LAST UPDATED: February 28, 2024
I. INTRODUCTION
This Privacy Policy (this “Policy”) covers any personal information ITS Holdings, LLC and its subsidiaries, parent companies, and affiliates, including but not limited to ITS National LLC and ITS Logistics, LLC (collectively, “ITS”, “us”, “we”, or “our”) obtains when you use our website located at https://www.its4logistics.com/(the “Website”), products or services offered by us on or through our Website, and any of our mobile applications (each, an “App”) (collectively, our “Services”). This Policy describes how we collect and use your information when you visit our Website or interact with our Services. We collect and use your personal information as described in this Policy.
PLEASE READ THIS POLICY CAREFULLY TO UNDERSTAND HOW WE HANDLE YOUR PERSONAL INFORMATION. IF YOU DO NOT AGREE TO THIS POLICY, PLEASE DO NOT ACCESS OR USE OUR WEBSITE.
II. CATEGORIES AND SOURCES OF INFORMATION WE COLLECT
The types of personal information ITS may collect from you and that we have collected from users over the last 12 months includes:
- Personal identifiers such as real name, postal address, email address, telephone number, unique personal identifier, online identifier, Internet Protocol address, driver's license number, or other similar identifiers.
- Biographical information such as name, age, gender, and date of birth.
- Professional information such as commercial skills, job title, and/or standing within a business.
- User-generated content such as posts and other content submitted to the Website.
- Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) such as insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information.
- Commercial information such as products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
- Internet or other similar network activity, such as browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.
- Any other personal information voluntarily provided to ITS.
ITS may also collect from you and has collected from users over the last 12 months the following types of sensitive personal information:
- User geolocation only through use of our mobile app.
- Account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account.
INFORMATION COLLECTED AUTOMATICALLY
Web Browser Cookies
We collect information about how you use our Website by setting and accessing cookies on your computer. The use of cookies allows us to personalize or enhance your experience and to gather statistical data, such as which pages are visited, the Internet provider’s domain name and the addresses of the sites visited immediately before coming to and immediately after leaving our Websites. We may link the anonymous visitor ID from your cookie to a user ID in our database to help us analyze web traffic and statistics. You may disable cookies on your browser. Please review your browser’s instructions for doing so. Note that certain features of the Website may not be available if you delete or reject cookies.
Pixel Tags
We may use pixel tags (also called web beacons or clear gifs) on our Website or in our emails. They can help us analyze what our customers like to do on our Website and the effectiveness of our features and advertising or whether you click or open the emails we send to you. They can also help us customize your browsing experience. We may use information collected through pixel tags or tracked links in combination with your personal information. We may also combine personal information you provide to ITS with other personal information (such as purchase history and demographic information). If we work with other companies to help us track, collect and analyze this information, they will be prohibited from using this information for any other purpose.
INTEREST-BASED ADVERTISEMENTS
Some of the advertisements presented on our Websites and Apps are provided by third-parties based on the activity of your browser or app. The information, which may contain personal information, may be provided to ITS by you or it may be derived by our advertising service providers from your browser’s activity over time and across non-related websites or apps. Such tracking can be accomplished with targeting cookies and/or pixels/web beacons. More information on interest-based advertising is available at the following Network Advertising Initiative link: https://thenai.org/about-online-advertising/.
INFORMATION FROM THIRD PARTIES
We may obtain information about you from a third-party such as demographic companies, analytics providers, advertising companies and networks, third-party retailers, and other third parties that we choose to collaborate or work with.
III. PURPOSE FOR COLLECTING PERSONAL INFORMATION
Your personal information is collected for specified, legitimate purposes and not processed further in ways incompatible with those purposes. Collected personal data is relevant to and not excessive for the purposes for which they are collected and used. We may collect your personal information when you:
- visit our Website;
- utilize our Services;
- download or use any of our Apps;
- communicate with us regarding our products and Services;
- complete a survey; and/or
- fill out a form.
ITS uses your personal information for the following purposes:
- To provide our Services to you, such as fulfilling orders and processing payments, creating, servicing and/or maintaining your accounts with us, and managing current or past subscriptions for Services.
- To communicate with you, including to respond to your inquiries or complaints, and to help you when you have questions.
- For marketing and advertising, such as to send you marketing and advertising materials via postal mail or email, and to show you advertisements for products and/or services tailored to your interests on social media and other websites.
- For analytics purposes, such as to understand how you use our Services, understand your preferences; determine what browser and devices you use to visit the Website; and to evaluate and improve our Services.
- To operate and improve our business, including to provide quality assurance, conduct research and development to develop new services and products, and perform accounting, auditing and other internal business functions.
- For legal and security purposes, such as to detect, prevent, and prosecute harmful, fraudulent, or illegal activity, loss prevention, identify and repair bugs on the Services, and to comply with applicable legal requirements, relevant industry standards and our policies.
- To process payments for contractors and employees, and to report payments to appropriate taxing authorities or as otherwise required by law.
We also may use or may have used the information in other ways for which we provide specific notice at the time of collection. We may also use aggregated personal information for the purpose of understanding how our users as a group use the Services and resources we provide.
IV. PERSONAL INFORMATION SOLD OR SHARED
We may “sell” or “share” personal information for the purpose of cross-context behavioral advertising, or use for targeted advertising. ITS has no actual knowledge of selling or sharing the personal information of individuals under the age of 16. To opt out of the selling or sharing of personal information, please see the “Methods of Exercising Data Subject Rights” section below.
V. STATEMENT OF SENSITIVE PERSONAL INFORMATION DISCLOSURES
ITS uses or discloses sensitive personal information for the following purposes:
(1) to perform the services or provide the goods reasonably expected by an average consumer who requests those good or services;
(2) to prevent, detect, and investigate security incidents;
(3) to resist and prosecute malicious, deceptive, fraudulent, or illegal actions;
(4) to ensure the physical safety of natural persons;
(5) to perform services on behalf of ITS; and/or
(6) to collect or process sensitive personal information where the collection or processing is not for the purpose of inferring characteristics about a consumer.
VI. DATA SUBJECT RIGHTS
- Right to Know What Personal Information is Being Collected (Right to Access): You have the right to request the following information:
- The categories of personal information collected about you.
- The categories of sources from which the personal information is collected.
- The business or commercial purpose for collecting, selling, or sharing your personal information.
- The categories of third parties to whom ITS discloses your personal information.
- The specific pieces of personal information we have collected about you.
- Right to Delete Personal Information: You have the right to request that ITS delete any personal information about you that ITS has collected from you.
- Right to Correct Inaccurate Personal Information: You have the right to request that ITS correct your inaccurate personal information if we maintain inaccurate personal information about you.
- Right to Know What Personal Information is Sold or Shared and to Whom: You have the right, if ITS sells, shares your information, to request that ITS disclose to you the following:
- The categories of personal information that ITS collected from you.
- The categories of personal information that ITS sold or shared about you and the categories of personal information for each category of third parties to whom the personal information was sold or shared.
- The categories of personal information that ITS disclosed about you for a business purpose and the categories of persons to whom it was disclosed for a business purpose.
- Right to Opt Out of Sale or Sharing of Personal Information: You have the right to direct ITS, if we sell or share your personal information to third parties, not to sell or share your personal information.
- Right to Limit Use and Disclosure of Sensitive Personal Information: You have the right to direct ITS to limit the use of your sensitive personal information to the use which is necessary to perform the Services.
- Right of No Retaliation Following Opt Out or Exercise of Other Rights: ITS may not discriminate against you if you exercise any of your rights as described above.
- Right to Data Portability: You have the right to obtain your personal information in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance.
VII. METHODS FOR EXERCISING DATA SUBJECT RIGHTS
You can submit a request to exercise on or more of your data subject rights stated above using the following methods:
- Via email to: legal@its4logistics.com
- Via phone at: 775-227-7705
After we receive your request, we will determine if the request is a verifiable customer request before acting on the request. You must provide enough information for us to be able to verify that it is the proper person making the request. We have 45 days in which to take action on your request. If we run into issues in honoring your request, we will notify you within those 45 days. The original 45-day period may be extended by 45 days if reasonably necessary. We will inform you, without delay, of the reasons, if we decide not to take action on your request. We will also inform you if you have rights to appeal our decision.
If you use an authorized agent to submit a request and the authorized agent does not provide a proper power of attorney, we may require you to either (1) verify your identity directly with us, or (2) directly confirm with us that you provided the authorized agent permission to submit the request.
VIII. OPT-OUT PREFERENCE SIGNAL
At this time, the Website does not respond to “do not track” signals. However, you can usually choose to set your browser to remove or reject browser cookies before using our Website, with the drawback that certain features of the Website may not function properly without the aid of cookies.
IX. DATA SECURITY
We apply commercially reasonable and appropriate administrative, technical, and physical safeguards to protect the confidentiality, integrity, and availability of your personal information. Such safeguards protect against unauthorized access, alteration, disclosure, unlawful processing and accidental loss, destruction, or damage of your personal information. Although these safeguards reduce the risk of adverse effects to the confidentiality, integrity, and availability of your personal information, they cannot ensure or guarantee against the possibility of a security incident.
We use a third-party payment processing systems that comply with the Payment Card Industry Data Security Standard (PCI-DSS), which is an industry wide security standard designed to protect the confidentiality and security of your credit card information, by encryption using secure socket layer technology (SSL) and storage with AES-256 encryption.
X. DATA RETENTION
ITS retains your personal information for as long as you have an open account or as necessary to provide you Services. Legal obligations or rights may require us to keep data even after you close your account.
XI. CHILDREN’S PRIVACY AND AGE-RELATED INFORMATION COLLECTION POLICIES
We do not knowingly collect or allow the collection of personal information with our Website or Services from users under the age of 16. If we have actual knowledge that we have collected personal information from someone under the age of 16 we will delete that personal information. If you believe that we have collected information from a person under the age of 16, please contact us at legal@its4logistics.com.
XII. DATA SUBPROCESSORS
We may contract with third-party service providers as data subprocessors to collect or process your personal information under our instruction. Service providers can perform many processing activities including but not limited to helping us operate our business and the Services or administer activities on our behalf, such as onboarding and vetting motor carriers.
XIII. INTERNATIONAL ACCESS TO OUR SERVICES
Our Services are available in the United States of America and on a limited basis in Canada and Mexico.
XIV. LINKS TO THIRD PARTY WEBSITES
Our Website and Services may contain links to third-party websites, services, or resources that are not covered under this Policy, our terms and conditions, or our terms of use. Upon visiting or using those third-party websites, services, or resources, we recommend that you review their privacy policy, terms and conditions, and terms of use before providing your personal information.
XV. TRANSFER OF CORPORATE ASSETS
If ITS is acquired by or merged with a third-party entity, ITS reserves the right to transfer or assign the personal information you provided to us as part of such merger, acquisition, sale, or other change of control to the new entity. In the event of bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditor’s rights generally, we may not be able to control how your personal information is processed. In such a situation arises, ITS would request that all applicable privacy laws and protection standards at least as stringent as ITS’s be applied to your personal information originally in our possession. In the event of a transfer of corporate assets, the information regarding the transfer will be posted on our Website.
XVI. CHANGES TO THIS PRIVACY POLICY
We reserve the right to update this Policy to accurately disclose changes as necessitated by applicable laws and other events. If those changes are material in nature, we will notify you by a notice placed on our public facing Website, a notification within our Services, and/or by electronic mail.
XVII. CONTACT US
If you have any questions or suggestions regarding our Privacy Policy please contact us by mail to ITS Holdings, LLC, 50 West Liberty Street, Suite 401, Reno, Nevada 89501 and by email to legal@its4logistics.com.