Last Updated: January 28, 2020
We take the privacy of our Customers and their downstream customers very seriously. We never share the information of our Customers’ customers under any circumstances, unless it is required to complete the transaction contracted with our Customer. In addition, we require our Customers, where applicable, to undertake to respect the European Union General Data Protection Regulation.
- Types of Information We Collect. In connection with access to our Services, we may collect Personal Information, such as your name, shipping/billing address, email address, phone, credit card/bank account number, username and password.We collect or otherwise receive information when you register or open an account, sign in, pay fees, purchase or otherwise use a Service, call us for support, or give us feedback. We may also obtain information from other companies or third parties, such as when you synchronize a third party account or service with your ShipWorks Account, or when we may use service providers to supplement the Personal Information you give us (e.g., validate your mailing address) to help us maintain the accuracy of your data and provide you with better service. We may collect content or other information that you may provide or create when you interact with our Services.We may automatically collect certain usage information when you access our Services (“Usage Data”), such as Internet Protocol (“IP”) addresses, log files, unique device identifiers, pages viewed, browser type, any links you click on to leave or interact with our Services, and other usage information collected from cookies and other tracking technologies. For example, we may collect IP addresses to track and aggregate retained in pseudonym form (replacing any directly identifying characteristics of personal information), to monitor the locations from which users navigate to our Services. We may also collect IP addresses from users when they log into the Services as part of our log-in and security features. We may also, when you enable location-based Services, collect Global Positioning System (GPS) location data and/or motion data.Our Services may change over time and we may introduce new features that may collect new or different types of information.
- How We Use Your Information. We may use your information, including your Personal Information, for the following purposes:Account Registration. We may use your name, address, phone number, billing information, and email address to register your account for certain Services we provide and to communicate important information to you. We may obtain additional Personal Information about you, such as address change information, from commercially available sources, to keep our records current. If you establish an administrator account that may be accessed by people other than you, please note that they may see and have the ability to change or delete your Personal Information. Please be careful to whom you grant administrator access to, as you are responsible for their actions.To Provide Our Services and Operate Our Business. We may use your information to operate our business, including providing Services you requested, provide you with support related to our Services, and to help us protect our Services, including to combat fraud and protect your information.Customer Service and Technical Support. We may use your name, address, phone number, email address, how you interact with our Services, and information about your computer configuration to resolve questions you may have about our Services and to follow up with you about your experience. We also offer various Internet chat services, for example, to speak with a ShipWorks customer support representative. Internet Chat transmissions are encrypted but you should not supply more Personal Information, than is required to address your specific issue. A transcript of the session may be retained to resolve questions or issues related to our Services.Communicate with You and Tell You About Other Services. We may use your information to communicate with you about our Services and to give you offers for third party products and services that we think may be of use to you. Please see below under “What You Can Do to Manage Your Privacy” for the choices you have regarding these communications.To Improve Services and Develop New Services. We will use your information to personalize or customize your experience and the Service, develop new features or services, and to improve the overall quality of ShipWorks’ Services.Feedback. We may use any information you volunteer in surveys you answer for us and combine them with answers from other customers in order to better understand our Services and how we may improve them. Answering any survey is optional.
- How We Share Your Personal Information. From time to time, we may need to share your Personal Information with others.Third Party Service Providers. We may share your information, including Personal Information and Usage Data, with third party service providers who perform various functions to enable us to provide our Services and help us operate our business, such as website design, sending email communications, telephone communication, SMS (text messaging), advertising, fraud detection and prevention, customer care, third party surveys or performing analytics. These companies are authorized to use your personal information only as necessary to provide these services to us. Our contracts with these third parties require them to maintain the confidentiality of the Personal Information we provide to them, only act on our behalf and under our instructions, and not use Personal Information for purposes other than the product or service they’re providing to us or on our behalf.United States Postal Service (USPS). ShipWorks is regulated by the USPS. As part of the regulatory relationship, ShipWorks collects certain information about you on behalf of the USPS. The USPS also may send us tracking data from their scans of your mail and packages in the mailstream. Our uses for the data include informing you about the status of your mail and packages through options like USPS Tracking, fraud detection and aggregating the data to help the USPS and us provide you better service. To learn more about USPS postage technology and ShipWorks’ relationship with the USPS, please visit the USPS Postage Solutions page. Information collected on behalf of USPS is used for the regulatory oversight function of USPS and is not used for other purposes.As part of ShipWorks providing services of the USPS, the USPS requires that you agree to the USPS Privacy Act Statement and to provide information about yourself that will be maintained in a Privacy Act System of Records by the Postal Service. Privacy Act Statement: Your information will be used to facilitate the purchase of USPS postage and fulfill transactional reporting requirements for USPS postage systems. Collection is authorized by 39 U.S.C. 401, 403, and 404. Providing the information is voluntary, but if not provided, your transaction may not be processed. The Postal Service does not disclose your information to third parties without your consent, except to facilitate the transaction, to act on your behalf or request, or as legally required. This includes the following limited circumstances: to a congressional office on your behalf; to financial entities regarding financial transaction issues; to a US Postal Service (USPS) auditor; to entities, including law enforcement, as required by law or in legal proceedings; and to contractors and other entities aiding us to fulfill the Service (service providers). For more information regarding our privacy policies, visit www.usps.com/privacypolicy.For more information regarding other specific carrier privacy policies, please see:
- UPS – https://www.ups.com/content/us/en/resources/ship/terms/privacy.html
- FedEx – https://www.fedex.com/us/security/index.html
- DHL ecommerce – http://www.dhl-usa.com/en/legal.html#privacy
- DHL Express – http://www.dhl.com/en/legal.html#privacy
- Syncing, Linking, Connecting Other Third Party Services with Your ShipWorks Service.We work with other companies or developers to offer you products and services and you may choose to sync, link or connect other third party services with your ShipWorks Service. Sometimes ShipWorks may let you know about the service or product, or another company may let you know about a ShipWorks service or product. If you choose to accept these services, providing your consent to either the third party or to us, we may exchange your information, including your Personal Information, as well as information about how you interact with each provider’s service or product. This exchange of information is necessary to maintain business operations and to provide the ongoing service that you have requested. By requesting or accepting these products or services, you are permitting us to provide your information, including your Personal Information, to the other party. Prior consent from European Union data subjects would be required prior to offering any information discussed in this section.
- Updating Your Personal Information. In connection with your right to manage your Personal Information you provide to us, you may access, update, change, correct or request deletion of your information either through the Service or through our customer support. You can reach our customer support by using the contact information provided in the “How to Contact Us” section of this Policy. We will respond to your request within a reasonable timeframe.
- Managing Marketing Communications From Us. We will honor your choices when it comes to receiving marketing communications from us.You have the following choices if you have been receiving marketing communications from us that you no longer wish to receive:
- You may contact ShipWorks at any time to request that your information not be shared with third parties (other than the USPS) or set preferences when you register with ShipWorks.
- Access the opt-out link in any email communication from ShipWorks or by clicking here.
- Remember that even if you choose not to receive marketing communications from us, we will continue to send you mandatory service or transactional communications.
- Cookies and Other Tracking Technologies. Generally we use these tracking technologies to:
- fulfill your requests for products and services, and improve our services.
- Remind us of who you are on return visits in order to deliver to you a better and more personalized service. This cookie is set when you first visit the ShipWorks Site.
- Estimate our audience size and measure traffic patterns regarding usage of ShipWorks’ network of Sites. Each browser accessing ShipWorks is given a unique cookie which is then used to determine the extent of repeat usage and usage by a registered user versus by an unregistered user.
- Track the number of entries in our promotions.
- Customize the advertising and content you see.
- Do Not Track. Our Services are not currently configured to respond to browsers’ “Do Not Track.” signals because at this time no formal “Do Not Track.” standard has been adopted. However, the practices of our partners and other third-party providers may change as a result of this feature being utilized. Click here for more information on “Do Not Track.”
- DATA RETENTION AND YOUR ACCESS RIGHTS
- Data Retention. In accordance with and as permitted by applicable law and regulations, we will retain your information as long as necessary to serve you, to maintain your account for as long as your account is active, or as otherwise needed to operate our business. When you close your account, we may continue to communicate with you about our Services, give you important business updates that may affect you, and let you know about products and services that may interest you, unless you have opted out of receiving marketing communications. We may also continue to use some of your information for business purposes and to improve our offerings or in some cases to develop new ones. We will retain and use your information as required by applicable regulations and ShipWorks’ records and information management policies to comply with our legal and reporting obligations, resolve disputes, enforce our agreements, complete any outstanding transactions and for the detection and prevention of fraud.
- Your Access Rights. Upon request and as required by applicable law, you may contact ShipWorks to confirm whether we maintain, or process on behalf of a third party, and of your Personal Information and to review it in order to verify its accuracy and the lawfulness of our processing of such Personal Information. Where you have determined that the Personal Information we collected about you is inaccurate or processed in violation of applicable law you may also request that your Personal Information be corrected, amended, or deleted. Requests for access to your Personal Information and to have it corrected, amended, or deleted should be sent to [email protected] or to the mailing address provided under “How to Contact Us.”EU data subjects have certain rights to access Personal Information about them, and to limit use and disclosure of their Personal Information. With our Privacy Shield certification (discussed below in Section 7), ShipWorks has committed to respect those rights. If you wish to request access, to limit use, or to limit disclosure, please contact us at [email protected] or the mailing address provided under “How to Contact Us” and please provide the name of the ShipWorks customer who submitted your Personal Information to our services.
- SECURITY OF YOUR INFORMATION. Keeping your Information safe is important to us. You can find out more about keeping your personal information safe while online from the U.S. government here. We provide reasonable and appropriate security measures in connection with securing Personal Information we collect. Though no method of transmission over the Internet, or method of electronic storage, is 100% secure.For example, we:
- Consistently work to update our security practices to implement accepted best methods to protect your Personal Information, and review our security procedures carefully.
- Comply with applicable laws and security standards.
- Securely transmit your sensitive Personal Information.
- Train our staff and require them to safeguard your data. Limit the staff with access to your Personal Information.
- Transmit, store, protect, and access all cardholder information in compliance with the Payment Card Industry’s Data Security Standards.
- INTERNATIONAL DATA TRANSFERS. In accordance with and as permitted by applicable law and regulations, we reserve the right to transfer your information, process and store it outside your country of residence to wherever we or our third party service providers operate. At this time United States person’s data shall be stored and kept within the United States. European Union data subjects may have their data stored in the European Union or the United States, and such data may be transferred to the United States to allow for completion of the Services required. All data stored and transferred would be done so subject to the E.U. – U.S. Privacy Shield Framework.
- E.U.-U.S. PRIVACY SHIELD. ShipWorks complies with the E.U. – U.S. Privacy Shield Framework.ShipWorks and its affiliates participate in and have certified their compliance with the E.U. – U.S. Privacy Shield Framework. ShipWorks is committed to subjecting all personal data, including Personal Information, received in the U.S. from European Union (EU) member countries, in reliance on the E.U. – U.S. Privacy Shield Framework, to the Framework’s applicable Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability (“European Personal Data”). To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List by clicking here.Under the E.U. – U.S. Privacy Shield Framework, ShipWorks collects, uses, and discloses EU Personal Data for the purposes described in the Privacy Statement. The choices and means that we offer for limiting use and disclosure of EU Personal Data are described above in Section 3, and we provide access as described in Section 4. ShipWorks is responsible for the processing of EU Personal Data that it transfers to a third party acting as an agent on its behalf. We remain liable in accordance with the Privacy Shield Principles if third-party agents that we engage to process such personal data on our behalf do so in a manner inconsistent with the Privacy Shield Principles, unless we prove that we are not responsible for the event giving rise to the damage.With respect to European Personal Data received or transferred pursuant to the Privacy Shield Framework, ShipWorks is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, ShipWorks may be required to disclose European Personal Data in response to lawful requests by public authorities, including meeting national security or law enforcement requirements.If you are a European data subject and have an unresolved privacy or data use concern, you can contact our Data Protection Officer at [email protected] or you can contact us as specified below in “How to Contact Us.” If you have any concerns that we have not addressed satisfactorily, you may also contact our U.S.‑based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.Under certain conditions, more fully described on the Privacy Shield website, if you are a European Union Data Subject, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
- COLLECTION AND USE OF CHILDREN’S PERSONAL INFORMATION. We do not knowingly collect information from minors.ShipWorks Services are intended for and directed to adults. Our Services are not directed to minors and we do not knowingly collect Personal Information from minors.
- YOUR CALIFORNIA PRIVACY RIGHTS.We do not share your Personal Information with third parties for their marketing purposes, if you have opted out of such information sharing.
Updated: January 28, 2020
Information We Collect
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:
|A. Identifiers.||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.||YES|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||A name, signature, address, telephone number, insurance policy number, bank account number, credit card number, debit card number, or any other financial information. Some personal information included in this category may overlap with other categories.||YES|
|C. Protected classification characteristics under California or federal law.||Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).||NO|
|D. Commercial information.||Records products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||YES|
|E. Biometric information.||Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.||NO|
|F. Internet or other similar network activity.||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.||YES|
|G. Geolocation data.||Physical location or movements.||YES|
|H. Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.||NO|
|I. Professional or employment-related information.||Current or past job history or performance evaluations.||N/A|
|J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).||Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.||NO|
|K. Inferences drawn from other personal information.||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||NO|
Personal information does not include:
- Publicly available information from government records.
- De-identified or aggregated consumer information.
- Information excluded from the CCPA’s scope, like:
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
We obtain the categories of personal information listed above from the following categories of sources:
- Directly from our customers or our partners. For example, from information customers provide to us or through our third party partners, related to the services for which they engage us.
- Directly and indirectly from activity on our website (www.shipworks.com), application, and/or webclient, as applicable. For example, from submissions through our website portal or website usage details collected automatically.
- From third parties that interact with us in connection with the services we perform.
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following business purposes:
- To fulfill or meet the reason for which the information is provided. For example, if you provide us with personal information in order for us to prepare a shipping label, we will use that information to prepare the label.
- To provide you with information, products or services that you request from us.
- To provide you with email alerts and other notices concerning our products or services, or events or news, that may be of interest to you.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
- To improve our website and present its contents to you.
- For testing, research, analysis and product development.
- As necessary or appropriate to protect the rights of our clients or others.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to you when collecting your personal information or as otherwise set forth in the CCPA.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information
We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
|Category B:||California Customer Records personal information categories.|
|Category D:||Commercial Information.|
|Category F:||Internet or other similar network activity|
|Category G:||Geolocation data.|
We disclose your personal information for a business purpose to the following categories of third parties:
- Our affiliates.
- Service providers.
- Third-party partners in connection with products or services we provide to you.
To improve our services, we have provided limited identifiers (including name and postal address) and limited commercial information to our parent company. The actions taken by us may be considered a “sale“ under the CCPA, but we received no monies for providing said information.
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you (also called a data portability
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
Only you or a person having the legal authority to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
- If you are a current customer of Company, you must log into your account and process any request through the application and/or webclient, as applicable.
We may be unable to respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Changes to Our Privacy Addendum
We reserve the right to amend this privacy addendum at our discretion and at any time. When we make changes to this privacy addendum, we will notify you by email or through a addendum on our website homepage.
If you have any questions or comments about this addendum, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
Email: [email protected]
One Memorial Drive, Suite 2000
St. Louis, MO 63102
Updated: January 28, 2020
If you are a resident of Nevada, you have the right to request certain information from us regarding the collection and sale of your personal information (as defined in Nevada Revised Statutes 603A.320) during your visit to our websites or when you otherwise interact with us online. If you have sought or acquired, by purchase or lease, any goods or services for personal, family, or household purposes from our us, you may ask us to disclose whether we have sold (for monetary consideration) certain information about you (including your first and last name, physical address, email address, telephone number, social security number, an identifier that allows you to be contacted either physically or online, or other contact information that allows us to identify you personally).
As a Nevada resident, you may also request to opt out of us sharing such information about you. To make this inquiry, please submit a request in writing to [email protected] with “Nevada Privacy Rights” in the subject line. You must include your full name, email address, account number and attest that you are a Nevada resident by providing a Nevada postal address in your request. Please state whether you are requesting information and/or opting out. We will respond to your request within 60 days or let you know if we need additional time. We may require additional information to verify your identity before we can respond.