Privacy Statement for Descartes Pacejet

This General Descartes Pacejet Privacy Policy (also referred to as the ‘ Privacy Policy’) provides information on the collection, use, and sharing (collectively referred to ‘ processing’ or ‘ process’) of personal information by Pacejet Logistics, Inc. (“Pacejet”, “we” or “us”) in connection with your use of Pacejet products, services and websites which link to this Privacy Policy, as well as your interactions with Pacejet via email. This Privacy Policy also explains the privacy rights you have in relation to these processing activities.

This Privacy Policy was last updated on January 5, 2024. However, the Privacy Policy can change over time, for example to comply with legal requirements or to meet changing business needs. The most up-to-date version can be found on our website. In case there is an important change that we want to highlight to you, we will also inform you in another appropriate way (for example via statement of changes on our website).

As used in this Privacy Policy, ‘personal information’ or ‘personal data’ means information that relates to an identified individual or to an identifiable individual. For example, this could include among other things name, address, email address, business contact details, or information gathered through your interactions with us via our websites. Personal information is also referred to as ‘ information about you.’

1. Information we collect

We collect your personal information in order to provide and continually improve our products and services.

Here are the types of personal information we collect:

• Information You Give Us: We receive and store any information you provide in relation to Pacejet. When you sign up for a Pacejet Account, we will ask you for personal information (e.g.; name, address, phone number) and business information (e.g.; information collected on the Pacejet Order Form) which will be used in our systems and setup. In addition, when you send email or other communications to Pacejet, we may retain those communications in order to process your inquiries, respond to your requests and improve our services. We may also use your email address to communicate with you about our services.
• Automatic Information: We automatically collect and store certain types of information about your use of Pacejet products, including information about your interaction with content and services available through the Pacejet website. Like many websites, we use “cookies” and other unique identifiers, and we obtain certain types of information when your web browser or device accesses Pacejet and other content served by or on behalf of Pacejet on other websites. These server logs may include information such as your web request, your interaction with a service, Internet Protocol address, browser type, browser language, the date and time of your request.
• Information from Other Sources: We offer some of our services on or through other web sites or software applications. Personal information that you provide to those sites may be sent to Pacejet in order to deliver the service.

2. Scope

This Privacy Policy applies to the processing of personal information by Pacejet.

When interacting with our websites, you also have the ability to link or connect with non-Pacejet websites, services, networks, third party applications or other features. The information collected by Pacejet when you enable a third party application is processed according to the Pacejet Privacy Policy. Enabling these features will lead to other parties than Pacejet processing information about you. Pacejet does not have any control over these features of other parties. We encourage you to review the privacy policies of these parties before using these features.

We offer some of our services on or through other web sites or software applications. Personal information that you provide to those sites may be sent to Pacejet in order to deliver the service. We process such information under this Privacy Policy.

3. Purpose

We use your personal information to operate, provide, develop, and improve the products and services that we offer our customers. These purposes include:

• to communicate and respond to your requests and inquiries to Pacejet;
• to deliver functionality on our sites and for their technical and functional management;
• to engage in transactions with customers, suppliers and business partners and to process orders for Pacejet products and services;
• to analyze, develop, improve and optimize the use, function and performance of our sites and products and services;
• to manage the security of our sites, networks and systems; and
• to comply with applicable laws and regulations and to operate our business.

To communicate and respond to your requests and inquiries to Pacejet

If you get in touch with us (such as by submitting contact forms on our sites, sending an email or by visiting social media platforms), we process information about you to communicate with you and to respond to your requests or other inquiries.

To deliver functionality on our sites and for their technical and functional management

When you choose to register with us (such as to make use of our services), we need to process the personal information provided by you so that we can create and manage an account for you. Upon creating your account, we will send you your login information. This personal information enables us to administer your account, for example by changing your password for you.

To engage in transactions with customers, suppliers and business partners and to process orders for Pacejet products and services

When you access Pacejet services, you or your applications may send shipping data such as a ship-from address, ship-to address, carrier services, product information, pricing and other data which we may retain to respond to your service requests and improve our services. This information may be transmitted to third parties, such as carriers, to provide services on your request. Additionally, when you access Pacejet services, you or your application may send data from your Enterprise Resource Planning (“ERP”) software, Warehouse Management Software (“WMS”), accounting systems, or other business applications which we may retain to respond to your service requests and improve our services.

To analyze, develop, improve and optimize the use, function and performance of our sites and products and services

We may process personal information in order to analyze, develop, improve and optimize the use, function and performance of our services and products, including for quality assurance and training purposes, as well as for marketing and sales campaigns.

To manage the security of our sites, networks and systems

We may collect site use data for security and operations management to help keep our site, networks and systems secure, or to investigate and prevent potential fraud, including cyber-attacks.

To comply with applicable laws and regulations and to operate our business

In some cases, we have to process personal information to comply with applicable laws and regulations. For example, to respond to a request from a regulator or to defend a legal claim. We may also process personal information in the performance and operation of our business, such as to conduct internal audits and investigations or for finance and accounting and archiving and insurance purposes.

4. Use of Information

Sharing within Pacejet

Information about you may be shared throughout Pacejet’s organization.

Pacejet employees are authorized to access personal information only to the extent necessary to serve the applicable purpose(s) and to perform their job functions.

Sharing with third parties

We may share personal information with the following third parties for a business purpose:

• Third-party service providers (for example, carriers, order fulfilment, analytics, website management, information technology and related infrastructure provision, customer service, e-mail delivery, auditing, and other similar service providers) in order for those service providers to perform business functions on behalf of Pacejet;
• Relevant third parties in the event of a reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings);
• As required by law, such as to comply with a subpoena or other legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to government requests, including public and government authorities outside your country of residence, for national security and/or law enforcement purposes.

When third parties are given access to personal information, we will take appropriate contractual, technical and organizational measures designed to ensure that personal information is processed only to the extent that such processing is necessary, consistent with this Privacy Policy, and in accordance with applicable law.

In the event the third party which receives personal information is Amazon.com Inc, please note: Amazon.com, Inc. requires Pacejet to comply with its Data Protection Policy for Merchant Web Services related to the retention of personally identifiable information (PII). As such, data captured on Amazon orders only will be automatically overwritten by Pacejet. Through this process, PII will be destroyed and non-recoverable in adherence to Amazon guidelines.

5. Information Security

Pacejet takes appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of information. These include internal reviews of our information collection, storage and processing practices and security measures, including appropriate encryption and physical security measures to guard against unauthorized access to systems where personal information is stored. Pacejet restricts access to personal information to Pacejet employees, and agents as stated herein. These individuals are bound by confidentiality obligations and may be subject to discipline, termination or prosecution in the event they fail to meet their obligations.

6. Cookies and similar technology

Cookies and similar technologies (e.g., pixels tags and device identifiers) are used by Pacejet and our advertising technology partners to recognize you and/or your device(s) on, off and across different services and devices for the purposes specified in Section 5 above.

Pacejet also uses cookies or similar technologies on its sites to collect online information such as your mobile device ID, IP address, and other information about your device. Most browsers are initially set up to accept cookies, but you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, some Pacejet features and services may not function properly if your cookies are disabled.

7. Privacy Choices

We provide multiple choices in respect of the information we process about you:

• Opt-out of our use or sharing of your personal information

You may withdraw consent you have previously provided for the processing of information about you, including for email marketing by Pacejet. As described above, you can choose not to provide certain information, but then you might not be able to take advantage of some of the Pacejet services.

• Delete personal information

You can ask us to erase or delete all or some of the information about you.

• Change or correct personal information

You can edit some of the information about you by. You can also ask us to change, update or fix information about you in certain cases, particularly if it is inaccurate.

• Object to, or limit or restrict use of personal information

You can ask us to stop using all or some of the information about you (for example, if we have no legal right to keep using it) or to limit our use of it (for example, if the information about you is inaccurate).

• Right to access and/or have your information provided to you

Pursuant to the E.U. General Data Protection Regulation (GDPR), California Consumer Privacy Act (CCPA), and other applicable laws and regulations, individuals in the EU/EEA and other jurisdictions may have data subject rights enabling them to request to access, delete, correct, remove or limit the use, or receive a copy of their personal information in Pacejet’s possession or for which Pacejet is otherwise responsible. You can exercise these choices by contacting Pacejet’s Data Privacy Officer at DPO@3gtms.com.

8. Rights under the California Consumer Privacy Protection Act (CCPA)

If you are a California resident, you may request that we:

• disclose to you the following information covering the 12 months preceding your request:
  • the categories and specific pieces of personal information we collected about you and the categories of personal information we sold (see Section 1);
  • the categories of sources from which we collected such personal information (see Section 1);
  • the business or commercial purpose for collecting or selling personal information about you (see Section 3); and
  • the categories of third parties to whom we sold or otherwise disclosed personal information (see Section 4).
• delete personal information we collected from you (see Section 7); or
• opt-out of any future sale of personal information about you (see Section 7).

We will respond to your request consistent with applicable law. If you are a California resident, you may obtain information about exercising your rights, as described above, by contacting us at DPO@3gtms.com.

9. DISPUTE RESOLUTION OR FILING A COMPLAINT

If you have any complaints regarding our compliance with this Privacy Policy, please contact our Data Privacy Officer first at DPO@3gtms.com. We will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with this Privacy Policy and in accordance with applicable law. We will cooperate with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of personal information that cannot be resolved between Pacejet and an individual.