyse information (including through de-identification or aggregation) to produce aggregate data, insights, derivative materials, and other information that is not personal information, for product development, research, improving our services, and for generating industry benchmarks, reports, or public statements that do not identify any individual or specific farm.
• To assess and improve the performance, functionality, and user experience of our websites, software platforms, and mobile applications.
• To conduct business processing functions including providing personal information to our related bodies corporate, contractors, service providers or other third parties (e.g., a payment processor).
  To ensure compliance where relevant to register your soil carbon project with the clean energy regulator; and to track your eligible activities to enable submission of your audit (e.eg, the Clean Energy Regulator).
• To update our records and keep your contact details up to date.
• To process and respond to any complaint made by you.
• To comply with any law, rule, regulation, lawful and binding determination, decision or direction of a regulator, or in co-operation with any governmental authority of any country.
• To send you direct marketing communications about our services, where you have consented or where permitted by law (as detailed in the "Direct marketing materials" section below).

Your personal information will not be shared, sold, rented, or disclosed other than as described in this Privacy Policy.

To whom may we disclose your information?

We may disclose your personal information to:

• Our Group Entities and Personnel: Our employees, related bodies corporate (within the "Atlas Ag" group), and their personnel, for the purposes of operating our websites, apps, and business, and providing services to you.
• Service Providers and Contractors: Third-party contractors or service providers who assist us in delivering our services or operating our business. This includes, without limitation, web hosting providers, IT systems administrators, mailing houses, couriers, payment processors, data entry service providers, electronic network administrators, data analytics providers, and customer support platforms.
• Professional Advisors: Such as accountants, solicitors, business advisors, and consultants.
• Business Partners and Integrations: Suppliers, government bodies, or other third parties with whom we have commercial relationships or integrate our services (e.g., for carbon project registration, livestock identification, or financial management), but only where necessary to provide you with a requested service or with your explicit consent.
• Other Organisations with Consent: Any organisation for any authorised purpose with your express consent.
• Law Enforcement and Regulators: Any third parties to the extent permitted or required by law, regulation, search warrant, subpoena, or court order (e.g., to a regulator for compliance purposes).

We may combine or share any information that we collect from you with information collected by any of our related bodies corporate (within Australia). No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All other categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

Direct marketing materials

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We may send you direct marketing communications and information about our services that we consider may be of interest to you. These communications may be sent via email and SMS in accordance with applicable marketing laws, such as the Spam Act 2003 (Cth).

You consent to us sending you those direct marketing communications. If you indicate a preference for a method of communication, we will endeavour to use that method whenever practical to do so. In addition, at any time you may opt-out of receiving marketing communications from us by contacting us (see the details below) or by using opt-out facilities provided in the marketing communications.

We do not provide your personal information to other organisations for their direct marketing purposes.

How can you access and correct your personal information?

You may request access to some of your personal information stored on the software platform by using the applicable software platform (for Atlas Carbon and/or MaiaGrazing and/or Atlas Grazing). If any of your information stored on the software platform is not correct, we encourage you to, in the first instance, attempt to correct the information using the functionality of the software platform.

Subject to the previous paragraph, you may request access to any personal information we hold about you at any time by contacting us (see the details below). Where we hold information that you are entitled to access, we will try to provide you with suitable means of accessing it (for example, by mailing or emailing it to you). We may charge you a reasonable fee to cover our administrative and other reasonable costs in providing the information to you. We will not charge for simply making the request and will not charge for making any corrections to your personal information.

There may be instances where we cannot grant you access to the personal information we hold. For example, we may need to refuse access if granting access would interfere with the privacy of others or if it would result in a breach of confidentiality. If that happens, we will give you written reasons for any refusal.

Subject to the first paragraph of this section, if you believe that personal information we hold about you is incorrect, incomplete, or inaccurate, then you may request us to amend it. We will consider if the information requires amendment. If we do not agree that there are grounds for amendment then we will add a note to the personal information stating that you disagree with it.

Your Rights

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In addition to your rights to access and correct your personal information as outlined above, you may have other rights regarding your personal information depending on your location and applicable privacy laws. These rights may include:

• Right to Erasure (Right to be Forgotten): The right to request the deletion of your personal information in certain circumstances.
• Right to Restriction of Processing: The right to request that we limit the processing of your personal information in certain situations.
• Right to Object: The right to object to the processing of your personal information for certain purposes, including direct marketing.
• Right to Data Portability: The right to receive your personal information in a structured, commonly used, and machine-readable format and to transmit that data to another controller.

Where applicable (e.g., for individuals in the European Union or United Kingdom under GDPR), these rights will be recognised and facilitated. If you wish to exercise any of these rights, please contact us using the contact details provided below. Please note that exercising certain rights may affect our ability to provide you with some or all of our services.

Transacting Anonymously or Using a Pseudonym

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Where practicable, we will give you the option of not identifying yourself or using a pseudonym when interacting with us. You acknowledge that if you don't provide us with personal information, we may be unable to provide you with access to certain sections of the Services or effectively respond to your query.

What is the process for complaining about a breach of privacy?

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If you believe that your privacy has been breached, please contact us using the contact information below and provide details of the incident so that we can investigate it.

We request that complaints about breaches of privacy be made in writing, so we can be sure about the details of the complaint. We will attempt to confirm as appropriate and necessary with you your understanding of the conduct relevant to the complaint and what you expect as an outcome.

We will inform you whether we will conduct an investigation, the name, title, and contact details of the investigating officer and the estimated completion date for the investigation process.

After we have completed our enquiries, we will contact you, usually in writing, to advise the outcome and invite a response to our conclusions about the complaint. If we receive a response from you, we will assess it and advise if we have changed our view.

If you are not satisfied with the way your privacy-related complaint is handled by us, you may refer your complaint to the Office of the Australian Information Commissioner (OAIC). Details of how to lodge a complaint with the OAIC may be found at www.oaic.gov.au or by calling 1300 363 992.

Do we disclose your personal information to anyone outside Australia?

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We may store and process your personal information in locations outside the country in which you reside. Our primary servers for providing the Services are located in Australia. However, we may transfer personal information to, and store it with, our related bodies corporate or third-party service providers located in other countries, including but not limited to:

• United States of America
• United Kingdom
• Countries within the European Economic Area (EEA)
• Other regions where our service providers operate.

When we transfer your personal information outside Australia, we take reasonable steps to ensure that the overseas recipient handles your personal information in accordance with the Act and the Australian Privacy Principles. This may include using contractual clauses (such as standard contractual clauses approved by relevant authorities) or relying on other legal mechanisms to safeguard your data.

By providing your personal information, you consent to its transfer to, and storage in, these overseas locations.

Data Retention

We retain your personal information for as long as necessary to provide you with our services, fulfil the purposes outlined in this Privacy Policy, and as required by applicable laws and regulations.

The specific retention periods depend on the type of data and the purpose for which it was collected:

• Customer Account Data: Retained for the duration of your active subscription and for a period thereafter as required for legal, tax, and audit purposes, or to facilitate re-engagement.
• Farm Data (including MaiaGrazing data): Retained while you are an active user of our services. Upon termination of your service for MaiaGrazing, you will have the opportunity to migrate your data to Atlas Grazing or export it. Data not migrated or exported will be retained for a limited period (e.g., 30-90 days) to allow for recovery or final export, after which it will be de-identified or securely deleted, unless a longer retention period is required by law.
• Atlas Grazing Data: Retained for the duration of your active subscription and for a period thereafter as required for legal, tax, and audit purposes.
• Support & Communication Data: Retained for a period sufficient to manage ongoing inquiries, maintain service quality, and for legal record-keeping.
• Transaction Records: Retained for a minimum period required by Australian tax and financial laws (typically 7 years).
• Website Usage & Analytics Data: Retained for a period necessary for analysis and service improvement, often in an aggregated or de-identified form.
• Job Applicant/Employee Data: Retained in accordance with workplace and privacy retention obligations.

We will securely delete or de-identify your personal information when it is no longer needed for these purposes or legally required to be retained.

Security

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We take reasonable steps to protect your personal information from misuse, interference, and loss, as well as from unauthorised access, modification, or disclosure. We may hold your information in either electronic or hard copy form. Personal information is destroyed or de-identified when no longer needed.

Our security measures include:

• Technical Safeguards: Implementing encryption for data in transit and at rest, maintaining firewalls, and using secure server infrastructure.
• Organisational Controls: Restricting access to personal information to authorised personnel on a need-to-know basis, and using multi-factor authentication (MFA) where appropriate.
• Physical Security: Securing physical access to our premises and data centers.
• Regular Monitoring: Regularly monitoring our systems for vulnerabilities and potential security breaches.

While we strive to protect your personal information, the internet is inherently insecure. We cannot provide any absolute assurance regarding the security of information you communicate to us online. Accordingly, any personal information or other information which you transmit to us online is transmitted at your own risk.

Links to Third-Party Websites

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Our websites and apps may contain links to other websites operated by third parties. We make no representations or warranties in relation to the privacy practices of any third-party website and we are not responsible for the privacy policies or the content of any third-party website. Third-party websites are responsible for informing you about their own privacy practices.

Contacting us

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If you have any questions about this Privacy Policy, any concerns, or a complaint regarding the treatment of your privacy or a possible breach of your privacy, please use the contact details below:

Email: hello@atlasag.ag

We will treat your requests or complaints confidentially. Our representative will contact you within a reasonable time after receipt of your complaint to discuss your concerns and outline options regarding how they may be resolved. We will aim to ensure that your complaint is resolved in a timely and appropriate manner.

Changes to our privacy policy

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We may change this Privacy Policy from time to time. Any updated versions of this Privacy Policy will be posted on our website. We review this policy annually and will notify you of any significant changes affecting your rights. Please review it regularly. Your continued use of our services after any changes to this Privacy Policy constitutes your acceptance of the revised policy.