USA Data Privacy Policy

BrightCell Logistics USA Data Privacy Statement

Effective date: January 1, 2023

1. GENERAL INFORMATION

This Statement is applicable on a global level ut may be supplemented with additional information about our privacy practices that may be provided as required by applicable laws and regulations in each country where we have presence through notices provided at the time of the data collection. Further, certain BrightCell Logistics affiliated companies’ websites may have additional information not contained in this Statement that describes how we handle Personal Information for those websites specifically. To the extent that a notice provided at the time of collection, or a website-specific privacy statement has conflict with this Statement, that notice, or privacy statement will prevail. This Statement also supplements and is incorporated into the Terms and Conditions of Use for this Site.

This Statement applies to residents of the United States. You can find our Global Privacy Statement at https://brightcell-logistics.com/

This Statement may be supplemented by additional information about our privacy practices that may be provided as required by applicable laws and regulations through notices provided at the time of data collection. This Statement also supplements and is incorporated into the Terms of Use of this Site.

Our Site is not intended for persons under the age of 18. We do not knowingly collect, use or disclose personally identifiable information ("PII") from anyone under the age of 18. If we determine that a User is under this age, we will not use or maintain his or her PII without the consent of a parent or guardian. If we become aware that we have collected PII from a child under the age of 18, we will use reasonable efforts to delete such information from our systems and records. For more information about the Children's Online Privacy Protection Act (COPPA), please visit the Federal Trade Commission's website at www.ftc.gov.

2. INFORMATION COLLECTED & USES

The types of personal information collected and used by BrightCell Logistics depend on the information you provide to us and the specific activities described below.

• If you send us an e-mail: You may choose to provide us with personal information when you communicate with us by e-mail or within a Site with a comment or question. In these cases, we use the personal information you provide to respond to your request and/or improve our service to you.
• If You Register or Participate in Site Surveys: A Site may offer you the option to add your name and email address to a distribution list for information about new products and services, special offers and other marketing opportunities. A Site may also solicit your feedback or offer opportunities to participate in surveys and questionnaires from time to time. We use the information you provide in surveys and questionnaires to help us design and create better products, personalize your experience, and provide advice and purchase recommendations. We will not add your name and email address to such a list or require you to participate in surveys and questionnaires unless you affirmatively or voluntarily allow us to do so. If you choose to be added to a distribution, you may remove your name and email address at any time, as described for that distribution.
• Research Data: For certain Sites, we may conduct research on the demographics, interests and behavior of our users based on information you provide to us from surveys, questionnaires and/or our server log files. We do this to better understand and serve our users. This research is compiled and analyzed in aggregate form to avoid identifying personal information related to any individual.
• Review invitation emails: We may contact you by email to invite you to review any services and/or products you have received from us to collect your feedback, to improve our services and products (the "Purpose"). We may also use outside companies to collect your feedback, which means we will share your name, email address and reference number with them for the Purpose. Those outside companies will have their own privacy policies so you can review how they handle and protect your information.
• Website Navigation Data: If you visit our Site, we may collect information such as: your IP address or other information about your service provider or device you are using, the pages you visit, including the times and dates, and the type of browser you use to access our Site.
• Submission of complaints and/or requests for services, product registration, etc.: We may ask you to provide personal information to BrightCell Logistics. Personal information may include your name, telephone number, e-mail address, username, password, claim/service request ID, login date, and details provided by you explaining the circumstances under which you are requesting assistance or information from BrightCell Logistics or similar information. As part of the claim and/or service request process, BrightCell Logistics or its affiliates may ask you to provide a copy of your driver's license, passport, military ID or other personal identification card. In addition, in order to process your claim and/or service request, and complete your transaction, BrightCell Logistics or its affiliates may request your shipping and billing information, credit card information or other preferred means of payment. While it is your choice to only provide the requested information, we cannot provide certain services you request if you do not provide the requested non-optional personal information. By submitting personal information to BrightCell Logistics, you agree that BrightCell Logistics may use the information in accordance with this Privacy Policy. For example, BrightCell Logistics may use the information to record and fulfill your complaint or service request, process your requests, tailor, and improve BrightCell Logistics' services to better meet your needs, provide benefits to which you are entitled, and comply with regulatory or contractual requirements related to the services provided to you. If you submit such personal information to BrightCell Logistics, BrightCell Logistics may share that information with third parties, as well as use that information for the purposes for which you submitted it.

3. SHARING INFORMATION WITH THIRD PARTIES

We may provide information about a user (customer) to a third party to process that customer's request or order or to service a customer's account.

We will disclose or share Personal Information in limited circumstances where we believe in good faith that disclosure is required by applicable law, to cooperate with regulators or law enforcement authorities, to respond to claims, and to protect the rights, property or safety of BrightCell Logistics or others. This may include, for example, exchanging information with other organizations for fraud protection and credit risk reduction.

We will use your email or other address (e.g., physical address) to send you important information related to your account.

We do not share the names and email addresses of recipients of our mailing lists or the results of our surveys and questionnaires with third parties, including vendors, except as noted above (e.g., review invitation emails). However, we may share aggregated and anonymized research data with business partners in certain circumstances, such as to collect funds owed to us by the business partner or to administer our relationships with those partners.

4. WITHHOLDING OF PERSONAL INFORMATION

We will retain and use your personal information as necessary to fulfill the purposes for which it was collected and as necessary to comply with our legal obligations, resolve disputes and enforce our agreements under applicable laws.

5. COOKIES

When you access one of our Sites, our server attaches a small text file to your hard drive, called a cookie. A "cookie" assigns you a unique identifier to recognize you each time you return to our Site, allowing us to remember where you have previously been on our Site and to help us track the pages you view on our Site. Cookies help us provide a better Site experience for our users.

We use this information to understand how our users navigate our Site and to determine common traffic patterns. We may also use this information to make site navigation and product recommendations and to help redesign our Sites, better customize the content, advertisements, and promotions that you and other users will see to make your experience on our Sites more efficient and enjoyable.

You have choices regarding the information collected from the use of cookies. By modifying your browser preferences, you can accept all cookies, receive notifications when a cookie is set, or reject all cookies. If you choose to reject all cookies, you will not be able to access those services or activities that require the placement of cookies. In addition, certain aspects of the Sites may not function properly if you set your browser to reject all cookies.

6. SECURITY

Our Site uses Secure Sockets Layer (SSL) encryption technology. SSL provides server authentication, data integrity and privacy on the Web. SSL encrypts your information as it is transmitted, verifies the identity of the server and helps ensure that the original message reaches its destination.

Although no data transmission over the Internet can be guaranteed to be 100% secure, we strive to protect your information to the extent possible. Once we receive your transmission, we will make every effort to ensure its security on our systems. In addition, we have incorporated industry-accepted security measures into the design, implementation, and daily operations of our Sites.

Please note, however, that we cannot guarantee the security of any information you transmit to us or from our Sites. Nor can we be responsible for criminal acts by third parties, such as "hackers," who may attempt to compromise our security measures through illegal means. Therefore, your use of our Sites is at your own risk.

7. ENDORSEMENTS AND LINKS TO OTHER SITES

Our Sites may contain advertisements for commercial information purposes, such as hyperlinks or web addresses of other companies or organizations. When you visit such links or web addresses, you are no longer within our Site and are subject to the privacy and security policies of the new site. We do not review and are not responsible for these other privacy and security policies within other sites.

8. PROHIBITIONS OF USE

The following activities are strictly prohibited under this Declaration:

1. Use of our Sites to transmit any material (by e-mail, instant messaging, posting or otherwise) that intentionally or unintentionally violates any applicable local, state/provincial, national or international law or any rule or regulation promulgated hereunder is prohibited.
2. Use of our Sites to access or attempt to access the accounts of others or to penetrate or attempt to penetrate BrightCell Logistics' or any other entity's security measures, software or hardware, electronic communication system or telecommunications system, whether or not the intrusion results in corruption or loss of data is prohibited.
3. Use of our Sites to collect or attempt to collect information about third parties without their authorization or consent is prohibited.

9. HOW TO CONTACT US

We value your opinions and comments. If you have questions or comments regarding this Statement or wish to access or correct Personal Information held about you by BrightCell Logistics, please contact us here.: globalcomunications@brightcell-logistics.com.

10. UPDATES TO THIS STATEMENT

We may update this Statement as necessary from time to time. If we modify our Statement, we will post the revised version on our Sites with an updated revision date. To learn about and review such revisions, you agree to visit our Sites periodically. If we make material changes to our Statement, where required by applicable law, we may also notify you by other means before the changes become effective, such as posting a specific notice on our Site or sending you a notification. By continuing to use our Site after such revisions become effective, you accept and agree to abide by the updated Statement.

11. NEVADA RESIDENTS

Nevada Residents: Nevada residents have the right to opt out of having certain pieces of their information sold. We do not sell "personal information" of Nevada residents, but, if you are a Nevada resident who has questions or would like to make this type of request, please send your email to ethics&compliance@brightcell-logistics.com.

12. CALIFORNIA RESIDENTS

If you are a California resident, the California Consumer Privacy Act ("CCPA") gives you certain rights and choices regarding how we collect, share, use and protect your "personal information" and how you can exercise those rights. The CCPA defines "personal information" as information that identifies, relates to, describes, or is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to a particular consumer or household.

Exceptions.

Certain information we collect may be exempt from the CCPA because it is considered public information or is covered by financial privacy laws, such as the Gramm-Leach Bliley Act, the California Financial Information Privacy Act, the Health Insurance Portability and Accountability Act, or the Fair Credit Reporting Act.

To the extent we collect "personal information" subject to the CCPA, that information, our practices and your rights are described below.

Information we collect.

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

1. Directly from you when you provide it to us. This includes information you provide when you fill out forms on our Site or App, such as information provided at the time you register to use our Site or App, post material on the Site or App, or request further services on the Site or App.
2. Automatically as you navigate through the Site.Information collected automatically may include usage information as described above, and we may also use these technologies to collect information about your online activities over time and across third-party websites or other online services.
3. Third parties, such as our trusted business partnersThe information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based advertising or other targeted content.

We do not control the tracking technologies of these third parties or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

Sharing personal information.

We may disclose your personal information to our trusted third-party business partners and service providers for business purposes. When we share your personal information in this manner, please be assured that we have service provider agreements in place that specifically state that the service provider may not use your personal information that is shared with them for any purpose other than the business purposes set forth in the agreement.

Disclosure of personal information.

BrightCell Logistics, may disclose the following categories of personal information for marketing purposes:

• Identification;
• Categories of personal information listed in California's Customer Records statute (California Civil Code § 1798.80(e));
• Commercial information;
• Internet or other similar network activity;
• Sensory information (i.e., audio information); and
• Inferences drawn from other personal information.

We disclose your personal information for marketing purposes to the following categories of third parties:

• Non-affiliated companies to help us provide, maintain, and operate our services or marketing. These companies are required to comply with the principles set forth in this Policy and only use such information for the purposes for which it was provided to them; and
• A third-party, in the event of a purchase, sale, lease, merger, or any other acquisition, disposition, transfer, conveyance or financing of all or part of BrightCell Logistics' business or any assets or stock of BrightCell Logistics' business or a division thereof so that you continue to receive the same or similar products and services from the third party. In such a case, BrightCell Logistics will provide notice of any material changes to this Policy, or our Services, in the manner described in this Policy. In these circumstances, personal information may be shared with actual or potential purchasers or transferees, or with the newly acquired business

Your rights and options.

The CCPA gives California residents specific rights with respect to their personal information. This section describes your CCPA rights and explains how to exercise them.

1. Access to Specific Information and Data Portability Rights.

   You have the right to request that we disclose to you certain information about our collection and use of your personal information during the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

   • The categories of personal information we collect about you;
   • The categories of sources of the personal information we collect about you;
   • Our business purpose for collecting or processing that personal information;
   • The categories of third parties with whom we share that personal information;
   • The specific pieces of personal information we collect about you (also called a data portability request);
   • If we sold or disclosed your personal information for commercial purposes, two separate lists disclosing:
   • Sales, identifying the categories of personal information that each category of recipient bought; and
   • Disclosures for marketing purposes, identifying the categories of personal information collected by each category of recipient.
2. Elimination request rights.

   You have the right to request that we delete any personal information about you that we have collected and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see "Exercising Your Rights" section), we will remove (and direct our service provider(s) to remove) your personal information from our records, unless an exception applies. We may deny your request for removal if retention of the information is necessary for us or our service provider(s) in the following events.:

   • Complete the transaction for which we collected the personal information, provide a good or service you requested, take action reasonably anticipated within the context of our business relationship, fulfill the terms of a written warranty or product recall made in accordance with federal law, or otherwise enter into a contract with you.
   • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activities, or prosecute those responsible for such activities.
   • Debug products to identify and repair bugs that impair existing intended functionality.
   • Exercise free speech, ensure the right of another consumer to exercise his or her free speech rights, or exercise another right provided by law.
   • Comply with the California Electronic Communications Privacy Act (California Penal Code § 1546 et. seq.).
   • Participate in public or peer-reviewed scientific, historical or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, where deletion of the information would make the research impossible or seriously impair the accomplishment of the research, if you previously provided your informed consent.
   • To permit only internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
   • To comply with a legal obligation.
   • Make other internal and lawful uses of that information that are consistent with the context in which you provided it.

To exercise the rights of access, data portability and deletion described above, send us a verifiable consumer request to ethics&compliance@brightcell-logistics.com

You can also contact us at:
Legal Department
BrightCell Logistics Holdings, LLC.
12600 NW 25th St, Suite 100
Miami, Florida 33182, United Sates.

Only you, or someone legally authorized 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 portability of consumer data twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information to allow us to reasonably verify that you are the person about whom we are collecting personal information or an authorized representative.
• Describe your request in sufficient detail to allow us to understand, evaluate and respond to it appropriately.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm that 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 the personal information provided in a verifiable consumer application to verify the identity or authority of the applicant to make the request.

Response time and format.

We strive to respond to a consumer's verifiable request within forty-five (45) days of receipt. If we need more time (up to an additional 45 days), we will inform you in writing of the reason and the extension period. If you have an account with us, we will send our written response to you at the physical address we have on file in our databases. If you do not have an account with us, we will send you our written response by e-mail, at your option. Any disclosure we provide will only cover the 12-month period prior to receipt of the consumer's verifiable request. The response we provide will also explain the reasons why we are unable to comply with a request if it applies. For data portability requests, we will select a format for providing your personal information that is readily usable and allows you to transmit the information from one entity to another entity without hindrance. We do not charge a fee for processing or responding to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will notify you why we made that determination and provide you with a cost estimate prior to completing your request.

Non-discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not do any of the following:

• Deny you goods or services.
• Charge you different prices or fees for goods or services, including by giving discounts or other benefits, or imposing penalties.
• Provide you with a different level or quality of goods or services.
• Suggest that you may receive a different price or fee for goods or services or a different level or quality of goods or services.