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Privacy Policy

Last Modified: February 8, 2023

1. Purpose and Scope

Freightcom Inc. and its affiliates and subsidiaries (the “Company”, “our”, “us” or “we”) are committed to protecting the Personal Information (defined below) of our customers and website users (“you”) from unauthorized collection, access, use, or disclosure, theft or loss. We value your privacy and are committed to being accountable for how we treat your Personal Information. All employees, partners and affiliates are required to adhere to the protections described in this Policy.

Personal Information” means any information (factual or subjective, recorded or not) about an identifiable individual, which includes information that can be used on its own or with other information to identify, contact, or locate a single person. Personal information does not include business contact information, including your name, title, or business contact information.

This Privacy Policy (the “Policy”) addresses the appropriate collection, use and disclosure of Personal Information, the individual’s right to limit access to his/her record, and the secure disposal of the data when it is no longer required.

In this Policy, we explain how we collect, use and disclose your Personal Information that we obtain when you use our services, visit or use our website https://www.freightcom.com and its subdomains or such other website as we may from time to time notify (our “Website”), or otherwise interact with us, and the steps we take to protect your Personal Information. The purpose of this Policy is to inform you of our privacy practices including:

  • a description of the types and categories of Personal Information we collect, or may collect about you;
  • how we collect your Personal Information;
  • the purposes for which we collect, use and disclose your Personal Information (i.e., why we collect it);
  • how we use or intend to use your Personal Information;
  • how to obtain access or request correction of your Personal Information;
  • with which parties we may share your Personal Information;
  • and to provide you with contact information should you have questions or concerns about our practices.

This Policy should be read in conjunction with the Terms of Use of our Website, the Freightcom Insurance Terms, and the Terms of Service.

Please read this Policy carefully to understand our policies and practices for collecting, processing, and storing your information. If you do not agree with our policies and practices, please do not use our Website. By accessing or using this Website, you indicate that you understand, accept, and consent to the practices described in this Policy. This Policy may change from time to time. Your continued use of this Website after we make changes indicates that you accept and consent to those changes, so please check the Policy periodically for updates.


Notice to California Residents
 

If you are a California resident, California law may provide you with additional rights regarding our use of your Personal Information. To learn more about our data collection practices and your California privacy rights, visit the California Consumer Privacy Act of 2018 (CCPA) Privacy Notice.

 

2. Overview of Our Privacy Practices

Our privacy practices are summarized here. The Company:

  1. collects Personal Information when you access or provide information through our website or make inquiries with us;

  2. may collect non-identifiable information regarding users, including the date and time users access our Website, Internet protocol (IP) address, cookies and web beacons;

  3. shares your Personal Information with our authorized employees, agents, service providers and legal representatives, and may also share this information with third parties engaged to provide products and services on our behalf (“Third Parties”), such as the extension of credit, or the provision of shipping information to third party carriers. When connecting to a Third-Party website within our website, such use is governed and controlled by the terms and conditions for those Third Parties. the Company Inc does not control the terms of Third Party websites. We may however, share your Personal Information with these Third Parties in order to fulfill the services you have requested through the use of our Website;

  4. will not share your Personal Information with Third Parties without your consent, except as set out in (3), unless you have (i) authorized us to do so; (ii) as required by law; or (iii) as disclosed to you when the Personal Information is collected;

  5. may collect and use your Personal Information to comply with applicable laws and regulations, to administer our Website, to protect you and us from fraud or other illegal activities, to contact you regarding your inquiries, and to communicate with you (provided you have opted to receive such information);

  6. allows you to withdraw your consent to the collection, storage, use, disclosure and retention of your Personal Information at any time by contacting us at legal "at" freightcom.com;

  7. will mitigate the risk and impact of potential harms involved in the disclosure of Personal Information through the adoption of reasonable physical, technical and organizational procedures appropriate to the sensitivity of the data in an effort to safeguard the Personal Information you provide to us.

 

To assist with meeting our privacy obligations, we have designated a contact person, the Privacy Officer, who is accountable for the Company’s compliance with applicable privacy legislation. The Company adheres to the privacy principles set out by the Canadian Standards Association (CSA). The CSA’s ten privacy principles serve as the basis of Canada’s federal privacy legislation, Personal Information Protection and Electronic Documents Act (S.C. 2000, c. 5). These principles form the basis of our Policy and how the Company collects, uses, discloses and safeguards the Personal Information we hold about you.

 

Privacy Principles

  1. Accountability: we are responsible for the collection, use and disclosure of Personal Information in our custody or control. our privacy contact person is accountable for compliance with our Privacy Policy and can be reached by email legal "at" freightcom.com or telephone at +1 (289) 371-1005.

  2. Identifying purposes for collecting Personal Information: we will identify the purposes for which Personal Information is collected at or before the time the information is collected.

  3. Consent for collection, use, and disclosure of Personal Information Your knowledge and consent are required for the collection, use or disclosure of Personal Information, except where otherwise permitted or required by law

  4. Limiting collection of Personal Information: we will limit the collection of Personal Information to that which is necessary for the authorized purposes identified. Information will be collected by fair and lawful means.

  5. Limiting use, disclosure, and retention of Personal Information: Personal information will not be used or disclosed for purposes other than those for which it was collected. Personal information will be retained only as long as necessary to fulfill those purposes.

  6. Accuracy of Personal Information: Personal information will be as accurate, complete and up to date as is necessary for the purposes for which it is to be used.

  7. Ensuring safeguards for Personal Information: Personal information will be protected by security safeguards appropriate to the nature and format of the information being stored
  8. Openness about Policy: we will provide you with specific information about our policies and practices relating to how we manage your Personal Information.
  9. Individual access to Personal Information: Upon your written request, we will inform you of the existence, use and disclosure of your Personal Information and will give you access to that information, with limited exceptions. you may challenge the accuracy and completeness of the information and may request to have it amended.
  10. Challenging compliance with the Policy you may address a challenge or complaint concerning compliance with the above principles to our Privacy Officer at legal "at" freightcom.com or to the relevant regulatory oversight body.

 

3. Personal Information We Collect About You

We collect only the information that is required to fulfill the purposes described in this Privacy Policy. We do not collect any other information, or allow information to be used for other purposes, without your express (i.e., verbal, written or electronic) consent - except where authorized to do so by law. We maintain information relating the users of our Website and the information they provide. Only Personal Information that is reasonably necessary is collected.

We collect and use several types of information from and about you, from various sources including:

(a) Information you Provide the Company Which Is Necessary to Use our Services

We ask for and collect the following Personal Information about you when you use our Website. This information is necessary for the adequate performance of the contract between you and us and to allow us to comply with our legal obligations and provide you with the Company’s website(s), products, services and applications. Without it, we may not be able to provide you with all the requested services.

  • Account or Registration Information. When you sign up for the Company account or subscribe to our services, we require certain information to create and validate your account, such as your contact information, including your name, business name, username, password, mailing address, freight broker status, shipping address, e-mail address, telephone number.
  • Identity Verification and Payment Information. Such as images of your government-issued ID (as permitted by applicable laws), your ID number or other verification information, bank account, credit card information or payment account information.

(b) Information you Choose to Give Us

You can choose to provide us with additional Personal Information beyond what is required to register for a basic account, including but not limited to the following:

  • information about your business, including industry type, preferred language(s), business name, business address, social media account handles and usernames, photos, website URL’s;
  • user preferences such as system-related settings, email preferences, units of measurement, shipping preferences, default packaging type, operational information about your business, address books of your customers, custom package information and product information including origin, price, and weight; or
  • information you submit when you fill in a form or respond to marketing efforts, such as survey responses and online reviews. We may collect records and copies of your correspondence (i.e., such as e-mail correspondence with various members of the Company) if you contact us or otherwise communicate with our customer service team, or share your experience with us.

(c) Information Automatically Collected By Using our Website and our Services

When you use our Website or our services, we automatically collect Personal Information. This information may include:

  • Geo-location Information. Such as precise or approximate location determined from your IP address depending on your device settings. we may also collect this information when you’re not using the app if you enable this through your settings or device permissions.

  • Usage Information. We collect information about your interactions with the Website, such as the pages products you viewed or searched for on our Website, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page and other information derived from your access and usage of our website information you input into our Website (such as search terms in the search bar), any links you click on, and similar information.

  • “Aggregate Information” means information about users we may collect to create information that is aggregated and anonymized that cannot be used to identify any natural person. We may collect aggregate information in order to develop statistics and analytics about our Website and improve the user experience and the delivery of our services. For example, we may aggregate Personal Information to calculate the percentage of users accessing a specific Website feature. Though Aggregate Information may be derived from Personal Information, it is not considered Personal Information because it cannot be used to identify any natural person.

  • Log Data and Device Information. We automatically collect log data and device information when you access and use our Website, even if you have not created a Website Account or logged in. That information includes, among other things: details about how you’ve used our Website, including if you clicked on links to third-party applications), IP address, MAC address, access dates and times, hardware and software information, browser type and version, time-zone settings, browser plug-in types, operating system, information about your internet connection, device information, device event information, unique identifiers, crash data, cookie data, and the pages you’ve viewed or engaged with before or after using our Website.

  • Cookies and Similar Technologies. We use cookies and other similar technologies when you use our platform or engage with our online ads or email communications. We may collect certain information by automated means using technologies such as cookies, web beacons, pixels, browser analysis tools, and server logs. “Cookies” are small files that are saved onto your device or browser through your web browser that allow us to collect certain Usage Information, and “pixel tags” are tiny graphics with unique identifiers that are embedded on the Website that allow us to collect certain Usage Information. you may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.

  • Web beacons. Pages of our Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

  • Pixels and SDKs. Third parties may use cookies, web beacons, and other storage technologies to collect or receive information from our websites and elsewhere on the internet and use that information to provide measurement services and target ads. For apps, that third parties, including Facebook, may collect or receive information from your app and other apps and use that information to provide measurement services and targeted ads. Users can opt-out of the collection and use of information for ad targeting by updating their third party account ad settings and by contacting us with a description of your request and validation information.

(d) Information from Third Parties

We collect Personal Information from other sources, such as:

  • Third-Party Service Providers. Some content or applications on the Website, including advertisements, are served by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Website. The information they collect may be associated with your Personal Information or they may collect information, including Personal Information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioural) advertising or other targeted content.

    You can opt-out of several third-party ad servers' and networks' cookies simultaneously by using an opt-out tool created by the Digital Advertising Alliance of Canada. you can also access these websites to learn more about online behavioural advertising and how to stop websites from placing cookies on your device. Opting out of a network does not mean you will no longer receive online advertising. It does mean that the network from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.

    We do not control these third parties' tracking technologies or how they are used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

  • Other Sources. To the extent permitted by applicable law, we may receive additional information about you, such as demographic data or information to help detect fraud and safety issues, from third party service providers and/or partners, and combine it with information we have about you. For example, we may receive background check results (with your consent where required) or fraud warnings from service providers like identity verification services for our fraud prevention and risk assessment efforts.

4. How We Use Your Information

We may use, store, and process Personal Information to (i) provide, improve, and develop our Website and our services, (ii) to perform our legal obligations and enforce our policies, and (iii) provide, personalize, measure, and improve our advertising and marketing.

(a) Provide, Improve, and Develop our Website and Services, including to: we use Personal Information to:

  • enable you to access and use the Website and our services,
  • perform analytics, debugging and conduct research,
  • provide you with information, products, or services that you request from us.
  • provide customer service or handle customer complaints,
  • send you messages, updates, security alerts, and account notifications,
  • To notify you about changes to our Website or any products or services we offer or provide though it,
  • to operate, protect, improve, our Website and our services, and personalize and customize your experience (based on your preferences).

 (b) Perform our Legal Obligations and Enforce our Policies: we may use Personal Information to:

  • detect and prevent fraud, spam, abuse, security incidents, and other harmful activity,
  • conduct security investigations and risk assessments,
  • verify or authenticate information provided by you,
  • comply with our legal obligations,
  • enforce our agreements with your or our third-parties,
  • enforce our Terms of Use, the Freightcom Insurance Terms, the Terms of Service and other policies.

(c) Provide, Personalize, and Improve our Advertising and Marketing. we may use Personal Information to:

  • send you marketing, advertising or promotional messages or materials, and other information based on your preferences,
  • personalize, measure, and improve our advertising,
  • administer surveys, sweepstakes, contests, or other promotional activities sponsored or managed by the Company or its third-party partners; and
  • analyze characteristics and preferences to send you promotional messages, marketing, advertising and other information that we think might be of interest to you (based on your preferences).


If you do not want us to use your information to promote our services to you, please use the unsubscribe mechanism, located at the bottom of our e-mails. We provide an opportunity for any user to unsubscribe from our services or opt-out of contact for marketing purposes on an ongoing basis by using the unsubscribe mechanism at the bottom of our e-mails.

we may use the information we have collected from you to enable us to display advertisements to our advertisers' target audiences. Even though we do not disclose your Personal Information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

 

5. Sharing and Disclosure of your Information

We will keep Personal Information that you provide to us private and will disclose such Personal Information only in accordance with this Policy. We do not sell, rent, or lease to third parties any Personal Information we collect from you.

We share your information as needed to fulfill the purposes described in this Privacy Policy and as permitted by applicable law. This includes sharing among our affiliated entities for internal business purposes, sharing with service providers, sharing with your consent, sharing for marketing purposes, sharing as part of corporate transactions, and sharing to protect lawful interests.

We may share your information in the following circumstances:

  • With our Subsidiaries or Affiliates – we may share information between and among the Company, its subsidiaries, and affiliated companies. For example, we may share your information with our subsidiaries and affiliated companies to process orders and requests, and expand and promote our product and service offerings.

  • With our Service Providers – we may share your information with service providers that provide us with support services, such as credit card processing, website hosting, email and postal delivery, location mapping, product and service delivery, or analytics services. We aim at contractually prohibit these service providers from retaining, using, or disclosing your confidential Personal Information for any purpose other than performing agreed upon services for us. We strive to ensure that our Service Providers process the Personal Information with the same standards set out in this Policy.

  • In the Context of Corporate Transactions – If we become involved with a merger, divestiture, restructuring, reorganization, dissolution, sale or transfer, or other corporate transaction or another situation involving the transfer of some or all of our business assets, we may share your information with business entities or people involved in the negotiation or transfer.
  • To Protect Property, Safety and Compliance with Applicable Law – we may disclose your information if we believe that the disclosure is required by law, if we believe that the disclosure is necessary to enforce our agreements or policies, or if we believe that the disclosure will help us protect the rights, property, health or safety of our customers or partners. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction. We may share your Personal Information enforce or apply our Terms of Use, the Freightcom Insurance Terms, the Terms of Service

  • With our Marketing Service Providers – we may share your information with marketing service providers to assess, develop and provide you with promotions and special offers that may interest you, administer contests, sweepstakes and events or for other promotional purposes.

  • With Your Consent – we may share information about you with other companies if you give us permission or direct us to share the information.

  • When the Information Does Not Identify you – we may share your information in a way that does not directly identify you. For example, we may share information about your use of our websites in a manner that does not identify you, or we may combine information about the nature or frequency of your transactions with similar information about other people and share the aggregated information for statistical analysis and other business purposes. For example, the information on a shipping label may include information about the company from which you have purchased a product, and your name and address.

  • When you Provide Information on our Website – If you post information, such as a review, on our Website, the information that you post may be seen by other visitors to our websites, including your user name.

We may transfer Personal Information that we collect or that you provide as described in this Policy to authorized employees, agents, legal representatives, contractors, service providers, and other third parties we use to support our business (such as analytics and search engine providers that assist us with Website administration, improvement and optimization, as well as credit agencies, carriers, and fulfillment centres) and who are contractually obligated to keep Personal Information confidential, use it only for the purposes for which we disclose it to them, and to process the Personal Information with the same standards set out in this Policy. Please note that third-party providers may change from time to time.

we may process, store, and transfer your Personal Information in and to a foreign country, with different privacy laws that may or may not be as comprehensive as Canadian law. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your Personal Information through the laws of the foreign country.

By submitting your Personal Information or engaging with the Website, you consent to this transfer, storage, or processing.

 

6. How Long We Keep Your Personal Information

Except as otherwise permitted or required by applicable law or regulation, we will only retain your Personal Information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. We will ensure that your records are disposed of in a secure and privacy protective manner. In the event that your Personal Information has been delivered to us by a third party who has provided your Personal Information to us only as a condition of such disposal requirements, we shall comply with such disposal requirements.


Under some circumstances, we may anonymize your Personal Information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.


You may request to have all your Personal Information deleted entirely by emailing legal “at” freightcom.com. Unless otherwise required by our vendors’ policies or applicable law, please note that if you request the erasure of your Personal Information:

  • We may retain some of your Personal Information for a limited period of time only as necessary for our legitimate business interests (i.e., to ensure that any pending claims or invoices are dealt with before completing the data deletion request).
  • We will retain a copy of your data deletion request, our requests for clarification/confirmation, and your confirmation of such data deletion request.
  • We may retain and use your Personal Information to the extent necessary to comply with our legal obligations, including tax or regulatory requirements.
  • In order to protect our data from accidental or malicious loss and destruction, residual copies of your Personal Information may not be removed from our backup systems.

 

7.  Choices About We Use and Disclose Your Information

We strive to provide you with choices regarding the Personal Information you provide to us. We have created mechanisms to provide you with the following control over your information:

  • Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this Website may not be accessible or may not function properly.

  • Promotional Offers from the Company. If you have opted in to receive certain emails from us, or if we have sent you a promotional email, but you no longer wish to have your email address/contact information used by the Company to promote our own or third parties' products or services, you can opt-out by clicking the unsubscribe link we have included in the email. This opt-out does not apply to information provided to the Company as part of a purchase, a system notification, a product service experience, or other transactions.

    We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. you can opt out of several third-party ad servers' and networks' cookies simultaneously by using an opt-out tool created by the Digital Advertising Alliance of Canada. you can also access these websites to learn more about online behavioural advertising and how to stop websites from placing cookies on your device. Opting out of a network does not mean you will no longer receive online advertising. It does mean that the network from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.

 

8.  How We Secure Your Personal Information

Safeguards are in place to protect the security of your information. We keep the Personal Information we collect about you confidential and have adopted reasonable physical, technical and organizational procedures appropriate to the sensitivity of the data to safeguard the Personal Information you provide to us. These safeguards are aimed at protecting Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification.

Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to our Website. Notwithstanding the security measures we have in place, no collection, storage or transmission of information over the Internet on websites or otherwise can be guaranteed to be completely secure, and therefore we cannot ensure, warrant or guarantee the security of any such information. As a result, we cannot warrant the security of any information you transmit to us, and you do so at your own risk.

Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website like message boards, which any Website visitor can view.

 

9.  Children Under the Age of 13

Our Website is not intended for children under 13 years of age. No one under age 13 may provide any information to or on the Website. We do not knowingly collect Personal Information from children under 13. If you are under 13, do not use or provide any information on this Website or on or through any of its features/register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or username you may use. If we learn we have collected or received Personal Information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at legal "at " freightcom.com.

 

10.  Third Party Hyperlinks

Our Website may contain hyperlinks to the websites of third parties. We are not responsible for the privacy practices or the content of such other websites. Linked websites are maintained by third parties. Such links are provided for your convenience and reference only. the Company does not operate or control, in any respect, any information, software, products or services available on such third-party websites. The inclusion of a link to such website does not imply any endorsement of the services or the site, its contents, or its sponsoring organization. We strongly advise you to review the privacy Policy of every website you visit.

 

11. Accessing and Correcting Your Personal Information

It is important that the Personal Information we hold about you is accurate and current. Please keep us informed if your Personal Information changes. By law you have the right to request access to and to correct the Personal Information that we hold about you.

You can review and change your Personal Information by logging into the Website and visiting your account profile page.

If you want to review, verify, correct, or withdraw consent to the use of your Personal Information you may also send us an email at legal “at” freightcom.com to request access to, correct, or delete any Personal Information that you have provided to us. If you have a user account with us, please note that we cannot delete your Personal Information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the Personal Information that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the Personal Information that we hold about you, or we may have destroyed, erased, or made your Personal Information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your Personal Information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

We will provide access to your Personal Information, subject to exceptions set out in applicable privacy legislation. Examples of such exceptions include:

  • Information protected by solicitor-client privilege.
  • Information that is part of a formal dispute resolution process.
  • Information that is about another individual that would reveal their Personal Information or confidential commercial information.
  • Information that is prohibitively expensive to provide


12.  Withdrawing Your Consent

Where you have provided your consent to the collection, use, and transfer of your Personal Information, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact us at marketing "at" freightcom.com. Please note that if you withdraw your consent we may not be able to provide you with a particular product or service. We will explain the impact to you at the time to help you with your decision.

13.  Changes To Our Privacy Policy

The Company reserves the right to modify this Privacy Policy at any time, and from time to time, in accordance with this provision. If we make changes to this Policy, we will post the revised Privacy Policy on our Website and update the “Last Modified” date at the top of this Policy. 

If we make material changes to how we treat our users' Personal Information, we will notify you by email to the primary email address specified in your account or through a notice on the Website home page. You are responsible for ensuring we have an up-to-date, active, and deliverable email address for you, and for periodically visiting our Website and this privacy Policy to check for any changes.

If you disagree with the revised Policy, you may cancel your account. If you do not cancel your account before the date the revised Policy becomes effective, your continued access to or use of the Website or our services will be subject to the revised Policy and you will be deemed to have consented to the revised Policy.


14.  Severability

If any term, provision, covenant, or condition of this Policy is held invalid or unenforceable for any reason, the remainder of the provisions shall continue in full force and effect as if this Policy had been executed with the invalid portion thereof eliminated.

15.  Contact Information and Challenging Compliance

We welcome your questions, comments, and requests regarding this Privacy Policy and our privacy practices. Please contact us at:

Privacy Officer

legal "at" freightcom.com

+1 (289) 371-1005

We have procedures in place to receive and respond to complaints or inquiries about our handling of Personal Information, our compliance with this Policy, and with applicable privacy laws. To discuss our compliance with this Policy please contact our Privacy Officer using the contact information listed above.

 



California Consumer Privacy Act Rights

As of January 1, 2020 verified California residents will have the right to:

  • request and receive disclosure of our personal information collection practices during the prior 12 months, including the categories of personal information we collect, the categories of sources of such information, our business purpose for collecting or sharing such information, and the categories of third parties with whom we share such information.

  • request and receive a copy of the personal information we have collected about them during the prior 12 months.

  • request and receive disclosure of our information sharing practices during the prior 12 months, including a list of the categories of personal information sold with the category of third party recipients and a list of the categories of personal information that we disclosed for a business purpose.

  • request that we not sell personal information about them and

  • request that we delete (and direct our service providers to delete) their personal information subject to certain exceptions.

In order to make a request for disclosure, California residents may contact us by phone number or contact page. We will ask you for information that allows us to reasonably verify your identity (that you are the person about whom we collected personal information) and will use that information only for that purpose. We may request that you submit a signed statement under penalty of perjury that you are the individual you claim to be. We will acknowledge receipt of your request within 10 days and will endeavor to respond within forty-five days of receipt of your request, but if we require more time (up to an additional forty-five days) we will notify you of our need for additional time. For requests that we not sell your information we will comply with your request within 15 days. We cannot respond to your request or provide you with personal information if we cannot verify your identity and confirm that the personal information relates to you.

We cannot verify your identity and confirm that the personal information relates to you.

You may make a request for disclosure of our information collection practices, the information we collected about you, or our sharing practices up to twice within a 12-month period. You may make a request that we not sell information or for deletion of your information at any time.

For requests for a copy of the personal information we have collected during the 12 months prior to your request we will endeavor to provide the information in a format that is readily useable, including by mailing you a paper copy or providing an electronic copy to your registered account, if you have registered an account with us.

For requests for deletion of your information please understand that California law permits us to retain certain information and not to delete it under certain circumstances. By way of example, we are not required to comply with a request to delete information if the information is necessary for us to complete a transaction for you or otherwise perform a contract; to detect, protect against, or prosecute security incidents, fraud or illegal activity; to use the information only internally in ways reasonably aligned with your expectations as our customer (such as maintaining sales records), and to comply with legal obligations. If we receive such a request from you we will notify any service providers we have engaged to delete your information as well.

We will not discriminate against you as a result of your exercise of any of these rights.


Selling Information.

We do not sell your information for monetary consideration and we do not disclose your information for other valuable consideration. If in the future, we enter into arrangements that fall within the definition of a “sale” under the CCPA, we will update this privacy policy and our compliance with the CCPA. 

Using an Authorized Agent. You may submit a request through someone holding a formal Power of Attorney. Otherwise, you may submit a request using an authorized agent only if (1) you provide the authorized agent with written permission to make a request and (2) you verify your own identity directly with us. We will require the agent to submit proof to us that they have been authorized to make requests on your behalf.

During the past 12 months, we have collected the following categories of information from the listed sources, used it for the listed business purposes and shared it with the listed categories of third parties. The categories of information include information we collect from our website visitors, registered users, employees, vendors, suppliers and any other person that interacts with us either online or offline. Not all information is collected about all individuals. For instance, we may collect different information from applicants for employment or from vendors or from customers.

 
 
Category of Information Collected Source Business Purposes* for use

Categories of third parties receiving information

Identifiers (name, alias, postal address, email address, phone number, fax number, account name, Social Security number, driver's license number, passport number, unique personal identifier, IP address)
  • Individuals submitting information to us;
  • information we automatically collect from site visitors;
  • information we may receive from third-party marketing and data partners.
  • Auditing relating to transactions;
  • security detection, protection and enforcement;
  • functionality debugging/error repair;
  • ad customization;
  • performing services for you;
  • internal research and development;
  • quality control.
  • Service providers (such as payment processors, mail houses, marketing partners, shipping partners, employee benefits partners);
  • affiliated companies;
  • government regulators;
  • law enforcement;

 

Sensitive Information (information related to your financial account, credit card information, information about your customers, username and password)

  • Individuals submitting information;
  • Credit agencies;
  • Payment processors;
  • Auditing relating to transactions;

  • security detection, protection and enforcement;

  • credit checks;

  • payment processing;

  • performing services for you;

  • quantity control;
  • Service providers (such as payment processors, credit agencies);
  • affiliated companies;
  • government regulators;
  • law enforcement;
Protected classification information (race, gender, ethnicity, religion)
  • Not collected
  • Not collected
  • Not collected
Commercial information (transaction history, your customer information, products shipped, delivery addresses, business website, business social media handles, information about corporate officers and directors, trade references, prices of your products)
  • Individuals submitting information;

  • information we automatically collect from Website visitors and Website users.
  • Auditing relating to transactions;

  • security detection, protection and enforcement;

  • functionality debugging/error repair;

  • ad customization;

  • performing services to you;

  • internal research and development;

  • quality control

  • Service providers (such as payment processors, mail houses, marketing partners, shipping partners, employee benefits partners)

  • government regulators

  • law enforcement
Electronic network activity (browsing or search history, website interactions, advertisement interactions)
  • Information automatically collected from site visitors.
  • Auditing relating to transactions;
  • security detection, protection, and enforcement;
  • functionality debugging/error repair;
  • ad customization;
  • performing services for you;
  • internal research and development;
  • quality control

 

  • N/A
Audio, video or similar information (customer service calls, security monitoring)
  • Individuals submitting information;
  • information we collect for security purposes
  • Auditing relating to transactions;
  • security detection, protection and enforcement;
  • performing services for you;
  • internal research and development;
  • quality control and training purposes
  • Service providers (such as payment processors, mail houses, marketing partners, shipping partners, employee benefits partners);
  • government regulators;
  • law enforcement;

 

Biometrics
  • Not collected
  • Not collected
  • Not collected

 

Geolocation
  • Information we automatically collect from site visitors.
  • Auditing relating to transactions;
  • security detection, protection and enforcement;
  • functionality debugging/error repair;
  • ad customization;
  • performing services for you;
  • internal research and development;
  • quality control
  • Service providers (such as payment processors, mail houses, marketing partners, shipping partners, employee benefits partners)
  • government regulators
  • law enforcement

 

Professional, educational or employment related information
  • Information submitted by individuals

  • Auditing relating to transactions;

  • security detection, protection and enforcement;

  • functionality debugging/error repair;

  • ad customization;

  • performing services for you;

  • internal research and development;

  • quality control
  • Service providers (such as payment processors, mail houses, marketing partners, shipping partners, employee benefits partners);

  • government regulators;

  • law enforcement;

Inference from the above (preferences, characteristics, behavior, attitudes, abilities, etc.)
  • Internal analytics
  • Shipping labels
  • Performing services for you

  • Internal research and development
  • Service providers (such as payment processors, mail houses, marketing partners, shipping partners, employee benefits partners)


*More specifically, the business purposes include:

(1) Performing services for you:

  • To administer or otherwise carry out our obligations in relation to any agreement to which we are a party;
  • To assist you in completing a transaction or order;
  • To allow tracking of shipments;
  • To prepare and process invoices;
  • To respond to queries or requests and to provide services and support;
  • To provide aftersales customer relationship management;
  • To create and manage our customer accounts;
  • To notify you about changes to our services and products;
  • To administer any promotion, contest, survey, or competition;
  • To provide you information regarding our products and services,
  • To offer our products and services to you in a personalized way, for example, we may provide suggestions based on your previous requests to enable you to identify suitable products and services more quickly.

(2) Advertising customization:

  • For marketing and promotions we believe you may find of interest and to provide you, or allow selected third parties to provide you, with information about products and services that may interest you.

(3) Auditing relating to transactions, internal research and development:

  • To provide for internal business administration and operations, including troubleshooting, Site customization, enhancement or development, testing, research, administration and operation of our Sites and data analytics;
  • To create products or services that may meet your needs;
  • To measure performance of marketing initiatives, ads, and websites “powered by” another company on our behalf.

(4) Security detection, protection and enforcement; functionality debugging, error repair:

  • As part of our efforts to keep our Sites safe and secure;
  • To ensure the security of your account and our business, preventing or detecting fraud, malicious activity or abuses of our Sites, for example, by requesting verification information in order to reset your account password (if applicable);
  • To ensure the physical security of our premises through the monitoring of surveillance images;
  • To resolve disputes, to protect the rights, safety and interests ourselves, our users or others, and to comply with our legal obligations.

(5) Quality control:

  • To monitor quality control and ensure compliance with our legal obligations, codes and ordinances, policies and procedures,
  • To develop and improve our products and services, for example, by reviewing visits to the Sites and various subpages, demand for specific products and services and user comments.