ICM, Inc. Privacy Notice
Privacy and Data Protection Notice

LAST UPDATED November 2, 2026

ICM Holdings, Inc., and its affiliate companies (ICM Tecnologia Em Biocumbustiveis, Ltda.; ICM Feed Innovation, LLC; and Pellet Technology USA, LLC) (collectively "ICM", "we", or "us") respects your privacy and is committed to protecting your Personal Information (PI). This privacy notice explains how ICM collects, uses, discloses, retains, and protects Personal Information (PI) when you visit our websites, interact with us, submit information to us, communicate with us, or apply for employment through our websites.

This privacy notice is intended to provide transparency regarding our privacy practices and to describe rights that may be available to individuals under applicable privacy and data-protection laws.

1. Who We Are

ICM Holdings Inc, is headquartered in Colwich, Kansas with a regional office in Brazil. ICM Holdings Inc provides innovative technologies, solutions and services to sustain agriculture and to advance renewable energy, including ethanol and feed technologies that will increase the supply of world protein.

Where a particular ICM Holdings Inc affiliate acts as the controller, business, or other responsible entity for particular processing activities, that entity may provide additional or separate privacy notices.

2. Scope

This Privacy Notice applies to Personal Information collected through:

• ICM Holdings Inc websites;
• online forms;
• contact and inquiry forms;
• career and recruiting activities;
• email and other electronic communications;
• customer and vendor interactions;
• events and conferences;
• social-media interactions; and
• reports or complaints submitted to ICM.

3. Personal Information We Collect

Depending on your relationship with ICM Holdings Inc, we may collect the following categories of Personal Information.

A. Identifiers and contact information

Examples include:

• name;
• postal address;
• email address;
• telephone number; and
• user or account identifiers.

B. Commercial and business information

Examples include:

• products or services requested;
• business relationship information;
• purchasing or transaction information;
• communications concerning ICM products and services; and
• customer or vendor relationship information.

C. Internet and electronic activity information

Examples include:

• IP address;
• browser type;
• device information;
• operating system;
• date and time of visits;
• approximate location derived from IP address;
• website interaction information; and
• cookie and similar technology information.

D. Sensitive Personal Information

ICM Holdings Inc does not collect, store, process or share Sensitive Personal Information. Our websites are not intended for children under 13 years of age, and as such, we do not knowingly collect or solicit any information from anyone under the age of 13 or knowingly allow children under the age of 13 to disclose their personal information to us.

4. Sources of Personal Information

We may obtain Personal Information:

• directly from you;
• from recruiters or employment-related sources;
• from publicly available sources;
• from social-media platforms; and
• automatically through websites, cookies and similar technologies.

5. How We Use Personal Information

We may use Personal Information for the following purposes:

• responding to inquiries;
• providing products and services;
• managing customer and vendor relationships;
• communicating with customers and prospective customers;
• processing employment applications;
• administering and improving website functionality and user experience;
• maintaining information security;
• investigating complaints or reports;
• complying with legal and regulatory obligations; and
• responding to lawful requests from governmental authorities.

We will not use Personal Information for materially incompatible purposes without providing additional notice or obtaining consent where required by law.

6. Legal Bases for Processing — GDPR

Where the GDPR or UK GDPR applies, ICM Holdings Inc will process Personal Data on an applicable legal basis, which may include:

• performance of a contract;
• compliance with a legal obligation;
• ICM's legitimate interests; and
• Consent.

Where we rely on legitimate interests, we will consider the interests, rights and freedoms of affected individuals. Where processing is based on consent, you may withdraw consent at any time, subject to applicable law.

GDPR transparency requirements include disclosure of purposes, categories of data, legal bases, retention periods, recipients, and applicable rights.

7. How We Share Personal Information

ICM Holdings Inc may disclose Personal Information to:

• Service providers and processors who perform services such as Information Technology, recruiting, website hosting, analytics, and legal services. These providers may process Personal Information only as permitted by their agreements with ICM and applicable law.
• ICM affiliates for legitimate business purposes and as permitted by applicable law.

8. Sale and Sharing of Personal Information

ICM Holdings Inc does not sell Personal Information for monetary consideration.

9. Cookies and Similar Technologies

Cookies are text files placed on your computer to collect standard internet log information and visitor behavior information. When you visit our Websites, we may collect information from you automatically through cookies or similar technology. ICM uses cookies to monitor our Websites, assess performance and traffic analytics, remember visitor behavior, and to make website improvements.

ICM Holdings Inc may use the following technologies: cookies, pixels, web beacons, or tags.

Where required, ICM will provide appropriate choices regarding non-essential cookies and similar technologies. You may also control certain cookies through your browser settings.

10. Universal Opt-Out Preference Signals

Where required by applicable law, ICM Holdings Inc will recognize Universal Opt-Out Mechanisms (UOOMs) or opt-out preference signals, including Global Privacy Control (GPC), where applicable.

11. Artificial Intelligence and Automated Decision-Making

ICM Holdings Inc is not using your Personal Information in Artificial Intelligence or Automated Decision-Making technologies.

12. Data Retention

ICM Holdings Inc retains Personal Information only for as long as reasonably necessary for the purposes described in this Notice, unless a longer period is required or permitted by law.

When Personal Information is no longer required, ICM will delete, destroy, anonymize, or otherwise dispose of it in accordance with applicable law and ICM's records-retention procedures.

13. Security

ICM Holdings Inc maintains administrative, technical and physical safeguards designed to protect Personal Information against unauthorized access, disclosure, alteration, loss, misuse, or destruction.

These safeguards may include:

• access controls;
• authentication;
• encryption;
• network and endpoint security; and
• monitoring.

No method of transmission or storage can be guaranteed to be completely secure.

14. Exercising Your Privacy Rights

To exercise your privacy rights, submit a request to ICM Holdings Inc by email [email protected] or call us at +1(877) 456-8588. Where required by law, ICM Holdings Inc will respond within the applicable statutory timeframe.

If you are not satisfied with our response to your requests, individuals may first contact ICM using the information above. Where applicable law provides a right to complain to a regulatory authority, individuals may also contact the relevant U.S. state Attorney General, or Data Protection authority.

For GDPR matters, this may include the supervisory authority in the individual's country of residence, place of work, or place of the alleged infringement.

For Brazilian matters, individuals may contact the Autoridade Nacional de Proteção de Dados (ANPD) where permitted by applicable law.

15. U.S. Privacy Rights

Depending on your state of residence and whether ICM Holdings Inc is subject to the applicable law, you may have rights* including:

• Access/Know — obtain information about Personal Information we process;
• Correction — request correction of inaccurate information;
• Deletion — request deletion of Personal Information;
• Portability — obtain certain Personal Information in a portable format;
• Appeal — appeal certain decisions concerning privacy requests; and
• Authorized agent — use an authorized agent where permitted.

*Not every right applies in every state, and exceptions may apply.

16. Data Protection Rights under GDPR and UK GDPR

Data subjects, residing in the European Economic Area, United Kingdom and Switzerland where GDPR or UK GDPR applies, have the following data protection rights:

• access;
• rectification;
• erasure;
• restriction;
• objection;
• data portability;
• withdrawal of consent; and
• the right to lodge a complaint with a supervisory authority.

ICM Holdings Inc will respond to GDPR rights requests within the applicable statutory period, generally one month, subject to permitted extensions.

17. Brazilian Residents Personal Data Rights under LGPD

Where Brazil's Lei Geral de Proteção de Dados Pessoais (LGPD) applies, individuals may have rights over their personal data:

• confirmation of processing;
• access;
• correction;
• anonymization, blocking or deletion where applicable;
• portability;
• deletion of Personal Data processed on the basis of consent, subject to statutory exceptions;
• information concerning public and private entities with which Personal Data has been shared;
• information concerning the possibility of refusing consent and the consequences;
• revocation of consent; and
• review of certain decisions based solely on automated processing.

18. Third-Party Website

ICM Holdings Inc websites may contain links to websites operated by third parties. This Privacy Notice does not apply to third-party websites or services. Individuals should review the privacy notices of those third parties before providing Personal Information.

19. Changes to this Privacy Notice

ICM Holdings Inc will update the privacy notice from time to time and without notice. Changes will be posted on this page and are effective when posted. Your continued use of this website after such changes have been posted signifies your agreement to be bound by the revised Privacy Notice.

20. How to Contact Us

If you have questions about this privacy notice, our privacy practices, or wish to file a concern, you may contact the Privacy / Data Protection Officer at:

INC Inc.
Attn: Privacy / Data Protection Officer
310 N. First Street, Colwich, KS 67030
Email: [email protected]
Telephone: +1 (877) 456-8588