OWNER AND OPERATOR OF THE SITE
The Site is owned and operated by Cargobase Pte Ltd having a principle place of business at 6 Ean Kiam Place, 429106 Singapore, and with company registration number 201311570K (“we”, “us”, and “our”).
OUR ROLE AS DATA CONTROLLER AND DATA PROCESSOR
We act in the capacity of a data controller and a data processor with regard to the personal data processed through the Site in terms of the applicable data protection laws, including the EU General Data Protection Regulation (GDPR). Our role depends on the specific situation in which personal data is handled by us, as explained in detail below:
- Data controller. We are responsible for the collection and use of your personal data through the Site and we make decisions about the types of personal data that should be collected from you and purposes for which such personal data should be used. Therefore, we act as a data controller with regard to the personal data collected directly through the Site (for example, when you send us an inquiry, register a user account, or conclude a service contract). We comply with data controller’s obligations set forth in the applicable laws.
- Data processor. We act in the capacity of a data processor in situations when you submit information, files or generate data through the Site for processing (“Your Data”) and Your Data contains your or other individuals’ personal data. We do not own, control, or make decisions about Your Data. We process Your Data only in accordance with the instructions issued by a respective data controller. To ensure that Your Data is processed in accordance with the strictest data protection standards, we have drafted and offer for conclusion a data processing agreement (the “DPA”) that can be received by contacting us at email@example.com.
This Statement covers only data collected through the Site and not any other data collection or processing, including, without limitation, data collection practices of webpages to which the Site links, or data that we or our affiliates collect offline or through webpages that do not display a direct link to this Statement, for example the Cargobase applications on which we host data for registered customers..
ACTIVELY SUBMITTED PERSONAL DATA
Through the Site, we collect the personal data that you actively submit:
- User account. When you register your user account, we collect your email address, name, company name and address, and any other information you decide to provide about yourself. We use the said information to register and maintain your user account, enable your access to the Site, provide you with the requested services, contact you, if necessary, and maintain our business records. The lawful bases on which we rely are ‘performing a contract with you’, ‘pursuing our legitimate business interests’ (i.e., operate, analyse, grow, and administer our business), and ‘your consent’ (for optional personal data).
- Inquiries. When you contact us by using the “Let’s Connect” functionality, we collect your business email, first name, last name, and company type and name. When you contact us by email, we collect your name, email address, and any information that you decide to include in your message. We use such data to respond to your inquiries. The lawful bases on which we rely are ‘pursuing our legitimate business interests’ (i.e., to grow and promote our business) and ‘your consent’ (for optional personal data).
PASSIVELY TRACKED DATA
When you visit the Site, we also passively track information on your computer and Internet connection, such as the IP address of your computer and/or Internet service provider, the date and time you access the Site, the Internet address of websites from which you link to our Site, the computer technology you are using and your movements and preferences on our Site. Such data does not allow us to identify you. Nevertheless, under certain laws, your IP address may be considered to be personal data. We collect passively tracked data primarily for purposes of administering, protecting and improving our Site and our systems, to better understand your preferences, to identify server problems, to compile aggregated statistics about Site usage. The lawful basis on which we rely when processing such personal data is ‘pursuing our legitimate interests’ (i.e. ensure security and proper functioning of the Site and examine the content available on the Site).
Unless you also actively submit personal data such as your name or address, passively tracked data does not typically allow us to identify you personally (even though it can theoretically be done, we do not have the means or an interest to find out who you are, unless you identify yourself voluntarily through an active submission of data). To the extent permitted by applicable law, we reserve the right to combine passively tracked data with personal data that you actively submit. If it happens, we will treat such combined data as personal data.
If you follow a link to the Site from an affiliate or promotion, we store information about your arrival from that affiliate or promotion in a session cookie.
- Essential technical cookies that are strictly necessary to ensure the correct functioning of the Site and provide the services requested by you;
- Marketing cookies that allow us to create, implement, and examine our marketing campaigns. Such cookies allow us to reach the right customers, analyse the productivity of our marketing campaigns, and offer you personalised advertisement; and
- Statistics cookiesthat allow us to generate statistical reports about how you use the Site.
Below, you can find a list of cookies that we use on the Site, including their purpose and expiration time:
|Essential Technical Cookies
|__stripe_mid||cargobase.com (US)||1 year||This cookie is necessary for making credit card transactions on the website. The service is provided by Stripe which allows online transactions without storing any credit card information.|
|__stripe_sid||cargobase.com (US)||1 day||This cookie is necessary for making credit card transactions on the website. The service is provided by Stripe which allows online transactions without storing any credit card information.|
|_GRECAPTCHA||cargobase.com (US)||179 days||This cookie is used to distinguish between humans and bots. This is beneficial for the website, in order to make valid reports on the use of the website.|
|elementor||cargobase.com (US)||Presistent||The cookie is used in context with the website's WordPress theme. The cookie allows us to implement or change the website's content in real-time.|
|m||m.stripe||2 years||The cookie determines the device used to access the website. This allows the website to be formatted accordingly.|
|google.com (US)||End of session||The cookie is used to distinguish between humans and bots.|
|lang||ads.linkedin.com (UK)||End of session||The cookie remembers the user's selected language version of a website.|
|__hssc||cargobase.com (US)||1 day||The cookie identifies if the cookie data needs to be updated in the visitor's browser.|
|__hssrc||cargobase.com (US)||End of session||The cookie is used to recognise the visitor's browser upon reentry on the website.|
|__hstc||cargobase.com (US)||2 years||The cookie sets a unique ID for the session. This allows the website to obtain data on visitor behaviour for statistical purposes.|
|__ga||cargobase.com (Singapore)||2 years||The cookie registers a unique ID that is used to generate statistical data on how the visitor uses the website.|
|__gat||cargobase.com (Singapore)||1 day||The cookie is used by Google Analytics to throttle request rate.|
|__gid||cargobase.com (Singapore)||1 day||The cookie registers a unique ID that is used to generate statistical data on how the visitor uses the website.|
|AnalyticsSyncHistory||linkedin.com (US)||1 year||The cookie is used in connection with data-synchronization with third-party analysis service.|
|hubspotutk||cargobase.com (US)||1 year||The cookie sets a unique ID for the session. This allows the website to obtain data on visitor behaviour for statistical purposes.|
|p.gif||ctypekit.net||End of session||Keeps track of special fonts used on the website for internal analysis. The cookie does not register any visitor data.|
|__ptq.gif||hubspot.com||End of session||The cookie sends data to the marketing platform Hubspot about the visitor's device and behaviour. Tracks the visitor across devices and marketing channels.|
|__fbp||cargobase.com (US)||3 months||The cookie is used by Facebook to deliver a series of advertisement products such as real time bidding from third-party advertisers.|
|ads/ga-audiences||google.com (US)||End of session||The cookie is used by Google AdWords to re-engage visitors that are likely to convert to customers based on the visitor 's online behaviour across websites.|
|linkedin.com (US)||2 years
|The cookie is used by the social networking service, LinkedIn, for tracking the use of embedded services.|
|embed/v3/counters.gif||perf.hsforms.com (US)||End of session||The cookie collects information on user preferences and/or interaction with web-campaign content. This is used on CRM-campaign-platform used by website owners for promoting events or products.|
|IDE||doubleclick.net (US)||1 year||The cookie is used by Google DoubleClick to register and report the website user's actions after viewing or clicking one of the advertiser's ads with the purpose of measuring the efficacy of an ad and to present targeted ads to the user.|
|lang||linkedin.com (UK)||End of session||The cookie is set by LinkedIn when a web page contains an embedded "Follow us" panel.|
|pagead/1p-iser-list/#||google.com (US)||End of session||The cookie tracks if the user has shown interest in specific products or events across multiple websites and detects how the user navigates between sites. This is used for measurement of advertisement efforts and facilitates payment of referral-fees between websites.|
|pagead/landing||double-click.net (US)||1 day||The cookie is used to check if the user's browser supports cookies.|
|tr||facebook.com (Netherlands)||End of session||The cookie is used by Facebook to deliver a series of advertisement products such as real time bidding from third-party advertisers.|
|UsersMatchHistory||linkedin.com (UK)||29 days||This cookie is used to track visitors on multiple websites, in order to present relevant advertisement based on the visitor 's preferences.|
When you make a payment for the use of the Site (by using your credit card or by a bank transfer), you will need to submit your payment details that depend on the chosen payment provider (like your name, credit card number, expiration date, security code, and billing address). Please note that we do not process payments through the Site - it is done by our third-party payment processors Stripe and banks. Your payment data is used to process your payments and maintain our business records. The lawful bases on which we rely are ‘performing a contract’, ’pursuing our legitimate business interests’ (i.e., administer our business), and ‘complying with our legal obligations”.
We do not deliver third-party online advertisements on our Site but we advertise our products and services on other websites. We work with service providers to deliver such targeted advertising. For example, as you browse the Site, advertising cookies will be placed on your computer so that we can understand what you are interested in. Our display advertising partner, AdRoll, then enables us to present you with retargeting advertising on other sites based on your previous interaction with the Site. The techniques our partners employ do not collect personal data such as your name, email address, postal address or telephone number. You can control how such advertising is shown to you or opt-out from targeted advertising by consulting the guide powered by the Digital Advertising Alliance available at https://youradchoices.com. For more information on opting-out from advertising features on your device, please visit https://www.networkadvertising.org.
NEWSLETTER AND SERVICE NOTICES
If you conclude a contract with us, we will send you a newsletter about our new services, features of the Site, and special offers. The lawful basis on which we rely is ‘pursuing our legitimate interests’ (i.e. to promote our business). You can opt-out from receiving our commercial communication at any time free of charge by clicking on the “unsubscribe” link included in our newsletters or by contacting us directly.
The newsletters sent by us may contain tracking pixels that allow us to conduct analysis of our marketing campaigns. Tracking pixels allow us to see whether you opened the newsletter and what links you have clicked on. We use such information to conduct analytics and pursue our legitimate business interests.
If we have your email address and it is necessary to do so, we may send you important informational messages, such as technical or administrative emails. Please note that such messages are sent on an “if-needed” basis and they do not fall within the scope of commercial communication that may require your prior consent. You cannot opt-out from service-related notices.
We do not collect or use any special categories of personal data (“sensitive data”) from you, unless you decide, at your own discretion, to provide such data to us. Sensitive data refers to your health, religious and political beliefs, racial origins, membership of a professional or trade association, or sexual orientation.
REFUSAL TO PROVIDE PERSONAL DATA
If you refuse to provide us with your personal data when we ask for it, we may not be able to perform the requested operation and you may not be able to use the full functionality of the Site, receive the requested information, use our services, or get our response. Please contact us immediately if you think that any personal data that we collect is excessive or not necessary for the intended purpose.
PROCESSING OF YOUR DATA
When you upload or create Your Data through the Site, we process Your Data as requested by you, including any personal data Your Data may contain. Your Data may contain the following information (without limitation): email addresses, names, and phone numbers. We process Your Data in order to (i) provide you with the requested services and (ii) perform our contractual obligations. The lawful basis on which we rely is ‘performing a contract with you’.
DISCLOSURE OF PERSONAL DATA
We are not in the business of selling or renting your personal data to telemarketers and we do not share your personal data with others, except as follows:
- We freely share your information within the Cargobase group of companies.
- We also may share information with trusted business partners, such as system integrators, distributors, and referral partners and any other party specifically identified on the page on which you submit your information.
- We engage agents and service providers (our data processors) who process data only on our behalf and for our purposes under confidentiality agreements. You can find a list of our data processors below.
- We may share your personal data as required by law or in the interest of protecting or exercising our or others’ legal rights, e.g., without limitation, in connection with requests from law enforcement officials and in connection with court proceedings.
- We may share or transfer your personal data in connection with a prospective or actual sale, merger, transfer or other reorganization of all or parts of our business.
- We reserve the right to fully use and disclose any information that is not personal data (such as statistics and survey results that do not identify you).
LIST OF DATA PROCESSORS
We choose our data processors carefully and make sure that they ensure an adequate level of protection of personal data that is consistent with this Statement and the applicable data protection laws. The data processors that will have access to your personal data are:
- Our cloud hosting, database, and content delivery service provider Amazon Web Services located in the United States;
- Our software service provider (for collecting user events) Segment located in the United States;
- Our chat service provider Intercom located in the United States;
- Our transactional email service provider Sendgrid located in the United States;
- Our monitoring service provider DataDog located in the United States;
- Our data analytics service provider Qlik located in the United States;
- Our analytics service provider Google Analytics located in the United States; and
- Our banks, independent contractors and consultants.
We and some of our data processors may be based outside the country where you reside. For example, if you reside in a country belonging to the European Economic Area (EEA), we may need to transfer your personal data outside the EEA. In case it is necessary to make such a transfer, we will make sure that the country in which our data processor is located guarantees an adequate level of protection for your personal data or we conclude an agreement with it that ensures such protection (e.g., a data processing agreement based pre-approved standard contractual clauses).
We and our data processors store your personal data only for as long as such personal data is required for the purposes described in this Statement or until you request us to update or delete your personal data, whichever comes first. After your personal data is no longer necessary for its purposes and there is no other lawful basis for storing it, we will immediately securely delete your personal data from our systems. We do not store any personal data longer than strictly necessary.
In seldom instances when we are obliged by law to store your personal data for certain period of time (e.g. for keeping accountancy records), we will store your personal data for the time period stipulated by the applicable law and delete the personal data as soon as the required retention period expires.
The Site is not intended for use by persons under the age of 18. We do not knowingly collect personal data belonging to persons younger than 18. If you become aware that such a person has provided us with his or her personal data and you are a parent or a legal guardian of that person, please contact us immediately and we will remove child’s personal data from our systems.
If personal data you have submitted through the Site is no longer accurate, current, or complete, and you wish to update it or exercise any of your rights listed below please send an e-mail to firstname.lastname@example.org and explain in detail your request. In order to verify the legitimacy of your request, we may ask you to provide us with an identifying piece of information, so that we can identify you in our system. We will answer your request within a reasonable time frame but no later than 30 days.
You have the following rights with regard to the personal data processed by us:
You have the right to control how we process your personal data. Subject to any exemptions provided by law, you have the following rights:
- Right of access: you can get a copy of your personal data that we store in our systems and a list of purposes for which your personal data is processed;
- Right to rectification: you can rectify inaccurate personal data that we hold about you;
- Right to erasure (‘right to be forgotten’): you can ask us to erase your personal data from our systems;
- Right to restriction: you can ask us to restrict the processing of your personal data;
- Right to data portability: you can ask us to provide you with a copy of your personal data in a structured, commonly used and machine-readable format and move that personal data to another processor;
- Right to object: you can ask us to stop processing your personal data;
- Right to withdraw consent: you have the right to withdraw your consent, if you have provided one; or
- Right to complaint: you can submit your complaint regarding our processing of your personal data.
If you would like to launch a complaint about the way in which we handle your personal data, we kindly ask you to contact us first and express your concerns. After you contact us, we will investigate your complaint and provide you with our response as soon as possible (no later than 2 weeks). If you are not satisfied with the outcome of your complaint, you have the right to lodge a complaint with your local data protection authority.
We do not discriminate you if you decide to exercise your rights. It means that we will not (i) deny any goods and services, (ii) charge you different prices, (iii) deny any discounts or benefits, (iv) impose penalties, or (v) provide you with a lower quality services. If we receive a request from a data subject whose personal data is processed by us through Your Data, wishing to exercise his/her rights, we will immediately notify the respective data controller and suggest the data subject to contact the controller directly. As a data processor, we do not accommodate requests from data subjects whose personal data we process through Your Data.
Transmissions over the Internet are never 100% secure or error-free. However, we take reasonable steps to protect your personal information from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Our security measures include secured networks, encryption, strong passwords, limited access to your personal data by our staff, anonymisation of personal data (when possible), and carefully selected data processors.
We reserve the right to change, modify, add or remove portions of this Statement from time to time. We will alert you that changes have been made by indicating on the Statement the date it was last updated.We recommend you torevisit this Statement on occasion to learn of any changes.
Please feel free to contact us with any comments, questions, complaints or suggestions you might have regarding the data protection practices described in this statement. You may send us an e-mail at email@example.com or write to us Cargobase Pte Ltd at Tanglin Post Office, PO 616, Singapore 912421.