(The practices described in this Privacy Policy are our current as of May 2018)
At our Company, we value the privacy of those who provide personal information to us. The Company is responsible for any personal information collected about you. That will predominantly be the Company in your jurisdiction, or the Company which is providing services to you or to which you are providing services.
1. What is the purpose and scope of this Privacy Policy?
The Company handles personal information relating to its Clients, suppliers and contractors. We have considered our obligations under data protection laws and have prepared this Privacy Policy in the interests of being transparent about our use of personal information. In this Privacy Policy, we describe what personal information we collect about our Clients, suppliers, vendors and contractors (whether from them directly or from third party sources), how we use that information, the legal basis upon which we process it, with whom it is shared, and how it is stored.
This Privacy Policy applies to our collection and use of personal information:
- through the Company website;
- when you become a customer of ours and/or we provide services to you; and / or
- if you are (or work for) one of our Clients, suppliers, vendors or contractors or provide services to us.
If you have any questions or comments on this Privacy Policy, you can contact us by email at [email protected] at any time.
Please read this Privacy Policy carefully to understand how we handle your personal information.
2. Information collection
We may collect and use any of the following information about you and we refer to this as “personal information” throughout this Policy:
2.1 Personal information you give us.
You may give us personal information through our Website or by contacting us by phone, email or other means. This includes, for example, when you provide your personal information to us in order to receive our services, or to provide goods or services to us.
The personal information you give us may include:
a) your name;
b) your job title;
c) company name;
d) email address;
e) your telephone number;
f) account information;
g) your and/or your company’s address;
h) other information provided when you correspond with us; and
i) any updates to the information provided to us.
We may obtain personal information from third party sources, such as agents.
Please note that we need certain types of personal information so that we can provide our services or receive goods or services from you. If you do not provide us with such personal information, or ask us to delete it, you may no longer be able to access and use our services, or to provide goods or services to us.
2.2 Personal information we collect about you.
Each time you visit our Website, we may automatically collect any of the following information:
a) technical information, including the Internet protocol (IP) address used to connect your computer to the internet, domain name which requests information, the files requested, browser type and version, browser plug-in types and versions, operating system and platform; and
b) information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time), time and length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, traffic data, location data, weblogs and other communication data and information provided when requesting further service or downloads.
c) Email addresses and passwords associated with logins to the Company Website’s and/or web applications.
3. Use of information
We collect, use and store the personal information listed above for the following reasons:
3.1 Providing services (if you are a customer):
a) to provide services to you, your company or your or your company’s Clients;
b) to verify your identity;
c) to resolve claims, including for cargo damage;
d) to pursue debt from our Clients and/or other responsible parties;
e) to notify you about changes to our services and to keep you informed about our fees and charges; and
f) for business development and marketing purposes, to contact you (including by email or post) with information about our services which we feel will be of interest to you or your Clients (you can opt out or let us know at any time if you would no longer like to hear from us).
3.2 Receiving services (if you are a supplier or contractor)
a) to enable us and/or our Clients to receive goods or services from you;
b) to verify your identity;
c) to resolve claims, including for cargo damage;
d) to pay debts; and
e) for business development and marketing purposes, to contact you (including by email or post) with information about our services which we feel will be of interest to you (or your Clients) (you can opt out or let us know at any time if would no longer like to hear from us).
3.3 Visiting our Website:
a) to allow you to access and use our Website;
b) to provide technical support;
c) to provide you with the information and services that you request from us;
d) to ensure the security of our services and Website;
e) to store information about your preferences, and to allow us to customize the Website according to your individual needs;
f) to recognize when you return to our Website; and
g) to improve and maintain our Website and prepare reports or compile statistics in order to improve our services. Such details will be anonymized as far as is reasonably possible.
3.4 To comply with any procedures, laws and regulations which apply to us, to comply with our legal obligations or, otherwise, where it is necessary for our legitimate interests or the legitimate interests of others; and
3.5 To establish, exercise or defend our legal rights where it is necessary for our legitimate interests or the legitimate interests of others or to comply with a legal obligation.
4. Legal basis for use of your personal information
4.1 Data protection and Privacy laws require us to have a legal justification for collecting, using and otherwise handling your personal information. We consider that our legal basis for using your personal information as set out in this Privacy Policy:
a) is necessary to perform our obligations under any contract with you (for example, to comply with our contract to provide services to you), to provide services to you, your company and/or Clients, or to receive goods or services from you or your company);
b) is necessary to comply with our legal obligations; or
c) where use of your personal information is not necessary for performance of a contract, to provide services, to receive goods or services or to comply with our legal obligations, use of your personal information is necessary for our legitimate interests or the legitimate interests of others; for example, to ensure the security of our Website.
4.2 In the future, other uses of your personal information may require us to obtain your consent (which can be withdrawn at any time, as described below). Where this is the case, that need for consent will be identified in this Privacy Policy.
5. Cookies
5.1 Some pages on our Website use cookies, which are small files placed on your internet browser when you visit our Website. We use cookies in order to offer you a more tailored experience in the future, by understanding and remembering your particular browsing preferences.
5.2 We use cookies on our Website with your consent (which you may withdraw at any time after giving it). If you wish to withdraw your consent at any time, you can activate the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts or our Website.
5.3 For detailed information on the cookies we use and the purposes for which we use them, please refer to our Cookies Policy. By continuing to use our Website, you are agreeing to our use of cookies as described in our cookies policy.
6. Disclosure of personal information
6.1 We may share your personal information with any company that is a member of our group, where it is in our legitimate interests to do so for internal administrative purposes (for example, to perform services for our Clients).
6.2 We will also share your personal information with certain third parties who handle personal information on our behalf; including:
a) our service providers, suppliers, sub-contractors and any other vendors we use to provide services, including but not limited to payment processors, third party data processors, suppliers of technical and support services and cloud service providers; and
b) companies that may assist us in marketing, advertising and promotional activities. Any third parties who handle your personal information on our behalf are limited (by law and/or by contract) in their ability to use your personal information for any purpose other than to provide services to or for us.
6.3 We may also share your personal information with third parties:
a) if we sell or buy any business or assets, we may disclose your personal information to the prospective seller or buyer of such business or assets;
b) if substantially all of the Company’s or any of its affiliates’ assets are acquired by a third party, in which case personal information held by the Company may be one of the transferred assets;
c) if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, any lawful request from government or law enforcement officials and as may be required to meet national security or law enforcement requirements or prevent illegal activity;
d) in order to enforce or apply our terms and conditions or any other agreement or to respond to any claims, to protect our rights or the rights of a third party, to protect the safety of any person or to prevent any illegal activity; or
e) to protect the rights, property, or safety of the Company, our Clients or other persons. This may include exchanging personal information with other organizations for the purposes of fraud protection and credit risk reduction.
6.4 We may also disclose and use anonymized, aggregated reporting and statistics about users of our services and / or our Website for the purpose of internal reporting or reporting to our group or other third parties, and for our marketing and promotion purposes. None of these anonymized, aggregated reports or statistics will enable our users to be personally identified.
6.5 Save as expressly detailed above, we will not share, sell or rent any of your personal information to any third party without notifying you and, where necessary, obtaining your consent.
7. Retention of personal information
7.1 We keep your personal information for no longer than necessary for the purposes for which the personal information is processed and as required by applicable law.
7.2 We currently store personal information for the following periods of time pursuant to our Electronic Data Retention and Destruction Policy:
a) Data that resides on the Company user desktops/laptops shall be retained for 4 years;
b) E-mails that reside on the Company mail backup platforms shall be retained for 4 years;
c) Data that resides on the Company provisioned storage (shared network drives and file locations) shall be retained for 7 years;
d) Data that resides in the Company operational systems shall be retained for 7 years; and
e) Data that resides in the Company financial systems shall be retained for 7 years.
8. Your rights
8.1 When you make a request to us in relation to your personal information, we may ask you to provide certain additional information for us to confirm your identity.
8.2 We will consider all requests and provide our response within the time period stated by applicable law.
8.3 Please note, however, that those rights will only apply in certain countries. Even where they do apply, there are certain exemptions to them; for example, we may not need to comply with a request from you to delete your personal information if we still need that information for our legitimate interests or to comply with a legal obligation.
8.4 If you would like further information in relation to these rights or would like to exercise any of them, please contact us by email at [email protected] at any time.
9. Security
9.1 The Company is committed to protecting personal information from loss, misuse, disclosure, alteration, unauthorised access and destruction and takes reasonable precautions to safeguard the confidentiality of personal information. Because the transmission of information over the internet is not completely secure, you acknowledge and accept that we cannot guarantee the security of your personal information transmitted to our Website and that any such transmission is at your own risk.
9.2 Where we have given you (or where you have chosen) a password which enables you to access your online account, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
10. Third Party Websites
Our Website may, from time to time, contain links to Websites operated by third parties including partner networks and other companies. Please note that this Privacy Policy only applies to the personal information that we collect through our Website and we cannot be responsible for personal information collected and stored by third parties. Third Parties’ Websites have their own terms and conditions and Privacy Policies, and you should read these carefully before you submit any personal information to these Websites. We do not endorse or otherwise accept any responsibility or liability for the content of such third-party Websites or third-party terms and conditions or policies.
11. Changes to our Privacy Policy
We may update our Privacy Policy from time to time. Any changes we make to our Privacy Policy in the future will be posted on this page. Please check back frequently to see any updates or changes to our Privacy Policy. By continuing to use our Website and / or our services, or by continuing to provide goods or services to us, you are confirming that you have read and understood the latest version of our Privacy Policy.
12. Further questions or making a complaint
12.1 If you have any queries or complaints about our collection, use or storage of your personal information, or if you wish to exercise any of your rights in relation to your personal information, please contact [email protected]. We will investigate and attempt to resolve any such complaint or dispute regarding the use or disclosure of your personal information.
12.2 To the extent that our processing of your personal information is subject to European data protection laws, you may also make a complaint to the relevant data protection authority. If you are unsure which data protection authority to contact, please contact [email protected] for further advise.