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 the 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 or request a demo). 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 is available for consultation at www.cargobase.com/dpa. A copy of your DPA 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.
ACTIVELY SUBMITTED PERSONAL DATA
Through the Site, we collect the personal data that you actively submit:
- Demo request. When you request a demo, we collect your business email, first name, last name, company type and name, and country. We use such data to provide you with the requested demo. The legal bases on which we rely are ‘pursuing our legitimate business interests ‘(i.e., to grow and promote our business) and 'your consent'. We store such data until the demo is delivered.
- Inquiries. When you contact us by using the “Drop us a line” functionality, we collect your business email, first name, last name, company type and name, and your country. 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 legal 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). We store such data until you stop communicating with us.
- Account data. If you have a registered user account on the Site, we collect your email address, first name, last name, phone number, company name, company address, company phone number, company website, and logo. We use such data to maintain your user account, provide you with the requested services, and maintain our business records. The legal bases on which we rely are 'performing our contractual obligations' and 'pursuing our legitimate business interests'.
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 legal basis on which we rely when processing such personal data is ‘pursuing our legitimate interests’ (i.e., to 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 and make sure that we have a legal basis for processing such data.
PROCESSING OF YOUR DATA
When you use the Site, you may create and submit various types of personal data belonging to others. For example, when you add a new user to your account, you need to add user’s email address, first name, last name, role, and team information. When you add shipping information, it may also contain personal data. We process Your Data only for the purposes of performing our contractual obligations to you, maintaining the Site and our business records, as described in our DPA. We do not re-purpose Your Data. The legal bases on which we rely are ‘performing our contractual obligations’ and ‘pursuing our legitimate interests’ (i.e., provide the Site and administer our business).
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|
|__cfruid||cargobase.com (USA)||End of session||
This cookie is a part of the services provided by Cloudflare, including load-balancing, deliverance of website content and serving DNS connection for website operators.
|__cf_bm||hubspot.com (USA)||1 day||
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 their website.
|_GRECAPTCHA||google.com (USA)||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 their website.
|google.com (US)||End of session||
The cookie is used to distinguish between humans and bots.
This cookie is used by the social sharing platform AddThis to store the user's usage history of the AddThis sharing widget.
|__ptq.gif||hubspot.com (USA)||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.
|embed/v3/counters.gif||perf.hsforms.com (USA)||End of session||
The cookie collects information on user preference and/or interaction with web campaign content. This is used on CRM-campaign-platform used by website owners for promoting events or products.
|__atuvc||cargobase.com (Ireland)||13 months||
This cookie updates the counter of a website's social sharing features.
|__atuvs||cargobase.com (Ireland)||1 day||
This cookie ensures that the updated counter is displayed to the user if a page is shared with the social sharing service. AddThis
This cookie is used by the social sharing platform AddThis.
|loc||addthis.com (USA)||13 months||
This is a geolocation cookie, which is used to help providers determine how users who share information with each other are geographically located (state level).
|uvc||addthis.com (USA)||13 months||
This cookie detects how often the social sharing servuce, AddThis encounters the same user.
|xtc||addthis.com (USA)||13 months||
This cookie registers the user's sharing of content via social media.
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 legal 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 may 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 or ask us to send you our newsletter, we will send you a newsletter about our new services, features of the Site, and special offers. The legal 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.
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 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 customer support chat and notification service provider Intercom located in the United States;
- Our web analytics service provider Clicky located in the United States;
- Our software service provider (for collecting user events) Segment located in the United States;
- Our transactional email service provider Sendgrid located in the United States;
- Our authentication service provider Auth0 located in the United States;
- Our monitoring service provider DataDog located in the United States;
- Our targeted advertising service providers Hubspot, DoubleClick (Google), Adroll, Facebook, and Linkedin located in the United States; and
- Our banks, payment service agents, 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 legal 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.
We retain non-personal data pertaining to you for as long as necessary for the purposes described in this Statement. This may include storing non-personal data for the period of time needed for us to examine our activities, fulfil our contractual obligations, pursue our legitimate interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes and enforce our agreements.
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 the person’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. Nevertheless, we take reasonable technical and organisational measures to protect your personal data 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 to revisit 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.