1.     INTRODUCTION 

We at CXCX Technology LLC (https://truckingcontrol.com/)consider the privacy of our users one of our main priorities.

This Privacy Policy is designed to clarify how we collect, use, disclose, and protect the information related to You or Your household when using our Service.

You acknowledge that this Policy is to be read in conjunction with our Terms of Service, and by accessing or using our Services, you agree to the collection and use of information in accordance with this Privacy Policy. If you disagree with our Terms of Services or Policy, please don’t use our Services.

2.     DEFINITIONS AND INTERPRETATIONS

A.    Interpretations

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

B.    Definitions

For the purposes of this Privacy Policy:

·       Account means a unique account created for You to access our Service or parts of our Service.

·       Business, for the purpose of the CCPA (California Consumer Privacy Act), refers to the Company as the legal entity that collects Consumers’ personal information and determines the purposes and means of the processing of Consumers’ personal information or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers’ personal information, that does business in the State of California.

                   Company (referred to as either “Company”, “We”, “Us”, or “Our” in this Policy) refers to CXCX Technology LLC, 34 N 

                Franklin Ave, Pinedale, WY 82941

For the purpose of the GDPR, the Company is the Data Controller.

·       Consumer, for the purpose of the CCPA (California Consumer Privacy Act), means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in the USA for other than a temporary or transitory purpose and (2) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose.

·       Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.

·       Country refers to: [Wyoming], [United States]

·       Data Controller, for the purposes of the GDPR (General Data Protection Regulation), refers to the Company as the legal person who, alone or jointly with others, determines the purposes and means of processing Personal Data.

·       Device means any device that can access the Service, such as a computer, a cellphone or a digital tablet.

·       Do Not Track (DNT) is a concept that has been promoted by US regulatory authorities, particularly the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing Internet users to control the tracking of their online activities across websites.

·       Personal Data or Personal Information is any information related to an identified or identifiable individual.

For the purposes of GDPR, Personal Data means any information relating to You, such as a name, an identification number, location data, online identifier or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.

For the purposes of the CCPA, Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with You.

·       Sale, for the purpose of the CCPA (California Consumer Privacy Act), means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer’s personal information to another business or a third party for monetary or other valuable consideration.

·       Service refers to a web-based Fleet Management Platform accessible via a Website.

·       Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used. For the purpose of the GDPR, Service Providers are considered Data Processors.

·       Third-party Social Media Service refers to any website or social network website through which a User can log in or create an account to use the Service.

·       Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

·       Website refers to [website] accessible from https://truckingcontrol.com/

·       You mean the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Under GDPR (General Data Protection Regulation), You can be referred to as the Data Subject or as the User, as you are the individual using the Service.

3.     WHAT INFORMATION DO WE COLLECT AND PROCESS? 

A.    Information You Provide to Us.  

While using Our Service (e.g., create an account, register for the Service, express an interest in obtaining information about Us or our Service, or otherwise use Services or interact with Us), We may ask You to provide certain personally identifiable information that can be used to contact, identify You and fulfil Your requests in connection with the Service. Personally identifiable information may include, but is not limited to:

·       Contact Information: [full name], [email address], [phone number],[company name], [billing address]

·       Account Information: [username and password you set to create your account on the Service], and [any other information that you add to your account]

·       Transactional Information: [payment method information, order numbers and information about that transaction] 

·       Marketing Information: [your preferences for receiving our marketing communications and your commitment to them].

·       Communication and Assistance Information: [any other information that you provide voluntarily when you contact customer and technical support or communicate with us in any other way, we will use such information to communicate with you, to resolve any issues, and will keep this communication for our records in the ordinary course of business]. 

B.    Automatically Collected Information.

While using Our Service, we automatically collect Usage Data:  

·       Usage Data may include information such as Your [Device’s Internet Protocol address (e.g., IP address), browser type, browser version, your activity on the Services (e.g., the pages of our Service that You visit, the time associated with your usage, and other actions you take such as which features you use, and other statistics), unique device identifiers and other diagnostic data].

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, [the type of mobile device You use, Your mobile device’s unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data].

We may also collect information that Your [browser sends whenever You visit our Service or when You access the Service by or through a mobile device].

C.    Information from Third-Party Social Media Services

We don’t allow You to create an account and log in to use the Service through the Third-party Social Media Services.

D.    Tracking Technologies and Cookies

We use cookies and similar tracking technologies to track the activity on our Service and store certain information. You can find out more about this in our:

·       Cookies Notice CLICK HERE. 

4.     WHAT INFORMATION WE DO NOT COLLECT AND PROCESS?

A.    Children Privacy.

Our Service does not address anyone under the age of 16. We do not knowingly collect personally identifiable information from anyone under the age of 16. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 16 without verification of parental consent, We take steps to remove that information from Our servers.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent’s consent before We collect and use that information.

B.    Sensitive Personal Information.

A particular category of Personal Data is sensitive personal information (e.g., racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership) and which requires special consideration to collect and process such data.

Our Service does not knowingly collect or process any sensitive personal information unless you have chosen to voluntarily disclose and share such information during your use of the Service.

If you inadvertently or intentionally transmit sensitive personal information to us, you will be considered to have explicitly consented to us processing that sensitive personal information.

5.     HOW DO WE USE THE INFORMATION WE COLLECT?   

We may use Personal Data for the following purposes:

A.    To provide and maintain our Service, including monitoring the usage of our Service.

B.    To manage your Account: to manage your registration in order to use the Service, the personal information you provide can give you access to the Services that are available to you as a registered user.

C.    For the performance of a Contract: the development, compliance and undertaking of the purchase contract for the products, items or Services you have purchased or of any other contract with us via Services.

D.    To contact you: to contact you by email, telephone calls, SMS, or other equivalent electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products, or contracted services, including the security updates, when necessary or reasonable for their implementation or changes to our terms of services or policies and other similar information. 

E.     To provide you with news, special offers and general information about other goods, services and events that we offer that are similar to those you have already purchased or enquired about unless you have opted not to receive such information.

F.     To manage your requests: to attend and manage your requests to us.

G.    To deliver targeted advertising to you: We may use your information to develop and display content and advertising (and work with third-party vendors who do so) tailored to your interests and/or location and to measure its effectiveness.

H.    To comply with our legal obligations: We may use your information to comply with our legal obligations, respond to legal requests, and exercise, establish, or defend our legal rights.

I.      For business transfers: We may use your information 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 about our Service users is among the assets transferred.

J.      For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and evaluating and improving our Service, products, services, marketing and your experience.

6.     DO WE SHARE THE INFORMATION WE COLLECT WITH THIRD PARTIES?  

We may share Your personal information in limited circumstances, as follows:

A.         Legal Requirements: Under certain circumstances, We may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency). We may disclose Your Personal Data in the good faith belief that such action is necessary to:

·      Comply with a legal obligation.

·      Protect and defend the rights or property of the Company.

·      Prevent or investigate possible wrongdoing in connection with the Service.

·      Protect the personal safety of Users of the Service or the public.

·      Protect against legal liability.

B.         For Business Transfer: We may share or transfer Your Personal Data in connection with or during negotiations of any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

C.         With Business Partners: We may share Your information with Our business partners to offer You certain products, services or promotions.

D.         With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or are under common control with Us.

E.          With Employees:  We may share Your information with our employees who need to know the information in order to help us provide our Services or to process the information on our behalf. We require our employees to honor this Privacy Policy.

F.          With Your Consent: We may disclose Your personal information for any other purpose with Your consent.

G.         With Service Providers: We may share your personal information with Service Providers to monitor and analyze the use of our Service, to show advertisements to You to help support and maintain Our Service, to advertise on third-party websites to You after You visit our Service, for payment processing, to contact You.

The Service Providers We use may have access to Your Personal Data. These third-party vendors collect, store, use, process and transfer information about Your activity on Our Service in accordance with their Privacy Policies:

Service Provider Categories

Service Providers

o   Analytics

 

We may use third-party Service providers to monitor and analyze the use of our Service.

ü  Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service.

This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

You can opt out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity.

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page:

https://policies.google.com/privacy

o   Email Marketing

 

We may use Your Personal Data to contact You with newsletters, marketing or promotional materials and other information that may be of interest to You.

You may opt out of receiving any or all of these communications from Us by following the unsubscribe link or instructions provided in any email We send or by contacting Us.

We may use Email Marketing Service Providers to manage and send emails to You.

ü  SendGrid

Their Privacy Policy can be viewed at:

 https://www.twilio.com/legal/privacy

o   Payments Processors

 

We may provide paid products and/or services within the Service. In that case, we may use third-party services for payment processing (e.g., payment processors).

We will not store or collect Your payment card details. That information is provided directly to Our third-party payment processors, whose use of Your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

ü  Stripe 

Their Privacy Policy can be viewed at:

https://stripe.com/privacy

o   Cloud Computing

We may use Service Providers that provide IT infrastructure and hosting to help provide and maintain Our Service

 

ü  Contabo

Their Privacy Policy can be viewed at

https://contabo.com/en/legal/privacy/

o [Behavioral Remarketing]

We may use remarketing services to advertise to You after You accessed or visited our Service. Our third-party vendors and We use cookies and non-cookie technologies to help Us recognize Your Device and understand how You use our Service so that We can improve our Service to reflect Your interests and serve You advertisements that are likely to be of more interest to You.

These third-party vendors collect, store, use, process and transfer information about Your activity on Our Service in accordance with their Privacy Policies and to enable Us to:

§  Measure and analyze traffic and browsing activity on Our Service

§  Show advertisements for our products and/or services to You on third-party websites or apps.

§  Measure and analyze the performance of Our advertising campaigns.

We may share information, such as hashed email addresses (if available) or other online identifiers collected on Our Service with these third-party vendors. This allows Our third-party vendors to recognize and deliver You ads across devices and browsers. To read more about the technologies used by these third-party vendors and their cross-device capabilities, please refer to the Privacy Policy of each vendor listed below.

ü  Google Ads (AdWords)

Google Ads (AdWords) remarketing service is provided by Google Inc.

You can opt out of Google Analytics for Display Advertising and customise the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads

Google also recommends installing the Google Analytics Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout – for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page:

https://policies.google.com/privacy

ü  Facebook

Facebook remarketing service is provided by Facebook Inc.

You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/516147308587266

To opt out from Facebook’s interest-based ads, follow these instructions from Facebook: https://www.facebook.com/help/568137493302217

Facebook adheres to the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. You can also opt out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/ or opt-out using your mobile device settings.

For more information on the privacy practices of Facebook, please visit Facebook’s Data Policy: https://www.facebook.com/privacy/explanation.]

o [Usage, Performance and Miscellaneous]

We may use third-party Service Providers to provide better improvement of our Service.

ü Invisible reCAPTCHA

We use an invisible captcha service named reCAPTCHA. reCAPTCHA is operated by Google.

The reCAPTCHA service may collect information from You and from Your Device for security purposes.

The information gathered by reCAPTCHA is held in accordance with the Privacy Policy of Google:

https://www.google.com/intl/en/policies/privacy/]

7.     WHERE DO WE TRANSFER YOUR INFORMATION?

Your information, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers outside Your state, province, country or other governmental jurisdiction where the data protection laws may differ from yours.

Your consent to this Privacy Policy, followed by Your submission of such information, represents Your agreement to that transfer.

We will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy, and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place, including the security of Your data and other personal information.

8.     HOW LONG DO WE KEEP YOUR INFORMATION?

We will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or improve the functionality of Our Service or We are legally obligated to retain this data for longer periods.

9.     HOW DO WE KEEP YOUR INFORMATION SAFE

We have implemented appropriate and reasonable technical and organisational measures designed to protect the security of the personal data we process. For example, we and/or our service providers use commercially reasonable security measures such as encryption, firewalls, and Secure Socket Layer software (SSL) or hypertext transfer protocol secure (HTTPS) to protect Personal Information. In addition to these measures, we ensure that login credentials are securely hashed and stored, preventing even our own staff from accessing them. Furthermore, direct access to our customers’ databases is strictly controlled and not accessible by our employees, ensuring an additional layer of security and privacy for our users.

However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal data, transmission of personal data to and from our Services is at your own risk. You should only access the Services within a secure environment.

10. WHAT ARE YOUR CHOICES AND RIGHTS?

A.    Refusal to Provide Information. We need to collect Personal Data to provide certain Services. If you do not provide information that we identify as necessary or required, we may be unable to provide those Services.

B.    Access and Update Your Information. If You have registered for an account with us through the Service, you may review and update certain account information by logging into the account.

C.    Delete Account. If You have registered for an account with us through the Services, You may request deletion of your account by sending an email to the email address specified in this Policy (HOW CAN YOU CONTACT US ABOUT THIS POLICY Section). Please note that some information may remain in our private records after the deletion of your account. We may use any aggregated data derived from or incorporating your personal data after you delete your account, but not in a manner that would identify you personally.

D.    Opt-out of Communications. You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email or by contacting us at the email address specified in this Policy. Please note that if you opt out of marketing-related emails, you may continue receiving service-related and other non-marketing emails.

E.     Do Not Track. Our Service does not respond to Do Not Track signals. However, some third-party websites do keep track of Your browsing activities. If You are visiting such websites, You can set Your preferences in Your web browser to inform websites that You do not want to be tracked. You can enable or disable DNT by visiting your web browser’s preferences or settings page. To find out more about “Do Not Track”, please visit http://www.allaboutdnt.com.

F.     Your Ad Choices. We may use cookies and similar tracking technologies to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in Our Cookies NoticeCLICK HERE.

Some of these third-party vendors may use non-cookie technologies that may not be impacted by browser settings that block cookies. Your browser may not permit You to block such technologies. You can use the following third-party tools to decline the collection and use of information for the purpose of serving You interest-based advertising:

·       The NAI’s opt-out platform: http://www.networkadvertising.org/choices/

·       The EDAA’s opt-out platform http://www.youronlinechoices.com/

·       The DAA’s opt-out platform: http://optout.aboutads.info/?c=2&lang=EN.

The tools above are provided by third parties, not by Us. We do not control or operate these tools or the choices that advertisers and others provide through these tools.

You may opt out of all personalized advertising by enabling privacy features on Your mobile device, such as Limit Ad Tracking (iOS) and Opt Out of Ads Personalization (Android). See Your mobile device Help system for more information.

G.    Additional Specific Rights. In addition to the choices and rights described elsewhere in this Privacy Policy, You may have some rights regarding your personal data, depending on your location and subject to local applicable laws, such as GDPR, CCPA, and other applicable privacy laws, such as request to access Your Personal Data, request to correct the Personal Data that We hold about You, Object to processing of Your Personal Data, Request erasure of Your Personal Data, Request the transfer of Your Personal Data, Withdraw Your Consent.

You may exercise by emailing the address specified in this Policy (HOW CAN YOU CONTACT US ABOUT THIS POLICY Section).

However, these are not absolute rights which only exist if the relevant conditions are met. For example, the right for erasure does not apply in case such personal data is required to comply with a legal obligation (legal compliance) or to establish, exercise, or defend legal claims (legal enforcement).

11. DO I HAVE SPECIFIC PRIVACY RIGHTS UNDER CERTAIN JURISDICTION?

A.      GDPR Privacy

This privacy notice section for European Economic Area (EEA) residents supplements the information in Our Privacy Policy, and it applies solely to all visitors, users, and others who reside there.

The General Data Protection Regulation (GDPR) requires Us to disclose Who are we? What personal data do we process? What do we do with your personal data? Where do we store your personal data, and with whom do we share it? For how long do we process personal data? which we have explained in this Privacy Policy.

·      Legal Basis for Processing Personal Data under GDPR

We may process Personal Data under the following conditions:

o   Consent: You have given Your consent for processing Personal Data for one or more specific purposes.

o   Performance of a Contract: Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.

o   Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.

o   Vital interests: Processing Personal Data is necessary in order to protect Your vital interests or those of another natural person.

o   Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.

o   Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.

In any case, We will gladly help to clarify the specific legal basis that applies to the processing, and in particular, whether the provision of Personal Data is a statutory or contractual requirement or a requirement necessary to enter into a contract.

·      Your Rights under the GDPR

We undertake to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights.

You have the right under this Privacy Policy, and by law if You are within the EU, to:

o   Request access to Your Personal Data. The right to access, update or delete the information We have on You. Whenever made possible, you can access, update or request the deletion of Your Personal Data directly within Your account settings section. If you are unable to perform these actions yourself, please contact Us to assist You. This also enables You to receive a copy of the Personal Data We hold about You.

o   Request correction of the Personal Data that We hold about You. You have the right to have any incomplete or inaccurate information We hold about You corrected.

o   Object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for Our processing, and there is something about Your particular situation which makes You want to object to our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes.

o   Request the erasure of Your Personal Data. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.

o   Request the transfer of Your Personal Data. We will provide to You, or to a third party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.

o   Withdraw Your consent. You have the right to withdraw Your consent on using your Personal Data. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Service.

However, these are not absolute rights which only exist if the relevant conditions are met. For example, the right for erasure does not apply in case such personal data is required to comply with a legal obligation (legal compliance) or to establish, exercise, or defend legal claims (legal enforcement).

·      Exercising of Your GDPR Data Protection Rights

You may exercise Your rights of access, rectification, cancellation and opposition by contacting Us by sending an email to the email address specified in this Policy (HOW CAN YOU CONTACT US ABOUT THIS POLICY Section). Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible within one month.

You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. For more information, if You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA.

B.       CCPA Privacy

This privacy notice section for California residents supplements the information contained in Our Privacy Policy, and it applies solely to all visitors, users, and others who reside in the State of California.

The California Consumer Privacy Act (CCPA) requires us to disclose the categories of personal data we collect and process and how we use it, the categories of sources from which we collect personal data, and the third parties with whom we share it, which we have explained in this Privacy Policy, but, for your convenience, we will make specific information more explicitly in accordance with the CCPA requirements, as follows:

·      Categories of Personal Information Collected

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. The following is a list of categories of personal information which we may collect or may have been collected from California residents within the last twelve (12) months.

Please note that the categories and examples provided in the list below are those defined in the CCPA. This does not mean that all examples of that category of personal information were, in fact, collected by Us, but reflects our good faith belief, to the best of our knowledge, that some of that information from the applicable category may be and may have been collected. For example, certain categories of personal information would only be collected if You provided such personal information directly to Us.

 

Categories

Examples

Collected

A.     Identifiers

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver’s license number, passport number, 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, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance 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 and history of products or services purchased or considered

Yes

E.      Biometric information.

Genetic, physiological, behavioural, 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.

Interaction with our Service or advertisement.

Yes

G.     Geolocation data.

Approximate physical location.

No

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

No

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 are drawn from other personal information.

Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behaviour, attitudes, intelligence, abilities, and aptitudes.

No

Under CCPA, personal information does not include:

o   Publicly available information from government records

o   Deidentified or aggregated consumer information

o   Information excluded from the CCPA’s scope, such as:

ü  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.

ü  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

·      Sources of Personal Information

We obtain the categories of personal information listed above from the following categories of sources:

o   Directly From You: For example, from the forms You complete on our Service, preferences You express or provide through our Service, or from Your purchases on our Service.

o   Indirectly from You: For example, from observing Your activity on our Service.

o   Automatically from You: For example, through cookies We or our Service Providers set on Your Device as You navigate through our Service.

o   From Service Providers. For example, third-party vendors for payment processing or other third-party vendors that We use to provide the Service to You.

·      Use of Personal Information for Business Purposes or Commercial Purposes

We may use or disclose personal information We collect for “business purposes” or “commercial purposes” (as defined under the CCPA), which may include the following examples:

o   To operate our Service and provide You with our Service.

o   To provide You with support and respond to Your inquiries, including investigating and addressing Your concerns and monitoring and improving our Service.

o   To fulfil or meet the reason You provided the information. For example, if You share Your contact information to ask a question about our Service, We will use that personal information to respond to Your inquiry. If You provide Your personal information to purchase a product or service, We will use that information to process Your payment and facilitate delivery.

o   To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

o   As described to You when collecting Your personal information or as otherwise set forth in the CCPA.

o   For internal administrative and auditing purposes.

o   To detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity, including, when necessary, to prosecute those responsible for such activities.

Please note that the examples provided above are illustrative and not intended to be exhaustive. For more details on how we use this information, please refer to the HOW DO WE USE THE INFORMATION WE COLLECT?  section.

If We decide to collect additional categories of personal information or use the personal information We collected for materially different, unrelated, or incompatible purposes, We will update this Privacy Policy.

 

·      Disclosure of Personal Information for Business Purposes or Commercial Purposes

We may use or disclose and may have used or disclosed in the last twelve (12) months the following categories of personal information for business or commercial purposes:

o   Category A: Identifiers

o   Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

o   Category D: Commercial information

o   Category F: Internet or other similar network activities

Please note that the categories listed above are those defined in the CCPA. This does not mean that all examples of that category of personal information were, in fact, disclosed but reflects our good faith belief, to the best of our knowledge, that some of that information from the applicable category may be and may have been disclosed.

When We disclose personal information for a business purpose or a commercial 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.

·      Sale of Personal Information

As defined in the CCPA, “sell” and “sale” mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means a consumer’s personal information by the business to a third party for valuable consideration. This means that We may have received some kind of benefit in return for sharing personal information, but not necessarily a monetary benefit.

Please note that the categories listed below are those defined in the CCPA. This does not mean that all examples of that category of personal information were, in fact, sold, but reflects our good faith belief, to the best of our knowledge, that some of that information from the applicable category may be and may have been shared for value in return.

We may sell and may have sold in the last twelve (12) months the following categories of personal information:

o   Category A: Identifiers

o   Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

o   Category D: Commercial information

o   Category F: Internet or other similar network activity.

·      Share of Personal Information

We may share Your personal information identified in the above categories with the following categories of third parties:

o   Service Providers

o   Payment processors

o   Our affiliates and employees

o   Our business partners.

o   Third-party vendors to whom You or Your agents authorize Us to disclose Your personal information in connection with products or services We provide to You.

·      Sale of Personal Information of Minors Under 16 Years of Age

We do not knowingly collect personal information from minors under the age of 16 through our Service, although certain third-party websites that we link to may do so. These third-party websites have their own terms of use and privacy policies, and we encourage parents and legal guardians to monitor their children’s Internet usage and instruct their children to never provide information on other websites without their permission.

We do not sell the personal information of Consumers We actually know are less than 16 years of age unless We receive affirmative authorization (the “right to opt-in”) from either the Consumer who is between 13 and 16 years of age or the parent or guardian of a Consumer less than 13 years of age. Consumers who opt-in to the sale of personal information may opt-out of future sales at any time. To exercise the right to opt-out, You (or Your authorized representative) may submit a request to Us by contacting Us.

If You have reason to believe that a child under the age of 13 (or 16) has provided Us with personal information, please contact Us with sufficient detail to enable Us to delete that information.

·      Your Rights under the CCPA

The CCPA provides California residents with specific rights regarding their personal information. If You are a resident of California, You have the following rights:

o   The right to notice. You have the right to be notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used

o   The right to request. Under CCPA, You have the right to request that We disclose information to You about Our collection, use, sale, disclosure for business purposes and share of personal information. Once We receive and confirm Your request, We will disclose to You:

ü   The categories of personal information We collected about You.

ü   The categories of sources for the personal information We collected about You.

ü   Our business or commercial purpose for collecting or selling that personal information.

ü   The categories of third parties with whom We share that personal information.

ü   The specific pieces of personal information We collected about You.

ü   If we sell Your personal information or disclose Your personal information for a business purpose, We will disclose to You:

§   The categories of personal information categories sold

§   The categories of personal information categories disclosed

o   The right to say no to the sale of Personal Data (opt-out). You have the right to direct Us to not sell Your personal information. To submit an opt-out request, please contact Us.

o   The right to delete Personal Data. You have the right to request the deletion of Your Personal Data, subject to certain exceptions. Once We receive and confirm Your 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:

ü   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.

ü   Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

ü   Debug products to identify and repair errors that impair existing intended functionality.

ü   Exercise free speech, ensure the right of another consumer to exercise their free speech rights or exercise another right provided for by law.

ü   Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et seq.).

ü   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.

ü   Comply with a legal obligation.

ü   Make other internal and lawful uses of that information that are compatible with the context in which You provided it.

o   The right not to be discriminated against. You have the right not to be discriminated against for exercising any of Your consumer’s rights.

·      Exercising Your CCPA Data Protection Rights

In order to exercise any of Your rights under the CCPA, and if You are a California resident, You can contact Us by sending an email to the email address specified in this Policy (HOW CAN YOU CONTACT US ABOUT THIS POLICY Section).

Only You or a person registered with the California Secretary of State that You authorize to act on Your behalf, may make a verifiable request related to Your personal information.

Your request to Us must:

o   Provide sufficient information that allows Us to reasonably verify You are the person about whom We collected personal information or an authorized representative.

o   Describe Your request with sufficient detail that allows Us to properly understand, evaluate, and respond to it.

We cannot respond to Your request or provide You with the required information if we cannot:

o   Verify Your identity or authority to make the request.

o   And confirm that the personal information relates to You.

We will disclose and deliver the required information free of charge within 45 days of receiving Your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice.

Any disclosures We provide will only cover the 12-month period preceding the verifiable request’s receipt.

For data portability requests, We will select a format to provide Your personal information that is readily useable and should allow You to transmit the information from one entity to another entity without hindrance.

 

·      Do Not Sell My Personal Information

You have the right to opt out of the sale of Your personal information. Once We receive and confirm a verifiable consumer request from You, we will stop selling Your personal information. To exercise Your right to opt-out, please contact Us.

The Service Providers we partner with (for example, our analytics or advertising partners) may use technology on the Service that sells personal information as defined by the CCPA law. If you wish to opt out of the use of Your personal information for interest-based advertising purposes and these potential sales as defined under CCPA law, you may do so by following the instructions below.

Please note that any opt-out is specific to the browser You use. You may need to opt-out on every browser that You use.

12. WHAT IS OUR STANCE ON THIRD–PARTY WEBSITES?

The Services may link to third-party websites, online services, or mobile applications and/or contain advertisements from third-party parties that are not affiliated with Us, which may link to other websites, services, or applications. Accordingly, We don’t make any guarantee regarding any such third parties, and we will not be liable for any loss or damage caused by the use of such third-party websites, services or applications.

The inclusion of a link towards a third-party website, service, or application does not imply an endorsement by Us. We cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this Privacy Policy. We are not responsible for any third parties’ content or privacy and security practices and policies, including other websites, services, or applications that may be linked to or from the Services.

You should review the policies of such third parties and contact them directly to respond to your questions.

13. DO WE MAKE UPDATES TO THIS PRIVACY POLICY?

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will inform You via email and/or a prominent notice on Our Service before the change becomes effective and update the “Last updated” date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

14.  HOW CAN YOU CONTACT US ABOUT THIS POLICY? 

If you have any questions or comments about this Policy, the ways in which We collect and use your information described herein, your choices and rights regarding such use, or wish to exercise your rights under GDPR, CCPA, and other applicable privacy laws, please do not hesitate to contact us by postal mail or by e-mail at:

www.truckingcontrol.com

CXCX Technology LLC,

 34 N Franklin Ave

 Pinedale, WY, 82941, Ste 687

 info@truckingcontrol.com