PRIVACY POLICY

1. Who we are and who is responsible for privacy

The Hutter Platform is operated by The Hutter Ltd., a company in Alberta, Canada. For PIPEDA and Alberta's PIPA, The Hutter Ltd. is the organization responsible for the personal information described in this policy.

Our Privacy Officer is the person responsible for privacy. You can reach the Privacy Officer at info@thehutter.com, or by writing to The Hutter Ltd., Alberta, Canada.

This policy explains what we collect, why, how we use and share it, how long we keep it, and how you can exercise your rights.

2. What this policy covers

This policy covers personal information we handle when you visit or use the platform, register for an account, buy or sell, connect a device, use Hutter AI, or contact us.

It does not cover a third-party website or service you reach through a link, or information a colony or school uploads under its own agreement with the people it serves. In those cases the colony or school decides how the information is used, and you should ask it about its practices.

3. What we collect, by role

• Account and contact details — name, email address, telephone number, mailing address, province or state, organization name, and the role you register for.
• Sign-in and security details — a hashed password, session cookies, and records of sign-in, verification and account changes.
• Colony and member records — the records a colony enters about its people, operations, livestock, crops, equipment and finances, including the name and role of a member the colony authorizes.
• Orders and payments — what was bought or sold, delivery details, invoices and a payment record. Full card details are handled by our payment processor; only the last four digits may be stored.
• Marketplace and trade records — listings, offers, inquiries, contracts and messages between the parties.
• Supplier, vendor and carrier records — business details, insurance or licence information where a feature requires it, and the people who act for the business.
• Professional and government records — the identity and credentials you give us when you apply for a professional or government role, and the records of the program you use.
• Device and sensor data — device identifiers, gateway details, readings, and camera stills where a camera is connected.
• Health and school records — health information a colony chooses to record, and education records a school or colony records about a student.
• AI content — the text, images and documents you submit to Hutter AI, and the responses it produces.
• Usage and technical data — pages visited, features used, browser and device type, the approximate region indicated by the network address, and error and security logs.
• Communications — messages sent through the platform and correspondence with us.
• Information you give us about other people — for example a contact person at a supplier. Make sure you are allowed to give it to us.

4. Why we collect it (identifying purposes)

We collect personal information for these purposes: • to create and secure your account and verify your identity • to run the portal or feature you use, and show records to the people you authorize • to process orders, payments, invoices and refunds • to send the messages you need — verification codes, confirmations, receipts, account notices and security alerts • to provide Hutter AI and keep a record of how it was used • to keep an audit trail and to detect, investigate and prevent fraud, abuse and security incidents • to comply with the law, respond to lawful requests and enforce our terms • to support you and answer your questions • to measure and improve the platform

We do not use your personal information for advertising, and we do not sell it.

5. Consent

We collect, use and disclose personal information with your consent, or as the law permits without consent. Consent can be express (for example, when you tick a box or sign up) or implied by the circumstances (for example, when you ask us to deliver an order and we give your address to a carrier).

When you accept the terms at signup, we record your acceptance: the version, the time, and the browser and network address the request came from. That record is the evidence of the consent you gave.

You may withdraw consent at any time, subject to reasonable notice, legal restrictions and contractual obligations. If you withdraw consent for information we need to run the service, we may not be able to keep providing it. To withdraw consent, contact the Privacy Officer.

We do not make a service conditional on consent to something that is not necessary to provide it.

6. Limiting collection

We collect only the personal information we need for the purposes described, and we collect it by fair and lawful means.

We do not collect a government identification number, biometric data or financial account details unless a law or a regulated feature genuinely requires it, and then we tell you why.

You may choose not to provide some information. If the information is needed for a feature, that feature may not work.

7. Limiting use, disclosure and retention

We use personal information only for the purposes described in this policy, or for a purpose you consent to. We do not sell personal information, we do not use it for advertising, and we do not share it with another colony.

We disclose personal information only: • to the service providers described below, under contract, and only as needed to run the platform • to another party to a transaction you take part in, where the transaction requires it (for example a seller and a carrier) • to a government authority, court or regulator where the law requires it or a valid legal process compels it • where we reasonably believe disclosure is necessary to protect someone's safety or to investigate fraud or a security incident • to a successor organization as part of a merger, acquisition or reorganization, under equivalent protection

Retention. We keep personal information only as long as needed for the purpose it was collected for, or as the law requires: • account and profile information — while the account is active, then for up to two years after it closes • transaction, tax and accounting records — for seven years from the transaction • audit trails and acceptance records — kept intact, because a record of who did what must not be rewritten; access to them is restricted • support and correspondence — for three years after the matter closes • security and access logs — for up to twelve months • AI conversations — while your account is active; a conversation you put away is kept so you can return to it, and it is not deleted unless you ask us and no legal hold applies

When information is no longer needed, we delete it, anonymize it, or, where deletion is not possible because of a legal hold or an audit trail, we restrict access to it.

8. Accuracy

We work to keep personal information accurate, complete and up to date for the purposes we use it for. You can correct your profile in your portal, and a colony administrator can correct its members' details.

If you cannot correct something, contact the Privacy Officer and we will correct it, or record your disagreement in the record.

9. Safeguards

We protect personal information with safeguards appropriate to its sensitivity: • access is limited by role and by colony, so one colony's records are not shown to another colony • passwords are hashed, not stored in readable form • traffic to and from the platform is encrypted in transit with TLS • our database and file-storage providers encrypt stored data at rest as part of their service • devices connect with per-device credentials that can be revoked • we keep audit and access logs, and we monitor for errors and security incidents • our staff and contractors are bound by confidentiality obligations

No system is completely secure. If a security incident affects your personal information, we follow the breach process described in this policy.

10. Openness

This policy is our public statement of how we handle personal information. It is published at /privacy with a version number and an effective date. If we change it, we update the version and the date. If the change is material, we tell account holders by email or in the platform before it takes effect.

You can ask us for information about our policies and practices. Contact the Privacy Officer.

11. Individual access

You can ask what personal information we hold about you, how we use it, and to whom we have disclosed it, and you can ask for a copy. Send the request to the Privacy Officer.

We will respond within 30 days after we receive your request, as PIPEDA section 8(3) requires: "not later than thirty days after receipt of the request". If we need more time, we will tell you why and when to expect an answer.

We may need to verify your identity before we release information. We may refuse a request where the law allows, in whole or in part, and we will tell you why and what you can do about it.

If you believe information is wrong, you can ask us to correct it. If we do not agree, we will record the disagreement and tell you.

12. Challenging compliance

If you have a concern about how we handle personal information, contact the Privacy Officer first. We will look into it and tell you what we found.

You may also complain to a regulator: • the Office of the Privacy Commissioner of Canada, for PIPEDA matters • the Office of the Information and Privacy Commissioner of Alberta, for PIPA matters

We will cooperate with a regulator's investigation.

13. Service providers and processing outside Canada

We use carefully selected service providers to run the platform. They are bound by contract to use personal information only for the service they provide to us, and are barred from using it for their own purposes. They fall into these categories: • application hosting — running and serving the platform • database and file storage — storing platform records and uploaded files • email and text-message delivery — sending verification codes, confirmations and notices • payment processing — processing payments and meeting financial-compliance requirements • AI processing — responding to the requests you make to Hutter AI • error logging and analytics — diagnosing faults and measuring page views

Where the information goes. Some of these providers are outside Canada. Personal information may be collected, used, disclosed or stored in Canada and the United States, and in the country where a provider processes a request. The purposes are the same ones listed in this policy: hosting, storage, delivery, payment, AI processing, monitoring and support. Personal information stored in another country is subject to that country's laws and may be accessible to its authorities.

Our own operations are in Alberta, Canada. We operate dedicated private servers for device, sensor and messaging infrastructure; the application and database run with the contracted providers listed above. We do not operate the LoRaWAN network server that may forward your device readings; that server is operated by you or your installer, and it sends readings to the platform. Device readings and device records are stored in the platform.

If you have a question about a provider or a country, contact the Privacy Officer.

14. Breach notification

If we discover a breach of our security safeguards involving personal information, we will contain it and assess the risk. Where there is a real risk of significant harm to an individual, we will notify the Privacy Commissioner of Canada and the affected individuals as soon as feasible. We will tell you what happened, what information was involved, and what you can do to reduce the risk. Under Alberta's PIPA, we will also notify the Commissioner where the law requires it. We keep a record of every breach and the steps we took.

15. Children

Accounts are for adults and organizations. If we learn that a child has opened an account, we will close it and delete what we can.

School and education features may hold information about children, including a name, a grade and a record the school or colony enters. That information is provided to us by the school or colony, which decides its purposes and who may see it. A child's name stays within the child's own school or colony.

We do not use children's information for advertising, profiling or sale. A parent or guardian can ask the school or colony that operates the feature for access or correction, or contact us and we will help.

16. Cookies

We use cookies and similar storage that the platform needs to work: to keep you signed in, to remember your language and viewing preferences, and to protect against cross-site request forgery. These are essential cookies; the platform does not work without them.

We do not use advertising cookies, cross-site tracking cookies or third-party behavioural advertising cookies. The platform uses a cookieless page-view measure that does not set a cookie and does not identify you.

You can block or delete cookies in your browser. If you block essential cookies, you may not be able to sign in or use parts of the platform.

17. Users in the United States

The platform is operated from Canada and our terms are governed by Alberta law. If you are in the United States, we honour your state privacy rights — including access, correction, deletion subject to legal retention, and a copy of your information — through the same Privacy Officer contact described in this policy, whatever your state's law provides. We will not discriminate against you for making a request.

Where a US law gives you a right that this policy does not describe, tell us and we will apply it to you.

18. Changes to this policy

We may update this policy. The version and effective date at the top of this page tell you which version applies. If a change is material, we will tell account holders by email or in the platform before it takes effect, and we will keep the previous version available on request.

Continued use after the effective date means the new version applies, to the extent the law allows.

19. How this policy maps to PIPEDA's ten principles

PIPEDA sets ten fair-information principles. This policy covers each of them: • Accountability — sections 1 and 12 (who we are; challenging compliance) • Identifying purposes — section 4 (why we collect) • Consent — section 5 • Limiting collection — section 6 • Limiting use, disclosure and retention — section 7 • Accuracy — section 8 • Safeguards — section 9 • Openness — section 10 • Individual access — section 11 • Challenging compliance — section 12

Alberta's PIPA adds the duties described in sections 1, 3, 4, 13 and 14: a person responsible for privacy, notice at collection, disclosure of processing outside Canada, and breach notification.