Privacy Policy

January 13, 2020

Last Updated and Effective as of : January 1, 2020

FreightPal, Inc., (hereinafter, “we”, “our” or “us”). We respect your privacy and are committed to protecting your information. Except as described in the California Privacy section below, this privacy policy discloses our practices regarding information collection and usage solely for the website located at www.freightpal.com  (the “Website”).
This privacy policy aims to give you information on how we collect and process your information through your use of the Website, including any data you may provide through the Website when you use our service or contact us using the contact information below.
It is important that you read this privacy policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing information about you so that you are fully aware of how and why we are using your data.
This privacy policy is provided in a layered format so you can click through to the specific areas set out below.

INFORMATION COLLECTION
Your provision of your personal information to us is completely voluntary. “Personal Information” is information that can specifically identify you. Categories of Personal Information we may collect include:

  • Identity Data, which includes name or other similar identifiers.
  • Contact Data, which includes address, email address and telephone numbers.

Additionally, we may also collect certain other types of information that, along with Identity Data and Contact Data, may be considered and specifically named “Non-Public Information” or “Personal Data” in certain jurisdictions, including the European Union (“EU”), including but not limited to:

  • Financial Data, which includes credit card, debit card or other payment card details.
  • Transaction Data, which includes details about payments to and from you.
  • Technical Data, which includes internet protocol (IP) address, location data, your login data, and device and browser information.
  • Profile Data, which includes your username and password, your dining interests, food allergies and preferences.
  • Usage Data, which includes information about how you use our Website and Partner Sites and advertising we serve on those sites.
  • Marketing and Communications Data, which includes your preferences in receiving marketing from us.

IF YOU ARE SITUATED IN THE EU, PLEASE SEE THE SECTION “ADDITIONAL EU DISCLOSURES” THAT PERTAIN TO OUR COLLECTION, USE AND DISCLOSURE OF YOUR PERSONAL DATA AND ADDITIONAL RIGHTS YOU HAVE UNDER APPLICABLE LAW.
We use different methods to collect data from and about you including through:
Direct interactions: You may give us your information by registering or contacting us. This includes information you provide when you:

  • create an account on our website;
  • subscribe to our service or publications;
  • book a shipment through our website and services;
  • request marketing to be sent to you; or
  • give us feedback.

Automated technologies or interactions: As you interact with our Website, we may automatically collect Technical Data and Usage Data about your use of our Website. Some of the ways in which we or our Website may collect information are further described below:

  • Cookies and other technologies: The Website may use cookies, a type of technology that installs a small amount of information on a website user’s computer or other device to permit a website to, for example, recognize future visits using that computer or device. The Website may use other similar technologies (including, without limitation, tracking pixels, as described further below, and other anonymous identifiers) to gather information about you, such as IP addresses and location data, to customize your visit, to enable us to enhance our service, or for other purposes. Please see our Cookie Policy located on the Freightpal.com homepage for further details.
  • Interest-Based Advertising: We currently do not, but may in the future, engage third-party vendors to use your information in connection with their own information to deliver targeted advertising to you when you visit our website or other websites. Cookies, described above, may be used in this process. For example, if you are searching for information on a particular product, our vendor may cause an advertisement to appear on other websites you view with information on that product.
  • Clickstream Data: As you use the Internet, a trail of electronic information is left at each website you visit. This information, sometimes referred to as “Clickstream Data,” can be collected and stored by a website’s server. For example, Clickstream Data can tell the type of computer and browsing software you use and the address of the website from which you linked to the website. The Website may collect and use Clickstream Data as a form of aggregate information to anonymously determine how much time visitors spend on each page of our website, how visitors navigate throughout the Website and how we may tailor our website to better meet the needs of visitors. This information often will be used to improve our Website and our services. Any collection or use of clickstream data will be anonymous and aggregated and will not intentionally contain any Personal Information.
  • Location Data: When given permission, we will collect the latitude and longitude coordinates of your device when you are setting a pick-up location. We use this information to help us improve the ease of use and limit user data entry.

INFORMATION USE AND SHARING

Subject to the section titled “Additional EU Disclosures”, we use information held about you to perform our services and for other purposes outlined below. Specifically, we use your information for a variety of purposes:

  • To perform a contract with you;
  • To perform specific services that you have requested;
  • To respond to your direct inquiries;
  • For joint marketing with other financial companies;
  • For our affiliates’ everyday business purposes;
  • Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests;
  • To send you FreightPal marketing materials;
  • To send you marketing materials for our affiliates’ products and services;
  • Where we need to comply with a legal or regulatory obligation; and
  • In other ways as required or permitted by law or with your consent.

Subject to the section titled “Additional EU Disclosures”, we will not disclose information that we collect about you to third parties without your consent and except as provided by this privacy policy. We may disclose information to third parties if you consent to us doing so, as well as in the following circumstances:

  • To use certain services on our Website, payment card information may be requested. We may ask you for credit card, debit card, or other payment information. By submitting your payment information through our Website, to the extent permitted by applicable law, you expressly consent to the sharing of your information with third-party payment processors, and other third-party service providers.
  • To third party service providers to provide website, application development, hosting, maintenance, and other services for us. These third parties may have access to or process your information as part of providing those services for us. Generally, we limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions, and we require them to agree to maintain the confidentiality of such information.
  • To respond to requests from law enforcement authorities and our regulators, or to respond to requests if we are involved in a legal proceeding.
  • To third parties as necessary to investigate and correct technical problems and malfunctions in the Service or the computer systems that support the Service.

If your account is closed, we may take steps to delete certain information, but we reserve our ability to retain and access the data for so long as required to comply with applicable laws. We will continue to use and disclose information in accordance with this privacy policy.

THIRD-PARTY LINKS AND SOCIAL NETWORKING SERVICES

The Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy policy of every website you visit.

The Website may integrate with social networking services. You understand that we do not control such services and are not liable for the manner in which they operate. While we may provide you with the ability to use such services in connection with our website, we are doing so merely as an accommodation and, like you, are relying upon those third-party services to operate properly and fairly.

You should be aware that information which you voluntarily include and transmit online in a publicly accessible blog, social network or otherwise online may be viewed and used by others. We are unable to control such uses of your information, and by using such services you assume the risk that the information provided by you may be viewed and used by third parties.

DATA SECURITY

We will keep your information confidential and limit access to your information to those who specifically need it to conduct their business activities, except as otherwise permitted by applicable law. We refer to industry standards and use reasonable administrative, technical and physical security measures to protect your information from unauthorized access, destruction, use, modification or disclosure. We require industry standard data security measures from those third parties who are authorized by us to process your information on our behalf.

DATA RETENTION

We will only retain your 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. To determine the appropriate retention period for your information, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of your information, the purposes for which we process your information and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymize information about you (so that it can no longer be associated with you) for research or statistical purposes in which case we may use and retain this information indefinitely without further notice to you.

ADDITIONAL EU DISCLOSURES

Our role as data controller and data processor
We generally act as the data controller of your information submitted through our website; however, under certain circumstances, carriers may engage us to provide them with certain processing services related to information owned or controlled by the service provider. We are not responsible for any carrier’s use of information for which it is an owner or controller. As processor for a carrier, we only act under their instruction with respect to the processing of your information. To learn more about how a carrier may use such information, you should review its privacy policy.
If you are situated in the EU and have any complaints regarding our privacy practices as data controller, you have the right to make a complaint at any time to your local Supervisory Authority. We would, however, appreciate the chance to address your concerns before you approach your Supervisory Authority so please contact us in the first instance. If you are situated in the EU and have a complaint, please contact our privacy team at info@freightpal.com.

Provision of Personal Data and failure to provide Personal Data
Where we need to collect Personal Data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we will not be able to provide services to you.

Legal basis for our processing of your Personal Data
Below are the types of lawful basis that we will rely on to process your Personal Data:
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject.

Change of purpose
We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your Personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Collection of Personal Data from third party sources
We do not collect or share Personal Data about, you from or to, any third parties and or public sources.

If we are relying on your consent to process your Personal Data, you have the right to withdraw your consent at any time by contacting us at info@freightpal.com.

Use of your Personal Data for marketing purposes
We strive to provide you with choices regarding certain Personal Data uses, particularly around marketing and advertising:

  • Promotional offers from us: We may use your Personal Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or used our services and have not opted out of receiving that marketing. For the EU, you must opt in in order to receive marketing communications.
  • Third-party marketing: We will get your express opt-in consent before we share your Personal Data with any company outside our company for marketing purposes.

To see how you can opt out of marketing communications, please see the section titled “Opt-Out”.

Rights of EU Data Subjects
Under certain circumstances, you have rights under data protection laws in relation to your Personal Data you have the right to:

  • Request access to your personal data (commonly known as a “Data Subject Access Request”). This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

For additional questions, please contact us at info@freightpal.com.

OPT OUT

Opting out of messages from us
To opt-out of any future promotional messages from us, you should unsubscribe in the body of the promotional message that was sent to you (found at the bottom of the email) or send an unsubscribe request to us at info@freightpal.com. We will process your request within a reasonable time after receipt.

Opting out of interest based advertising
The online advertising industry provides a service through which you may opt-out of receiving targeted ads from certain data partners and other advertising partners that participate in self-regulatory programs. We comply with the Self-Regulatory Principles for Online Behavioral Advertising set forth by the Digital Advertising Alliance (DAA) and the European Interactive Digital Advertising Alliance (“EDAA”). We do not currently serve any advertising, but if at such time as we do, you can opt-out of targeted advertising from certain providers at www.aboutads.info/consumers. Please note that by opting out, you will continue to see generic advertising that is not tailored to your specific interests and activities. Please note that cookie-based opt-outs must be performed on each device and browser that you wish to have opted-out. For example, if you have opted out on your device browser, that opt-out will not be effective on your mobile device. You must separately opt out on each device. EU residents who have provided their consent to our use of cookies and similar technologies can use the EDAA’s opt out tool.

Opting out of cookies
If you want to stop or restrict the placement of cookies or flush any cookies that may already be on your computer or device, please refer to and adjust your web browser preferences. Further information on cookies is available at www.allaboutcookies.org. By deleting our cookies or disabling future cookies you may not be able to access certain areas or features of our Website or some of its functionality may be affected. Cookies and similar items are not used by us to automatically retrieve personally identifiable information from your device without your knowledge. For more information about cookies, please visit our Cookie Policy.

Opting out of location tracking
You may also adjust the settings on your mobile device to allow or restrict the sharing of location information. For example, the “location” permissions on your mobile device may allow you to elect whether to never share location information with us, to share location information only while you are using the app, or always share location information even if you are not using the app. If you elect to not share your location information, you may be unable to access some features of our Services that are designed for mobile devices. Also, in the event that you prevent the sharing of location information, we may still estimate your general location based on the IP address you use to access our Services.

DATA RELATING TO CHILDREN
Our Website is designed for those 18 years of age and older. We do not knowingly collect information from anyone under the age of 13 (or such other age as may be restricted under local law). If we are made aware that we have received such information, or any information in violation of our policy, we will use reasonable efforts to locate and remove that information from our records.

CROSS BORDER TRANSFERS
Our Website is maintained in the United States. If you are visiting from the regions with laws governing data collection and use that may differ from those in the United States, please note that you may be transferring your information to the United States and in other countries around the world. You understand that data stored in the United States may be subject to lawful requests by the courts or law enforcement authorities in the United States. If you are situated in the EU, whenever we transfer your personal data to processors outside of the EU, we ensure appropriate and suitable safeguards are used in such transfer. We may use specific contracts approved by the European Commission which give Personal Data the same protection it has in the EU.

CALIFORNIA PRIVACY
This section of the privacy policy provides information to California (“CA”) residents whose personal information is processed pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), whether through the Website or offline. It describes the categories of Personal Information that FreightPal collects, and the purposes for which that information is collected.
This section does not apply to Personal Information that is protected under federal financial privacy laws. Personal Information does not include information that is publicly available or that has been de-identified or aggregated.

Why we collect Personal Information
Depending on your relationship with us (e.g., FreightPal user, partner, prospect or vendor), we may use information about you for our business purposes, including:

  • To perform a contract with you;
  • To perform specific services that you have requested;
  • To respond to your direct inquiries;
  • Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests;
  • To send you FreightPal marketing materials;

Your CA privacy rights
As a California resident, beginning after January 1, 2021, you may have certain rights over the Personal Information we have about you, depending on the type of relationship you have with us.
We do not offer an opt out of sale link on our homepage for the purposes of the CCPA. We may share Personal Information with our service providers, with third parties with whom we jointly offer products or services, with third parties from whom you request a product or service through us, in the context of a merger, acquisition, bankruptcy, or other corporate transaction, or as otherwise permitted by the CCPA.

UPDATES TO THIS PRIVACY POLICY
We reserve the right, at our discretion, to change, modify, add, or remove portions from this privacy policy at any time. However, if at any time in the future we plan to use your information in a way that materially differs from this privacy policy, we will post such changes here and email you. We encourage you to periodically review the Website for the latest information on our privacy practices. You are bound by any changes to the privacy policy when you use the website after such changes have been first posted.