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Corporate Privacy Policy

Privacy Policy and CCPA
General ContactE-MailPrivacy Policy & Notice for CCPA

Privacy Notice

Last updated July 01, 2020

Thank you for choosing to be part of our community at FreightTrust and Clearing Corporation, doing business as Freight Trust (“ Freight Trust ”, “ we ”, “ us ”, or “ our ”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about this privacy notice, or our practices with regards to your personal information, please contact us at admin@freighttrust.com.

When you visit our website https://freighttrust.com (the ” Website ”), use our mobile application, as the case may be (the ” App ”) and more generally, use any of our services (the ” Services ”, which include the Website and App), we appreciate that you are trusting us with your personal information. We take your privacy very seriously. In this privacy notice, we seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy notice that you do not agree with, please discontinue use of our Services immediately.

This privacy notice applies to all information collected through our Services (which, as described above, includes our Website and App), as well as any related services, sales, marketing or events.

Please read this privacy notice carefully as it will help you understand what we do with the information that we collect.

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the

Services (such as by posting messages in our online forums or entering competitions, contests or giveaways) or otherwise when you contact us.

The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make and the products and features you use. The personal information we collect may include the following:

Personal Information Provided by You. We collect app usage; past and current partners; cv and other job application data such as background checks; data collected from surveys; work performance, salary, bonuses, disciplinary actions; purchase history; financial information (credit card number, purchase history, invoices); mailing addresses; email addresses; phone numbers; names; and other similar information.

Payment Data. We may collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument. All payment data is stored by Freight Trust. You may find their privacy notice link(s) here: https://freighttrust.com/privacy-policy.

All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about who and when you use our Services and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

The information we collect includes:

Log and Usage Data. Log and usage data is service-related, diagnostic usage and performance information our
servers automatically collect when you access or use our Services and which we record in log files. Depending
on how you interact with us, this log data may include your IP address, device information, browser type and
settings and information about your activity in the Services (such as the date/time stamps associated with your
usage, pages and files viewed, searches and other actions you take such as which features you use), device
event information (such as system activity, error reports (sometimes called 'crash dumps') and hardware
settings).
Device Data. We collect device data such as information about your computer, phone, tablet or other device
you use to access the Services. Depending on the device used, this device data may include information such
as your IP address (or proxy server), device application identification numbers, location, browser type,
hardware model Internet service provider and/or mobile carrier, operating system configuration information.
Location Data. We collect information data such as information about your device's location, which can be
either precise or imprecise. How much information we collect depends on the type of settings of the device you
use to access the Services. For example, we may use GPS and other technologies to collect geolocation data
that tells us your current location (based on your IP address). You can opt out of allowing us to collect this
information either by refusing access to the information or by disabling your Locations settings on your device.
Note however, if you choose to opt out, you may not be able to use certain aspects of the Services.

Information collected through our App

In Short: We collect information regarding your geo-location, mobile device, push notifications, when you use our App.

If you use our App, we also collect the following information:

Geo-Location Information. We may request access or permission to and track location-based information from
your mobile device, either continuously or while you are using our App, to provide certain location-based
services. If you wish to change our access or permissions, you may do so in your device's settings.
Mobile Device Access. We may request access or permission to certain features from your mobile device,
including your mobile device's bluetooth, camera, contacts, microphone, sensors, sms messages, storage,
calendar, reminders, gps, telematics, electronic logging devices, meta-data, pki, 2fa (two-factor authentication),
pgp keys, x.509 certificate , pki#11, oauth, openid, and other features. If you wish to change our access or
permissions, you may do so in your device's settings.
Mobile Device Data. We automatically collect device information (such as your mobile device ID, model and
manufacturer), operating system, version information and system configuration information, device and
application identification numbers, browser type and version, hardware model Internet service provider and/or
mobile carrier, and Internet Protocol (IP) address (or proxy server). If you are using our App, we may also
collect information about the phone network associated with your mobile device, your mobile device's operating
system or platform, the type of mobile device you use, your mobile device's unique device ID and information
about the features of our App you accessed.
Push Notifications. We may request to send you push notifications regarding your account or certain features of
the App. If you wish to opt-out from receiving these types of communications, you may turn them off in your
device's settings.

The information is primarily needed to maintain the security and operation of our App, for troubleshooting and for our internal analytics and reporting purposes.

2. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

In Short: We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.

We may process or share your data that we hold based on the following legal basis:

Consent: We may process your data if you have given us specific consent to use your personal information in
a specific purpose.
Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate
business interests.
Performance of a Contract: Where we have entered into a contract with you, we may process your personal
information to fulfill the terms of our contract.
Legal Obligations: We may disclose your information where we are legally required to do so in order to comply
with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in
response to a court order or a subpoena (including in response to public authorities to meet national security or
law enforcement requirements).
Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or
take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to
the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

More specifically, we may need to process your data or share your personal information in the following situations:

Business Transfers. We may share or transfer your information in connection with, or during negotiations of,
any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another
company.
Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to
honor this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners or
other companies that we control or that are under common control with us.
Business Partners. We may share your information with our business partners to offer you certain products,
services or promotions.
Other Users. When you share personal information (for example, by posting comments, contributions or other
content to the Services) or otherwise interact with public areas of the Services, such personal information may
be viewed by all users and may be publicly made available outside the Services in perpetuity. Similarly, other
users will be able to view descriptions of your activity, communicate with you within our Services, and view your
profile.

3. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.

4. DO WE USE GOOGLE MAPS?

In Short: Yes, we use Google Maps for the purpose of providing better service.

This Website or App uses Google Maps APIs which is subject to Google’s Terms of Service. You may find the Google Maps APIs Terms of Service here. To find out more about Google’s Privacy Policy, please refer to this link.

We use the Google Maps API to retrieve certain information when you make location-specific requests. This includes:

■ Location
■ ELD Information
■ Metadata
■ Other
■ IP and Geolocation
■ Operating System Information, e.g. MAC Address, OS Version
■ Client Information: e.g. Browser Version, Cookies, etc
■ 3rd Party Interface Injections, e.g. Browser Extensions
■ Network Routing and Provider Information

For a full list of what we use information for, please see the previous section titled “WILL YOUR INFORMATION BE SHARED WITH ANYONE?”. We obtain and store on your device (‘cache’) your location. You may revoke your consent anytime by contacting us at the contact details provided at the end of this document.

The Maps APIs that we use store and access cookies and other information on your devices. If you are a user currently in the European Economic Area (EU countries, Iceland, Liechtenstein and Norway), please take a look at our Cookie Notice.

5. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

In Short: We may transfer, store, and process your information in countries other than your own.

Our servers are located in United States, Germany, United Kingdom, France, and Sweden. If you are accessing our Services from outside United States, Germany, United Kingdom, France, and Sweden, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information (see “WILL YOUR INFORMATION BE SHARED WITH ANYONE?” above), in United States, United Kingdom, Germany, and other countries.

If you are a resident in the European Economic Area, then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. We will however take all necessary measures to protect your personal information in accordance with this privacy notice and applicable law.

EU-U.S. and Swiss-U.S. Privacy Shield Framework:

FreightTrust and Clearing Corporation complies with the EU-U.S. and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union, the United Kingdom and Switzerland to the United States and has certified its compliance with it. As such, FreightTrust and Clearing Corporation is committed to subjecting all personal information received from European Union (EU) member countries, the United Kingdom and Switzerland in reliance on the Privacy Shield Framework, in accordance with the Privacy Shield Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List.

FreightTrust and Clearing Corporation is responsible for the processing of personal information it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf.

With respect to personal information received or transferred pursuant to the Privacy Shield Framework, FreightTrust and Clearing Corporation is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (“FTC”). In certain situations, we may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

EU, UK and Swiss customers may contact FreightTrust and Clearing Corporation with questions or complaints concerning this notice at the following: admin@freighttrust.com.

Privacy Shield organizations must respond within 45 days of receiving a complaint.

We maintain reasonable and appropriate security measures to protect personal information we process from loss, misuse, unauthorized access, disclosure, alteration, or destruction, taking into account the nature of the personal information and the risks involved in processing that information, in accordance with the Privacy Shield.

If you are from the EU, UK or Switzerland, you have the right to request access to the personal information that we hold about you and request that we correct, amend, or delete it if it is inaccurate or processed in violation of the Privacy Shield. If you would like to exercise these rights, please write to us at the contact details provided below. We may request specific information from you to confirm your identity and we will respond to your request in accordance with the Privacy Shield Principles and applicable data protection laws.

If you have not received a timely or satisfactory response from FreightTrust and Clearing Corporation to your question or complaint, please contact the independent recourse mechanism listed below, and they will investigate and assist you free of charge.

An independent dispute resolution mechanism is operated by the __. If the dispute concerned human resources personal information or information is obtained in connection to the employment relationship, we will cooperate with the competent EU, UK or Swiss data protection authorities and comply with the guidance of such authorities.

In limited situations, EU, UK and Swiss individuals may seek redress from the Privacy Shield Panel, a binding arbitration mechanism.

If there is any conflict between the terms of this notice and the Privacy Shield Principles, the Privacy Shield Principles shall govern.

To learn more about the Privacy Shield program, and to view our certification, please visit: http://www.privacyshield.gov.

Binding Corporate Rules:

These include, a set of Binding Corporate Rules (“BCRs”) established and implemented by FreightTrust and Clearing Corporation. Our BCRs have been recognized by EEA data protection authorities as providing an adequate level of protection to the personal information we process internationally. You can find a copy of our BCRs here: github.com/freight-trust/legal/.

6. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than eighteen (18) months past the termination of the user’s account.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

8. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at admin@freighttrust.com.

9. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: In some regions, such as the European Economic Area, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

In some regions (like the European Economic Area), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws.

If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

If you are resident in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.

If you have questions or comments about your privacy rights, you may email us at admin@freighttrust.com.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

■ Contact us using the contact information provided.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with applicable legal requirements.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. To opt-out of interest-based advertising by advertisers on our Services visit http://www.aboutads.info/choices/.

Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list – however, we may still communicate with you, for example to send you

service-related emails that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes. To otherwise opt-out, you may:

■ Contact us using the contact information provided.

10. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

11. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with a Service, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g. backups, etc.).

CCPA Privacy Notice

The California Code of Regulations defines a “resident” as:

(1) every individual who is in the State of California for other than a temporary or transitory purpose and
(2) every individual who is domiciled in the State of California who is outside the State of California for a temporary
or transitory purpose

All other individuals are defined as “non-residents.”

If this definition of “resident” applies to you, certain rights and obligations apply regarding your personal information.

What categories of personal information do we collect?

We have collected the following categories of personal information in the past twelve (12) months:

Category Examples Collected
A. Identifiers
Contact details, such as real name, alias, postal address,
telephone or mobile contact number, unique personal
identifier, online identifier, Internet Protocol address, email
address and account name

NO

B. Personal information categories
listed in the California Customer
Records statute
Name, contact information, education, employment,
employment history and financial information

YES

C. Protected classification
characteristics under California or
federal law
Gender and date of birth NO
D. Commercial information Transaction information, purchase history, financial details
and payment information NO
E. Biometric information Fingerprints and voiceprints NO
F. Internet or other similar network
activity
Browsing history, search history, online behavior, interest
data, and interactions with our and other websites,
applications, systems and advertisements

NO

G. Geolocation data Device location NO
H. Audio, electronic, visual, thermal,
olfactory, or similar information
Images and audio, video or call recordings created in
connection with our business activities

NO

I. Professional or employment-related
information
Business contact details in order to provide you our
services at a business level, job title as well as work history
and professional qualifications if you apply for a job with us

YES

J. Education Information Student records and directory information NO
K. Inferences drawn from other
personal information
Inferences drawn from any of the collected personal
information listed above to create a profile or summary
about, for example, an individual’s preferences and
characteristics

NO

We may also collect other personal information outside of these categories in instances where you interact with us in- person, online, or by phone or mail in the context of:

Receiving help through our customer support channels
Participation in customer surveys or contests; and
Facilitation in the delivery of our Services and to respond to your inquiries

How do we use and share your personal information?

More information about our data collection and sharing practices can be found in this privacy notice.

You may contact us by email at admin@freighttrust.com, or by referring to the contact details at the bottom of this document.

If you are using an authorized agent to exercise your right to opt-out, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf.

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be “selling” of your personal data.

FreightTrust and Clearing Corporation has not disclosed or sold any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. FreightTrust and Clearing Corporation will not sell personal information in the future belonging to website visitors, users and other consumers.

Your rights with respect to your personal data

Right to request deletion of the data - Request to delete

You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation or any processing that may be required to protect against illegal activities.

Right to be informed - Request to know

Depending on the circumstances, you have a right to know:

whether we collect and use your personal information;
the categories of personal information that we collect;
the purposes for which the collected personal information is used;
whether we sell your personal information to third parties;
the categories of personal information that we sold or disclosed for a business purpose;
the categories of third parties to whom the personal information was sold or disclosed for a business purpose;
and
the business or commercial purpose for collecting or selling personal information.

In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

We will not discriminate against you if you exercise your privacy rights.

Verification process

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with the information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g. phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.

We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. If, however, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity, and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.

Other privacy rights

you may object to the processing of your personal data
you may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the
processing of the data
you can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a
request from an authorized agent that does not submit proof that they have been validly authorized to act on
your behalf in accordance with the CCPA.
you may request to opt-out from future selling of your personal information to third parties. Upon receiving a
request to opt-out, we will act upon the request as soon as feasibly possible, but no later than 15 days from the
date of the request submission.

To exercise these rights, you can contact us by email at admin@freighttrust.com, or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.

12. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may contact our Data Protection Officer (DPO), Sam Bacha, by email at admin@freighttrust.com, by phone at +1 628-222-5915, or by post to:

FreightTrust and Clearing Corporation admin@freighttrust.com


Wilmington, DE 19801 United States

If you are a resident in the European Economic Area, the “data controller” of your personal information is FreightTrust and Clearing Corporation. FreightTrust and Clearing Corporation has appointed Data Retention Coordinator to be its representative in the EEA. You can contact them directly regarding the processing of your information by FreightTrust and Clearing Corporation, by email at admin@freighttrust.com, by phone at +1 628-222-5915, or by post to:

HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM

YOU?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please visit: https://freighttrust.com/data-provider-service. We will respond to your request within 30 days.