(a) Valuing your privacy and safeguarding your personal data.
At SIO, we respect your privacy and adhere to applicable data protection and privacy laws and relevant e-commerce laws globally. We strive to consistently exceed our clients’ expectations regarding the products and services that we offer to our contract logistics and freight management customers. We create experiences that our customers value by responsibly using information with which you entrusted us.
This Privacy Notice describes the way we treat all the personal data you provide or that we have obtained through our Websites and Applications.
(b) Applicability and links to other third party applications and/or websites
This Privacy Notice applies to all visitors and anyone who accesses or uses our products and services of websites.
SIO Websites and Applications may contain links to and from the applications and/or websites of our partner networks, advertisers, third parties and affiliates. They are merely for informational purposes. If you follow a link to any of these applications and/or websites, please bear in mind that they have their own privacy policies and that we assume no responsibility or liability arising whatsoever nor endorse any practices from their policies.
BY ACCESSING SIO WEBSITES AND APPLICATIONS AND ACCEPTING THE STATEMENT WITH THE LINK OK, I AGREE AND CONTINUING TO ACCESS THE CEVA WEBSITES AND APPLICATIONS, YOU ACCEPT THE TERMS AND THE PROCESSING OF PERSONAL DATA DESCRIBED IN THE PRIVACY NOTICE. IF YOU DO NOT AGREE, PLEASE REFRAIN FROM ACCESSING CEVA WEBSITES AND APPLICATIONS.
YOU MAY WITHDRAW YOUR CONSENT AT ANY TIME. WE WILL THEN REFRAIN FROM FURTHER PROCESSING YOUR PERSONAL DATA, EXCEPT TO THE EXTENT THE PROCESSING OF YOUR PERSONAL DATA IS LAWFUL FOR OTHER REASONS EVEN WITHOUT YOUR CONSENT, SUCH AS LAWFUL PURPOSES AS FULFILLING THE CONTRACTUAL OBLIGATIONS OR COMPLIANCE WITH LAW OR TO PROTECT OUR OR THIRD PARTIES LEGITIMATE INTERESTS (SUCH AS THE UNINTERRUPTED AVAILABILITY OF OUR WEBSITE OR ENFORCEMENT OF VIOLATIONS OF LAW).
2. SOURCES OF PERSONAL DATA AND WHAT PERSONAL INFORMATION ABOUT CUSTOMERS DO CEVA WEBSITES AND APPLICATIONS COLLECT?
(a) Controller and Processors of Personal Data
SIO is the data controller of the personal data you (data subject) provide us or we received in our Websites and Applications. For processing your personal data for purposes other than SIO Websites and Applications usage, each legal entity from SIO is the data controller of your personal data individually.
(b) Types of Personal Data collected and Sources of Personal Data
We collect personal data directly from our customers through SIO Websites and Applications.We obtain, use, disclose and otherwise process personal data about customers to (i) process transactions they request, including online purchases and transactions, (ii) improve SIO Websites and Applications, quality of service and customers on line experience, (iii) send communications about our products, services, campaigns, promotions, and customer satisfaction surveys, (iv) prevent and detect fraud and abuse, (v) process information or claims in connection with incidents at our facilities, (vi) enable service providers to perform certain activities on SIO’s behalf, (vii) protect the log in details of the subscribers and system integrity of the SIO Websites and Applications, (viii) comply with legal obligations, policies and procedures and for internal administrative and analytics purposes,(ix) allow valid customers to access their accounts and receive tracking confirmation as to where their products are currently located, (x) allow customers to monitor the assembly processes of all or part of their supply chain management solutions, and (xi) to commence, protect or defend SIO in actual or threatened legal proceedings.
We collect the following types of personal data about you from the following sources:
We receive and store any information you enter on SIO Websites and Applications or give us in any other way such as during registration, accessing your account or profile, submitting queries or as part of a survey or competition or utilising customer support or communicate with us or requesting quotation for services or purchasing or using our products or services.
Due to such actions, you supply us with your (i) name, postal address, email address, phone numbers, (ii) data necessary to process your payment (including the credit card/payment instrument information and personal security code associated with your credit card) for on line purchases or to make requests for a quotation for our services and purchases (under the SIO Applications), to apply for a refund, or to communicate with customer services regarding a refund to the credit card/payment instrument, (iii) name and contact information for the sender and addressee, their delivery address for the subscriber or make purchases of our products and services. Demographical data such as your age, gender, country, preferred language, passport number and citizenship, date of birth and country of residence are also collected. Such information is collected to meet our contractual obligations to our landlords and airport and port authorities and legal obligations towards customs and other regulatory authorities.
When you register for membership, subscribe for services or the newsletter or other marketing communications including blogs or customer comments or use the SIO Websites and Applications or purchases online or at our facilities, we collect log in details, passwords, any password questions and hints, similar security information used for authentication and account access is also collected for the access into your personal account and profile and to utilise the customer services and resources elements of SIO Websites and Applications.
You can choose not to provide certain information, but then you might not be able to utilise many of the features of the SIO Websites and Applications. See What Are My Choices section below.
We receive and store information where you interact with us through using our products and services, including online technologies (ie Cookies) and receiving error reports or usage data from software applications on your devices online.
We collect and analyse device, connectivity and configuration data including the Internet protocol (IP) address used to connect your computer or device to the internet, computer and connection information such as browser type, version, time zone and other computer software installed on the device, browser plug in types and versions, operating system, shopping preferences, wish list, purchase history, the features you use and pages accessed and web sites visited.
We also collect the Uniform Resource Locator (URL) clickstream to and from our SIO Websites and Applications, including date and time, cookie number, products and services viewed and searched for and the phone number used to contact our customer support teams. We collect technical information to help us identify your device for fraud prevention and diagnostic purposes such as any problems to the product and settings, error reports including data as to the type and severity of the problem, details of software and hardware related to an error, contents of files you were using when an error occurred and data about other software on the device.
We collect browser data including persistent and session cookies and other online technologies as set out below in the Online Technologies section below. We utilise Google Analytics to assist with software tools to measure and collect the performance data on SIO Websites and Applications including download error or performance issues caused. Further information can be found under Google Analytics Terms of Service & Privacy.
Most browsers allow you to opt out of cookies or turn on do not track. For more information, see What are My Choices section below.
We receive information about you from other sources and add it to our account information. The third party sources include:
3. LAWFUL PURPOSES FOR PROCESSING AND USING YOUR PERSONAL DATA
(a) Lawful purposes
Your personal data is processed on the basis of a lawful “justification” for such processing, to the extent required by or permissible under applicable law. The processing of special categories of personal data (including data relating to health, sexual preferences racial or ethnic origin, religious beliefs) is always justified on an additional basis as set out below.
In the majority of cases, the processing of your personal data will be justified on one of the following bases:
(a) It is provided for in your contract of providing products and services requested by you to be provided by us;
(b) It is necessary for us to comply with a legal obligation; or
(c) It is in our legitimate interests as a business and as your supplier of contractually requested goods, and our interests are not overridden by your interests, fundamental rights or freedoms including legitimate interests as set out below.
The processing of special categories of personal data will be justified by one of the above conditions and normally by one of the following special conditions:
(a) It is necessary for the purposes of carrying out legal obligations;
(b) It is carried out subject to your explicit consent;
(c) It is necessary for the establishment, exercise or defence of legal claims; or
(d) In exceptional circumstances, it is necessary to protect your vital interests and you are incapable of giving consent;
(e) Purposes of processing personal data
We obtain, use, disclose and otherwise process personal data about customers to:
We use personal data to carry out your contractual transactions with us and to provide our products and services to you as requested by you. This includes using your personal information to register or subscribe to any services provided thorough SIO Websites and Applications.
Where we process your personal data on the basis of our legitimate interests, those will be our interests in:
We use personal data we collect to communicate with you and personalize our communications with you. i.e. respond to your queries, accommodate your preferences and registration for program membership. We communicate with you by email or phone or SMS to inform you about our services, how to keep your subscription or account active, to communicate regarding a refund or customer inquiry or assisting with web site or SIO Websites and Applications access or technical queries or to participate in a customer survey or a competition or to receive a discount rebate from customer services for service irregularities or to invite you to attend an event sponsored by the SIO Websites and Applications. These communications are to maintain our customer relationship with you and is in furtherance of our legitimate interests of SIO and the Group.
4. SHARING YOUR PERSONAL DATA
Nevertheless, within our corporate group of SIO, certain services are centralised to provide one or more affiliates for the entire group or a part of it.
We will not transfer or disclose your personal information outside our corporate group of SIO other than as set out below:
(a) in connection with a joint venture or business combination where SIO corporate group holds less than 50% ownership or does not have effective management control of such joint venture or business combination;
(b) to third party service providers (companies or individuals) that we employ to perform functions on our behalf such as fulfilling orders, delivering to requested locations, sending postal mail and email, removing repetitive information from customer lists, analysing data, providing marketing assistance, providing search results and links, processing credit card payments and providing customer service. These providers have access to personal information needed to perform their functions, but may not use it for other purposes and include the following categories of data recipients:
(c) in connection with the proposed merger, acquisition or sale or as a result of the actual sale of all or part of the assets of, or shares in SIO or a business transfer of business activities of SIO occurs other than without a sale or acquisition;
(e) to comply with legal or regulatory requirements or obligations in accordance with applicable law, a court order or a subpoena,
(f) with regulatory authorities, airport or port authorities, duty free trading zones, SIO and Group landlords and concession partners and customs and tax authorities to show the calculation of such customs or tax exemptions; or
(g) to data analytical firms, Google Analytics Inc. or;
(h) in an emergency, such as to safeguard the life, health, or property of an individual; or
(i) with your consent to proceed to share your personal information with third parties where required by applicable law.
(j) we may transfer all or some of our rights under our financial agreements with you or companies which you represent to third parties which will provide (or are involved in providing) funding to us. If such a transfer takes place, your personal data or personal data which you provide to us may be processed by the entities participating in such funding arrangement in order that such funding arrangements may be evaluated, monitored and administered (including, without limitation, providing certain information about the financial agreement(s) you or the companies you represent have with us to third parties when we obtain funding through a securitisation so that a third party can evaluate, monitor and administer the pool of financial agreements with respect to which funding is being provided to us) subject to such third party or parties agreeing to act in accordance with applicable law.
5. STORING YOUR PERSONAL DATA
Your personal information you have provided to the controllers be located in a SIO server within the European Union, unless the local data protection laws require that the local SIO entity will be included in a file owned by the local SIO entity, the purpose of which is to manage the business relationship with you, in accordance with the provisions of the local data protection laws. However, the customer relationship and the personal data if any is held with can be accessed or communicated to group or affiliated companies of SIO.
SIO and (local SIO entity) will manage the customer relationship with you and any marketing materials can be provided, in accordance with your preferences, by SIO as Controller or by the local SIO entity as a processor on behalf of SIO.
6. SECURITY OF PERSONAL DATA
Your personal data will be secured by taking security measures that are commensurate with the sensitivity of the personal data processed. To this end, SIO and all Group entities maintain appropriate physical, technical, and administrative security measures with a view to protecting personal data against theft; accidental loss; unauthorised alteration; unauthorised or accidental access, processing, erasure, use, disclosure or copying; and/or accidental or unlawful destruction.
When we have provided (or you have chosen) a password allowing access to certain benefits of the SIO Websites and Applications, you are responsible for safeguarding it and keeping it confidential and you undertake not to allow it to be used by third parties. Unfortunately, the transmission of information thorough the internet is not completely secure. Although we will take all reasonable commercial measures to protect your personal data, we cannot guarantee the security of any personal information or data you disclose on line. You accept the inherent security implications of using the internet and to the extent permitted by law, we will not be responsible for any breach of security, unless we have been acting with gross negligence and only within the limitations as set out in the terms and conditions of use for SIO Websites and Applications.
7. TRANSFERS OF DATA OUTSIDE OF YOUR COUNTRY
Your personal data (as described above) may be transferred to other Group entities or to third parties described above, only to the extent required for SIO and group companies to perform their obligations to you, or for you to access your SIO Websites and Applications, or for the purposes described above in this Notice, provided such purposes are in accordance with applicable laws. In particular:
A list of the countries located outside the EU to which your Personal Data may be transferred, and an indication of whether they have been determined by the European Commission to grant adequate protection to Personal Data, can be found at https://ec.europa.eu/info/strategy/justice-and-fundamental-rights/data-protection/data-transfers-outside-eu_en.
Transfers of Personal Data in accordance with this Section 7 are based on the same legal bases as applicable for the respective purposes of processing as set out above.
8. RETENTION OF PERSONAL DATA
SIO data retention policy requires that personal data be retained for no longer than required to fulfil the purposes for which it was collected. In general, personal data, or records containing personal data, will be retained for periods of time required in accordance with applicable legal, tax, or accounting obligations. In specific circumstances, and in accordance with applicable law, SIO may retain your personal data for longer periods of time (such as for the duration of the relevant statute of limitation) so that we have an accurate record of our dealings with you or to protect the legitimate interests of SIO. In all cases, where your information is no longer required, SIO will ensure it is disposed of in a secure manner.
SIO Websites and Applications do not provide products and services to children. We do not knowingly collect personal information from children under the age of 18 years, without the consent of the child’s parent or guardian. Accordingly, the parent will need to complete and submit a fully completed and signed Parental Personal Data Consent Form (in the form provided by SIO) along with evidence of the person’s identity to us.
10. ONLINE TECHNOLOGIES INCLUDING COOKIES
A "cookie" is a small text file that identifies your mobile device and/or equipment on our server. None of the Cookies we use collect your personal information and they cannot be used to identify you, only the mobile device and/or equipment used. Unless stipulated otherwise, we will not pass personally identifiable data to third parties.
We use 'persistent' cookies. 'Persistent' cookies usually have a long shelf life because they are "collected" and "updated" every time a user visits an application and/or page where the same or a similar cookie is being used.
Information obtained through cookies is used by us and by third parties that we have hired in order to show you advertising related to your preferences.
Cookies generally help us provide better SIO Websites and Applications, which allows us to monitor which pages you find useful and those which are not. A cookie does not allow us to access any other data on your mobile device, equipment or to any information about you, other than the data you choose to share with us. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can modify your browser setting to decline cookies if you prefer. Cookies, including those which have already been set, can be deleted from your hard drive.
Google Analytics are used to help us understand how to make the best use of our content and find out how we can improve it. These cookies allow us to track your progress through our SIO Websites and Applications, collect personal data at their origin, which applications and/or pages you visit, and the time you spend on the site. This data is then stored by Google in order to create reports.
11. WHAT ARE YOUR RIGHTS?
You have the right under applicable law to access, obtain a copy and correct personal data concerning you, subject to limited exceptions that may be prescribed by applicable laws. Where justified and mandated by applicable law, you may also require that your personal data be deleted or blocked, or you may be entitled to obtain information about the processing of your data, or object to further processing of your data.
In the event your personal data is processed on the basis of your consent, you have the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal. You can do this by (i) in some cases deleting the relevant Personal Data from the relevant IT system (although note that in this case it may remain in back-ups and linked systems until it is deleted in accordance with our data retention policy) or (ii) contacting us directly.
You also have the following additional rights:
Where your personal data is subject to restriction in this way we will only process it with your consent or for the establishment, exercise or defence of legal claims.
To exercise your rights, you may contact SIO securely and confidentially. Alternatively, you can send your request , written comments, questions or concerns to our office in Germany.
12. WHAT ARE MY CHOICES?
SIO Websites and Applications provide you with access to a range of information about your account and your interactions with us. To ensure that your personal data is accurate and up to date, we encourage you to regularly review and update your information as appropriate, if your communication preferences change or your contact details or address has changed. If you have subscribed to SIO Websites and Applications, especially the customer services and resources sections of the CEVA Websites and Applications, then you can either access your profile and make the changes or request the changes are made by sending an email request along with evidence of your identity to us.
13. CHANGES TO OUR PRIVACY NOTICE
Changes and amendment to the terms of this Privacy Notice can be made at any time and shall apply as soon as they are published on SIO Websites and Applications. Should you not agree to any changes or amendments, then you should refrain from continuing to use our services or products or access SIO Websites and Applications. You can unsubscribe from receiving or using our products and services at any time by sending an email request to unsubscribe your profile to us.