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Supplemental Privacy Policy EU Residents



AIO Ag, LLC (“AIO”, “we”, “us”, “our”) is committed to protecting your privacy and maintaining the security of any personal information that we receive from you.


This privacy policy is supplemental to our existing Privacy Policy and applies to individuals who are resident in the European Union. In the event of any conflict between this policy and our existing Privacy Policy, the terms of this policy shall prevail.


If either privacy policy changes, we will place an updated version on our website.



The purpose of this policy is to explain to you what personal information we collect and how we may use it.


We are the controller of any personal information which you provide to us which means that we decide the purposes and means of the processing of that personal information.


We obtain your information through agreements, contracts, emails, letters, telephone calls, SMS messages, cookies and conversations when registering for our products and/or services and during the course of our relationship (including information gained when you use our learning tools or websites). Much of the information we obtain about you is provided by you when you decide to establish an agreement and/or contract to work with AIO. At that time, you will be required to complete an application with a grain dealer to whom we introduce business to, generally known as a Grain Dealer and/or Grain Merchant.


We may monitor or record phone calls with you and monitor (and maintain a record of) all emails and electronic communications sent by or to us.


We follow strict security procedures in the storage and disclosure of information that you have given us to prevent unauthorized access.


We or the respective Grain Dealer you have chosen to create a contract with may process the following types of personal information:

  • name;

  • contact details including address, email details and phone numbers;

  • age or date of birth;

  • gender;

  • occupation;

  • assets and income;

  • information received from consumer reporting agencies, such as your credit history and creditworthiness;

  • hedging knowledge and experience;

  • user names and passwords;

  • information relating to your cash grain hedging including your hedging history, activity and cash grain orders

  • IP address;

  • social security number, national insurance number, passport or other MiFIR national identifier;

  • transaction reporting reference;

  • power of attorney / agent details;

  • phone device type;

  • operating system;

  • device ID;

  • cookie ID;

  • Google 360 ID;

  • GUID; and

  • information about your use of our services, products and facilities (including information gained when you use our learning tools or websites).



To comply with applicable regulations, we need to confirm the name and address of our customers and certain third parties. We may ask you to provide physical forms of identity verification when you establish an agreement and/or contract.  Alternatively, we or the respective Grain Dealer you have chosen to create a contract with may use a credit reference agency to verify your identity. Our search is not seen or used by lenders to assess your ability to obtain credit.


As well as checking your identity, the personal information we hold may be used for:

  • considering any of your applications;

  • carrying out risk assessments;

  • complying with our legal and regulatory obligations;

  • performing our obligations under any contract we have with you;

  • administering our relationship with you including resolving queries or issues;

  • establishing and managing your agreement and/or contract;

  • reviewing your ongoing needs;

  • providing you with the information, products and services that you request from us;

  • checking your instructions to us;

  • investigating any complaint you may make;

  • providing evidence in any dispute or anticipated dispute between you and us;

  • recovering amounts payable;

  • training our staff;

  • enhancing our customer service and products;

  • undertaking product development and analysis; and

  • detecting or preventing fraud or other crimes.

Where you have consented to direct marketing, we may send you marketing material from time to time by post, email, telephone, SMS or other electronic messaging services.


We may share your personal information with:

  • any regulatory, law enforcement or tax authority;

  • such third parties as we reasonably consider necessary in order to prevent crime;

  • Grain Dealers whom we introduce business to and who you’ve chosen to create a contract with;

  • third-party service providers and advisers who provide us with administrative, financial, research or other services in connection with the services we provide to you;

  • our commercial partners;

  • our professional advisers;

  • financial service institutions (e.g., advisers, grain dealers, brokers, trust companies and banks) with whom we have joint marketing agreements, such as agreements to market financial services or products that we jointly offer, endorse or sponsor;

  • our auditors for the purposes of carrying out financial and regulatory audits;

  • our agents, including Grain Dealers and credit reference agencies, acting on our behalf, carrying out such credit and identity checks, including money laundering checks, compliance regulatory reporting and fraud prevention checks, as we may reasonably consider necessary or desirable, including requesting a reference from your bank or any credit reference agency. Any third party referred to in this clause may share any personal information concerning you with us and other organizations involved in credit reference, the prevention of fraud and/or crime  and/or  money laundering or for similar purposes  or to recover debts involved;

  • courts, tribunals, regulatory or tax authorities and government agencies to enable us to enforce our agreement with you or to comply with the requirements of a court, regulator, tax authority or government agency;

  • the purchaser or potential purchaser of one or more of our businesses or product/service lines and their professional advisers;


Generally, we require that organizations with whom we share your personal information acknowledge the confidentiality of your data, undertake to respect your right to privacy, and comply with the data protection principles and this policy.


We use cookies and web beacons (also known as action tags or single-pixel gifs), and other technologies (collectively, “cookies”) to provide us with data we can use to improve your experience and to know you better. Cookies are small text files sent from Web servers that may be stored on your computer. Cookies enable us to capture how you arrived at our site, when you return, which pages on our site you visit, and to recognize that you are already logged on when we receive a page request from your browser. We may link the information we store in cookies to personally identifiable information you submit while on our site. We will never share this information with any third party. Cookies are readable only by us and do not contain any personal information nor do they contain account or password information. We cannot and will not gather information about other sites you may have visited.


We may share usage information about visitors to our websites with reputable advertising companies for the purpose of targeting our Internet banner advertisements. The information collected by the advertising company through the use of these pixel tags is not personally identifiable. We may also use third party software to track and analyze usage and volume statistical information including page requests, form requests and click paths. The third party may use cookies to track behavior and may set cookies on behalf of AIO Ag.


All web browsers have settings that allow you to block cookies. By visiting our website with your browser set to allow cookies, you consent to our use of cookies as described above. If you choose to block cookies you may use our services but some functions may not work as designed.


In some cases, we are also provided with your name and contact details by third-party referrers.

We also gather information relating to you and your online behavior:

  • to help optimize our website, to give you a good user experience and to personalize your use and our communications to you;

  • to help us monitor, support and improve the performance of our site (by analyzing your use and experience of our site);

  • to help us understand more about you and the products and services you use and are interested in; and

  • to tailor the online advertising you receive.

Knowing more about you helps us to understand our customers better, which means we can give you recommendations about products and services you may be interested in, and provide you with relevant advertising and customized communications that are of interest to you.


We combine information that you provide to us with information that is publicly available and/or that we receive from third parties such as advertisers and/or other reputable sources who have obtained your permission to do so, or have otherwise explained to you that this may happen.


You should only give us personal information about someone else (such as a joint applicant) with their permission. Where information is provided by you about someone else, or someone discloses information about you, it may be added to any personal information that is already held by us and it will be used in the ways described in this privacy notice. Sometimes, when you open a joint agreement, contract, or product, this may mean that your personal information will be shared with the other applicant. For example, contracts made by you will be seen by your joint account holder and vice versa.


The legal basis for our processing of personal information will depend on why we process your information.


Where you wish to enter into or have signed a contract to receive services from us, we will process your personal information to enable us to enter into and perform our contract with you.  If you don’t provide the personal information requested then we may not be able to provide some or all of those services to you.


Where you use our website, we will process your personal information collected by using cookies in accordance with this policy.


We may also need to process your personal information to comply with our legal and regulatory obligations including in relation to:

  • performing anti-money laundering, terrorism prevention and sanctions screening checks, complaints and investigations or litigation;

  • obtaining information about your relevant hedging knowledge and experience so that we can assess whether a service is appropriate for you;

  • obtaining information about your other hedging activities in order to ascertain your status for the purposes of regulations which apply to establishing purchase or sales contracts with a registered Grain Dealer; and

  • submitting and disclosing reportable data to a Grain Dealer.

We also have a legitimate interest to process your personal information for:

  • performing the services or supplying the products or information you have agreed to receive from us;

  • ongoing management of our relationship with you and to maintain contact with you;

  • our internal business purposes which may include business and disaster recovery, document retention/storage, IT service continuity (e.g. back-ups and helpdesk assistance) to ensure the quality of the services we provide to you;

  • corporate transactions;

  • marketing analytics including marketing campaign optimization and web analytics to enable us to develop and target the marketing of our products and services;

  • keeping our records updated and studying how customers use our products/services;

  • developing our products and services, growing our business and informing our marketing strategy;

  • defining the types of customers for our products and services and keeping our website(s) and platform(s) updated and relevant; and

  • portfolio analysis and experience studies to enable us to improve the products and services we offer to customers.

If you have consented to direct marketing, we will use relevant personal information to enable us to provide you with personal information about products, news and services that may be of interest to you.


All countries in the European Economic Area (“EEA”) have similar standards of legal protection for your personal information. The personal information that we collect from you may be transferred, and stored, outside the EEA. It may also be processed by staff operating outside the EEA who work for us. Such staff may be engaged in, among other things, the fulfilment of your agreement and/or contract, the processing of your payment details and the provision of support services. Where we transfer personal information or share it with others outside the EEA, we will ensure that a similar degree of protection is afforded to it by use of model clauses approved by the European Commission, by transferring to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission or by transferring to third parties who are part of the Privacy Shield.


We shall hold information about you on electronic and/or paper files whilst you are a customer and for at least five years after you cease to be a customer.


If you want help with our Privacy Policy or have questions about it, please contact us by phone at +1-312-300-4070 or by email at


If you are unhappy about any aspect of the way we collect, share or use your personal information, we would like you to tell us.


This section explains your rights in relation to your personal information in more detail. The various rights are not absolute and are subject to certain exceptions or qualifications.

You are entitled to receive personal information free of charge except in the following circumstances where we may charge a reasonable fee to cover our administrative costs of providing the personal information for:

  • manifestly unfounded or excessive/repeated requests, or

  • further copies of the same information.

Alternatively, we may be entitled to refuse to act on the request.


Please consider your request responsibly before submitting it. We will respond as soon as we can. Generally, this will be within one month from when we receive your request but, if the request is going to take longer to accommodate, we will let you know.


In order to exercise any of the rights described below please contact us by phone at +1-312-300-4070 or by email at

Accessing your information


You have the right to:

  • confirmation that your personal information is being processed

  • access to your information, and

  • other certain information (most of which may be in our Privacy Policy).

You can request copies of paper and electronic records about you that we hold, share, or use. To accommodate your request, we can request proof of identity and enough personal information to enable us to locate the personal information you request of us.


We can only provide you with your information, not personal information about another person.  Also, where access would adversely affect another person’s rights, we are not required to provide this.  Due to legal privilege, we may not be able to show you anything that we learned in connection with a claim or legal proceeding.


Please clearly set out in your access request the personal information that you are requesting.  If this is not clear, we may come back to you to ask for further personal information by way of clarification.

Correcting your information

You have the right to obtain from us without undue delay the rectification of inaccurate personal information concerning you.   If you tell us that the personal information we hold concerning you is incorrect, we will review it and if we agree with you, we will correct our records. If we do not agree with you, we will let you know. If you wish, you can tell us in writing that you believe our records still need to be incorrect and we will include your statement when we give your personal information to anyone outside AIO Ag, LLC. You can contact us using the details in the section above in the main body of the privacy notice heading “Obtaining further personal information from us.”


You may also have the right to have incomplete personal information completed, including by means of providing a supplementary statement, whether this is appropriate in any particular case depending on the purposes for which your personal information is being processed.


We need to notify any third parties with whom we have shared your personal information that you have made a rectification request. We will take reasonable steps to do this, but if it is not possible or may involve disproportionate effort, we may not be able to do this or ensure they rectify the personal information they hold.


Generally, if you ask us in writing, we will let you see the personal information that we hold about you, or take steps to correct any inaccurate information.


Due to legal privilege, we may not be able to show you anything that we learned in connection with a claim or legal proceeding.

Erasing your information


You have a right to have your personal information erased, and to prevent processing, where:

  • the personal information is no longer necessary for the purpose it was originally collected/processed;

  • you withdraw consent (where previously provided);

  • you object to the processing and our legitimate interests in being able to keep processing your personal information don’t take priority;

  • we have been processing your personal information in breach of data protection laws; or

  • the personal information must be erased in order to comply with a legal obligation.



The right to erasure does not apply where we are required to retain it for legal or regulatory purposes or where your information is processed for certain specified reasons, including for the exercise or defense of legal claims.

More importantly, if we have to erase your data we may not be able to provide you with our services.


Where we have provided the personal information you want to be erased to third parties, we need to inform them about your erasure request, so they can erase the personal information in question.  We will take reasonable steps to do this, but this may not always be possible or may involve disproportionate effort.


It may also be that the recipient is not required/able to erase your personal information because one of the exemptions above applies.

Restricting processing of your information


You have the right to restrict the processing of your personal information:

  • where you disagree with the accuracy of the information, we need to restrict the processing until we have verified the accuracy of the information;

  • when processing is unlawful, and you oppose erasure and request restriction instead;

  • if we no longer need the personal information but you need this to establish, exercise or defend a legal claim; or

  • where you have objected to the processing in the circumstances detailed in paragraph (A) of “Objecting to processing”, and we are considering whether those interests should take priority.



Where we have disclosed your relevant personal information to third parties, we need to inform them about the restriction on the processing of your information, so that they do not continue to process this.


We will take reasonable steps to do this, but this may not always be possible or may involve disproportionate effort.


We will also inform you if we decide to lift a restriction on processing.

Taking your personal information with you


The right to data portability only applies:

  • to personal information you have provided to us (i.e. not any other information);

  • where the processing is based on your consent or for the performance of a contract; and

  • when processing is carried out by automated means.



We can refuse your data portability request if the processing does not satisfy the above criteria.  Also, if the personal information concerns more than one individual, we may not be able to transfer this to you if doing so would prejudice that person’s rights.

Objecting to processing

You can object to processing in the following circumstances:


You have the right to object, on grounds relating to your particular situation, at any time to processing of personal information concerning you which is based on legitimate interests.


If we can show compelling legitimate grounds for processing your personal information which override your interests, rights and freedoms, or we need your personal information to establish, exercise or defend legal claims, we can continue to process it.  Otherwise, we must stop using the relevant information.


You can object at any time to your personal information being used for direct marketing purposes (including profiling related to such direct marketing).


If you sign up to receive newsletters or other e-mail messages from us, you can opt-out at any time free of charge by clicking the unsubscribe link at the bottom of the message.  You may also choose to opt-out from receiving marketing materials from us via the following methods:

  • Call us by phone at +1-312-300-4070

  • send an email to:

  • send a letter to:

230 W Monroe St
Suite 845
Chicago, IL  60606
United States

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