Pilot draft — subject to revision before public launch.
Privacy Policy — DRAFT
Last updated: [Insert launch date] Effective: [Insert launch date]
This Privacy Policy explains how GroundTruth Ag, Inc. ("Company," "we," "us," or "our") collects, uses, and shares information when you visit livingsoillab.bio (the "Site"), place an order, or otherwise interact with us. By using the Site or placing an order, you agree to this Privacy Policy.
1. Who we are
GroundTruth Ag, Inc., a Delaware corporation, principal place of business at [EarthOptics HQ address]. Privacy and data-rights inquiries: privacy@livingsoillab.bio.
2. Information we collect
We collect information you provide directly, information collected automatically when you use the Site, and information we receive from service providers.
Information you provide directly:
- Contact information: name, email address, mailing address, phone number (if provided).
- Order and payment information: items ordered, ship-to address, billing address, and a payment-method token. Full payment-card numbers are collected and processed by our payment processor (Stripe) and are not stored on our systems.
- Communications: the contents of any email or support message you send us.
- Optional inputs at sample collection: the U.S. state your sample was collected in, and any contextual notes you choose to provide (e.g., crop type, soil concerns). You decide whether to provide these.
Information collected automatically when you use the Site:
- Device and usage information: browser type, device type, IP address, pages viewed, links clicked, referring URL, and approximate location derived from IP.
- Cookies and similar technologies: small files placed on your device to help the Site function, remember your preferences, and measure ad performance. You can control cookies in your browser settings; some Site functions may not work without them.
- Third-party advertising and analytics pixels: we use the Meta Pixel and the Reddit Conversion Pixel to measure the performance of advertising campaigns. These pixels collect a hashed identifier and event data (e.g., "page viewed," "checkout started," "purchase completed"). See Section 6.
Information from service providers:
- Payment processing: Stripe provides us with order status, last four digits of the card, and refund status. See Stripe's privacy notice at stripe.com/privacy.
- Shipping: the shipping carrier provides tracking events for your kit.
3. How we use information
We use the information we collect to:
- Process and fulfill your pre-order, including communicating about it (transactional emails);
- Operate, maintain, and improve the Site and the Service;
- Run and measure marketing campaigns and customer-acquisition tests;
- Respond to your inquiries and provide customer support;
- Comply with legal obligations and enforce our Terms of Service;
- Send marketing emails — only if you opt in — and you may unsubscribe at any time.
We do not use your information to make decisions that produce legal or similarly significant effects about you without human involvement.
4. Legal bases (for users in jurisdictions where this applies)
Where required by applicable law, our legal bases for processing your personal information are:
- Performance of a contract — to fulfill the pre-order you placed;
- Legitimate interests — to operate and improve the Site, prevent fraud, and measure marketing performance;
- Consent — for marketing email and certain non-essential cookies; and
- Legal obligation — to comply with applicable law.
5. How we share information
We do not sell personal information for money. We share personal information only in the following circumstances:
- Service providers acting on our behalf: payment processing (Stripe), email delivery (transactional and, if you opt in, marketing), shipping carriers, the laboratory partner that analyzes your soil sample (an EarthOptics-affiliated facility), and analytics providers. Each is bound by a written contract that restricts their use of your information.
- Advertising platforms (Meta, Reddit) — see Section 6.
- Compliance and protection — if required by law, subpoena, or to protect the rights, property, or safety of the Company, customers, or others.
- Business transfers — if the Company is acquired or merged, your information may be transferred as part of that transaction; if so, we will notify you.
6. Advertising platforms and "sale or share" under California law
We use the Meta Pixel and the Reddit Conversion Pixel on the Site. These pixels enable Meta and Reddit to (a) measure the performance of our ads, (b) attribute conversions, and (c) help us reach similar audiences. The data shared with these platforms typically includes a hashed identifier, page-view events, and conversion events. Under the California Consumer Privacy Act (CCPA / CPRA), this activity may be considered a "sale" or "sharing" of personal information for the purpose of cross-context behavioral advertising.
California residents (and residents of other states with similar laws): you may opt out of this sharing at any time by following the "Do Not Sell or Share My Personal Information" link in the Site footer, or by emailing privacy@livingsoillab.bio. We honor the Global Privacy Control (GPC) signal as a valid opt-out request.
7. Your rights
Depending on where you live, you may have the following rights with respect to your personal information:
- Right to know / access — confirm whether we process information about you and request a copy.
- Right to delete — request that we delete personal information we have collected about you, subject to legal exceptions.
- Right to correct — request correction of inaccurate personal information.
- Right to opt out of sale or sharing for cross-context behavioral advertising (see Section 6).
- Right to limit use of sensitive personal information — we do not knowingly use sensitive personal information for purposes beyond those listed in this Policy.
- Right to non-discrimination for exercising these rights.
To exercise these rights, email privacy@livingsoillab.bio from the email address associated with your account (or include enough information for us to verify your identity). We will respond within 45 days, with one 45-day extension permitted if we notify you in writing.
8. Data retention
We retain personal information only for as long as needed to fulfill the purposes described in this Policy, comply with legal obligations, resolve disputes, and enforce our agreements. Order records are typically retained for seven (7) years for tax and accounting reasons. Email-marketing lists are retained until you unsubscribe, after which we retain a suppression record indefinitely so we honor your opt-out. Site analytics data is typically retained for 24 months.
9. Security
We use commercially reasonable administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, loss, misuse, and alteration. No method of internet transmission or electronic storage is 100% secure.
10. Children
The Site and Service are not directed to children under 13, and we do not knowingly collect personal information from children under 13. If you believe a child has provided us personal information, email privacy@livingsoillab.bio and we will delete it.
11. International users
The Site is operated from the United States and intended for U.S. residents. If you access the Site from outside the United States, you understand that your information will be transferred to and processed in the United States.
12. Changes to this Policy
We may update this Privacy Policy from time to time. If we make material changes, we will notify you by email (for customers) and post the updated Policy on the Site with a new "Last updated" date.
13. Contact
Questions or requests under this Policy: privacy@livingsoillab.bio, or write to GroundTruth Ag, Inc., Attn: Privacy, [EarthOptics HQ address].
Drafted by Claude, 2026-05-12. CCPA-compliant disclosure block included. GDPR-light language included though we do not market to EU residents. Outside-counsel review recommended before full launch; not required for the smoke test. Bracketed placeholders need filling before this goes live: launch date, EarthOptics HQ address, brand-domain. The "Do Not Sell or Share" link must be wired to a real opt-out mechanism (typically a banner or form) before publishing.