Privacy Policy

1. Introduction

Trazo ("we," "us," or "our") respects your privacy and is committed to protecting your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our organic recordkeeping platform.

This policy applies to our website, web application, QR code scanning services, and all related software and services (collectively, the "Platform").

2. Information We Collect

2.1 Personal Information

We collect personal information that you provide directly to us:

• Account Information: Email address, first and last name, phone number (optional)
• Profile Data: Profile images, user preferences, notification settings
• Authentication Data: Email verification status, password (encrypted), social login IDs

2.2 Business Information (Producer Accounts)

• Company Details: Business name, trade name, description, industry classification
• Business Address: Street address, city, state, country, postal code
• Tax Information: Tax ID, EIN, RUT, or other fiscal identification numbers
• Contact Information: Business email, phone, website, social media profiles
• Business Metadata: Employee count, certifications, sustainability practices

2.3 Agricultural Production Data

• Farm Information: Establishment names, locations, geospatial coordinates
• Crop Data: Crop types, production methods, agricultural practices
• Records & Carbon Data: Record-completeness checks, emission factors, direct operational emission estimates
• Production Events: Agricultural timelines, equipment usage, chemical applications
• Environmental Data: Weather conditions, soil data, irrigation information
• Personnel References: Names of the people recorded as having performed logged work ("performed by"). On public consumer pages these are masked to initials (e.g. "Farm team (A.T.)") unless the producer explicitly enables full names

2.4 Usage and Analytics Data

• Platform Usage: Feature utilization, session duration, user interactions
• QR Code Analytics: Scan counts and the approximate region of a scan, derived on our own servers from a one-way-hashed IP address using a local geolocation database. The IP address is stored only as a hash and is not sent to any third party
• Device Information: Browser type, device model, operating system, IP address
• Educational Engagement: FAQ views and helpfulness votes, counted in aggregate per article — we do not track educational progress per user

2.5 Payment and Subscription Data

• Billing Information: Subscription plans, billing cycles, payment history
• Usage Metrics: Storage used, QR scans, productions tracked for billing
• Payment Processing: Payment methods handled securely by Stripe (we do not store credit card numbers)

2.6 NOP Audit Documentation Data

When you generate a NOP Audit PDF for an organic certifier, the Platform compiles the following information into the export:

• Photo Metadata: Field photos you have uploaded may carry EXIF metadata including GPS coordinates, camera model, and capture timestamp. This metadata is embedded in the audit PDF as part of tamper-evidence captions. You can disable GPS on your camera or strip EXIF before upload if you prefer not to share precise location data with your certifier.
• Record Change History: Every edit to a production record is logged with timestamp and the responsible user (farmer, field manager, or automated system). Change logs are retained for 5 years and included in audit PDFs you share with certifiers.
• Drift Detector Findings: Chemical and soil amendment inputs you log are automatically matched against the OMRI Listed Products database and the USDA National List of Allowed and Prohibited Substances. Mismatches and unresolved inputs are surfaced in the audit PDF as drift findings. These matches use fuzzy text comparison and may produce false positives or false negatives.
• Compliance Snapshot: The page-1 snapshot derives PASS / REVIEW / FAIL outcomes from the data you have entered. It is generated automatically; Trazo does not independently verify the underlying records.

3. How We Use Your Information

3.1 Platform Services

• Provide record-completeness checks and direct operational emission estimates using published EPA/USDA emission factors
• Generate and manage QR codes for consumer transparency access
• Track agricultural production events and sustainability metrics

3.2 Account Management

• Create and maintain user accounts with role-based access control
• Process subscription payments and manage billing cycles
• Send service-related notifications and account updates
• Provide customer support and technical assistance

3.3 Platform Improvement and Research

• Analyze usage patterns to improve Platform functionality
• Create aggregated, anonymized datasets for agricultural research
• Develop new features and carbon calculation methodologies
• Monitor Platform performance and security

3.4 Legal Compliance

• Comply with applicable tax, financial, and regulatory record-keeping requirements
• Maintain agricultural data integrity for certification and audit purposes
• Respond to legal requests and prevent fraud
• Maintain audit trails for regulatory compliance

3.5 Legal Basis for Processing (GDPR Art. 6)

For users in the European Economic Area (EEA) and United Kingdom, we process your personal data under the following legal bases:

Where processing is based on consent, you may withdraw consent at any time without affecting the lawfulness of processing performed before withdrawal. To withdraw consent, contact privacy@trazo.io.

4. How We Share Your Information

4.1 Third-Party Service Providers

We share information with trusted service providers who assist in operating our Platform:

• USDA APIs: Crop type and state only, to look up published emission-factor data. No farm identity, location, or personal data is included in these requests. Organic certification cross-checks run against a locally stored copy of the USDA Organic Integrity Database, not by sending your data to USDA
• Stripe: Billing information, usage metrics for payment processing and subscription management
• DigitalOcean: Application hosting and managed database services
• AWS: Media file storage (S3) for images, documents, and QR codes
• Deepgram: Voice audio, streamed from your browser for speech-to-text transcription when you use voice logging. Audio is sent directly from your device to Deepgram and is not stored by Trazo
• OpenAI: The text transcript of a voice entry, plus text data, for AI-powered field extraction. OpenAI does not receive voice audio (Trazo has opted out of model training; your data is not used to train OpenAI models)
• Vercel Analytics: Anonymized page view and performance data for platform improvement (no PII collected)

4.2 Consumer Transparency Sharing

A production becomes publicly visible only when its producer explicitly publishes it; a published season can be unpublished at any time. Public consumer pages then show:

• Documented farming practices with dates, photos, and certification status. No score, grade, tier or badge of Trazo's own is shown to consumers — practices are counted, not graded
• Direct operational emission estimates, in expandable sections
• Farm location at the precision level the producer selects (exact, approximate, or hidden)

What consumer pages never show. A uniform withholding policy applies to every farm on the Platform and cannot be altered per account. Public pages never include: worker-safety and regulatory compliance fields (such as restricted-entry intervals, applicator identities and certification numbers, or permit numbers); supplier and purchase records (supplier names, invoices, lot numbers), with supplier names also removed from free-text notes; the full names of farm personnel unless the producer has expressly enabled them; and internal record categories that exist for certifier review rather than consumers (input-sourcing searches, transport logistics, buffer-strip disposition, and equipment-cleanout logs). Because the policy is uniform, producers cannot selectively hide individual practice records or field values from published seasons — what a consumer page shows means the same thing for every farm.

4.3 Legal Requirements

We may disclose information when required by law or to: comply with legal process or government requests; protect against fraud or security threats; enforce our Terms of Service; protect the rights, property, or safety of Trazo, users, or the public.

4.4 Aggregated Data

We may share aggregated, anonymized data that cannot identify individual users or businesses for research, industry reports, and platform improvement purposes.

4.5 Certifier Sharing (NOP Audit PDF)

When you export a NOP Audit PDF, the Platform produces a file you control. Trazo does not transmit the PDF to any certifier on your behalf. You choose when, how, and to whom you share it (typically by uploading to your certifier's portal such as MyCCOF or emailing it directly). Once you share the PDF, the recipient will have access to the data described in Section 2.6, including photo EXIF/GPS metadata, change-history attribution, drift findings, and the compliance snapshot.

Trazo is a documentation platform and is not a USDA-accredited certifier. We do not represent your operation to any certifier and do not receive their decisions. Recipients of the PDF are bound by their own privacy obligations, not ours.

5. Data Storage and Security

5.1 Data Storage Locations

• Primary Database: PostgreSQL hosted on DigitalOcean Managed Database
• File Storage: AWS S3 for images, documents, and QR codes
• Security Logs: Rotating log files with limited retention

5.2 Security Measures

• Authentication: JWT tokens with 15-minute access and 7-day refresh periods (30 days with Remember Me)
• Access Control: Role-based permissions with granular user roles
• Rate Limiting: 100 requests/hour for anonymous users, 1000/hour for authenticated users
• Encryption: HTTPS for all data transmission, secure cookie handling
• Input Validation: Comprehensive validation, especially for carbon calculation data

5.3 International Data Transfers

Your data may be transferred to and processed in countries other than your own, including the United States where our primary servers are located. For these transfers, we implement:

• EU-US Data Privacy Framework: Compliance with adequacy decisions where applicable
• Standard Contractual Clauses (SCCs): EU Commission-approved transfer mechanisms
• Technical Safeguards: Encryption, access controls, and monitoring systems
• Contractual Protections: Data processing agreements with all third-party processors

EU residents can request details about specific transfer mechanisms and safeguards applicable to their data.

6. Data Retention

We retain your information for different periods depending on the type of data and legal requirements:

• Account Information: Until account deletion + 90 days
• Agricultural Data: 7 years or until deletion request
• Payment Records: 7 years (tax and financial compliance)
• Usage Analytics: 2 years
• Security Logs: 1 year

7. Your Privacy Rights

7.1 Access and Control

You have the following rights regarding your personal information:

• Access: Request a copy of your personal information
• Correction: Update or correct inaccurate information
• Deletion: Request deletion of your personal information (subject to limitations)
• Portability: Receive your data in a portable format
• Restriction: Limit how we process your information

7.2 California Consumer Privacy Act (CCPA) Rights

California residents have additional rights under the CCPA:

• Right to know what personal information is collected and how it's used
• Right to delete personal information (with certain exceptions)
• Right to opt out of the sale of personal information (we do not sell personal information)
• Right to non-discrimination for exercising CCPA rights

7.3 European Union GDPR Rights

EU residents have rights under the General Data Protection Regulation (GDPR):

• Legal basis for processing (legitimate interest, consent, contract performance)
• Right to withdraw consent where processing is based on consent
• Right to object to processing based on legitimate interests
• Right to file complaints with supervisory authorities

7.4 Limitations on Rights and GDPR Compliance

Some privacy rights may be limited by technical and legal constraints:

• Legal Requirements: Data required for compliance with agricultural regulations and audit trails
• Aggregated Data: Information that has been anonymized and cannot identify individuals
• Active Legal Proceedings: Data subject to litigation hold or investigation requirements

Important: We will provide detailed explanations of any limitations when processing your requests.

8. Cookies and Tracking Technologies

We use cookies and similar technologies to enhance your experience and analyze Platform usage:

• Essential Cookies: Required for Platform functionality and security
• Analytics Cookies: Help us understand how the Platform is used (opt-in only)
• Functional Cookies: Remember your preferences and settings

You can control cookie settings through the cookie consent banner displayed on your first visit, or through your browser preferences. For detailed information about specific cookies, see our Cookie Policy.

9. Data Breach Notification

In the event of a data breach that may affect your personal information, we will:

• Authority Notification: Report to supervisory authorities within 72 hours when required by law
• Individual Notification: Notify affected users without unreasonable delay if high risk to rights and freedoms
• Remedial Actions: Implement immediate containment and recovery measures
• Documentation: Maintain records of breach assessment and response actions

10. Children's Privacy and Age Verification

Our Platform is a business tool and is not intended for children under 18. Registration requires accepting our Terms of Service, under which you represent that you are at least 18 and, where you act for a business, authorized to do so. We do not knowingly collect personal information from children under 18.

If we become aware that we have collected information from a child under 18, we will delete it promptly. Parents or guardians who believe their child has provided information to us should contact us immediately at privacy@trazo.io.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable laws. We will notify you of material changes by:

• Email notification to your registered email address
• Prominent notice on our Platform
• Updated "Last modified" date at the top of this policy

For changes that affect consent-based processing (such as analytics or voice recording), we will seek your affirmative consent before applying the new terms. For other changes, continued use of the Platform after the notice period constitutes acceptance of the updated Privacy Policy.

12. Contact Us

If you have questions about this Privacy Policy or want to exercise your privacy rights, please contact us:

We will respond to your privacy requests within 30 days (or as required by applicable law). For verification purposes, we may need to confirm your identity before processing certain requests.