Compass Ag Solutions, LLC – Unified Privacy Policy

Effective as of December 18th, 2025, for Compass Ag Solutions, LLC and All Current and Future Affiliates

This Privacy Policy (“Policy”) applies to Compass Ag Solutions, LLC (“Compass Ag Solutions,” “Compass,” “we,” “our,” or “us”) and all of its current and future affiliated or subsidiary business lines (collectively, the “Compass Companies”), including but not limited to:

• Compass Hedging, LLC
• Compass Ag Insurance, LLC
• Compass Software Solutions, LLC
• And any other Compass business lines that may be established in the future and that do not maintain their own separate privacy notice.

Compass Companies are committed to respecting and protecting the privacy and security of your personal information. This unified Policy applies across all Compass Companies, except where additional legal or regulatory obligations apply—such as those applicable to Compass Hedging, LLC. Where such additional obligations apply, those requirements will control.

1. Applicability and Purpose

This Policy governs how the Compass Companies collect, use, share, and safeguard your personal information (“PII”). Where applicable, specific Compass Companies (such as Compass Hedging, LLC) may also be subject to additional regulatory requirements through R.J. O’Brien and/or StoneX. All Compass business lines adhere to the same privacy principles, security standards, and data-handling practices described here.

2. Relationship with R.J. O’Brien and/or StoneX

Compass Hedging, LLC conducts regulated brokerage and hedging services in partnership with R.J. O’Brien and/or StoneX and therefore complies with additional privacy and regulatory requirements established by those firms. R.J. O’Brien and/or StoneX, and their affiliates, believe in respecting the privacy and security of your personal information. Please review their full policy at: https://www.rjobrien.com/Privacy-Policy.pdf. These provisions supplement, but do not replace, this Compass unified Privacy Policy. To the extent there is any inconsistency between this Policy and the privacy policies of R.J. O’Brien and/or StoneX with respect to brokerage or hedging related information, the R.J. O’Brien and/or StoneX policies and will control. For all PII not processed in connection with regulated brokerage or hedging services, this Policy will control.

3. Collection of Personal Information

Compass collects personal information from a variety of sources, including information you provide directly, information generated automatically through your use of our websites, systems, or software, and information obtained through third-party service providers, or business partners. The categories of information we collect reflect the nature of your interactions with us and the services you use, and may include, without limitation:

• Personal Identifiers
  • Name, address, email address, phone number
  • Date of birth
  • Identification documents and account credentials
• Technical Information
  • Internet Protocol (IP) address, browser type, device data
  • Usage, diagnostic, and interaction information collected through cookies, web beacons, pixels, or similar technologies used for functionality, security, performance, and other operational purposes
• Business and Operational Information (not treated as Personal Information)
  • Details you choose to provide in connection with our services, such as livestock and feed inventory, production-related information, or similar operational data
• Financial Information Related to Services
  • Information necessary to provide hedging, risk management, or account-related services, such as position data, margin information, and other financial details relevant to your commercial activities

4. Internal and Vendor Information Sharing

Compass may share information internally among the Compass Companies and with approved third-party vendors and service providers, including, but not limited to:

• R.J. O’Brien and/or StoneX – for brokerage and hedging services
• Hudson Insurance Group – for insurance underwriting and policy administration
• Pinion – Accounting / Tax and Advisory Services
• Other trusted vendors and service providers – supporting customer service, compliance, data hosting and processing, technology operations, and other operational or administrative functions performed on our behalf

All third-party vendors and service providers are contractually obligated to maintain confidentiality and data security consistent with this Policy and applicable law. Compass does not sell or share customer information for marketing purposes outside of the Compass Companies.

5. Software Products and End User License Agreements (EULAs)

For customers who access Compass software solutions or technology products, use of those products is also governed by a separate End User License Agreement (“EULA”). The EULA and this Privacy Policy work together to define how Compass collects, uses, and safeguards personal and operational data within software applications. In the event of a conflict between the Privacy Policy and a specific EULA provision regarding data handling, the EULA will control for software-specific data practices. For all other data handling matters relating to PII this Privacy Policy will control.

Some Compass software products may connect to or receive data from third-party providers, including but not limited to Turnkey Computer Systems, Micro Technologies, Hi-Plains Systems, Performance Livestock Analytics, and FY3000. These third-party data sources may have their own privacy terms and data-handling policies, which apply in addition to this Privacy Policy. Compass encourages all users to review those third-party policies prior to enabling any external data connection. Compass is not responsible for the privacy practices of such third parties but ensures that integrations are implemented only with reputable providers under commercially reasonable safeguards.

6. SMS Privacy, Terms, and Conditions

• SMS Consent Communication: Phone numbers obtained for SMS will not be shared to unaffiliated third-parties for marketing purposes.
• Types of SMS Communications: Customer care, follow-up messages, account notifications, daily subscriptions.
• Message Frequency: May vary by communication type.
• Potential Fees: Standard carrier message and data rates may apply.
• Opt-In Method: Via online form or other approved methods.
• Opt-Out Method: Reply “STOP” or contact us directly.
• Help: Text “HELP” or contact https://compassagsolutions.com/contact-us/ or (970) 372-0482.
• Standard Messaging Disclosures: Message frequency may vary. Message and data rates may apply.

7. Electronic Communications and Business Conduct

Any electronic communication sent to Compass or its business lines is not considered received or effective until a Compass representative explicitly acknowledges the communication. This includes, but is not limited to, instructions, orders or time-sensitive requests. If you do not receive an acknowledgement, you should assume the communication has not been received.  If no confirmation is received within a reasonable period, you must follow up through a separate communication method or platform.

All business-related communications must occur through official Compass business systems, which are recorded and retained for training, supervision, and compliance monitoring. Communications sent through personal or unauthorized channels are not recognized as official business communications and may not be monitored or retained.

8. Use and Disclosure of Information

We may use your PII in a manner that is consistent with this Policy, including:

• To establish, service, and manage customer relationships
• To respond to inquiries and process transactions
• To share information internally or with R.J. O’Brien and/or StoneX, Hudson Insurance Group, or other vendors assisting in legitimate business operations
• To comply with regulatory or legal requirements
• To protect and defend the rights, property, or safety of us or third parties, including enforcing contracts or policies, or in connection with investigating and preventing fraud or unauthorized activity
• In connection with mergers, acquisitions, or restructuring activities
• For any other purposes disclosed when PII is collected or to which you consent; and
• As otherwise specifically described in this Policy

9. Confidentiality and Security

Access to your personal information is restricted to authorized Compass employees and approved vendors. Compass takes various steps to protect the information you provide to us from loss, misuse, and unauthorized access or disclosure, and maintains physical, electronic, and procedural safeguards to protect your data. While we take data protection precautions, no security measures are infallible, and we do not guarantee the security of user information.

10. Accuracy and Updates

Compass Companies rely on customers to ensure that personal information is complete and up to date. Please notify us promptly of any updates or corrections.

11. USA Patriot Act Notice

Federal law requires all financial institutions to obtain, verify, and record information that identifies each person who opens an account.

12. Policy Updates

Compass reserves the right to modify or update this Policy at any time, without advance notice. Any update to the Policy will become effective upon posting on the compassagsolutions.com website.

Summary Statement

This Policy applies to Compass Ag Solutions, LLC, Compass Hedging, LLC, Compass Ag Insurance, LLC, Compass Software Solutions, LLC, and any future Compass business lines. Compass may share information internally and with trusted partners such as R.J. O’Brien and/or StoneX, Hudson Insurance Group and Pinion. For users of Compass software, this Privacy Policy works in conjunction with the Compass End User License Agreement (EULA). Together, these documents outline how data is collected, used, and protected across all Compass business lines and technology platforms. Compass Hedging, LLC also complies with the enhanced privacy and regulatory standards of R.J. O’Brien and/or StoneX, which supplement this Policy.