Effective Date: January 10, 2024
Last Updated: January 10, 2024
This Privacy Policy describes how Mdd Capital Shipping, Inc. (“OD”, “we” or “us”) and our affiliated entities collect, use, disclose, and process your Personal Information. This Privacy Policy applies to your use of OD’s websites including www.mddcapitalshipping.com, ir.mddcapitalshipping.com, www.odmove.com, and insider.mddcapitalshipping.com, (collectively the "Sites"), as well as information collected online and offline (collectively, the “Services”), and describes our privacy practices relating to our Sites and Services.
We reserve the right to change this Privacy Policy at any time. If we change our Privacy Policy, we will post an updated version on this website. Please check back periodically to see if this Privacy Policy has been updated.
If you do not consent to the collection, use and disclosure of your Personal Information as described in this Privacy Policy, please do not use our Sites, or submit any Personal Information to us through our Services. Your continued use of our Sites and Services is your agreement to the terms of this Privacy Policy.
Who We Are
We are a leading, less-than-truckload (""), union-free, motor carrier providing regional, inter-regional, and national services through a single integrated organization. Our service offerings, which include expedited transportation, are provided through an expansive network of service centers located throughout the continental United States. Through strategic alliances, we also provide services throughout North America. In addition to our core services, we offer a range of value-added services including container drayage, truckload brokerage, and supply chain consulting.
Your Privacy is Important to Us
We value your privacy. We are committed to protecting it. We collect, use, disclose and process your Personal Information to operate our Sites and provide you with certain Services as detailed in this Privacy Policy. Before accessing, using, or interacting with the Sites and Services you should carefully review the terms of this Privacy Policy. Your use of our Sites and Services is governed by this Privacy Policy and our Terms & Conditions.
Definitions
“Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular person or household (whether alone or in combination with other information), or as defined by applicable law. “Personal Information” does not include: (i) publicly available information or lawfully obtained, truthful information that is a matter of public concern; or (ii) information that is deidentified or aggregate information.
“Sensitive Personal Information” has different meanings depending on applicable law. Sensitive Personal Information may include information such as: (a) social security, driver’s license, state identification card, or passport number, (b) account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an online account,; (c) precise geolocation, (d) racial or ethnic origin, religious or philosophical beliefs, or union membership, (e) the contents of an email and/or text messages unless OD is the intended recipient of the communication, (f) genetic data, and (g) information about a child, or (h) as Sensitive Information is defined by applicable law. Sensitive Personal Information may include the processing of biometric information for the purpose of uniquely identifying an individual, Personal Information collected and analyzed concerning an individual’s mental/physical health, and Personal Information collected/ analyzed concerning an individual’s sex life/sexual orientation. Sensitive Personal Information that is publicly available is not considered Sensitive Personal Information or Personal Information.
Personal Information We Collect About You
Set forth below are the categories of Personal Information we collect (and that have collected in the preceding 12 months), the categories of sources from which the Personal Information was collected, and the business or commercial purpose for such collection. Please note that we may not collect all the Personal Information referenced below related to you and we may not use your Personal Information for all purposes set forth in this Privacy Policy.
Category of Personal Information | What We Collect | Categories of Sources from which Personal Information is Collected | Business Purpose for Collection |
PERSONAL INFORMATION | |||
Personal Identifiers | Alias Alien Registration Number Bank Account Number Beneficiary Information Contact Information (and Relationship to Employee) Credit/Debit Card Number Country of Citizenship Date of birth Dependent information Driver’s License Number Email Address Emergency Contact Information Financial Information First/Last Name/Middle Initial Geolocation Health insurance information Insurance Policy Number Internet Protocol Address Medical Information Names of Relatives Employed by Us Online Account Login/Password Online Identifiers Passport Number Postal address Signature Social security number Telephone Number
Unique Personal Workers’ Compensation Information
| Directly from you Automatically, when you visit our Sites Automatically from systems that we use, for operations, logistics, shipping, and corporate services Our service providers | For processing operations, logistics, shipping, corporate, transactional purposes, and other services we provide To manage the recruitment process, evaluate and confirm an applicant’s qualifications for employment, and to make hiring decisions To take steps prior to entering an employment relationship with you To manage our employment relationship with our employees Security To assess your working capacity To administer benefits To contact a designated emergency contact in the event of an emergency To keep records for our business operations To protect our, customers, employees, property, equipment, and information To monitor employee performance To monitor employee statistics To enforce our policies To ensure that we are complying with our legal and contractual obligations, and to establish, exercise and defend legal and contractual rights and claims Regulatory reporting For analytics purposes For diagnostic purposes |
Protected Characteristics | Age (over 40) Color Disabilities (mental/ physical including HIV/AIDS, cancer, and genetic characteristics) Gender Identity/Gender Expression Genetic information Marital Status Medical Conditions (including genetic characteristics, cancer or a record or history of cancer) Military or Veteran Status National Origin Pregnancy, Childbirth, Breastfeeding and/or Related Medical Conditions Race Religion (includes religious dress/grooming practices) Request for Family Care Leave Request for Pregnancy Disability Leave Sex/Gender Sexual Orientation
| Directly from you Automatically when you visit our Sites | Regulatory reporting To monitor employee statistics To make reasonable accommodations for employees who have a disability To manage our employment relationship with our employees To ensure that we are complying with our legal and contractual obligations |
Commercial Information | Purchasing/Consuming Histories/Tendencies Records of Personal Property/Products/ Services Purchased/ Obtained/Considered
| Directly from you Automatically when you visit our Sites | For processing operations, logistics, shipping, corporate, transactional purposes, and other services we provide in connection with employee relocations To recruit employees and perform background screening To manage wages and expenses For reporting purposes For analytics purposes
|
Biometric Information | Fingerprints Identifying Medical Information Photographs Voice recordings
| Directly from you | To administer employee timekeeping and reporting* To manage our employment relationship with our employees Security To protect our customers, employees, property, equipment, and information To ensure that we are complying with our legal and contractual obligations, and to establish, exercise and defend legal and contractual rights and claims Regulatory reporting *Please see our biometric policy for more information
|
Internet and Other Electronic Network Activity Information | Browsing History Corporate Managed Mobile Device Usage Electronic Network Activity Information Information Interaction with our Sites/ Applications/ Advertisements Search history
| Directly from you Automatically when you visit our Sites | To manage our employment relationship with our employees To enforce our policies To operate and manage IT and communications systems and facilities Security To manage our employee programs |
Geolocation Data | Internet Protocol Address | Directly from you Automatically when you visit our Sites | To manage our employment relationship with our employees Security |
Audiovisual Information | Electronic Information (e.g., meeting recordings) Visual Information (e.g., camera footage)
| Directly from you Automatically when you visit our Sites or locations | To keep record of meetings To manage our employment relationship with our employees Security |
Professional or Employment-Information | Accomplishments/Awards Business Travel Information Discipline/Counseling information Employment History Employment Status (full-time/part-time/regular/ temporary) Employment Termination Information Hours worked Job assignments Licenses/Certification History Pay rate/Compensation Payroll deduction information Professional History Performance Evaluation Information Sanctions with Professional Bodies Training/Development Information Work Schedule | Directly from you Former employers Our service providers | To manage the recruitment process, evaluate and confirm an applicant’s qualifications for employment and to make hiring decisions To take steps prior to entering into an employment relationship with you To manage our employment relationship with our employees To assess your working capacity To keep records for our business operations To monitor employee statistics To ensure that we are complying with our legal and contractual obligations, and to establish, exercise and defend legal and contractual rights and claims Regulatory reporting
|
Education Information | Educational History | Directly from you Our service providers | See previous row |
Inferences
| Dominant Influence/Social/ Compliance Information Behavioral Assessment Information Predictive Behavior Information
| Directly from you
| To manage the recruitment process, evaluate and confirm an applicant’s qualifications for employment and to make hiring decisions To take steps prior to entering into an employment relationship with you To manage our employment relationship with our employees To assess your working capacity To recruit employees and perform background screening
|
SENSITIVE PERSONAL INFORMATION
| |||
Sensitive Personal Identifiers | Alien Identification Number Driver’s License Information/Status (including driver history/ penalties/restrictions/ expiration dates) Passport Number/ Similar Information Social Security Number State Identification Card Number
| Consumer reporting agencies Directly from you Our service providers | To monitor employee statistics To make reasonable accommodations for employees who have a disability To manage our employment relationship with our employees To ensure that we are complying with our legal and contractual obligations To recruit employees and perform background screening To manage wages and expenses To administer healthcare and other benefits Regulatory reporting |
Account Information
| OD Account Username/Password Transactional/Payment Information (including credit/debit card information)
| Directly from you | To operate and manage our IT and communications systems and facilities Security |
Precise Geolocation
| Electronic Logging Device Information from Trucks Employee Key Cards | Automatically through electronic logging device technology Directly from you | To manage workforce activities and personnel Regulatory reporting Security |
Sensitive Protected Characteristics | Racial Origin Ethnic Origin Religious Beliefs
| Directly from you
| To monitor employee statistics To make reasonable accommodations for employees To manage our employment relationship with our employees To ensure that we are complying with our legal and contractual obligations Regulatory reporting |
Contents of Communications
| Email Not Intended for Business Purposes Sent via OD Systems/ Devices/Platforms Messages/Materials In OD Systems/Devices/ Platforms Not Intended For Business Purposes | Directly from you Automatically when you use OD systems/devices/ platforms Our service providers | To monitor employee activity To manage our employment relationship with our employees To ensure that we are complying with our legal and contractual obligations Security
|
Sensitive Biometric Information | Fingerprints Identifying Medical Information Photographs Voice recordings
| Directly from you | To administer employee timekeeping and reporting* To manage our employment relationship with our employees Security To protect our customers, employees, property, equipment, and information To ensure that we are complying with our legal and contractual obligations, and to establish, exercise and defend legal and contractual rights and claims Regulatory reporting *Please see our biometric policy for more information
|
Health Information | Disability Information Family Leave Act Medical Information Health Insurance Information Job Restrictions/Medical Limitations Medical History Other Health Information Other Information to Determine Reasonable Accommodations Safety Incident Information Substance Abuse Testing Vaccine Status Workplace Accident/ Illness Information
| Directly from you Our service providers
| To manage our employment relationship with our employees To assess your working capacity To administer benefits To make reasonable accommodations for employees who have a disability To contact a designated emergency contact in the event of an emergency To keep records for our business operations Security To monitor employee statistics To ensure that we are complying with our legal and contractual obligations, and to establish, exercise and defend legal and contractual rights and claims Regulatory reporting |
Sex Life or Sexual Orientation Information | Sexual Orientation | Directly from you | To manage our employment relationship with our employees To administer benefits Regulatory reporting To comply with law or legal process, such as tax deductions, reporting, and record-keeping requirements |
We only use Sensitive Personal Information for purposes disclosed herein. We do not use or disclose Sensitive Personal Information for purposes other than those specified in this Privacy Policy.
We also collect Personal Information as necessary to respond to law enforcement/ governmental agency (e.g., Federal Motor Carrier Safety Administration) requests, comply with legal/contractual obligations, exercise legal/contractual rights, and initiate or respond to legal claims.
Aggregated/Deidentified Information - We may aggregate and/or de-identify your Personal Information so that it can no longer be linked to you. We may use and share aggregated/de-identified information for any purpose at our sole discretion.
Cookies and Tracking Technologies
Our Sites and Services use cookies and similar technologies. Cookies are small files that our Sites or Service Providers may transfer to your computer through a web browser that enables our Sites or Service Provider systems to recognize your browser and capture and remember certain information. In general, OD and our Service Providers use cookies and other technologies to optimize the functionality of our Sites, to help us understand how the Sites are used, and to provide you with interest-based content or advertising based upon browsing activity.
If you would like to opt-out of cookies, visit www.aboutcookies.org or www.allaboutcookies.org for further information. These websites also tell you how to set your browser not to accept cookies and how to remove cookies from your browser. However, some of the features on our Sites may not function if you remove or delete cookies. For more information about our use of cookies, please see our Cookies Policy.
Personal Information We Disclose About You and the Business Purposes for Disclosure
We do not sell your Personal Information and we do not share your Personal Information for cross context behavioral advertising as those terms are defined by applicable law.
Your Personal Information may be disclosed to external service providers for the sole purpose of delivering products and services to us. For example, we may disclose your Personal Information with third-party background check providers to verify the information you have provided to us obtain the necessary background checks prior to extending an offer of employment. When we disclose Personal Information to our service providers we take commercially reasonable steps, including contract terms, to maintain the confidentiality of your information against unauthorized access, use, modification, or other misuse.
The business purposes for which we disclose Personal Information to our service providers, contractors, and vendors include:
- Advertising and Marketing Services: We disclose Personal Information to our Service Providers for advertising and marketing services on our own behalf.
- Auditing of Ad Impression: We disclose Personal Information for auditing purposes related to counting ad impressions to unique visitors and verifying the positioning/quality of ad impressions.
- Functionality & Debugging: We disclose Personal Information to engage in debugging to identify and repair errors that impair functionality.
- Quality Control & Improvement of Products and Services: We disclose Personal Information to verify, maintain, and improve our products and services.
- Research & Development: We disclose Personal Information for internal research related to technological development and demonstration.
- Security and Fraud Detection: We disclose Personal Information for our security and fraud detection services including detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for such activity.
- Services on Our Behalf: We may disclose Personal Information for services performed on our behalf, including maintaining/servicing accounts, providing services for employees, processing or fulfilling requests and transactions, verifying employee information, processing payroll, expense payments, evaluating and responding to requests, providing storage, etc.
- Short-Term/Transient Use: We disclose Personal Information for short-term, transient use, including, but not limited to, non-personalized advertising that may be shown as part of your interaction with us, provided that the Personal Information is not disclosed to another third party and is not used to build a profile about you or otherwise alter your experience outside the current interaction with us.
The following chart sets forth the categories of Personal Information we have disclosed to our service providers for a business purpose over the past 12 months.
Categories of Personal Information that We Disclose | Business Purposes for the Disclosure of Personal Information | |
PERSONAL INFORMATION |
| |
Identifiers | Advertising and Marketing Services Auditing of Ad Impression Functionality & Debugging Quality Control & Improvement of Products/Services Research & Development Security and Fraud Detection Services on Our Behalf Short-Term/Transient Use | |
Protected Characteristics | Services on Our Behalf Short-Term/Transient Use | |
Commercial Information | Advertising and Marketing Services Functionality & Debugging Quality Control & Improvement of Products/Services Research & Development Security and Fraud Detection Services on Our Behalf Short-Term/Transient Use | |
Biometric Information | Functionality & Debugging Security and Fraud Detection Services on Our Behalf Short-Term/Transient Use | |
Internet Information | Advertising and Marketing Services Auditing of Ad Impression Functionality & Debugging Quality Control & Improvement of Products/Services Research & Development Security and Fraud Detection Services on Our Behalf Short-Term/Transient Use | |
Geolocation Data | Advertising and Marketing Services Auditing of Ad Impression Functionality & Debugging Quality Control & Improvement of Products/Services Research & Development Security and Fraud Detection Services on Our Behalf Short-Term/Transient Use | |
Audiovisual Information | Advertising and Marketing Services Functionality & Debugging Quality Control & Improvement of Products/Services Research & Development Security and Fraud Detection Services on Our Behalf Short-Term/Transient Use | |
Professional or Employment Information | Advertising and Marketing Services Security and Fraud Detection Services on Our Behalf Short-Term/Transient Use | |
Education Information | Advertising and Marketing Services Security and Fraud Detection Services on Our Behalf Short-Term/Transient Use | |
Inferences | Advertising and Marketing Services Services on Our Behalf Short-Term/Transient Use | |
SENSITIVE PERSONAL INFORMATION |
| |
Sensitive Personal Identifiers | Security and Fraud Detection Services on Our Behalf Short-Term/Transient Use | |
Account Information | Functionality & Debugging Security and Fraud Detection Services on Our Behalf Short-Term/Transient Use | |
Precise Geolocation | Functionality & Debugging Quality Control & Improvement of Products/Services Research & Development Security and Fraud Detection Services on Our Behalf Short-Term / Transient Use | |
Sensitive Protected Characteristics | Security and Fraud Detection Services on Our Behalf Short-Term/Transient Use | |
Contents of Communications | Functionality & Debugging Security and Fraud Detection Services on Our Behalf Short-Term/Transient Use | |
Sensitive Biometric Information | Functionality & Debugging Security and Fraud Detection Services on Our Behalf Short-Term/Transient Use | |
Sex Life or Sexual Orientation Information | Security and Fraud Detection Services on Our Behalf Short-Term/Transient Use | |
As Necessary: We may also disclose Personal Information, as necessary: (a) to comply with required legal process, (b) to respond to requests from public/government authorities, (c) to enforce our Terms & Conditions, (d) to protect our operations and to protect our/your/others’ rights, privacy, safety, property and information, and (e) to allow us to pursue available remedies or limit the damages that we may sustain. We may also use Personal Information in connection with or during negotiation of any reorganization, acquisition, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).
We only use Sensitive Personal Information for purposes disclosed herein. We do not use or disclose Sensitive Personal Information for purposes other than those specified herein.
Adobe and/or Google Analytics
Our Sites may use Adobe and/or Google Analytics to help us analyze user activity. These analytics platforms use cookies to generate information about visitors to our Sites for purposes of compiling activity reports, analyzing user interests, and providing other information related to usage of the Sites. Adobe and/or Google may transfer this information to third parties where required to do so by law, or where such third parties process information on their behalf. Adobe and Google will not associate your IP address with other data. Data collected by Adobe and Google Analytics is subject to the privacy policies of those companies. If you want to know more about how data is collected, used, and shared by Adobe and Google, please review the Adobe Privacy Policy here and the Google Privacy Policy here.
You may prevent Adobe and Google Analytics from collecting your information by disabling cookies on your browser as noted above or you may opt-out of Google’s use of cookies by visiting the Adobe or Google Analytics Opt-out Pages.
Adobe Launch and Google AdWords
Our Sites may use Adobe Launch and/or Google Tag Manager and AdWords. Both platforms are marketing tracking and remarketing services provided by Adobe and Google. OD uses these services to track and deliver online ads. Adobe Launch and Google Tag Manager share information from our Sites with another data sources (Adobe Analytics, Google Analytics) to analyze your interests and deliver content that may interest you. Both platforms use tools, such as cookies, to enable us to display ads on sites across the Internet based upon your visits to the Sites. You can personalize the ads you receive, opt-out of ads from other advertising networks, or opt-out of ads from Adobe and Google by visiting the Adobe or Google Ads Settings. For more information on Adobe’s and Google’s privacy practices, please visit Adobe’s and Google’s Privacy Policy.
DoubleClick
DoubleClick uses cookies to collect and store data about users from their browsing history to best place advertisements of interest to users. Cookies from DoubleClick may collect your browsing information and share it with Google. For more information on Google’s privacy practices, please visit Google’s Privacy Policy.
Sharing Information and User Content Through Social Media
We may share your Personal Information with social media sites that specialize in social commerce so you can connect with us through your social networks, and share information and content such as reviews, photos, text, videos, and usage data (“User Content”). We provide our social media Service Providers with access to our Sites and Services so we can generate interest in our Sites and Services among members of your social networks and to allow you to share your interest in our Sites and Services with friends in your network. These social media Service Providers may collect or register your views (including whether you liked or purchased services from us) and make those views available to us and on public portions of our Sites. For example, when you use our hashtags in a social media post or respond to one of our usage requests, your post is shared with us, and may appear on our Sites. By using our hashtags or responding to one of our usage requests, you are consenting to our use of the information you post for commercial purposes and without compensation. For more information, please see our Terms & Conditions which are incorporated herein.
If you do not agree to all of these terms, please do not submit user content to us or reply to our usage requests. If you do not want a social media platform to share information about you, you must contact that the social media provider and determine whether it gives you the opportunity to opt-out of sharing such information.
We reserve the right to select the content that appears on our Sites and social media accounts. We may choose not to display your content even if you express an opinion about our Sites and Services, use our hashtags, or affirmatively consent to a usage request. We reserve the right to remove content from our Sites and social media accounts at our sole discretion at any time and without notice.
How We Protect Your Personal Information
We take the security of your Personal Information seriously. We have implemented commercially reasonable administrative, technical, and physical safeguards to protect your Personal Information from loss, accidental destruction, misuse, as well as unauthorized disclosure and access. We accept no liability for any unauthorized disclosure of your Personal Information. You are responsible for maintaining the secrecy of any credentials used to access your account with us. You should report actual or suspected unauthorized activity to privacy@mddcapitalshipping.com immediately, and in no event later than 24 hours after discovery.
OD specifically reserves the right to terminate your access to our Sites and Services and any contract you have with us in the event we learn or suspect you have disclosed your account or password information to an unauthorized third party.
Our Retention Policy – How Long We Keep Your Personal Information
We retain your Personal Information for the periods necessary to: (a) fulfill the purposes described in this Privacy Policy, (b) meet the timelines required or recommended by regulators, professional bodies, or associations, (c) comply with applicable laws, legal holds, and other legal obligations (including contractual obligations), and (d) comply with your requests.
To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and applicable legal requirements.
Third Party Links
Our Sites and Services may contain links to third party websites and services that are not owned or controlled by us, including links to social media platforms. This Privacy Policy applies only to Personal Information collected by our Sites and Services. Links to other websites or social media platforms do not constitute or imply an endorsement or recommendation by us of the content on third party sites. Third-party sites may have their own cookies, web beacons and other tracking technologies to collect information about you or ask you to provide Personal Information directly to them. We are not responsible for the privacy and security practices of other websites or social media platforms or the Personal Information they collect. Please refer to the applicable third parties’ privacy policies to understand their privacy practices and your rights.
Email Communications
You may unsubscribe from our marketing communications by clicking the “unsubscribe” link found in every commercial email we send, or by sending us a request to unsubscribe at privacy@mddcapitalshipping.com. If you opt-out of receiving marketing email communications, we may still send you email messages related to your account with us, including specific transactions or our Services. Unsubscribing yourself from our marketing communications will not affect our service to you.
Text Messages and Alerts – Opting-in and Out
You have the choice to opt-in to receiving text messages and alerts on the mobile phone number(s) you have shared with us. Once you have opted-in, we may send you text messages (i) regarding your account; (ii) to investigate or prevent fraud; and (iii) to alert you in the event of an emergency. We may send you text messages and alerts using autodialed technology. We will not contact you via text messages or alerts for marketing purposes without your prior, express, written consent. You do not have to opt-in to text messages and alerts to use and enjoy our Sites and Services. If you opt-in, standard text messaging charges may apply.
You may choose to opt-out from our text messages/SMS and alerts at any time. Just text "STOP" to the short code. After you send the SMS message "STOP" to us, we will send you an SMS message to confirm that you have been unsubscribed. After you receive our SMS message, you will no longer receive text/SMS messages from us. If you want to join again, resubscribe and we will start sending SMS messages to you again. Please keep in mind that if you opt-out of receiving text messages and alerts we may not be able to contact you with important messages regarding your account. However, if there is an emergency or account question, we will make every attempt to contact you in other ways, such as by email or on a landline phone.
Public Forums, Community and Reviews
We offer various communities and forums across our Sites and Services, as well as the ability to provide reviews of our Services. We offer several features that allow users to connect and communicate in public or semi-public spaces as part of our Sites and Services. You do not have to use these features, but if you do, please use common sense and good judgment when posting in these communities or sharing your Personal Information with others.
Please be aware that any Personal Information you choose to submit in any communities, forums, or reviews can be read, collected, or used by others, or could be used to send unsolicited messages to you. We may engage our Service Providers to assist in providing community services to you. OD generally does not control or remove user content from public forums or communities on our Sites (though we reserve the right to do so in our sole discretion at any time without notice). Your posts may remain public if you subsequently close your account(s) with us.
Despite our safety and privacy controls, we cannot guarantee that you will not encounter inappropriate or illegal conduct from other users when using public forums on our Sites. You can help us to make our Sites (including public forums) welcoming for all users by reporting any offensive or unwelcome conduct to us.
Our Services Are Not Intended for Children
Our Sites and Services are not intended for children nor targeted to children under the age of sixteen (16). We do not knowingly collect Personal Information from children under the age of 16. If we learn that we possess information from a child under the age of 16, we will delete such information in accordance with the Children’s Online Privacy Protection Act (“COPPA”) and other applicable laws. If you are a parent or guardian and you believe that your child under the age of 16 has provided us with personal information without your consent, please contact us at privacy@mddcapitalshipping.com or 1-617-669-3639.
Do Not Track
We do not currently have the technology to automatically respond to “Do Not Track” (DNT) signals sent by web browsers, mobile devices, or other mechanisms.
Third parties, such as Google Analytics, may collect data that relates to you on our websites, across time, and over other websites. Third parties’ responsiveness to do-not-track signals is governed by their privacy policies. You also may limit certain tracking by disabling cookies in your web browser. For more information on Do Not Track, please visit https://allaboutdnt.com/.
Your Rights Regarding Your Personal Information
Depending on your state of residency, you may have certain rights related to your Personal Information. Nevada residents should refer to the “Nevada Privacy Notice” below. California residents should refer to the “Your California Privacy Rights” section below for a description of California specific rights. Your rights may now or soon include the right to: (1) confirm whether we hold or process your Personal Information, (2) request access to your Personal Information, (3) request deletion of your Personal Information, (4) obtain a copy of your Personal Information, (4) request correction of your Personal Information, (4) restrict the collection or processing of your Sensitive Personal Information, (5) opt-out of the processing of your Personal Information for targeted advertising or other purposes, (6) opt-out of the sale of your Personal Information, and (7) restrict the use of your Personal Information for certain profiling purposes.
To opt-out please call our toll free number at 1-617-669-3639, email us at privacy@mddcapitalshipping.com or submit a Consumer Request Form here.
If you submit a request related to your Personal Information, the following generally describes the process we use to verify your identity:
- Password Protected Accounts. If you have a password-protected account with us, we may use existing authentication practices to verify your identity but will require re-authentication before disclosing or deleting data. If we suspect fraudulent or malicious activity relating to your account, we will require further verification before complying with a request to know or delete.
- Verification for Non-Accountholders. If you do not have, or cannot access, a password-protected account with us, we will generally verify your identity to a reasonable degree of certainty by matching at two or three data points provided by you with reliable data points maintained by us. For valid requests to delete Personal Information, we will verify your identity to a reasonable degree or a reasonably high degree of certainty depending on the sensitivity of the Personal Information and the risk of harm posed by unauthorized deletion. We will act in good faith when determining the appropriate standard to apply.
- Verification by Authorized Agent. You may designate an authorized agent to make the above requests on your behalf if permitted by applicable law. An authorized agent must submit proof to us that the agent has been authorized by you to act on your behalf, and you will need to verify your identity directly with us through the processes described above. If you wish to submit an authorized agent request, you can do so by emailing us at privacy@mddcapitalshipping.com.
If there is no reasonable method by which we can verify your identity, we will state so in response to your request including an explanation of why we have no reasonable method to verify your identity.
There may be situations where we cannot grant your request. For example, if you ask us to delete Personal Information that we are obligated to keep to comply with applicable law, we may not be able to fulfill some or all of your request. We may also decline to grant your request where our use of your Personal Information serves a legitimate purpose such as for security purposes. Your request may also be denied if it compromises the privacy of others, is overly repetitive or extremely burdensome to fulfill.
If, after reviewing your request, we determine that we cannot honor it, we will notify you of that decision via email. If you wish to appeal any such decision, please see the Appeals process described below.
Appeal of Denials of Consumer Requests and Complaints
Depending on your state of residency, you may have the right to appeal the denial of your consumer request. To appeal the denial of a consumer request please send an email to privacy@mddcapitalshipping.com. We respond to all verifiable requests for an appeal as soon as we reasonably can and no later than legally required.
If your appeal is denied and/or you are unsatisfied with the outcome of your request, you may contact the Attorney General of your state. For residents of Colorado, Connecticut, and Virginia you may file a complaint with the attorneys general of your state using the links below:
- Residents of Colorado: https://coag.gov/file-complaint/
- Residents of Connecticut: https://www.dir.ct.gov/ag/complaint/
- Residents of Virginia: https://www.oag.state.va.us/consumercomplaintform/form/start
Nevada Privacy Notice
For residents of Nevada, please note that OD does not “sell” your Personal Information as that term is defined under Nevada law.
Your California Privacy Rights
California residents may be entitled to exercise certain privacy rights pursuant to the CCPA, as amended by the CPRA, and related regulations. Your right to submit certain requests as a California resident are described below. Please note that these rights are subject to certain exceptions and certain of these rights are subject to verification mechanisms.
- Right to Know Personal Information Collected About You. You have the right to know: (1) the categories of Personal Information we have collected about you; (2) the categories of sources from which the Personal Information is collected; (3) the business or commercial purpose for collecting and disclosing Personal Information; (4) the categories of third parties to whom we disclose Personal Information; and (5) the specific pieces of Personal Information we have collected about you. You also have the right to know the list of all third parties to whom we have disclosed Personal Information, as defined under California Civil Code Section 1798.83(e) (a/k/a the “Shine the Light Law”), during the preceding year for third-party direct marketing purposes. You may submit a request by calling us at 1-617-669-3639, emailing us at privacy@mddcapitalshipping.com.
- Right to Know Personal Information Disclosed and to Whom. You have the right to request that we disclose to you: (1) the categories of Personal Information that we collected about you; and (2) the categories of Personal Information that we disclosed about you for a business purpose and the categories of persons to whom it was disclosed for a business purpose. You may submit a request by calling us at 1-617-669-3639, emailing us at privacy@mddcapitalshipping.com.
- Right to Request Deletion of Your Personal Information. You have the right to request that we delete your Personal Information, subject to certain exceptions. Following receipt of a request, we will let you know what, if any, Personal Information we can delete from our records. If we cannot delete all your Personal Information, we will let you know the reason. You may submit a request by calling us at 1-617-669-3639, emailing us at privacy@mddcapitalshipping.com.
- Right to Correct Inaccurate Information. If you believe that any of the Personal Information, we maintain about you is inaccurate, you have the right to submit a request for us to correct that information. Upon receipt of a request, we will use commercially reasonable efforts to correct the information as you direct. You may submit a request by calling us at 1-617-669-3639, emailing us at privacy@mddcapitalshipping.com.
- Right to Opt-Out of the Sale and Sharing of Your Personal Information. As a California resident, you generally have the right to opt-out of the sale or sharing of your Personal Information. However, because we do not sell your Personal Information or use your Personal Information for cross-context behavioral advertising, this right does not apply when we collect and use your information.
- Right to Limit the Use of Your Sensitive Personal Information. We limit the use of Your Sensitive Personal Information to the purposes listed above. Therefore, this right may not apply to you.
- Right to Non-Discrimination for Exercising Your Rights. If you choose to exercise any of your rights, you have the right to not receive discriminatory treatment by us.
When you make a request to know, delete and/or correct, to help protect your privacy and maintain security, we will take steps to verify your identity. Our verification procedure may differ depending on whether you have an account with us or not and the request you are making. The following generally describes the verification processes we use:
- Password Protected Accounts. If you have a password-protected account with us, we may use existing authentication practices to verify your identity but will require re-authentication before disclosing, correcting, or deleting data. If we suspect fraudulent or malicious activity relating to your account, we will require further verification (as described below) before complying with a request to know or delete.
- Verification for Non-Accountholders. If you do not have, or cannot access, a password-protected account with us, we will generally verify your identity as follows:
- For requests to know categories of Personal Information, we will verify your identity to a reasonable degree of certainty by matching at least two data points provided by you with reliable data points maintained by us.
- For requests to know specific pieces of Personal Information, we will verify your identity to a reasonably high degree of certainty by matching at least three data points provided by you with reliable data points maintained by us. We will also require a declaration, signed under penalty of perjury, that the person requesting the information is the person whose information is the subject of the request or that person’s authorized representative. We will maintain all signed declarations as part of our records for the legally required period.
- For requests to correct or delete Personal Information, we will verify your identity to a reasonable degree or a reasonably high degree of certainty depending on the sensitivity of the Personal Information and the risk of harm posed by unauthorized deletion or change. We will act in good faith when determining the appropriate standard to apply.
If there is no reasonable method by which we can verify your identity, we will state so in response to a request to know or delete Personal Information, including an explanation of why we have no reasonable method to verify your identity.
If you use an authorized agent to submit a request to know, delete or correct, we may require the authorized agent to provide proof that you gave the agent signed permission to submit the request. We may also require you to do either of the following: (a) verify your own identity directly with us; and/or (b) directly confirm with us that you provided the authorized agent permission to submit the request. This requirement does not apply if you have provided the authorized agent with power of attorney pursuant to California Probate Code sections 4121 to 4130.
We will respond to requests to know and delete no later than 45 calendar days. If we cannot verify your request within 45 days, we may deny your request. If necessary, we may take up to an additional 45 days to respond to your request but in such an event will provide you a notice and an explanation of the reason that we will take more than 45 days to respond to your request.
Your Obligations
If you provide us with the Personal Information of any third party, you are responsible for providing a copy of this Privacy Policy (e.g., emergency contact, beneficiaries) prior to disclosing their Personal Information. If you choose to provide us with a third party's Personal Information (such as name, email, and phone number), you represent that you have the third party's permission to do so.
How to Contact Us
If you have any questions or concerns about our privacy policies and practices, please contact us by calling us at 1-617-669-3639, emailing us at privacy@mddcapitalshipping.com or by mail at:
Mdd Capital Shipping
Attention: Privacy,
500 Mdd Capital Way
Thomasville, North Carolina 10001