PERSONAL INFORMATION WE COLLECT
We may collect or may have collected the following categories of information about you. In some cases, the information we collect may fall within more than one category:
- Contact information and personal identifiers, such as your name, address, email address, telephone number, and username or social media handle.
- Device identifiers, such as information about your device like your IP address, or other online identifiers.
- Demographic information, such as your age, sex, and gender (some of which may be protected by applicable law).
- Commercial information, such as the services you have used, purchased, returned or considered, and your preferences.
- Payment information, such as your method of payment and payment card information (including payment card number, expiration date, delivery address and billing address).
- Biometric information, including facial recognition and other biometric identification information.
- Identity verification information, in order to verify you when you call customer support or make other requests.
- Geolocation information, such as information provided by mobile device GPS services when using our logistics app.
- Online or network activity information, such as information regarding your interaction with the Site, digital properties, and advertisements, information about your browsing and search history on the Site, and log file information, which includes, but may not be limited to, your browser type, webpages you visit, and other electronic network activity.
- Audio information, such as recordings of your voice when you call our customer support.
- Inferences drawn from or created based on any of the information identified above.
HOW WE COLLECT YOUR PERSONAL INFORMATION
We may collect or may have collected personal information about you from various sources. The categories of sources from which we may collect personal information are:
- Directly from you, such as when you visit the Site, use our App, order services from us, enroll to become a contractor with us, contact us with a question or complaint, or sign-up to receive marketing communications.
- Cookies and automatic collection methods. When you visit the Site or use one of our App, and when you open or click on emails we send you, we (and third parties we work with) may automatically collect information from your browser or device using technologies such as cookies, web beacons, pixel tags, and similar technologies. Cookies are small text files that websites send to your computer or other Internet-connected device to uniquely identify your browser or to store information or settings in your browser. Web beacons or pixel tags are small images which are embedded into the Site or emails that provide us with information about your browser or device, or whether you open or click on the emails we send you. These technologies enable us, or the third parties who place such technologies, to collect information such as device identifiers and online or other network activity information.
- Through other technologies, such as call recording technology when you speak to customer support, and for contractors, from GPS and other asset-management technologies attached to our equipment.
- From our business partners and service providers, such as demographic companies, analytics providers, advertising companies and networks, third-party retailers, and other third parties that we choose to collaborate or work with.
- From our affiliates that you have interacted with.
HOW WE USE YOUR PERSONAL INFORMATION
We may use or may have used the information we have about you:
- To provide products and services to you, such as fulfilling orders and processing payments, creating, servicing and/or maintaining your accounts with us, and managing current or past orders and services.
- To communicate with you, including to respond to your inquiries or complaints, and to help you when you have questions.
- For marketing and advertising, such as to send you marketing and advertising materials via postal mail, text message or email, and to show you advertisements for products and/or services tailored to your interests on social media and other websites.
- For analytics purposes, such as to understand how you use our services, properties and the Site, understand your preferences; determine what browser and devices you use to visit the Site; and to evaluate and improve our products, services, advertisements, and website and App.
- To operate and improve our business, including to provide quality assurance, conduct research and development to develop new services and products, and perform accounting, auditing and other internal business functions.
- For legal and security purposes, such as to detect, prevent, and prosecute harmful, fraudulent, or illegal activity, loss prevention, identify and repair bugs on the Site or App, and to comply with applicable legal requirements, relevant industry standards and our policies.
- To process payments for contractors and employees, and to report payments to appropriate taxing authorities or as otherwise required by law.
We also may use or may have used the information in other ways for which we provide specific notice at the time of collection.
HOW WE SHARE YOUR PERSONAL INFORMATION
In general, we do not share personal information about you with third parties for such third-parties’ own marketing or advertising purposes. We do share personal information with third parties for other purposes. For example, we share personal information with:
- The ITS family of brands and companies, such as our affiliates, parents, and subsidiaries. We share information within this “family” as a normal part of conducting business and offering products and services to our customers;
- Service providers that provide services to us, that help us market or advertise to you (including co-branded marketing and advertising), or that provide products or services to you (such as delivering packages to you). Even with this access to personal information necessary to perform these functions, those third parties are not authorized by ITS to disclose your information for any other purposes;
- Parties to business transactions such as those we deal with in mergers, acquisitions, joint ventures, sales of assets, reorganizations, divestitures, dissolutions, bankruptcies, liquidations, or other types of business transactions. In these types of transactions, personal information may be shared, sold, or transferred, and it may be used subsequently by a third party;
- Online third-party companies for our own advertising purposes, including to: serve advertisements across the Internet; track and categorize your activity and interests over time on the Site and App, and on third-party websites and mobile applications; and to identify the different device(s) you use to access websites and mobile applications. We share information with these companies, and these companies may collect information—including automatically collected information when you use the Site or App. These third‑party companies also may possess or obtain information about you from your interactions: directly with the third-party companies; with other websites, mobile applications, or companies that the third-party companies work with; or from your interactions with advertisements the third-party companies help to display to you. The information that these companies collect or that we share may be used to customize or personalize the advertisements that are displayed to you; and
- Additional third parties such as law enforcement, government entities, courts, or other third parties as required or allowed by applicable law, or otherwise to help prevent harm or fraud to us, you, our customers, or other third parties. We also may share personal information with third parties upon your request or with your approval, though we may not be able to accommodate all requests.
CHILDREN’S PERSONAL INFORMATION
The Site is not directed at or intended for children under the age of 18 and we do not knowingly collect personal information from such individuals. If you become aware that your child has provided us with personal information without your consent, please contact us at email@example.com and we will take steps to remove such information within a reasonable time.
HOW WE SECURE PERSONAL INFORMATION
In addition, we also take commercially reasonable measures to secure and protect all other information transmitted via or stored on the Site or our App and transmitted to and from the Site or our App. These measures include the use of appropriate technical, physical, and administrative safeguards. Nevertheless, no security system is impenetrable. We cannot and do not guarantee that information that users of the Site or our App may happen to transmit or otherwise supply, or that any communications conducted on or through the Site or our App, is or will be secure.
CALIFORNIA PRIVACY RIGHTS
Under the California Consumer Privacy Act (“CCPA”), California residents have certain rights regarding the personal information that businesses have about them. This includes the rights to request access or deletion of your personal information, as well as the right to direct a business to stop selling your personal information.
Right to Notice. You have the right to be properly notified of the following:
Right to Access Your Information: You have the right to request the following covering the 12 months preceding your request:
- The specific pieces of personal information we have collected about you
- The categories of personal information that we have collected about you
- The categories of sources from which we collected the personal information
- The purpose for collecting or selling the personal information
- The categories of personal information that we have disclosed about you, the purpose for disclosing such personal information and the categories of third parties with whom we disclosed such personal information
- The categories of personal information that we have sold about you, as well as the categories of third parties to whom we sold such personal information
If you would like to exercise your right to request access, please submit your request by emailing us at firstname.lastname@example.org or calling us at 775-227-7705.
Right to Deletion: You have the right to request that we delete any personal information about you that we have collected from you. Please note that there are exceptions where we do not have to fulfill a request to delete information, such as when the deletion of information would create problems with the completion of a transaction or compliance with a legal obligation. If you would like to exercise your right to request deletion, please submit your request by emailing us at email@example.com or calling us at 775-227-7705.
Right to Opt-Out of Sale: We do not sell personal information as defined under California law.
Please note that we may still use aggregated and de-identified personal information that does not identify you or any individual; we may also retain information as needed in order to comply with legal obligations, enforce agreements, and resolve disputes.
Right to Non-Discrimination: We will not discriminate against you (e.g., through denying goods or services, or providing a different level or quality of goods or services) for exercising any of the rights afforded to you.
Verifiable Consumer Requests: Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may only make a verifiable consumer request for access to your personal information twice within a 12-month period. The verifiable consumer request must: 1) Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative of that person; and 2) Describe your request with sufficient detail that allows us to properly understand, evaluate and respond to it. We cannot respond to your request to exercise your access and/or deletion rights 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. However, we do consider requests made through your password-protected account sufficiently verified when the request relates to personal information associated with that specific account. 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 attempt to respond to a verifiable consumer request within 45 days after we receive it. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing within 45 days after we receive your initial request. 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 prior to the date we receive the verifiable consumer request. The response we provide will also provide the reasons we cannot comply with a request, if applicable. For access 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. 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.
Financial Incentive: We may offer you various financial incentives such as discounts and special offers when you provide us with contact information and identifiers such as your name and email address. When you sign-up for our loyalty program, email list or other discounts and special offers, you opt-in to a financial incentive. You may withdraw from a financial incentive at any time by opting out from our email or closing your loyalty member account. Generally, we do not assign monetary or other value to personal information, however, California law requires that we assign such value in the context of financial incentives. In such context, the value of the personal information is related to the estimated cost of providing the relevant financial incentive(s) for which the information was collected.
California’s Shine the Light law. California residents with an established business relationship with us can request information once a year about sharing their personal information with third parties for the third parties’ direct marketing purposes. If you would like to request more information under the California Shine the Light law, and if you are a California resident, you can email us at firstname.lastname@example.org.
OPT-OUT FROM MAILINGS
We provide you with several opportunities to agree to receive communications about special offers or programs from ITS and any of our affiliated brands or divisions. If at any time you wish to stop receiving communications from us please send us an email to email@example.com with the phrase “Privacy Opt-out: ITS Mailings” in the subject line, and we will remove you from our mailing list. Alternatively, for e-mail communications, you may opt out of receiving such communications by following the unsubscribe instructions set forth at the bottom of our promotional e-mail messages.
WHO CAN YOU CONTACT FOR MORE INFORMATION?
If you have any questions or suggestions about our privacy practices, please contact us at firstname.lastname@example.org.