Privacy Policy
The Expeditor Transport Services (TEX)
Privacy Policy Effective date is Wednesday, January 1, 2020.
This is the privacy policy ("Privacy Policy") for information
collected by The Expeditor Transport Services, Inc. (together TEX) and for https://www.thExpeditor.com
("Site"). The Site
is operated by or on behalf of TEX.
Our Privacy Policy explains:
● What information we collect and why we
collect it.
● How we use that information.
● The choices we offer, including how to
access and update information.
Weve tried to keep this Privacy Policy
as simple as possible but if you have any questions, please feel free to
contact us at privacy@thExpeditor.com.
We collect information to provide better
services to all those with whom we deal. We collect information in the
following ways:
● Information
you give us. For
example, information that you provide to us when contacting us for inquiries
about potential investment or other commercial opportunities, employment
details if you send us a CV, resumι or other details
of your employment history in connection with an advertised job vacancy or a
general enquiry regarding employment opportunities with us. When you do, we may
ask for personal information like your name, email address, telephone number
and other details.
● Information
we collect or receive in the course of our investment business. We may receive or collect personal
information in the course of our investment activities, such as when
researching potential investment opportunities or in conducting our legal and
commercial due diligence. This could include, for example, information about
the management and other personnel at a company
we may be assessing an investment in.
● Information
we get from your use of our Site.
We may collect information about the parts of the Site that you use and how you
use it. This information includes:
We may collect
device-specific information (such as your hardware model, operating system
version, unique device identifiers, and mobile network information including
phone number).
When you use our Site, we may
automatically collect and store certain information in server logs. This may include:
●
details
of how you used our Site;
●
Internet
protocol address;
● device event information, such as
crashes, system activity, hardware settings, browser type, browser language,
the date and time of your request and referral URL; and/or
● cookies that may uniquely identify your browser.
We may collect and process
information about your actual location and use various technologies to
determine location, including IP address.
We may collect and store
information (including personal information) locally on your device using
mechanisms such as browser web storage (including HTML 5) and application data
caches.
We may use various
technologies to collect and store information when you visit our Site, and this
may include using cookies or similar technologies to identify your browser or
device. You may set your browser to block all cookies, including cookies
associated with this Site or to indicate when a cookie is being set by us.
We use personal information
to manage and operate our business, including to explore new
investment opportunities, manage our existing portfolio, develop and maintain
our contacts and recruit staff. Where necessary, we may also use
personal information to protect the interests of TEX, our employees and
affiliates (for example in the event of a legal claim).
When you contact us, we keep
a record of your communication to help solve any issues you might be facing. We
may use your email address to inform you about our business, such as letting
you know about upcoming events or changes to our business.
We use the information we
collect from our Site to provide, maintain, protect and improve it and to
protect our users. We may use information collected from cookies and other
technologies to improve your user experience and the overall quality of our
Site.
If data protection law
applies to our processing of your personal information, it is important that
you know the lawful basis on which we process your personal information.
We rely on the following
legal basis, under the data protection law, to process your personal data:
● Where we have obtained your consent, for
example to action a request from you or respond to your specific query. You can
withdraw your consent at any time, but we may still need to retain a record of
your correspondence with us.
● Where it is necessary for the purposes of
our legitimate interests to manage our existing investments and explore new
investment opportunities, including conducting legal and commercial due diligence.
● Where it is necessary to comply with a
legal obligation, for example under anti-money laundering or anti-bribery legislation.
TEX is headquartered in the
US, with an office in the US. Consequently, any information we collect will be
transferred to, and stored in, the US and other countries where the data
protection laws may offer a lower standard of protection than in your country
of residence. Where personal information is transferred outside the US, we will
take all steps reasonably necessary to ensure that it is subject to appropriate
safeguards and that it is treated securely and in accordance with this Privacy Policy.
TEX Management Company,
L.L.C. has certified to the U.S. Department of Commerce that it adheres to the
Privacy Shield Principles. We comply with the -U.S and Swiss-US Privacy Shield
Frameworks as set forth by the U.S. Department of Commerce regarding the
collection, use, and retention of personal information transferred to the
United States, respectively. If there is any conflict between the terms in this
Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles
shall govern. To learn more about the Privacy Shield
Framework, and to view our certification.
We are responsible and remain
liable for the processing of personal information we receive, under the Privacy
Shield Frameworks, including if we subsequently transfer to a third party
acting as an agent on its behalf. We comply with the Privacy Shield Principles
for all onward transfers of personal information from the United States,
including the onward transfer liability provisions.
With respect to personal
information received or transferred pursuant to the Privacy Shield Frameworks,
we are subject to the regulatory enforcement powers of the U.S. Federal Trade
Commission. In certain situations, we may be required to disclose personal
information in response to lawful requests by public authorities, including to meet US national security or law enforcement
requirements.
In compliance with the
Privacy Shield Principles, we commit to resolve complaints about our collection
or use of your personal information. Inquiries or complaints regarding our
Privacy Shield policy should first contact us at privacy@TEX.com.
TEX is subject to the
investigatory and enforcement powers of the U.S. Federal Trade Commission. TEX
may be required to share your personal information, including the disclosure of
US personal information, to public authorities and law enforcement agencies in
response to lawful requests, including requests to meet national security and
law enforcement requirements.
We will comply with any
requests to exercise your rights in accordance with applicable law, and so
there may be circumstances where we are entitled to refuse your request. For example,
where permitted to by law, we may reject requests that are unreasonably
repetitive, require disproportionate technical effort (for example, developing
a new system or fundamentally changing an existing practice), risk the privacy
of others, or would be extremely impractical (for instance, requests concerning
information residing on backup systems).
Where we can provide
information access and correction, we will do so free of charge, except where
it would require a disproportionate effort (where we are permitted to charge a
fee under applicable law). We aim to maintain any information we hold and our
Site in a manner that protects information from accidental or malicious
destruction.
To make any requests
regarding your personal information, or if you have any questions or concerns
regarding your personal information, you should contact us at privacy@TEX.co. You are also entitled to contact your
local supervisory authority for data protection. In the US, the data protection
authority is the Information Commissioners Office.
You have the right to object
(opt-out) of your personal information being used for purposes which are materially different to the purposes
for which it was collected, as described in this
Privacy Policy (including being disclosed to a third party). We may refuse your
request where we have a right to do so (for example, if the use is necessary to
comply with a legal obligation). To exercise any of your rights, please contact
us at privacy@TEX.com
We do not sell your personal
information. We share personal information with companies, organizations and
individuals outside of TEX in the following circumstances:
We may share personal
information with companies, organizations or individuals outside TEX when we
have your consent to do so.
We provide personal
information to our affiliates or other trusted businesses or persons to process
it for us or for similar reasons (for example, in connection with using shared
compute resources and servers), based on our instructions and in compliance
with our Privacy Policy and any other appropriate confidentiality and security
measures.
We share information with our
legal and other professional advisors, for example if they are advising us on
an investment transaction or where otherwise necessary to obtain their advice.
We may share personal
information with companies, organizations or individuals outside TEX if we have
a belief in good faith that access, use, preservation or disclosure of the
information is reasonably necessary to:
●
meet
any applicable law, regulation, legal process or enforceable governmental request;
●
enforce
applicable terms of service, including investigation of potential violations;
●
detect,
prevent or otherwise address fraud, security or technical issues; and/or protect
against harm to the rights, property or safety of TEX, our users or the public,
as required or permitted by law.
If TEX is involved in a
merger, acquisition or asset sale of TEX, we will use reasonable endeavors to
ensure the personal information we process continues to be subject to the same
protections set out in this Privacy Policy.
We work hard to protect our
Site and any information that we hold from unauthorized access or unauthorized
alteration, disclosure or destruction. In particular:
●
We
review our information collection, storage and processing practices, including
physical security measures, to guard against unauthorized access to systems.
●
We
restrict access to personal information to TEX employees, contractors, service
providers and agents who need to know that information in order to process it
for us and who are subject to strict contractual confidentiality obligations.
They may be disciplined or their contract
terminated if they fail to meet these obligations.
Our Privacy Policy applies to
all of the services offered and businesses operated by TEX
but excludes services and businesses that have separate privacy policies
that do not incorporate this Privacy Policy.
Our Privacy Policy does not
apply to services offered or businesses operated by other companies or
individuals. Our Privacy Policy does not cover the information practices of
other companies and organizations that advertise our services and that may use
cookies, pixel tags and other technologies.
Our Privacy Policy may change
from time to time. We will post any Privacy Policy changes on this page and, if
deemed necessary, we will provide a more prominent notice.
Please submit any questions,
concerns or comments you have about this Privacy Policy or any requests
concerning your personal information by email to privacy@TEX.com.
For the purposes of US data
protection law, The Expeditor Transport Services, or TEX US Management is the
data controller of your personal information.