21 July 2021
PERSONAL INFORMATION USAGE
We gather various types of Personal Information from our users, as explained in more detail below, and we use this Personal Information internally in connection with our Services, including to personalize, provide, and improve our services, to allow you to set up a user account and profile, to contact you and allow other users to contact you, to fulfill your requests for certain products and services, and to analyze how you use the Services. In certain cases, we may also share some Personal Information with third parties, but only as described below.
PART I - INFORMATION COLLECTION
INFORMATION PROVIDED BY YOU
- Testimonials - When you authorize us to post testimonials about our products and services on websites, we may include your name and other personal information in the testimonial. You will be given an opportunity to review and approve the testimonial before we post it. If you wish to update or delete your testimonial, you can contact us at firstname.lastname@example.org.
- Payment Processing - When you buy something from us, we ask you to provide your name, contact information, and credit card information or other payment account information. If you submit your card information, we store the name and address of the cardholder, the expiry date and the last four digits of the credit card number. We do not store the actual credit card number. For quick processing of future payments, if you have given us your approval, we may store your credit card information or other payment information in an encrypted format in the secured servers of our Payment Gateway Service Providers.
- Event Registration and other form submissions - We record information that you submit when you (i) register for any event, including webinars or seminars, (ii) subscribe to our newsletter or any other mailing list, (iii) submit a form in order to download any product, white paper, or other materials, (iv) participate in contests or respond to surveys, or (v) submit a form to request customer support or to contact CARRIYO for any other purpose.
- Interactions with CARRIYO - We may record, analyze and use your interactions with us, including email, telephone, and chat conversations with our sales and customer support professionals, for improving our interactions with you and other customers.
INFORMATION COLLECTED AUTOMATICALLY
- Information from browsers, devices and servers - When you visit our websites and mobile applications, we collect information that web browsers, mobile devices and servers make available, such as the internet protocol address, browser type, language preference, time zone, referring URL, date and time of access, operating system, mobile device manufacturer and mobile network information. We include these in our log files to understand more about visitors to our websites.
- Information from application logs and mobile analytics - We collect information about your use of our products, services and mobile applications from application logs and usage analytics tools and use it to understand how your business use and needs can improve our products. This information includes clicks, scrolls, features accessed, access time and frequency, errors generated, performance data, storage utilized, user settings and configurations, and devices used to access and their locations.
INFORMATION COLLECTED BY THIRD PARTIES
- Referrals - If someone has referred any of our products or services to you through any of our referral programs, that person may have provided us your name, email address and other personal information. You may contact us at email@example.com to request that we remove your information from our database. If you provide us information about another person, or if another person gives us your information, we will only use that information for the specific reason for which it was provided to us.
- Payment Processing - If you contact any of our reselling partners, or otherwise express interest in any of our products or services to them, the reselling partner may pass your name, email address, company name and other information to CARRIYO. If you register for or attend an event that is sponsored by CARRIYO, the event organizer may share your information with us. CARRIYO may also receive information about you from review sites if you comment on any review of our products and services, and from other third-party service providers that we engage for marketing our products and services.
EVENT REGISTRATIONS AND FORM SUBMISSIONS
When you interact or engage with us on social media sites such as Facebook, Twitter, LinkedIn and Instagram through posts, comments, questions and other interactions, we may collect such publicly available information, including profile information, to allow us to connect with you, improve our products, or better understand user reactions and issues. We must tell you that once collected, this information may remain with us even if you delete it from the social media sites. CARRIYO may also add and update information about you, from other publicly available sources.
PURPOSES FOR USING INFORMATION
In addition to the purposes mentioned above, we may use your information for the following purposes:
- To keep you posted on new products and services, upcoming events, offers, promotions and other information that we think will be of interest to you;
- To ask you to participate in surveys, or to solicit feedback on our products and services;
- To set up and maintain your account, and to do all other things required for providing our services, such as enabling collaboration, providing website and mail hosting, and backing up and restoring your data;
- To understand how users use our products and services, to monitor and prevent problems, and to improve our products and services;
- To provide customer support, and to analyze and improve our interactions with customers;
- To detect and prevent fraudulent transactions and other illegal activities, to report spam, and to protect the rights and interests of CARRIYO, CARRIYO’s users, third parties and the public;
- To update, expand and analyze our records, identify new customers, and provide products and services that may be of interest to you;
- To analyze trends, administer our websites, and track visitor navigations on our websites to understand what visitors are looking for and to better help them;
- To monitor and improve marketing campaigns and make suggestions relevant to the user.
LEGAL BASIS FOR COLLECTING AND USING INFORMATION
- Legal processing bases applicable to CARRIYO - If you are an individual from the European Economic Area (EEA), our legal basis for information collection and use depends on the personal information concerned and the context in which we collect it. Most of our information collection and processing activities are typically based on (i) contractual necessity, (ii) one or more legitimate interests of CARRIYO or a third party that are not overridden by your data protection interests, or (iii) your consent. Sometimes, we may be legally required to collect your information, or may need your personal information to protect your vital interests or those of another person.
- Withdrawal of consent - Where we rely on your consent as the legal basis, you have the right to withdraw your consent at any time, but this will not affect any processing that has already taken place.
- Legitimate interests notice - Where we rely on legitimate interests as the legal basis and those legitimate interests are not specified above, we will clearly explain to you what those legitimate interests are at the time that we collect your information.
YOUR CHOICE IN INFORMATION USE
- Opt out of non-essential electronic communications - You may opt out of receiving newsletters and other non-essential messages by using the ‘unsubscribe’ function included in all such messages. However, you will continue to receive notices and essential transactional emails.
- Disable cookies - You can disable browser cookies before visiting our websites. However, if you do so, you may not be able to use certain features of the websites properly.
- Optional information - You can choose not to provide optional profile information such as your photo. You can also delete or change your optional profile information. You can always choose not to fill in non-mandatory fields when you submit any form linked to our websites.
SHARING OF PERSONAL INFORMATION
CARRIYO does not rent or sell Personal Information in personally identifiable form to anyone, provided certain Personal Information may be transferred in connection with business transfers, as described below. This section describes under which circumstances Personal Information may be shared with third parties:
- Third-party service providers - We may need to share your personal information and aggregated or de-identified information with third-party service providers that we engage, such as marketing and advertising partners, event organizers, web analytics providers and payment processors. These service providers are authorized to use your personal information only as necessary to provide these services to us.
- Domain or Telecommunication registrars - When you register a domain or Sender ID through CARRIYO from domain name registrars, we share your name and contact information such as your physical address, email address and phone number with them as per the regionally applicable registration rules.
- Reselling partners - We may share your personal information with our authorized reselling partners in your region, solely for the purpose of contacting you about products that you have downloaded or services that you have signed up for. We will give you an option to opt out of continuing to work with that partner.
- Other cases - Other scenarios in which we may share the same information covered under Parts I and II are described in Part III.
YOUR RIGHTS WITH RESPECT TO INFORMATION WE HOLD ABOUT YOU AS A CONTROLLER
If you are in the European Economic Area (EEA), you have the following rights with respect to information that CARRIYO holds about you. CARRIYO undertakes to provide you the same rights no matter where you choose to live.
- Right to access: You have the right to access (and obtain a copy of, if required) the categories of personal information that we hold about you, including the information's source, purpose and period of processing, and the persons to whom the information is shared.
- Right to rectification: You have the right to update the information we hold about you or to rectify any inaccuracies. Based on the purpose for which we use your information, you can instruct us to add supplemental information about you in our database.
- Right to erasure: You have the right to request that we delete your personal information in certain circumstances, such as when it is no longer necessary for the purpose for which it was originally collected.
- Right to restriction of processing: You may also have the right to request to restrict the use of your information in certain circumstances, such as when you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Right to data portability: You have the right to transfer your information to a third party in a structured, commonly used and machine-readable format, in circumstances where the information is processed with your consent or by automated means.
- Right to object: You have the right to object to the use of your information in certain circumstances, such as the use of your personal information for direct marketing.
- Right to complain: You have the right to complain to the appropriate supervisory authority if you have any grievance against the way we collect, use or share your information. This right may not be available to you if there is no supervisory authority dealing with data protection in your country.
RETENTION OF INFORMATION
We use all appropriate technical, organizational and administrative security measures to protect any information we hold in our records from loss, misuse, and unauthorized access, disclosure, alteration and destruction. Unfortunately, no company or service can guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.
Among other practices, your account is protected by a password for your privacy and security. If you access your account via a third-party site or service, you may have additional or different sign-on protections via that third-party site or service. You must prevent unauthorized access to your account and Personal Information by selecting and protecting your password and/or other sign-on mechanism appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account.
PART II - INFORMATION PROCESSING
INFORMATION ENTRUSTED TO CARRIYO AND ITS PURPOSE
- Information provided in connection with services: You may entrust information that you or your organization (“you”) control, to CARRIYO in connection with use of our services or for requesting technical support for our products. This includes information regarding your customers and your employees (if you are a controller) or data that you hold and use on behalf of another person for a specific purpose, such as a customer to whom you provide services (if you are a processor). The data may either be stored on our servers when you use our services, or transferred or shared to us as part of a request for technical support or other services.
- Information from mobile devices: When you elect to allow it, some of our mobile applications have access to the camera, call history, contact information, photo library, and other information stored on your mobile device. Our applications require such access to provide their services. Similarly, when you elect to provide access, location-based information is also collected for purposes including, but not limited to, locating nearby contacts or setting location-based reminders. This information will be exclusively shared with our mapping providers and will be used only for mapping user locations. You may disable the mobile applications' access to this information at any time by editing the settings on your mobile device. The data stored on your mobile device and their location information to which the mobile applications have access will be used in the context of the mobile application, and transferred to and associated with your account in the corresponding services (in which case the data will be stored on our servers) or products (in which case the data will remain with you unless you share it with us).
(All the information entrusted to CARRIYO is collectively termed “service data”)
OWNERSHIP AND CONTROL OF YOUR SERVICE DATA
We recognize that you own your service data. We provide you complete control of your service data by providing you the ability to (i) access your service data, (ii) share your service data through supported third-party integrations, and (iii) request export or deletion of your service data.
HOW WE USE SERVICE DATA
We process your service data when you provide us instructions through the various modules of our services. For example, when you create a shipment record, information such as the name and address of the recipient will be used to book the shipment with a third party carrier company and generate a shipping label; and when you use our messaging service for email notifications, the email addresses of the recipient of a shipment will be used for sending the emails.
If you have enabled notification on our desktop and mobile applications, we will push notifications through a push notification provider such as Apple Push Notification Service, Google Cloud Messaging or Windows Push Notification Services. You can manage your push notification preferences or deactivate these notifications by turning off notifications in the application or device settings.
WHO WE SHARE SERVICE DATA WITH
- CARRIYO and third-party sub-processors: In order to provide services and technical support for our products, CARRIYO engages other third parties.
- Employees and independent contractors: We may provide access to your service data to our employees and individuals who are independent contractors of the CARRIYO involved in providing the services (collectively our “employees”) so that they can (i) identify, analyze and resolve errors, (ii) manually verify transactional records to troubleshoot issues, or (iii) manually verify emails or any content that you have provided during the usage of the Services. We ensure that access by our employees to your service data is restricted to specific individuals and is logged and audited. Our employees will also have access to data that you knowingly share with us for technical support or to import data into our products or services. We communicate our privacy and security guidelines to our employees and strictly enforce privacy safeguards within CARRIYO.
- Collaborators and other users: Some of our products or services allow you to collaborate with other users or third parties. Initiating collaboration may enable other collaborators to view some or all of your profile information. For example, when you edit a document that you have shared with other persons for collaboration, your name and profile picture will be displayed next to your edits to allow your collaborators to know that you made those edits.
- Third-party integrations you have enabled: Some of our products and services support integrations with third-party products and services. If you choose to enable any third-party integrations, you may be allowing the third party to access your service information and personal information about you. We encourage you to review the privacy practices of the third-party services and products before you enable integrations with them.
- Other cases: Other scenarios in which we may share information that are common to information covered under Parts I and II are described in Part III.
RETENTION OF INFORMATION
We hold the data in your account as long as you choose to use CARRIYO Services. Once you terminate your CARRIYO account, your data will eventually get deleted from active database according to our Terms of Service.
DATA SUBJECT REQUESTS
If you are from the European Economic Area and you believe that we store, use or process your information on behalf of one of our customers, please contact the customer if you would like to access, rectify, erase, restrict or object to processing, or export your personal data. We will extend our support to our customer in responding to your request within a reasonable timeframe.
PART III - GENERAL
We do not knowingly collect or solicit personal information from anyone under the age of 16. If you are under 16, please do not attempt to register for the Services or send any personal information about yourself to us. If we learn that we have collected personal information from a child under age 16, we will delete that information as quickly as possible. If you believe that a child under 16 may have provided us personal information, please contact us at firstname.lastname@example.org.
OWNER AND DATA CONTROLLER
Entity: CARRIYO FZ-LLC, In5Tech, Dubai, United Arab Emirates
Data Protection officer: João Vieira
Owner contact email: email@example.com
LOCATIONS AND INTERNATIONAL TRANSFERS
By accessing or using our products and services or otherwise providing personal information or service data to us, you consent to the processing, transfer, and storage of your personal information or Service Data within the countries where CARRIYO operates. Such transfer is subject to a group company agreement that is based on EU Commission’s Model Contractual Clauses.
DO NOT TRACK (DNT) REQUESTS
Some internet browsers have enabled 'Do Not Track' (DNT) features, which send out a signal (called the DNT signal) to the websites that you visit indicating that you don't wish to be tracked. Currently, there is no standard that governs what websites can or should do when they receive these signals. For now, we do not take action in response to these signals.
EXTERNAL LINKS ON OUR WEBSITES
DISCLOSURES IN COMPLIANCE WITH LEGAL OBLIGATIONS
We may be required by law to preserve or disclose your personal information and service data to comply with any applicable law, regulation, legal process or governmental request, including to meet national security requirements.
ENFORCEMENT OF OUR RIGHTS
We may disclose personal information and service data to a third party if we believe that such disclosure is necessary for preventing fraud, investigating any suspected illegal activity, enforcing our agreements or policies, or protecting the safety of our users.
We do not intend to sell our business. However, in the unlikely event that we sell our business or get acquired or merged, we will ensure that the acquiring entity is legally bound to honor our commitments to you. We will notify you via email or through a prominent notice on our website of any change in ownership or in the uses of your personal information and service data. We will also notify you about any choices you may have regarding your personal information and service data.