Definition: The terms “we,” “us,” and “our” are used to refer to APL Logistics Ltd and its Affiliatesi (collectively “APLL Group”).
We are committed to maintaining the privacy of individuals, including users who access our website (the “Site”). This Privacy Policy explains the types of information we gather in our business and what we do with it. By using the Site, you agree to the terms and policies described in this Privacy Policy.
For applicable data protection law, including the EU General Data Protection Regulation (Regulation (EU) 2016/679), APLL Group is the data controller of information collected through this Site.
1. Information We Collect
We collect personal information directly from you when you provide it to us, for example, when you register and conduct business transactions on the Site. Individuals who register on the Site are referred to in this Privacy Policy as “Registered Users.” We also use cookies; please see our Cookie Notice.
Personal information means information about an identifiable individual. It may include your name, address, telephone and fax number, e-mail address, financial information, such as a credit card number, and employment-related information, such as may be found on a resume or job application. Personal information does not include business contact information (e.g., office address, switchboard telephone number) in jurisdictions that do not recognize such information as personal information.
We may collect the following kinds of personal information from you:
a) Information about you, such as your name, address, email, and other contact details, the name and address of the company you are associated with, your User ID and other account details when you register with us, and any bank account or other payment details you give us, jobs you are interested in and your relevant experience, qualifications, and salary when you apply for a job with us;
b) Information about your use of our services, such as details of your bookings;
c) Details about services we have provided to you in the past;
d) Information about your use of the Site; and
e) Any other information you provide us when you contact us, including when you use our inquiry form, telephone number, email address, or write to our postal address, or which you provide to us through our ethics reporting resource.
You are responsible for maintaining the confidentiality of any User ID that may be assigned to you, as well as any account number, account name, or passwords, if applicable, for the services you utilize through the Site.
2. How We Use Your Personal Information and Our Lawful Basis for Doing So
We process your personal information for the following purposes and in accordance with the following lawful grounds:
a) To identify you and to verify your identity, for our legitimate interest of fraud detention and protection and to enable us to carry out our contract with you (if applicable);
b) to allow us to contact you for service(s) or opportunities as requested by you, such as customer service or information about the provision of our services, in accordance with our legitimate interest in communicating with customers and potential customers about our services;
c) to allow you to apply for employment and to provide you with information about a job opportunity if you have submitted a resume online, in accordance with our legitimate interest in hiring new staff;
d) to make improvements to materials or products offered on the Site and to the Site in general, in accordance with our legitimate interest to do so;
e) to enable Registered Users to access the functionalities described on the Site, including, without limitation, tracking shipments and viewing outstanding charges, to fulfill our contract with you or in accordance with our legitimate interest in providing our services to the company with which you are associated;
f) to obtain other user-specific information where we need more information to provide you with services you have requested in order to enter into or carry out a contract with you;
g) where legally required or where it is in our legitimate interest to do so, to comply with requests from law enforcement and regulatory authorities;
h) to obtain legal advice in accordance with our legitimate interest to do so or to establish, exercise, or defend legal claims, depending on the circumstances;
i) to consult our professional advisors, for example, for audit purposes, in accordance with our legitimate interest to operate our business efficiently and transparently;
j) to investigate violations of either the Privacy Policy or the “Terms of Use” in accordance with our legitimate interest to do so, and
k) to notify Registered Users about important changes to the Site or promotions or opportunities. For this processing, we rely on our legitimate interest in contacting you about our services. You may always decline to receive these messages by following the process to Opt Out as described below or as described within a particular message;
l) When ordering products or services on the Site, you may be asked to provide a credit card number. Depending on the activity, some of the information that we ask you to provide is identified as mandatory and some as voluntary. If you do not provide the mandatory data with respect to a particular activity, you will not be able to engage in that activity. We process this payment information to carry out a contract with you or in accordance with our legitimate interest in providing our services to the company with which you are associated.
Your email address is collected to send you an email confirming your new member registration and confirmations for other services you transact with us online.
Registered Users may access and change their information at any time via the Site as described in Section 10 below.
3. International Transfers
When you submit personal information through this Site, you understand that this information may be transferred across national boundaries and may be stored and processed in any of the countries in which we transact business. Where we transfer personal data within the APLL Group, we have a robust agreement in place to protect your personal data and your rights, which incorporates the European Commission’s approved model clauses.
In certain countries or with respect to certain activities, the collection, transfer, storage, and processing of your information may be undertaken by our trusted third-party service providers. Such third-party service providers are bound by contract not to use your personal information for their purposes and to treat the information as confidential. In the case of transfers of personal information from the European Economic Area, our contracts with such third parties incorporate the European Commission’s approved model clauses to ensure that your rights are protected if we transfer your personal information outside of the European Economic Area.
4. How We Share Your Personal Information with Third Parties
We share your personal information with our vendors, who perform functions for which we engage them. For example, we may use third parties to host the Site or assist us in providing functionality on the Site, provide data analysis and research on the Site, send out email updates about the Site and our products and services, remove repetitive information from our user lists, and to process payments.
We also have established relationships with various service providers whose services are available to you from this Site or from websites that are linked to this Site or who support us by providing services that are transparent to you. Typically, these providers offer services that you might find useful, such as those that can be used in conjunction with our services and products. To use those services, you may be required to provide personal information to the providers.
These include, for example, providers of:
- website support and other IT services;
- payment support services;
- transport services;
- warehousing services;
- freight forwarding services;
- consolidation services;
- custom clearance services;
- ports and terminals–related services;
- legal advisors, auditors, and accounts;
- ethics reporting resource, and
- all other logistics services not already mentioned above.
If you are an employee or other agent of a company that is a customer of ours and are using the Site and our services on behalf of that customer, we may share your personal information with that customer to facilitate your use of the Site and our provision of services for that customer.
If we sell assets (or the assets of a division or subsidiary) to another entity, or we (or a division or subsidiary) are acquired by, or merged with, another entity, we may provide to such entity your personal information that is related to that part of our business that was sold to or merged with the other entity without your consent.
Other than as described in this Privacy Policy or as otherwise specifically communicated to you by us, we do not provide information supplied by you to any third parties except where law, court order, or a governmental authority requires or based upon the good faith belief that disclosure is necessary including, without limitation, to protect our rights when we have reason to believe that disclosing the information is necessary to enforce our rights, protect our property or the property and safety of others, to identify, contact or bring legal action against someone who may be causing interference with our rights or causing harm to third parties, and as needed to support external auditing, compliance, and corporate governance functions.
5. How Long We Keep Your Information
We hold your personal information for as long as we need to for legitimate legal or business reasons, including to comply with any regulatory obligations. How long we keep your information depends on the record types and our relationship with you.
6. Links to Third Party Websites
The Site may contain links to websites other than our own and for which we are not responsible. Such websites may collect personal information from you. These websites may send their cookies to you and may collect information and use it in a way inconsistent with this Privacy Policy.
When you use such websites, unless expressly provided to the contrary, the collection and use of your personal information will be governed by the privacy policy applicable to that website, which should identify the entity that is collecting your personal information. Unless we explicitly state otherwise, such references in no way indicate our endorsement, recommendation, or preference of any such products, services, or information contained on any other site.
In some cases, the third-party websites are our service providers. You should be aware that our agreements with these service providers often require them to share personal information collected from you with us. In such instances, we may use this information in a manner consistent with this Privacy Policy.
7. Use of Cookies and Log Files
The Site does not use persistent or stored cookies; however, it does use temporary or session cookies.
Temporary or session cookies act as randomly generated session IDs; they last only while the Registered User is logged onto the Site and are canceled at the end of the session (i.e., when the Registered User logs out of the Site or closes their Web browser program).
The Site uses temporary cookies for security purposes. Each time a Registered User logs onto the Site, the Site server generates a temporary session ID, which it associates with the user’s login name, password, and device, such as a computer or mobile phone, during that particular session.
This allows the Registered User to move from page to page on the Site during a specific session without re-entering the user login name and/or password. The temporary cookie allows the Site server to continuously verify that the user is permitted as the user moves from page to page during a specific session.
When the Registered User logs out of the Site, the temporary session ID is canceled and removed from the temporary memory of the user’s device. The association between the temporary session ID and the specific user login name and password is also terminated on the Site server.
We also use log files to analyze anonymous site usage. A “log file” is a data file that records a Registered User’s activity while using the Site.
For detailed information about cookies and how we use the cookies on our Site, see our Cookie Policy.
8. Security
While we have taken measures designed to protect the personal information that we collect, for example, we restrict physical access to servers containing personal information and use firewalls and other technical security measures designed to protect personal information from being accessed by unauthorized persons. However, please know that (i) no computer system is immune from intrusion, and (ii) information transmitted to the Site may need to pass through many systems to process such information. Therefore, we cannot guarantee the absolute security or confidentiality of information transmitted to the Site.
9. Changes to this Privacy Policy
The effective date of this Privacy Policy is set forth at the top of this web page. We may alter, update, or otherwise change this Privacy Policy at any time to reflect material changes in how we use your information. Any such changes will be posted on this page. You should periodically check this Privacy Policy to review the current terms and guidelines applicable to your use. Your continued use of the Site following the posting of such changes will indicate your full acceptance of those changes.
10. Do Not Track
Our Site does not currently take any action when it receives a “Do Not Track” request. “Do Not Track” is a privacy preference that you can set in your web browser to indicate that you do not want certain information about your webpage visits collected across websites when you have not interacted with that service on the page. For details, including how to turn on “Do Not Track”, visit www.donottrack.us.
11. Updating Your Personal Information and Your Communication Choices
At any time, you can access and correct your personal information and update your privacy preferences, including exercising your right to unsubscribe as a Registered User of the Site, by emailing privacy@apllogistics.com.
As a Registered User, you will occasionally receive email messages from us about products and services we offer, which we think you might be interested in. If you would prefer not to receive these messages, you may opt-out by following the instructions in the e-mail message or by contacting us. We reserve the right to limit certain services to Registered Users who will accept email messages.
12. Additional Information for European Users
Where European Union or EU Member State law applies, depending on the lawful grounds which we are using to process the personal information in question and on your reasons, you also have the right to ask us to:
a) delete your information,
b) correct (rectify) it,
c) restrict it (i.e., stop us from using it),
d) object to us using it for marketing or other purposes, and
e) to ask us to transfer it to an alternative service provider.
Our response will depend on our justification for processing the personal information and the lawful grounds we rely on for processing that information.
Please use the contact details below when you contact us to exercise your rights. In your communication with us, please provide information to help us verify your identity. We may ask you to provide additional information to help us verify your identity, depending on the nature of the request and the information you initially submit.
In the European Economic Area (EEA), you also have the right to complain to your local data protection supervisory authority if you feel that we have not respected your data protection rights under the EEA data protection law. A list of European supervisory authorities is available here.
13. Additional Information for U.S. Residents
California Residents
Section 1 (Information We Collect) describes the categories of personal information we have collected about California residents in the past 12 months and the categories of sources from which we collect that personal information. Section 2 (How We Use Your Personal Information and Our Lawful Basis for Doing So) describes the business purposes for using the personal information we collect. We may disclose the personal information we collect to the third parties listed in Section 4 (How We Share Your Personal Information with Third Parties) for a business purpose.
We do not sell your personal information for monetary consideration. However, we may use third-party cookies for Site analytics purposes. The collection of data through the use of these third-party cookies for our purposes may be considered a “sale” under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CPRA”). Accordingly, in the past 12 months, we have “sold” (as defined under the CPRA) Internet or other electronic network activity information, including information regarding your interaction with the Site and our email communications, and similar information collected by third-party cookies and transmitted to our third-party website analytics vendors.
We do not sell personal information about minors under the age of 16.
If you are a California resident, the CPRA provides you with certain rights regarding your personal information. These rights are:
a) Right to Know
You have the right to request that we disclose what personal information we collect, use, disclose, sell, or share. Specifically, you may request that we disclose to you the following:
• The categories of personal information we have collected about you.
• The categories of sources from which the personal information is collected.
• The business or commercial purpose is to collect, sell, or share personal information.
• The categories of third parties with whom we disclose personal information.
• The specific pieces of personal information we have collected about you.
You may also request that we disclose to you:
• The categories of personal information that we have sold or shared about you and the categories of third parties to whom the personal information was sold or shared, by category or categories of personal information for each third party to whom the personal information was sold or shared.
• The categories of personal information we disclosed about you for a business purpose and the categories of persons to whom it was disclosed for a business purpose.
b) Right to Request Deletion
You have the right to request that we delete any personal information collected about you. If it is necessary for us to maintain your personal information for certain purposes, we are not required to comply with your deletion request. If we determine that we will not delete your personal information when you request us to do so, we will inform you and tell you why we are not deleting it.
c) Right to Opt-Out of Sale or Sharing of Personal Information
As described above, we do not sell your personal information for monetary consideration. However, we may use third-party cookies for analytics purposes, and the collection of data through certain third-party cookies for our analytics purposes may be considered a “sale” under the CPRA. To opt out of having your information shared with third-party website analytics service providers for this purpose, visit our “Do Not Sell or Share My Personal Information” web page.
d) Right to Correct Inaccurate Personal Information
You have the right to request a business that maintains inaccurate personal information about you to correct that inaccurate personal information, taking into account the nature of the personal information and the purposes of the processing of the personal information.
e) Right to Limit Use and Disclosure of Sensitive Personal Information
We do not collect your sensitive personal information.
f) No Discrimination
You have the right not to be discriminated against because you exercised any of your aforementioned rights.
Residents of Other U.S. States
The laws of Colorado, Connecticut, Virginia, and Utah provide the following rights to “consumers” (i.e., state residents who act in an individual or household context and exclude individuals acting in a commercial context). Other states may provide similar rights.
a) The right to confirm whether or not an entity is processing your personal information and accessing such personal information;
b) For Virginia, Colorado, and Connecticut residents, the right to correct inaccuracies in their personal information, taking into account the nature of the personal information and the purposes of the processing of your personal information;
c) The right to delete personal information provided by, or for Virginia, Colorado, and Connecticut residents obtained about you;
d) The right to obtain a copy of your personal information that an entity processes in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance, where the processing is carried out by automated means; and
e) The right to opt out of the processing of personal information for purposes of:
• Targeted advertising;
• The sale of personal information; or
• For Virginia, Colorado, and Connecticut residents, profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
How to Submit a Request
If you are a resident of California or other states that provide you with rights relating to your personal data, you can exercise those rights by submitting a verifiable request to us. You can do so by emailing us at privacy@apllogistics.com or visiting our “Request Form.”
To submit a verifiable request, you will be asked to provide certain information to help us verify your identity. The information we ask you to provide to initiate a request may differ depending upon the type of request, the type, sensitivity, and value of the personal information that is the subject of the request, and the risk of harm to you that may occur as a result of unauthorized access or deletion, among other factors. If you maintain an online account with us, we may require that you verify your identity for a request through the normal account authentication process, meaning you will need to sign on with your username and password. You may also designate an authorized agent to make a request on your behalf by providing the agent with signed written permission to do so.
14. Contact Us
If you have any inquiries or concerns with respect to your personal information or you have other related inquiries or concerns, you may write to our Data Protection Manager:
Mr. Joost Saveniers Email: privacy@apllogistics.com
In your communication, please describe in as much detail as possible the nature of your inquiry or how you believe this Privacy Policy has not been complied with so that we may investigate your inquiry.
Please note that if you provide us with inconsistent privacy preferences (for example, by indicating on one occasion that third parties may contact you with marketing offers and indicating on another occasion that they may not), we cannot guarantee that your most recent privacy preference will be honored.
i“Affiliate” means any entity within APLL Group from time to time that is directly or indirectly controlled by APL Logistics Ltd or is in a joint venture with APL Logistics Ltd. The controlling interest of any Affiliate must be at least fifty percent (50%) of the voting power or a smaller interest that is the maximum interest permitted in a jurisdiction.