Effective June 2, 2022 (Last updated June 2, 2022)
WeFreight (WeFreight Investment FZCO, DSO-IFZA, Dubai Digital Park, Dubai Silicon Oasis, Dubai, United Arab Emirates), and its subsidiaries (“WeFreight”, “we”, “us” or “our”), respect your preferences concerning the collection and use of your personal data.
This policy reflects our current data protection policies and practices and describes how we collect personal data when you access or use WeFreight websites on which this policy appears (the “Websites”) and how we use such personal data (hereinafter, the “Policy”).
WeFreight operates in more than 100 countries. Unless otherwise stated, this Policy applies to all jurisdictions in which WeFreight operates. Certain regions, countries, and/or individual states may have additional requirements, which are detailed, by jurisdiction, below. We also encourage you to review our table of contents, above, which identifies the portions of this Policy that apply to specific locations.
WeFreight is the primary controller of personal data collected through the Websites. This Policy, except as provided below, applies only to the personal data that we collect online, from users of our Websites.
WeFreight also collects and processes personal data it did not collect from you. This is the case where WeFreight receives personal data from your device as part of the electronic communication itself – the standard electronic greeting between your computer, the network, and our servers. At this time, our server will also query your computer to see if there are “cookies” previously set by our Websites to facilitate log in or other site navigation procedures.
Our Websites may contain applications that allow you to book shipments, in which case you need to provide us with third-party personal data required to arrange for such shipment. In such case, you represent and warrant to WeFreight that you have obtained all necessary third-party consents for the processing of such personal data contemplated by the shipment.
In order to pursue the purposes referred to under this Policy, WeFreight may need to share certain personal data with subsidiaries and affiliates in different jurisdictions (which may also act as data controllers), with service providers (e.g., those needed for the operation of the Websites, credit card clearing houses, transport companies, etc.) and other third parties, including Government agencies and marketing entities. We share personal data to the parties referred above only to the extent needed to run our Websites and conduct the activities referred to in this Policy.
In certain, limited circumstances, where permitted by applicable law, we may share or transfer personal data to unrelated third parties. For example, we may provide personal data to a third party (i) at your request; (ii) to comply with a legal requirement or court order; (iii) to investigate a possible crime, such as identity theft; (iv) in connection with the sale, purchase, merger, reorganization, liquidation or dissolution; or (v) under similar circumstances. If such an event occurs, we will take appropriate steps to protect your personal data.
WeFreight takes appropriate steps to ensure that its personnel, its affiliates and third-party vendors are bound by duties of confidentiality and that, if applicable, WeFreight implements measures such as EU standard contractual clauses to ensure that any transferred personal data remains protected and secure.
WeFreight may implement profiling activities, which enable us to better understand your potential needs and expectations so as to provide you with tailored information and/or services, the most likely to be of interest to you. Please note that such profiling activities will not make you subject to any legal consequences as it is just a useful way for us to better get to know you and to adapt our services proposals accordingly. To exercise your right to object to such profiling, please contact us at email@example.com.
We do conduct e-mail marketing activities. If in the use of our Websites you have provided us with e-mail or other personal data, we will ask your consent to send you e-mail marketing material, except in the event that you are an existing customer and such permission is not required according to law. We will include an “unsubscribe” link in each electronic communication so that you can advise us whether you wish to continue receiving such communications going forward.
What are my rights regarding my personal data?
You are entitled to: (i) request access to your personal data processed by WeFreight; (ii) request the rectification of your personal data; (iii) request the erasure of your personal data; (iv) request the restriction of processing or object thereto; (v) receive your personal data in a structured and standard format as part of your right to portability; and (vi) lodge a complaint with a local supervisory authority.
Should you be willing to exercise the rights referred to under this section, you may write to us at firstname.lastname@example.org.
The CCPA defines “personal information” to mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. Personal information does not include publicly available, deidentified or aggregated information. For purposes of this “Notice to California Residents” section we will refer to this information as “Personal Information.”
The CCPA contains an exception that is relevant to us. Some of the CCPA’s privacy rights explained below do not apply to personal information reflecting a written or verbal communication or a transaction between us and a consumer, where the consumer is acting as an employee, owner, director, officer, or contractor of another entity and when the communication or transaction occur solely within the context of us conducting due diligence regarding, or providing or receiving a product or service to or from such entity.
What Categories of Personal Information does WeFreight Collect?
As discussed, some of the CCPA’s privacy rights discussed herein do not apply to the Personal Information listed above because of the CCPA’s business-to-business exemption.
Has WeFreight Disclosed or Sold Personal Information?
If we determine that your request is subject to an exemption or exception, we will notify you of our determination. If we determine that your request is not subject to an exemption or exception, we will comply with your request upon verification of your identity and, to the extent applicable, the identity of the California resident on whose behalf you are making such request. Our verification process may differ depending on whether you maintain a relationship and/or account with WeFreight (i.e., a password-protected account).
If you maintain a relationship and/or account with WeFreight, we may verify your identity through existing authentication practices available through your account. Prior to disclosing or deleting the Personal Information, we will ask you to re-authenticate yourself with respect to that account.
If you do not maintain a password-protected account, or if you are an account-holder but we suspect fraudulent or malicious activity with your account, we will verify your identity either to a “reasonable degree of certainty” or a “reasonably high degree of certainty” depending on the sensitivity of the Personal Information and the risk of harm to you by unauthorized disclosure or deletion, as applicable.
For requests to access categories of Personal Information and for requests to delete Personal Information that is not sensitive and does not pose a risk of harm by unauthorized deletion, we will verify your identity to a “reasonable degree of certainty” by verifying at least two data points that you previously provided to us and which we have determined to be reliable for the purpose of verifying identities.
For requests to access specific pieces of Personal Information or for requests to delete Personal Information that is sensitive and poses a risk of harm by unauthorized deletion, we will verify your identity to a “reasonably high degree of certainty” by verifying at least three pieces of Personal Information previously provided to us and which we have determined to be reliable for the purpose of verifying identities. In addition, you will be required to submit a signed declaration under penalty of perjury stating that you are the individual whose Personal Information is being requested.
If you have questions about this Policy, please contact us at email@example.com.