Effective Date: 09/08/2011

Data2Logistics, LLC (“Data2Logistics”) has been awarded TRUSTe's Privacy Seal signifying that this privacy policy and practices have been reviewed by TRUSTe for compliance with TRUSTe's program requirements including transparency, accountability and choice regarding the collection and use of your Personal Data. TRUSTe's mission, as an independent third party, is to accelerate online trust among consumers and organizations globally through its leading privacy trustmark and innovative trust solutions. If you have questions or complaints regarding our privacy policy or practices, please contact us at Privacy@Data2Logistics.com. If you are not satisfied with our response you can contact TRUSTe here. The TRUSTe program covers only information that is collected through this Web site, and does not cover information that may be collected through our applications

Data2Logistics complies with the U.S. – E.U. Safe Harbor framework and the U.S. - Swiss Safe Harbor framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data from European Union member countries and Switzerland. Data2Logistics has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Data2Logistics’ certification, please visit http://export.gov/safeharbor.

If you have questions or concerns regarding this Policy, you should first contact Privacy@Data2Logistics.com. If contacting us does not resolve your complaint, you may raise your complaint with TRUSTe by Internet at http://www.truste.org/consumers/watchdog_complaint.php, by mail at WatchDog Complaints, TRUSTe, 55 Second Street, 2nd Floor, San Francisco, CA, USA 94105, by phone at 415-520-3400, or by fax at 415-520-3420. If you are mailing TRUSTe to lodge a complaint, you must include the following information: the name of company, the alleged privacy violation, your contact information, and whether you would like the particulars of your complaint shared with the company. For information about TRUSTe or the operation of TRUSTe's dispute resolution process, see http://www.truste.org/consumers/watchdog_complaint.php or request this information from TRUSTe at any of the addresses listed above. The TRUSTe dispute resolution process shall be conducted in English.

Data2Logistics collects and uses Personal Data to provide world-class services for our employees, clients, and partners. This Policy is designed to set forth how Data2Logistics handles Personal Data that it collects in the normal course of business on www.data2logistics.com and via other methods. We will share your personal information with third parties only in the ways that are described in this privacy statement. We do not sell your Personal Data to third parties. Data2Logistics strives to be global and consistent in how it handles personal data. Our privacy policy applies to: 1. All individuals who provide Personal Data, such as consumers, clients, research subjects, job applicants, and others; 2. All locations where we operate, even where local regulations do not exist; and 3. Information supplied via other methods, such as in person, written, via the Internet, direct mail, telephone, or facsimile may be collected as well.

This Policy describes Data2Logistics’ standard global procedure governing access to and use of Data2Logistics’ Personal Data across borders. As part of this Policy, Data2Logistics will comply in all material respects with the European Union Privacy Directive (Directive 95/46/EC) and implementing legislation enacted by the member states of the European Union with respect to its operations in those member states, and other privacy laws, rules, and regulations that may apply to Data2Logistics, its employees, or its clients in those countries where Data2Logistics has operations.

This Policy is also designed to inform all employees about their obligation to protect the privacy of all individuals (whether co-employees, independent contractors, sub-contractors or clients) and the security of their personal information. The violation of this Policy, whether negligent or intentional, will be subject to disciplinary action by Data2Logistics.

SCOPE
This is a Global Policy. Data2Logistics will extend the protection of the Safe Harbor Privacy Principles to all personal data originating outside of the United States, and which is transferred to Data2Logistics facilities in the United States. Outside of the United States, Data2Logistics facilities are required to comply with this Policy as well as the privacy laws in force in their local jurisdictions

DEFINITIONS
“Controller,” in this case, refers to Data2Logistics and its authorized representatives, which determine the purposes and means of processing of Personal Data.

“Data Subject” in this case refers to any third person who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his or her physical, physiological, mental, economic, cultural or social identity.

“General Business Purpose” means the Processing of Personal Data for any activity related to the commercial operations of Data2Logistics’ worldwide organization. This could include, but is not limited to its sales, marketing, and research and development operations; protecting intellectual property; the provision of services; internal operations.

“Personal Data” means any information related to an identified or an identifiable person. For example, a Data Subject’s home address, e-mail address and/or phone number, would constitute Personal Data.

“Processor” means a natural or legal person, or any other entity that processes Personal Data on behalf of the Controller and under its control. Data2Logistics requires Processors to protect the privacy, confidentiality and security of Data2Logistics Personal Data.

“Processing” of Personal Data means any operation or set of operations which is performed upon Personal Data, whether or not by automatic means, such as collection, recording, organization, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, erasure or destruction.

“Data2Logistics” means Data2Logistics, LLC, as well as its subsidiary companies.

“Sensitive Data” is a subset of Personal Data, and refers to any Personal Data pertaining to racial or ethnic origins, trade union membership, medical or health conditions, political or religious beliefs, sex life, or criminal history.

“Third Party” means any natural or legal person, public authority, agency or any other entity other than the Data Subject, the Controller, the Processor and the persons who, under the direct authority of the Controller or the Processor, are authorized to process the Personal Data.

GENERAL

Data2Logistics Global Data Privacy Policy (“Policy”) has been designed to comply with the Safe Harbor Privacy Principles. The European Commission has determined that U.S. based companies that comply with the Safe Harbor Privacy Principles provide an adequate degree of privacy protection. Accordingly, transfers to Data2Logistics facilities in the United States satisfy the requirements of the EU Directive on Data Protection (Directive 95/46). For more information about the Safe Harbor Privacy Principles and to view our certification, visit the U.S. Department of Commerce's Safe Harbor Web site [http://export.gov/safeharbor] If you would like to contact us directly about Safe Harbor, please send an e-mail to Privacy@Data2Logistics.com

How We Use and Safeguard Personal Data
As needed, authorized individuals within Data2Logistics may from time to time utilize and/or transfer the Data Subject’s Personal Data among various Data2Logistics worldwide locations. These international transfers of Personal Data are necessary in order to carry out Data2Logistics’ General Business Purposes. To safeguard this Personal Data, and to comply with current legal requirements, Data2Logistics has formalized and implemented a standard global procedure governing access to and use of Personal Data across borders. Data2Logistics collects certain Personal Data which is not Sensitive Data such as name, email address, mailing address, and phone number from individuals who wish to contact us for more information regarding our products, or with questions or problems.

Tracking Technologies

Cookies
A cookie is a small text file that is stored on a user’s computer for record-keeping purposes. We use cookies on this site. We do link the information we store in cookies to Personal Data you submit while on our site. We use only session ID cookies. We use session cookies to make it easier for you to navigate our site. A session ID cookie expires when you close your browser. We do not use persistent cookies which remain on your hard drive for an extended period of time. You can remove persistent cookies by following directions provided in your Internet browser’s “help” file. If you reject cookies, you may still use our site, but your ability to use some areas of our site will be limited. The use of cookies by our partners, affiliates, tracking utility company, service providers is not covered by our privacy statement. We do not have access or control over these cookies. Our partners, affiliates, tracking utility company, service providers use session ID cookies for their own tracking purposes

Clear Gifs
We may employ or our third party advertising partner may employ a software technology called clear gifs (a.k.a. Web Beacons/Web Bugs), that help us better manage content on our site by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users. In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly on Web pages and are about the size of the period at the end of this sentence. We do not tie the information gathered by clear gifs to our customers’ Personal Data.

Log Files
As is true of most Web sites, we may use third party tracking-utility technology or partners to gather certain information automatically and store it in log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. We may use this information, which does not identify individual users, to analyze trends, to administer the site, to track users’ movements around the site and to gather demographic information about our user base as a whole.

POLICY

Quality of Personal Data
Data2Logistics will take reasonable steps that Personal Data and Sensitive Data are: a. Obtained, where possible, directly from the Data Subject to whom the Personal Data relates; b. Obtained and processed fairly and lawfully by Data2Logistics for and General Business Purposes; c. Relevant to and no more revealing than is necessary for General Business Purposes; and d. Kept up to date to maintain data accuracy while data is under the control of Data2Logistics and kept only for so long as is reasonably necessary.

Notice and Use of Personal Data
Data2Logistics informs Data Subjects what information we collect, how it is used, whether it may be temporarily transferred to others to provide the products or services requested and how to contact Data2Logistics with privacy inquiries. Data2Logistics’ use of Personal Data and Sensitive Data will be limited to General Business Purposes, and will not be kept longer than is necessary.

Individual Rights of Access to Personal Data
Data2Logistics takes steps to make sure that the personal information it uses is correct. Data2Logistics will allow Data Subjects reasonable access to Personal Data and Sensitive Data about themselves during normal working hours and upon reasonable request and will be allowed to update and/or correct any inaccurate information.

Security of Personal Data
Data2Logistics will take reasonable precautions to protect Personal Data and Sensitive Data from loss, misuse, unauthorized access, disclosure, alteration and destruction. For these purposes, Data2Logistics will classify such data into three levels of security within Data2Logistics:

 a.   Level 1 (known as “Data2Logistics Public Data”)
This is Personal Data such as job title, workplace location, office telephone number and/or e-mail address. Data2Logistics Public Data will be available for unrestricted use within Data2Logistics and/or to Processors. Data2Logistics Public Data may be disclosed outside of Data2Logistics for General Business Purposes.

 b.   Level 2 (known as “Data2Logistics Private Data”)
This is Personal Data such as the data subject’s home contact information, e.g., home address, home e-mail address, and home telephone number. Data2Logistics Private Data can only be disclosed for General Business Purposes to authorized personnel within Data2Logistics and to Processors who are authorized to access and/or use such Data2Logistics Private Data on behalf of a Data2Logistics business unit. It will be disclosed to Third Parties only with the prior written permission of the concerned, except as may be allowed under EU law or the Safe Harbor Principles.

 c.   Level 3 (known as “Data2Logistics Sensitive Data”)
Sensitive Data will be treated as highly-restricted data by Data2Logistics and will be stored locally. Transfers of Data2Logistics Sensitive Data, either outside the country of origin or outside of Data2Logistics, will occur only as required for General Business Purposes. Recipients of Data2Logistics Sensitive Data may include authorized Data2Logistics Users or Processors who are authorized to access and/or use such Sensitive Data by a Controller authorized to have access to such Data2Logistics Sensitive Data. Data2Logistics Sensitive Data will be disclosed to Third Parties only with the prior written permission of the Data Subject, except as may be allowed under EU law or the Safe Harbor Principles.

We may also disclose your Personal Data as required by law and when we believe that disclosure is necessary to protect our rights and/or to comply with a judicial proceeding, court order, or legal process served on our Web site. Additionally, following a merger, acquisition, or sale of all or a portion of Data2Logistics’ assets, you will be notified via a prominent notice on our Web site of any change in ownership, as well as any choices you may have regarding your Personal Data.

Accountability
Data2Logistics expects its employees, independent contractors, subcontractors, and partners to maintain the trust placed in Data2Logistics by those Data Subjects who provide Personal Data to Data2Logistics. Data2Logistics provides privacy training to its employees to highlight the importance of privacy in its global business conduct program. Those who manage Personal Data complete periodic privacy self assessments to make sure that Personal Data is secure and protected. We also use other third parties such as an email service provider to send out emails on our behalf. When you provide us with your Personal Data, we will share your Personal Data only as necessary for the third party to provide that service. Data2Logistics will periodically audit privacy compliance, and where necessary, will extend by contract its privacy policies and data protection practices to Data2Logistics’ supplier and partner relationships.

Procedure for Accessing Personal Data Data2Logistics must receive specific authorization in order to access Personal Data and Sensitive Data classified as Level 2 and above, except when a Data Subject requests access to his or her own data. You may correct, update, delete or deactivate your personal information by emailing our Customer Support at CustomerSupport@Data2Logistics.com. We will respond to your request to access within 30 days.

Transfer of Data
Subject to this policy, Data2Logistics may from time to time transfer Personal Data and Sensitive Data within and between its various worldwide locations for General Business Purposes, in compliance with country of origin regulations, EU law, and the Safe Harbor Privacy Principles and this Policy. Data2Logistics’ personnel, partners, affiliates, tracking utility company, service providers, consultants, and clients who receive Personal Data may be located in the Data Subject’s home country, the United States, or any other country in which Data2Logistics or its affiliates do business. Therefore, Personal Data may be transferred to any country in the world, including but not limited to The Netherlands, the United States of America, and other countries where Data2Logistics does business, and where the privacy laws may be more or less protective than the privacy laws where the Data Subjects live or work.

Testimonials
We post client testimonials on our web site which may contain personally identifiable information. We do obtain the client's consent via email prior to posting the testimonial to post their name along with their testimonial. If you wish to request the removal of your testimonial you may contact us at CustomerSupport@Data2Logistics.com.

Surveys
From time-to-time we may provide you the opportunity to participate in surveys via email. If you participate, we will request certain personally identifiable information from you. Participation in these surveys is completely voluntary and you therefore have a choice whether or not to disclose this information. The requested information typically includes contact information (such as name and shipping address), and demographic information (such as zip code). We use this information to gather feedback and insight from our clients regarding our performance, desired enhancements, process improvements, new service offerings, etc. We use the information for internal training purposes, to design and prioritize the development of new service features and to improve our service delivery.

Links to Other Web Sites
Our Site includes links to other Web sites whose privacy practices may differ from those of Data2Logistics. If you submit personal information to any of those sites, your information is governed by their privacy statements. We encourage you to carefully read the privacy statement of any Web site you visit.

Service-related Announcements
We will send you strictly service-related announcements on rare occasions when it is necessary to do so. For instance, if our service is temporarily suspended for maintenance, we might send you an email. Generally, you may not opt-out of these communications, which are not promotional in nature.

Status of Policy
This policy is subject to change, and Data2Logistics will provide updates from time to time about changes to this policy. In case of the sale of the company, acquisition or merger, bankruptcy or other change in corporate status, this Policy could change. In addition, this Policy may be supplemented by other company policies and statements. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this Site prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

For More Information
Questions or concerns about how Data2Logistics handles employee Personal Data are to be directed to the Data Subjects supervisor or in-country human resources manager. If the human resource manager cannot answer the question, it will be directed to the Director of Human Resources. Clients and other interested parties may contact us at Privacy@Data2Logistics.com or via postal mail at Data2Logistics, 12631 Westlinks Drive Suite 3 - Fort Myers FL 33913.