ADM is committed to protecting your privacy. This document discribes how we gather, collect and use customers’ & prospects’ data.
A. GENERAL INFORMATION
B. INFORMATION FOR WEBUSERS
C. INFORMATION FOR CUSTOMERS, SUPPLIERS, LOGISTICS PARTNERS & PUBLIC
D. PERSONAL DATA RIGHTS
A. GENERAL INFORMATION
1. Overview
At Archer Daniels Midland Company (“ADM”) (“we,” “our” or “us”), we are committed to protecting the confidentiality, accuracy and integrity of any personal data you provide to us. We always strive to safeguard such data from misappropriation, loss, misuse, unauthorized access, disclosure and/or alteration. We only collect personal data that is relevant for our described purposes.
2. Scope
This Privacy Notice has been created to provide relevant information and demonstrate that your personal data is processed in a legal and responsible manner.
European Union: Information in grey is applicable only where Regulation EU 2016/679 (GDPR) or a privacy law with the same requirements applies to you. The GDPR applies to you where the processing of your personal data is done in the context of the activities of a relevant establishment in the Union, or where the offering of goods or services, or the monitoring of your behaviour, has occurred and you are in the Union.
California : The California Resident Privacy Notice applies to residents of California.
3. Controller
Below are the contact details of the ‘Controller’ of your data – that is, the entity responsible – and also the contact details of our Data Protection Officers.
| Controller | EU Data Protection Officer | Brazil Data Protection Officer |
| ADM Group c/o Chief Privacy Officer 77 West Wacker, Suite 4600 Chicago, IL 60601 Telephone: +1 312 634-8100 Email: dataprivacy@adm.com | EU Data Protection Officer c/o ADM Germany GmbH Ferdinandstraße 5 20095 Hamburg Germany Telephone: 0049 (0) 40 3013 774 Email: privacyeu@adm.com You can contact the Data Protection Officer in relation to any questions, comments or complaints you have regarding your personal data. | ADM Brazil c/o Data Protection Officer Av. Roque Petroni Jr., 999 9º Andar 04707-000, São Paulo, SP, Brazil Telephone: +55 11 5185 3500 Email: privacidade@adm.com |
B. INFORMATION FOR WEBUSERS
1. Purpose and Legal Basis
Below you will find information about how we process your personal data, the purpose for our processing of your personal data and the legal basis for our processing of your personal data according to the GDPR if applicable.
Website visitor (this data is always collected and processed by us when you visit our sites)
| Purpose of the processing | Legal basis for our processing (EU) |
| (i) Personalised advertising; (ii) Technical provision & optimisation of our site; (iii) Understand your interests; (ii) Provide information, products and services. | Article 6(1)(f): Our legitimate interest is: (i) To provide you with personalised advertising for ADM when you leave our site; (ii) The successful technical provision of our website, the IT security and its continued optimisation by utilising user data; (iii) To understand what parts of our website you visit, and which of our products do you seek information; (iv) To provide you with information about our company and our products and services. |
Communications, Contact & Downloads
| Purpose of the processing | Legal basis for our processing (EU) |
| (i) To make contact with you where you have so requested (primarily for investor communications and annual reports); (ii) To send you a quote; (iii) Allow you to contact us; (iv) To allow you to download materials relevant to your interests; (v)To send you promotional material from time to time. | Article 6(1)(f): Our legitimate interest is: (i) To make contact with you where you so request; (ii) To send you a quote where you so request; (iii) To allow you to contact us where you so wish; (iv) To allow you to download relevant materials: Article 6(1)(a): Consent. (v) Your consent is entirely voluntary and can be withdrawn at any time. |
‘ADM Delivers’ & Logistics
| Purpose of the processing | Legal basis for our processing (EU) |
| (i) To provide you with a quote from our logistics team; (ii) The provision of our ADM Delivers portal; | Article 6(1)(b) The provision of the personal data for these purposes is not mandatory by law or contract however, achieving the planned purpose for the processing will be considerably restricted. |
Careers
| Purpose of the processing | Legal basis for our processing (EU) |
| (i) The provision of our ADM job postings; (ii) Facilitating your job application; (iii) Assessing your job application; (iv)Contacting you further. | Article 6(1)(b) The provision of the personal data for these purposes is not mandatory by law or contract however, achieving the planned purpose for the processing will be considerably restricted. |
ADMFarmview (e-ADM)
| Purpose of the processing | Legal basis for our processing (EU) |
| (i) The provision of our ADMFarmview portal and software. | Article 6(1)(b) The provision of the personal data for these purposes is not mandatory by law or contract however, achieving the planned purpose for the processing will be considerably restricted. |
Credit (e-ADM)
| Purpose of the processing | Legal basis for our processing (EU) |
| (i) Provision of our ADM credit service; (ii) Process your credit application; (iii) Process invoices and trading information; (iv) Manage ADM account information; (v) Security and/or fraud prevention. | Article 6(1)(b) The provision of the personal data for these purposes is not mandatory by law or contract however, achieving the planned purpose for the processing will be considerably restricted. |
Help Desk (e-ADM)
| Purpose of the processing | Legal basis for our processing (EU) |
| (i) Provision of our helpdesk service; (ii) Provide you with assistance where you request it. | Article 6(1)(b) The provision of the personal data for these purposes is not mandatory by law or contract however, achieving the planned purpose for the processing will be considerably restricted. |
Futures & Options (e-ADM)
| Purpose of the processing | Legal basis for our processing (EU) |
| (i) Provide our futures, commodities and options service/portal (ii) Allow you to run reports based on your interest in this area | Article 6(1)(b) The provision of the personal data for these purposes is not mandatory by law or contract however, achieving the planned purpose for the processing will be considerably restricted. |
e-ARTCO Barge Management System (e-ADM)
| Purpose of the processing | Legal basis for our processing (EU) |
| (i) Provision of our e-ARTCO Barge Management system/portal | Article 6(1)(b) The provision of the personal data for these purposes is not mandatory by law or contract however, achieving the planned purpose for the processing will be considerably restricted. |
2. Recipients of your Personal Data
Here you will find information about recipients to whom we may need to share your personal data. We only share your personal data where it is necessary. We will never share your personal data without a valid reason or interest connected to the above stated purpose.
| Recipient | Function |
| ADM Group | ADM may share your personal information with subsidiaries and affiliated companies to provide the services you have requested. These subsidiaries and affiliated companies will handle your personal data in accordance with this Notice. |
| Unaffiliated third parties | 1. ADM may share your personal data with unaffiliated third parties who perform administrative, marketing, professional or technological support functions; 2. ADM may share your personal data with unaffiliated third parties with whom we enter into joint venture agreements, branding agreements or other strategic alliances, or in the event of a sale, merger, reorganization, liquidation or other similar event; 3. ADM may share your personal data with unaffiliated third parties who help us to process your requests to do business with ADM, such as processing a credit application, performing a background check based on reference information, managing ADM account information, or facilitating trading and processing payments; 4. ADM may share your personal data with third parties who assist us with our job postings, or with whom we have agreements. |
| Authoritative Bodies | ADM may be required to disclose personal data by law or legal process, for the administration of justice, for investigation of breaches, for interacting with governmental anti-fraud databases, to protect the security or integrity of our databases or this website, to protect and defend the rights or property of ADM, to protect the personal safety of ADM website users, to take precautions against legal liability, to protect your or our legal claims and interests, defend against litigation and to comply with a government organization’s orders or regulations. We reserve the right to contact appropriate authorities when activities occur that we suspect are illegal and/or violate our policies. |
3. Transfer to third countries and/or international organisations
If you are located in the European Union, personal data collected will be processed in a country where the adequacy of that countries data protection laws have not been approved by an adequacy decision of the European Commission. ADM is a U.S.-based company and therefore personal data processing occurs in the USA, but also some of the service providers are based outside the EU. Where we transfer personal data in this manner, ADM will ensure that any such agreements involving the processing of your personal data will be concluded so that your personal information is protected to an acceptable EU standard under standard EU contractual clauses for the transfer of data, which provide you and your personal data with adequate safeguards. If you would like more information as to how we protect your personal data in these circumstances, please contact the Data Protection Officer with the contact details that we provided above.
4. Storage of your Personal Data
We store your personal data for a period reasonable for our purposes of processing and/or for a period of time that is required of us by the laws applicable in your local area. We do not process your data any longer than we need to.
If you would like more information about our retention periods, please contact the Data Protection Officer.
5. Website Cookies
Our website uses cookies. For more information, see our Cookie Policy. You can opt-out of receiving interest-based ads from third parties who are members of the Network Advertising Initiative (NAI) or who follow the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising by visiting the opt-out pages on the NAI website and DAA website. (http://www.networkadvertising.org/choices/) and (http://www.aboutads.info/choices/).
These processing operations are based on Article 6(1)(f) of the GDPR. Our interest is the ongoing optimization and usability of our website. Where we ask for your consent, our processing operations are based on Art. 6(1)(a) of the GDPR. Your consent is entirely voluntary and can be withdrawn at any time.
6. Location Targeted Advertising & Tracking
Where legally permissible, we may use targeted advertising technologies that are able to identify your mobile device based on your location. Where your device is intercepted in a relevant location, your IP address and location will be processed in order to provide specific advertising relating to ADM. This occurs at specific events where ADM is present, including fairs. When such processing occurs, you will be presented with ADM advertising when you open an internet browser on your device. Toggle your device privacy settings to control location tracking and advertising.
These processing operations are based on Article 6(1)(a) of the GDPR. Your consent is entirely voluntary and can be withdrawn at any time.
7. External Links
This website may provide links to external websites. When you click on one of these links, you will be transferred from this website and connected to the website of the organization or company that you have selected. Even if an affiliation exists between ADM and such a website, ADM may not exercise any control over linked sites and we do not imply any endorsement of the activities of these websites. Unless specifically stated, this Privacy Notice does not govern the data collection and use practices of those websites and we cannot ensure they are compliant with the data protection standards contained in this Privacy Notice.
If you visit a website that is linked from this website, you should familiarize yourself with that site’s privacy practices before providing any personal information.
C. INFORMATION FOR CUSTOMERS, SUPPLIERS, LOGISTICS PARTNERS & PUBLIC
1. Purposes and legal Basis
Below you will find information relevant in the instance that ADM processes personal data about you where you are a customer, supplier, a member of the general public or logistics partner.
Managing contractual relationship
| Purpose of the processing | Legal basis for our processing (EU) |
| (i) Management of contact persons; (ii) Facilitate the performance of the contractual relationship and fulfilment of contractual rights and obligations and related services, including the optimization of processes; (iii) Facilitate communications; (iv) Manage and facilitate the information flow; (v)Comply with laws and regulations. | Article 6(1)(f): Our legitimate interest is: (i) Managing contact persons for communication and customer care; (ii)Carrying out of the contractual relationship and related rights and obligations; (iii) Facilitate communications relevant to the contractual relationship; (iv) Process information relevant to the contractual relationship. Where this is a direct contractual relationship: Article 6(1)(b) The provision of the personal data for these purposes is not mandatory by law or contract however, achieving the planned purpose for the processing will be considerably restricted |
Marketing
| Purpose of the processing | Legal basis for our processing (EU) |
| (i) Send you marketing material such as emails and/or newsletters, allow you to participate in prize competitions or other promotional offers, or send you technical information and/or legal updates. | Article 6(1)(a): Consent Where we explicitly ask for your consent; your consent is entirely voluntary and can be withdrawn at any time. Where you enter into a contractual relationship with us: Article 6(1)(b) The provision of the personal data for these purposes is not mandatory by law or contract, however, achieving the planned purpose for the processing will be considerably restricted. Article 6 (1) (f): Our legitimate interest is: Where your electronic contact details have been collected in the context of the sale of a product or service, such contact details may be used for our interest of direct marketing of similar products and/or services; you can object to the processing at any time. |
Visitors
| Purpose of the processing | Legal basis for our processing (EU) |
| (i) Access control (ii) Ensuring safety and security | Article 6(1)(f): Our legitimate interest is: Managing the safety and security of our facilities and people |
2. Storage of your personal data
The personal data noted above shall be deleted after the expiry of the purpose for which they were collected, insofar as no legal archiving rights, obligations or warranty periods justify a storage or retention of the personal data for other legal reasons.
3. Recipients of your Personal Data
Generally, your personal data will not be transmitted to third parties, unless there is a relevant need in conjunction with the above stated purposes, as outlined below:
| Recipient | Function |
| ADM Group | ADM may share your personal information with subsidiaries and affiliated companies to provide the services you have requested. These subsidiaries and affiliated companies will handle your personal data in accordance with this Notice. |
| Unaffiliated third parties | 1. Insofar as your personal data is maintained in a business application such as a customer relationship management or enterprise resource planning system, your personal data will be shared with the companies who provide such services and will be physically processed by them accordingly; 2. Where we engage external service providers to support us in promotional and/or advertising activities, your personal data will be shared accordingly. 3. Where it is necessary for the carrying out of a contractual relationship, we will share your data with partners, customers and suppliers (including logistics partners). |
| Authoritative Bodies | ADM may share your personal information with authoritative bodies as may be required by law. |
4. Transfer to third countries and/or international organisations
If you are located in the European Union, personal data collected will be processed in a country where the adequacy of that countries data protection laws have not been approved by an adequacy decision of the European Commission, especially as ADM is a U.S.-based company and therefore personal data processing occurs in the USA. Where we transfer personal data in this manner, ADM will ensure that any such agreements involving the processing of your personal data will be concluded so that your personal information is protected to an acceptable EU standard under standard EU contractual clauses for the transfer of data, which provide you and your personal data with adequate safeguards. If you would like more information as to how we protect your personal data in these circumstances, please contact your Data Protection Officer with the contact details that we provided above.
D. PERSONAL DATA RIGHTS
1. Your Rights
You have many actions available to you in relation to our processing of your data. You may use the contact information below to request:
a. Access to your data, pursuant to Article 15 GDPR: You have the right to request information as to whether we are processing personal data concerning you, and subsequent access to this personal data.
b. Rectification of your data, pursuant to Article 16 GDPR: You have the right to the rectification of your personal data that is inaccurate or incomplete, this includes by means of a supplementary statement.
c. Erasure of your data, pursuant to Article 17 GDPR: You have the right to ask us for the erasure of your personal data, where no exemption for retaining the personal data applies.
d. Restriction of our processing of your data, pursuant to Article 18 GDPR: You have the right to request a restriction on the processing of your personal data in particular circumstances.
e. Data Portability, pursuant Article 20 GDPR: In some circumstances, you may be entitled to request that your personal data be provided to you in machine readable format. This is applicable where the processing of your personal data is based on consent (Article 6(1)(a)), where special categories of personal data are being processed based on consent (Article 9(2)(a)), or where your personal data is processed on the basis of Article 6(1)(b). This right to data portability includes the right to have your personal data transferred directly to another controller.
f. Objection to our processing of your data pursuant to Article 21 GDPR: Where your personal data is processed for the purpose of performing tasks carried out in the public interest (Article 6(1)(e)), for the purpose of legitimate interests of the controller (Article 6(1)(f)), or for the purpose of direct marketing and profiling related to this (Article 21(2)), you are able, based on the grounds relating to your particular situation, to object to the processing of your personal data.
(Where the processing of your personal data is based on your consent, you are not able to object to this processing pursuant to Article 21 of the GDPR. However, you do have the right to withdraw your consent based on Article 7(3) of the GDPR. This shall have the same practical effect as objecting to the processing, should you wish to do so).
If you wish to exercise these rights, please contact our DPO at privacyeu@adm.com or, outside of the EU, contact dataprivacy@adm.com.
2. Complaints
You may submit a general complaint regarding your personal information to a supervisory authority regarding our processing of your personal data.
Comments
All comments relating to this Privacy Notice and/or regarding your personal data should be directed to dataprivacy@adm.com.
Last Update : December, 2022
