Privacy Policy

Please take time to read our privacy policy ("policy") as it sets out important information relating to how we handle your personal information.

In this Policy, references to "we", "us" or "Congistics" are references to Congistics Corporation.

HOW TO CONTACT US

Questions, comments and requests regarding this Policy should be addressed to our Data Protection team through the following means:

Data Protection Team
Legal Department
5 River Rd, Suite 118
Wilton, CT 06897
USA

Email Address: feedback@congistics.com

INTRODUCTION

We will collect personal information when you use the Site and the associated services and as part of the normal course of business. This Policy sets out how we collect and use personal information and your rights regarding our use of your personal information.

Other information you provide when you communicate with us, including your full name, contact details and business email address, phone number and details of our communications.

We use this information for certain activities, including:

Contacting you to answer your questions regarding our brands;

Marketing regarding Congistics services and products which may be of interest and to promote our business and brand;

Responding to your questions and requests and otherwise customize your digital markets experience;

We use this information because:

We have a legitimate business interest to:

Manage and promote our business and brand;

Provide and improve our services;

Operate our business;

Improve the performance and user experience of our websites;

Monitor, investigate and report any attempts to breach the security of our websites; and

Resolve any concerns or disputes you may have.

We have collected your consent (where required under applicable law) to use your information for marketing. Where we rely upon your consent, you have the right to withdraw this consent by contacting the Data Protection Officer on the contact details above.

Information we collect about your use of our website and apps.

Categories of information we collect about you include:

Information captured in our web logs such as device information (e.g. device brand and model, screen dimensions), unique identification numbers (e.g. IP address and device ID), and browser information (e.g. URL, browser type, pages visited, date/time of access), geo-location and other device-specific information, Internet connection information;

1. FURTHER INFORMATION

Where we collect and use information for our legitimate interests as mentioned above, a legitimate interest will only apply when we consider that your interests or rights requiring protection of your personal information do not override our legitimate interests. For more information regarding our legitimate interests as applied to your personal information, please contact us.

Our websites and online services are for individuals who are at least 18 years old. Our online services are not designed to be used by individuals under the age of 18.

Your personal information may also be processed if it is necessary: to respond to a lawful request from a law enforcement or regulatory authority, body or agency; in the defense of legal claims or in order to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or violations of any of our Site terms.

2. WHEN WE DISCLOSE YOUR INFORMATION

When we have your consent or authorization to do so;

To comply with applicable laws, protect rights, safety and property, and respond to lawful requests from public authorities (such as disclosing data in appropriate situations for national security or law enforcement purposes);

Your personal information will also be transferred to other third party organizations in certain scenarios (subject to applicable law):

If we sell, purchase or transfer any part or all of our business or assets (including in bankruptcy), or in the event of another corporate change, in which case we may disclose your Information to the prospective seller, buyer or administrator of such business or assets including for pre-transaction review under suitable terms as to confidentiality;

If we are reorganized or sold, information may be transferred to a buyer who can continue to provide services to you;

If we are defending a legal claim, our property, our website or other users, Information may be transferred as required in connection with defending such claim.

If there is an emergency which requires us to share your data or for the health and safety of our Site's users or the general public.

3. DATA SUBJECT RIGHTS

We ensure that the personal information we collect about you is accurate, complete and used for its intended purpose. You may access, review, correct and update your Information or close your account by contacting us by email on the contact details above. If you a citizen of the European Union you also have the rights listed below.

3.1 EUROPEAN UNION RESIDENTS

In certain circumstances, you have certain rights regarding your personal information. A summary of each right and how you can exercise it is below. To exercise any of these rights, please contact us. Such requests should include information to allow us to verify your identity (e.g. your name, address, email address or other information reasonably required).

Where we receive your request to exercise one of these rights, we will respond without undue delay and in any event within one month of receipt of the request. This may be extended by a further two months in certain circumstances, e.g. where requests are complex or numerous.

We will provide the information free of charge, except where requests are manifestly unfounded or excessive, e.g. because of their repetitive character. In these circumstances we may charge a reasonable fee or may refuse to act on the request. We will advise you of any fees prior to proceeding with a request. We may ask for additional information to verify your identity before carrying out a request.

Right How you can exercise the right

Right to access and/or correct your personal information You have the right to access personal information we hold about you, and to be provided with a copy of the information (in most circumstances). You also have the right to correct any information we may hold about you that is inaccurate.

Right to restrict use of your personal information You have the right to ask us to restrict processing of your personal information where one of the following applies:

The processing is unlawful, but you want us to restrict use of the data instead of deleting it;

Where you contest the accuracy of your personal information, the restriction will apply until we have verified the accuracy or corrected your personal information;

We no longer require the personal information for the purposes of processing, but are required to keep it in connection with a legal claim;

You have exercised your right to object to the processing. The restriction will apply until we have taken steps to verify whether we have compelling legitimate grounds to continue processing.

Right to request deletion of your personal information

You have the right to ask us to delete your personal information in most circumstances. If you want to opt-out from receiving marketing communications, the best way to do so is to allow us to retain your information with a “do not contact” tag so we know not to contact you in the future.

There are also certain exceptions where we may refuse a request for erasure, for example, where the personal information is required to comply with a legal obligation or for the establishment, exercise or defense of legal claims.

Right to object to processing of your personal information You may object to our use of your personal information for marketing purposes. You may also object to processing of your personal information in cases where we have used legitimate interests as the basis for processing. In such cases, we will stop processing your personal information until we verify that we have compelling legitimate grounds for processing that outweigh your interests, rights, and freedoms in asking us to stop processing the data, or in limited cases where we need to continue processing the data for the establishment, exercise, or defense of legal claims.

Right to data portability In most cases, you have the right to receive all personal information you have provided to us in a structured, commonly used, and machine-readable format and to transmit this data to another data controller, where technically feasible.

Right to lodge a complaint with a supervisory authority If you object to our processing of your personal information, you have the right to complain to the data protection authority in the country where you reside, where you work, or where an alleged infringement of data protection laws has taken place.

4. RETENTION PERIODS

We will retain your personal information for as long as required to perform the purposes for which the data was collected, depending on the legal basis for which that data was obtained and/or whether additional legal/regulatory obligations require us to retain it.

In general terms, this will mean that your personal information will be kept for the duration of our relationship with you and:

the period required by tax and company laws and regulations; and

as long as it is necessary for you to be able to bring a claim against us and for us to be able to defend ourselves against any legal claims. This will generally be the length of the relationship plus the length of any applicable statutory limitation period under local laws.

5. CHOICES ABOUT YOUR INFORMATION

We believe it is important to give you choices about the use of your Information. We will use your personal information as described in this Policy. If we want to use your information for a purpose not described in this Policy, we will first get your consent to do so.

Marketing Communications

We will respect your wishes not to receive marketing communications. You can change your marketing preferences by contacting us at feedback@congistics.com. Please note that we will continue to send you service-related communications regardless of any opt-out request. We will not sell or share your information with third parties (other than our subsidiaries or affiliates) for their own promotional or marketing purposes unless you give us consent to do so and where permitted by applicable law.

California Online Privacy Protection Act Notice Concerning Do Not Track Signals

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. We do not recognize or respond to browser-related DNT signals, as the industry is currently working toward a common approach to responding to DNT. To learn more about Do Not Track, please click here.

6. SECURITY

We have implemented administrative, technical, and physical security measures to help prevent unauthorized access. Despite these measures, no data transmission over the Internet can be entirely secure, and we cannot guarantee or warrant the security of any information you transmit via our websites or apps. Please note that you are responsible for maintaining the security of your credentials used to access any Digital Markets service or account, and you must report suspected unauthorized activity to us.

We make reasonable efforts to restrict access to information to only those employees, contractors, and agents who need such access in order to operate, develop, improve, or deliver our programs, products, and services.

7. COOKIES AND SIMILAR TECHNOLOGIES

A cookie is a small text file which includes a unique identifier that is sent by a web server to the browser on your computer, mobile phone or any other internet enabled device when you visit an on-line site. Cookies and similar technologies are widely used to make websites work efficiently and to collect information about your online preferences. For simplicity, we refer to all these technologies as "cookies".

Some of our website pages may contain electronic images known as web beacons (also known as clear gifs, tags or pixels) that allow us to count users who have visited our pages. Web beacons collect only limited information, e.g. a cookie number, time and date of a page view, and a description of the page on which the web beacon resides. We may also carry web beacons placed by third party advertisers. These beacons do not carry any information that could directly identify you.

More detailed information on how we use cookies and other web technologies can be found here.

8. SMS Terms and Conditions

You represent that you are the owner of the wireless device for which you have authorized enrollment in the ControlBoard SMS Program and are responsible for messages sent from the device. By continuing to use the SMS Program, you agree that we will not be liable for any unauthorized access or interception of text communications with us. Message and data rates may apply from your mobile carrier and, by enrolling in the SMS Programs, you agree to pay any such charges. Message frequency will vary based on the SMS Program and user activity.

To stop receiving text messages, text STOP. You consent that following a request to STOP, you will receive one final message confirming that you have been unsubscribed. To re-enroll, reply JOIN and you will receive confirmation of your re-enrollment. You agree that you will promptly notify us if your mobile phone number changes.

We reserve the right to terminate any of the SMS Programs, in whole or in part, at any time without notice.

You agree that we will not be liable for any delays or failures in your receipt of any SMS messages as delivery can be unpredictable based on transmission from your network operator and processing by your mobile device. SMS message services are provided on an AS IS, AS AVAILABLE basis.

Your SMS information will not be shared with third parties.

9. MISCELLANEOUS

9.1 LINKS

We provide links to other websites or resources that are not part of the products, programs, or services run by Congistics. We do not control these websites or their privacy practices, and any information you provide to these sites is subject to the privacy notices of those sites and not this Policy.

9.2 CALIFORNIA PRIVACY RIGHTS

Subject to certain limits under California Civil Code § 1798.83, California residents may request certain information regarding our disclosure of information to third parties or their direct marketing purposes. To make such a request, please contact us as specified at the beginning of this Policy.

9.3 CHANGES TO THIS POLICY

From time to time, we may change and/or update this Policy. If this Policy changes in any way, we will post an updated version on the Site. We recommend you regularly review the Site to ensure that you are always aware of our information practices and any changes to such. Any changes to this Policy will go into effect on posting to this page.

Updated September 2022

Please take time to read our privacy policy ("policy") as it sets out important information relating to how we handle your personal information.

In this Policy, references to "we", "us" or "Congistics" are references to Congistics Corporation.

HOW TO CONTACT US

Questions, comments and requests regarding this Policy should be addressed to our Data Protection team through the following means:

Data Protection Team
Legal Department
5 River Rd, Suite 118
Wilton, CT 06897
USA

Email Address: feedback@congistics.com

INTRODUCTION

We will collect personal information when you use the Site and the associated services and as part of the normal course of business. This Policy sets out how we collect and use personal information and your rights regarding our use of your personal information.

Other information you provide when you communicate with us, including your full name, contact details and business email address, phone number and details of our communications.

We use this information for certain activities, including:

Contacting you to answer your questions regarding our brands;

Marketing regarding Congistics services and products which may be of interest and to promote our business and brand;

Responding to your questions and requests and otherwise customize your digital markets experience;

We use this information because:

We have a legitimate business interest to:

Manage and promote our business and brand;

Provide and improve our services;

Operate our business;

Improve the performance and user experience of our websites;

Monitor, investigate and report any attempts to breach the security of our websites; and

Resolve any concerns or disputes you may have.

We have collected your consent (where required under applicable law) to use your information for marketing. Where we rely upon your consent, you have the right to withdraw this consent by contacting the Data Protection Officer on the contact details above.

Information we collect about your use of our website and apps.

Categories of information we collect about you include:

Information captured in our web logs such as device information (e.g. device brand and model, screen dimensions), unique identification numbers (e.g. IP address and device ID), and browser information (e.g. URL, browser type, pages visited, date/time of access), geo-location and other device-specific information, Internet connection information;

1. FURTHER INFORMATION

Where we collect and use information for our legitimate interests as mentioned above, a legitimate interest will only apply when we consider that your interests or rights requiring protection of your personal information do not override our legitimate interests. For more information regarding our legitimate interests as applied to your personal information, please contact us.

Our websites and online services are for individuals who are at least 18 years old. Our online services are not designed to be used by individuals under the age of 18.

Your personal information may also be processed if it is necessary: to respond to a lawful request from a law enforcement or regulatory authority, body or agency; in the defense of legal claims or in order to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or violations of any of our Site terms.

2. WHEN WE DISCLOSE YOUR INFORMATION

When we have your consent or authorization to do so;

To comply with applicable laws, protect rights, safety and property, and respond to lawful requests from public authorities (such as disclosing data in appropriate situations for national security or law enforcement purposes);

Your personal information will also be transferred to other third party organizations in certain scenarios (subject to applicable law):

If we sell, purchase or transfer any part or all of our business or assets (including in bankruptcy), or in the event of another corporate change, in which case we may disclose your Information to the prospective seller, buyer or administrator of such business or assets including for pre-transaction review under suitable terms as to confidentiality;

If we are reorganized or sold, information may be transferred to a buyer who can continue to provide services to you;

If we are defending a legal claim, our property, our website or other users, Information may be transferred as required in connection with defending such claim.

If there is an emergency which requires us to share your data or for the health and safety of our Site's users or the general public.

3. DATA SUBJECT RIGHTS

We ensure that the personal information we collect about you is accurate, complete and used for its intended purpose. You may access, review, correct and update your Information or close your account by contacting us by email on the contact details above. If you a citizen of the European Union you also have the rights listed below.

3.1 EUROPEAN UNION RESIDENTS

In certain circumstances, you have certain rights regarding your personal information. A summary of each right and how you can exercise it is below. To exercise any of these rights, please contact us. Such requests should include information to allow us to verify your identity (e.g. your name, address, email address or other information reasonably required).

Where we receive your request to exercise one of these rights, we will respond without undue delay and in any event within one month of receipt of the request. This may be extended by a further two months in certain circumstances, e.g. where requests are complex or numerous.

We will provide the information free of charge, except where requests are manifestly unfounded or excessive, e.g. because of their repetitive character. In these circumstances we may charge a reasonable fee or may refuse to act on the request. We will advise you of any fees prior to proceeding with a request. We may ask for additional information to verify your identity before carrying out a request.

Right How you can exercise the right

Right to access and/or correct your personal information You have the right to access personal information we hold about you, and to be provided with a copy of the information (in most circumstances). You also have the right to correct any information we may hold about you that is inaccurate.

Right to restrict use of your personal information You have the right to ask us to restrict processing of your personal information where one of the following applies:

The processing is unlawful, but you want us to restrict use of the data instead of deleting it;

Where you contest the accuracy of your personal information, the restriction will apply until we have verified the accuracy or corrected your personal information;

We no longer require the personal information for the purposes of processing, but are required to keep it in connection with a legal claim;

You have exercised your right to object to the processing. The restriction will apply until we have taken steps to verify whether we have compelling legitimate grounds to continue processing.

Right to request deletion of your personal information

You have the right to ask us to delete your personal information in most circumstances. If you want to opt-out from receiving marketing communications, the best way to do so is to allow us to retain your information with a “do not contact” tag so we know not to contact you in the future.

There are also certain exceptions where we may refuse a request for erasure, for example, where the personal information is required to comply with a legal obligation or for the establishment, exercise or defense of legal claims.

Right to object to processing of your personal information You may object to our use of your personal information for marketing purposes. You may also object to processing of your personal information in cases where we have used legitimate interests as the basis for processing. In such cases, we will stop processing your personal information until we verify that we have compelling legitimate grounds for processing that outweigh your interests, rights, and freedoms in asking us to stop processing the data, or in limited cases where we need to continue processing the data for the establishment, exercise, or defense of legal claims.

Right to data portability In most cases, you have the right to receive all personal information you have provided to us in a structured, commonly used, and machine-readable format and to transmit this data to another data controller, where technically feasible.

Right to lodge a complaint with a supervisory authority If you object to our processing of your personal information, you have the right to complain to the data protection authority in the country where you reside, where you work, or where an alleged infringement of data protection laws has taken place.

4. RETENTION PERIODS

We will retain your personal information for as long as required to perform the purposes for which the data was collected, depending on the legal basis for which that data was obtained and/or whether additional legal/regulatory obligations require us to retain it.

In general terms, this will mean that your personal information will be kept for the duration of our relationship with you and:

the period required by tax and company laws and regulations; and

as long as it is necessary for you to be able to bring a claim against us and for us to be able to defend ourselves against any legal claims. This will generally be the length of the relationship plus the length of any applicable statutory limitation period under local laws.

5. CHOICES ABOUT YOUR INFORMATION

We believe it is important to give you choices about the use of your Information. We will use your personal information as described in this Policy. If we want to use your information for a purpose not described in this Policy, we will first get your consent to do so.

Marketing Communications

We will respect your wishes not to receive marketing communications. You can change your marketing preferences by contacting us at feedback@congistics.com. Please note that we will continue to send you service-related communications regardless of any opt-out request. We will not sell or share your information with third parties (other than our subsidiaries or affiliates) for their own promotional or marketing purposes unless you give us consent to do so and where permitted by applicable law.

California Online Privacy Protection Act Notice Concerning Do Not Track Signals

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. We do not recognize or respond to browser-related DNT signals, as the industry is currently working toward a common approach to responding to DNT. To learn more about Do Not Track, please click here.

6. SECURITY

We have implemented administrative, technical, and physical security measures to help prevent unauthorized access. Despite these measures, no data transmission over the Internet can be entirely secure, and we cannot guarantee or warrant the security of any information you transmit via our websites or apps. Please note that you are responsible for maintaining the security of your credentials used to access any Digital Markets service or account, and you must report suspected unauthorized activity to us.

We make reasonable efforts to restrict access to information to only those employees, contractors, and agents who need such access in order to operate, develop, improve, or deliver our programs, products, and services.

7. COOKIES AND SIMILAR TECHNOLOGIES

A cookie is a small text file which includes a unique identifier that is sent by a web server to the browser on your computer, mobile phone or any other internet enabled device when you visit an on-line site. Cookies and similar technologies are widely used to make websites work efficiently and to collect information about your online preferences. For simplicity, we refer to all these technologies as "cookies".

Some of our website pages may contain electronic images known as web beacons (also known as clear gifs, tags or pixels) that allow us to count users who have visited our pages. Web beacons collect only limited information, e.g. a cookie number, time and date of a page view, and a description of the page on which the web beacon resides. We may also carry web beacons placed by third party advertisers. These beacons do not carry any information that could directly identify you.

More detailed information on how we use cookies and other web technologies can be found here.

8. SMS Terms and Conditions

You represent that you are the owner of the wireless device for which you have authorized enrollment in the ControlBoard SMS Program and are responsible for messages sent from the device. By continuing to use the SMS Program, you agree that we will not be liable for any unauthorized access or interception of text communications with us. Message and data rates may apply from your mobile carrier and, by enrolling in the SMS Programs, you agree to pay any such charges. Message frequency will vary based on the SMS Program and user activity.

To stop receiving text messages, text STOP. You consent that following a request to STOP, you will receive one final message confirming that you have been unsubscribed. To re-enroll, reply JOIN and you will receive confirmation of your re-enrollment. You agree that you will promptly notify us if your mobile phone number changes.

We reserve the right to terminate any of the SMS Programs, in whole or in part, at any time without notice.

You agree that we will not be liable for any delays or failures in your receipt of any SMS messages as delivery can be unpredictable based on transmission from your network operator and processing by your mobile device. SMS message services are provided on an AS IS, AS AVAILABLE basis.

Your SMS information will not be shared with third parties.

9. MISCELLANEOUS

9.1 LINKS

We provide links to other websites or resources that are not part of the products, programs, or services run by Congistics. We do not control these websites or their privacy practices, and any information you provide to these sites is subject to the privacy notices of those sites and not this Policy.

9.2 CALIFORNIA PRIVACY RIGHTS

Subject to certain limits under California Civil Code § 1798.83, California residents may request certain information regarding our disclosure of information to third parties or their direct marketing purposes. To make such a request, please contact us as specified at the beginning of this Policy.

9.3 CHANGES TO THIS POLICY

From time to time, we may change and/or update this Policy. If this Policy changes in any way, we will post an updated version on the Site. We recommend you regularly review the Site to ensure that you are always aware of our information practices and any changes to such. Any changes to this Policy will go into effect on posting to this page.

Updated September 2022

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