Privacy Policy

Version 2026.04.28-1 published 2026-04-29 03:05

CORTEX AGRITECHNOLOGY INC. (“Cortex”)

PRIVACY POLICY

Last updated: April 16, 2025

This privacy policy (the “Privacy Policy”) describes the relationship between Cortex Agritechnology Inc. (“we”, or “us”), the products and services operated by Cortex (collectively, such services, including any new features and applications, the “Services”), and the users of the Services (“you” or “your”). This Privacy Policy describes matters with respect to your information and personal identifiable information (collectively, “Personal Data”) and other information that is collected from users of the Services. Please read this Privacy Policy carefully, as it applies to all interactions you have with the Services. Wherever Cortex collects Personal Data, we make an effort to provide a link to this Privacy Policy.

1. Collection of Personal Data and Other Information

1.1 Authorized Purposes - Cortex may collect Personal Data for the following purposes:

(a) to provide you the Services;

(b) to administer, plan, and manage the relationship with you and to communicate with you;

(c) to provide you with information and customize your experience;

(d) to better understand how Cortex may improve the Services, prevent abuse, develop and conduct our business and operations, and for other internal business purposes;

(e) to provide you with information on current and future services or other developments with respect to Cortex (in accordance with Canada’s Anti-Spam Legislation); and

(f) to comply with applicable legal and regulatory requirements or to protect Cortex’s legal rights and property;

(collectively, the “Authorized Purposes”).

1.2 Voluntary Personal Data

Cortex collects Personal Data from you when you voluntarily provide such information, such as when you contact Cortex with inquiries or register yourself or your company online for access to the Services. The type of information we may collect from you includes, for example, your name, email address, address, phone number, and other information you choose to provide. We may also collect Personal Data where we have a legal duty or right to do so.

1.3 Technical Information

When you use the Services, we receive data about your device, software, operating system, IP address, the date and time of each request you make to Cortex or in connection with the Services, and how you view and interact with the Services (“Anonymous Technical Information”).

1.4 Location Information

Cortex may collect and use your location information (for example, by using the location services on your mobile device) to provide certain functionality of the Services. Cortex may use your location information in an aggregate way, as described in Section 3.5 below.

2. Processing of Personal Data and Other Information

2.1 Processing Purposes

Cortex will only process Personal Data for the purposes of performing its obligations and exercising its rights under this Privacy Policy, Cortex’s End User Licence Agreement, or as otherwise instructed by you in writing from time to time.

2.2 Data Transfers and Storage

If you provide Cortex with Personal Data, you acknowledge and agree that such Personal Data may be transferred from your current location to the offices and servers of Cortex and the authorized third parties (including services providers) referred to herein located in Canada and the United States for processing and storage purposes. Where information is stored in these jurisdictions, it may be subject to the laws of the relevant jurisdiction and accessible by that jurisdiction’s authorities and law enforcement.

2.3 Linking Technical Data

Anonymous Technical Information will not be linked with Personal Data without your consent, or unless Cortex (or its service providers) have detected or reasonably suspect any unlawful use of Cortex’s services or a security breach, or Cortex has a legal duty or right to do so.

3. Use and Disclosure of Personal Data and Other Information

3.1 Permitted Use and Disclosure

Cortex only uses or discloses Personal Data as reasonably required to facilitate the Authorized Purposes listed above, as contemplated by Cortex’s End User Licence Agreement, or with your prior written consent. In some cases, Cortex may share Personal Data with third party service providers performing functions on Cortex’s behalf, including, for example, vendors that provide information technology services or provide analytics or assessment services. Cortex does not otherwise use or disclose Personal Data unless Cortex has your consent, Cortex has a good faith belief that disclosure of the information is necessary to protect the rights or property of Cortex, or Cortex has a legal duty or right to do so.

3.2 Use for Provided Purpose

If you provide Personal Data for a certain reason, Cortex may use the Personal Data in connection with the reason for which it was provided. For instance, if you contact Cortex by email, Cortex will use the Personal Data you provide to answer your question or resolve your problem. Also, if you provide Personal Data in order to obtain access to the Services, Cortex will use your Personal Data to provide you with such access and to monitor your use of such Services.

3.3 Sharing Personal Data

We may share your personally identifiable data only under these circumstances:

(a) with your consent, after letting you know what information will be shared, and with whom;

(b) if we believe it is reasonably necessary to comply with a law, regulation or legal process. If we’re going to release your information, our policy is to provide you with reasonable advance notice under the circumstances unless we’re prohibited from doing so by law or court order. We may disclose your information without giving you prior notice if we believe it’s necessary to prevent imminent and serious bodily harm to a person. Nothing in this Privacy Policy is intended to limit any legal objections or defenses you might have to efforts by third parties to compel disclosure of your information, including legal orders from the government;

(c) to our affiliates or third parties helping us offer and improve our service, such as those providing Cortex certain technical tools and analytics services that help us understand how people use Cortex so we can make it better. We require those companies to observe the limitations in this Privacy Policy; or

(d) if we sell, transfer or otherwise share some or all of our assets, including the information identified in this Privacy Policy, in connection with a merger, acquisition, reorganization, or sale of assets in the event of a bankruptcy.

3.4 Non-Personal Data Sharing

To help us improve the Services, including advertising, we may share non-personally identifiable, non-aggregate information, including, without limitation, Anonymous Technical Information, with other companies (such as research companies and analytics providers). As with your personally identifiable information, we require that such companies observe the limitations in this Privacy Policy.

3.5 Aggregated Data and Research

In an ongoing effort to better understand and serve users, Cortex may conduct research on user demographics, interests, and behaviour based on the Personal Data and other information provided to Cortex. This research may be compiled and analyzed on an aggregate basis, and Cortex may share this aggregate data with its affiliates and agents. This aggregate information does not identify you personally. Cortex may disclose aggregated user statistics as permitted by applicable laws.

4. Storage of Information

4.1 Cookies and Local Storage

We use cookies and HTML5 local storage to help us create your session, know when you’re logged in, keep you logged in for your convenience, and help us remember certain information about how you interact with Cortex. “Cookies” are small text files placed on computers that can collect and store a variety of information. Permanent cookies are stored indefinitely on a user’s hard drive unless manually deleted, while temporary cookies are automatically deleted from the user’s browser upon logging out of a website. Most browsers give you the option to turn off cookies and HTML5 local storage, or require your approval before using them to keep information. If you choose not to keep information in cookies or HTML5 local storage, portions of Cortex may not work as intended.

4.2 Third-Party Tracking

Some third-party websites and services that Cortex partners with or connects with through the Services may use cookies, web beacons, or other technologies to keep track of your Internet activity. Please note that this Privacy Policy explains Cortex’s policies only, and does not cover the practices of other services.

4.3 Account Deletion

If you would like to delete your Cortex account, you can do so by notifying us in writing at support@cortex.ag. If we delete your account, we may still keep some log information in a non-personally identifiable form and any other information you have made publicly available through Cortex.

5. Consent and Your Rights

5.1 Consent to Data Practices

You provide your consent to the collection, use, and disclosure of Personal Data by us when you provide your information to us or use the Services.

5.2 Withdrawal of Consent

You can deny or withdraw your consent to our collection, use and disclosure of your Personal Data at any time upon reasonable notice, subject to any legal or contractual requirements. However, if consent is denied or withdrawn, we may not be able to provide the Services.

5.3 Access to Personal Data

We will provide you with access to the Personal Data that we hold about you in accordance with applicable laws. We reserve the right to require that any request for access to Personal Data be made in writing. Generally, there is no cost for such access. However, we reserve the right to charge such costs on a case-by-case basis in accordance with applicable laws. You will be notified in advance if charges apply.

5.4 Accuracy of Personal Data

We make every reasonable effort to ensure that Personal Data is accurate and complete. This may involve requesting further information or updates from you. It is your responsibility to notify us if there is a change to your Personal Data that may affect your relationship with us. We will correct or amend the Personal Data in our files where it can be shown that the information is incorrect or incomplete.

5.5 Marketing Communications

Cortex may use Personal Data to inform you of current and/or new products or services or other developments that Cortex believes will be of interest to you in accordance with applicable laws, including Canada’s Anti-Spam Legislation (CASL). Such communications may be made by way of telephone, text message, direct messaging, e-mail, fax or regular mail. You may opt-out of receiving such communications by sending an email to support@cortex.ag.

6. Protection and Retention of Personal Data

6.1 Security Safeguards

Cortex has in place commercially reasonable policies, procedures and safeguards designed to protect Personal Data under its control against loss, theft, damage or unauthorized or unlawful access or processing.

6.2 Affiliated Companies

Cortex has a close working relationship with its affiliated companies including, for example, Cortex’s parent company (Agrihub Inc.) and its subsidiary companies. Personal Data may be shared with these organizations to facilitate the Authorized Purposes listed above in accordance with this Privacy Policy.

6.3 Limited Access

Cortex limits access to Personal Data to those individuals and sub-processors who need to have access to the Personal Data for the purposes of Cortex performing its obligations and exercising its rights under this Privacy Policy or Cortex’s End User Licence Agreement.

6.4 Privacy Incident Response

The protection of Personal Data is of paramount concern to Cortex. We are prepared to take appropriate and timely steps in the event of any incidents involving Personal Data in accordance with applicable privacy laws.

6.5 Incident Notification

If Cortex becomes aware of any loss, theft, damage or unauthorized or unlawful processing of your Personal Data, we will notify you and comply with your commercially reasonable instructions in connection therewith.

6.6 Retention Period

Cortex retains Personal Data as long as is reasonable to fulfill the purposes for which the information was collected, or for legal or business purposes.

6.7 Return or Disposal of Data

Upon termination of this Privacy Policy, Cortex will return (or, upon your written instruction, securely dispose of) all Personal Data in our possession or control, subject to any legal requirements that require us to retain or maintain such Personal Data.

7. Changes to this Privacy Policy

7.1 Policy Revisions

We may revise this privacy policy from time to time. This Privacy Policy was last updated on the date indicated above. The most current version will govern our use of your information. If we make changes that we think will substantially alter your rights, we will notify you by email.

7.2 Continued Use After Changes

Please review this Privacy Policy periodically, and especially before you provide any Personal Data. Your continued use of the Services after any changes or revisions to this Privacy Policy shall indicate your consent to and agreement with the terms of such revised Privacy Policy.

8. Contact Information

Questions, concerns, or feedback regarding this Privacy Policy or the Services can be directed to us at support@cortex.ag.