This section applies to Personal Information that we collect and process when you visit the In & Out Customs Sites, and in the usual course of our business, such as in connection with our recruitment, events, sales and marketing activities or when you visit our offices. In this section, "you" and "your" refer to Visitors.
Information We Collect
(i) Information you provide to us on the In & Out Customs Sites or otherwise: Our In & Out Customs Sites offer various ways to contact us, such as through form submissions, email or phone, to inquire about our company and Service. For example, we may ask you to provide certain Personal Information when you express an interest in obtaining information about us or our Service, take part in surveys, subscribe to marketing, apply for a role with In & Out Customs, or otherwise contact us. We may also collect Personal Information from you in person when you attend our events or trade shows, if you visit our offices (where you will be required to register as a visitor and provide us with certain information that may also be shared with our service providers) or via a phone call with one of our sales representatives. You may choose to provide additional information when you communicate with us or otherwise interact with us, and we may keep copies of any such communications for our records.
The Personal Information we collect may include:
- Business contact information (such as your name, phone number, email address and country);
- Professional information (such as your job title, institution or company);
- Nature of your communication;
- Marketing information (such as your contact preferences); and
- Any information you choose to provide to us when completing any ‘free text’ boxes in our forms.
The information we collect automatically includes:
- Device information: such as your IP address, your browser, device information, unique device identifiers, mobile network information, request information (speed, frequency, the site from which you linked to us (“referring page”), the name of the website you choose to visit immediately after ours (called “exit page”), information about other websites you have recently visited and the web browser you used (software used to browse the internet) including its type and language)
- Usage data: such as information about how you interact with our emails, In & Out Customs Sites, and other websites (such as the pages and files viewed, searches, operating system and system configuration information and date/time stamps associated with your usage).
We may use the information we collect through our In & Out Customs Sites and in connection with our events and marketing activities (alone or in combination with other data we collect) for a range of reasons in reliance on our legitimate interests, including:
- To provide, operate, optimize, and maintain the In & Out Customs Sites.
- To send you marketing information, product recommendations and non-transactional communications (e.g., marketing newsletters, telemarketing calls, SMS, or push notifications) about us, in accordance with your marketing preferences, including information about our products, services, promotions or events as necessary for our legitimate interest in conducting direct marketing or to the extent you have provided your prior consent.
- For recruitment purposes if you have applied for a role with In & Out Customs.
- To respond to your online inquiries and requests, and to provide you with information and access to resources or services that you have requested from us.
- To manage the In & Out Customs Sites and system administration and security.
- To manage event registrations and attendance, including sending related communications to you.
- To register visitors to our offices for security reasons and to manage non-disclosure agreements that visitors may be required to sign.
- To improve the navigation and content of the In & Out Customs Sites.
- To identify any server problems or other IT or network issues.
- To process transactions and to set up online accounts.
- To compile aggregated statistics about site usage and to better understand the preferences of our Visitors.
- To help us provide, improve and personalize our marketing activities.
- To facilitate the security and continued proper functioning of the In & Out Customs Sites.
- To carry out research and development to improve our In & Out Customs Sites, products and services.
- To conduct marketing research, advertise to you, provide personalized information about us on and off our In & Out Customs Sites, and to provide other personalized content based on your activities and interests to the extent necessary for our legitimate interests in supporting our marketing activities or advertising our Service or instances where we seek your consent.
- To carry out other legitimate business purposes, as well as other lawful purposes, such as data analysis, fraud monitoring and prevention, identifying usage trends and expanding our business activities in reliance on our legitimate interests.
- To cooperate with public and government authorities, courts or regulators in accordance with our legal obligations under applicable laws to the extent this requires the processing or disclosure of Personal Information to protect our rights or is necessary for our legitimate interest in protecting against misuse or abuse of our In & Out Customs Sites and Service, protecting personal property or safety, pursuing remedies available to us and limiting our damages, complying with judicial proceedings, court orders or legal processes, or responding to lawful requests.
- Blog. We have public blogs on the In & Out Customs Sites. Any information you include in a comment on our blog may be read, collected, and used by anyone. If your Personal Information appears on our blogs and you want it removed, contact us. If we are unable to remove your information, we will tell you why.
- Social media platforms and widgets. The In & Out Customs Sites include social media features, such as the Facebook Like button. These features may collect information about your IP address and which page you are visiting on our In & Out Customs Site, and they may set a cookie to make sure the feature functions properly. Social media features and widgets are either hosted by a third party or hosted directly on our In & Out Customs Site. We also maintain presences on social media platforms, including Facebook, Twitter, and Instagram. Any information, communications, or materials you submit to us via a social media platform is done at your own risk without any expectation of privacy. We cannot control the actions of other users of these platforms or the actions of the platforms themselves. Your interactions with those features and platforms are governed by the privacy policies of the companies that provide them.
How We Share Information
Other examples include analyzing data, hosting data, engaging technical support for our Service, processing payments, and delivering content.
(iii) Any competent law enforcement body, regulatory body, government agency, court or other third party where we believe disclosure is necessary (a) as a matter of applicable law or regulation, (b) to exercise, establish, or defend our legal rights, or (c) to protect your vital interests or those of any other person.
(v) Any other person with your consent.
Legal Basis for Processing Personal Information (EEA and UK Persons Only)
If you are located in the EEA or UK, our legal basis for collecting and using the Personal Information described above will depend on the Personal Information concerned and the specific context in which we collect it.
If you are a Member, we may need the Personal Information to perform a contract with you. In some limited cases, we may also have a legal obligation to collect Personal Information from you. If we ask you to provide Personal Information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Information is mandatory or not, as well as of the possible consequences if you do not provide your Personal Information.
Where required by law, we will collect Personal Information only where we have your consent to do so.
If you have questions or need further information concerning the legal basis on which we collect and use your Personal Information, please contact us using the contact details provided in the "Questions and Concerns" section below.
Your Choices and Opt-Outs
Members and Visitors who have opted in to our marketing emails can opt out of receiving marketing emails from us at any time by clicking the "unsubscribe" link at the bottom of our marketing messages.
Also, all opt-out requests can be made by emailing us using the contact details provided in the "Questions and Concerns" section below. Please note that some communications (such as service messages, account notifications, billing information) are considered transactional and necessary for account management, and Members cannot opt out of these messages unless you cancel your In & Out Customs account or order.
We take appropriate and reasonable technical and organizational measures designed to protect Personal Information from loss, misuse, unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in the processing and the nature of the Personal Information. If you have any questions about the security of your Personal Information, you may contact us at firstname.lastname@example.org.
(i) We operate in the United States
Our servers and offices are located in the United States, so your information may be transferred to, stored, or processed in the United States. While the data protection, privacy, and other laws of the United States might not be as comprehensive as those in your country, we take many steps to protect your privacy.
(ii) Data transfers from Switzerland, United Kingdom, or the EEA to the United States
In & Out Customs participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. We are committed to subjecting all Personal Information received from EEA member countries, United Kingdom, and Switzerland, respectively, in reliance on each Privacy Shield Framework, to each Framework’s applicable Principles. To learn more about the Privacy Shield Frameworks, visit the U.S. Department of Commerce’s Privacy Shield website.
In & Out Customs is responsible for the processing of Personal Information we receive under each Privacy Shield Framework and subsequently transfer to a third party acting as an agent on our behalf. We comply with the Privacy Shield Principles for all onward transfers of Personal Information from the EEA, United Kingdom, and Switzerland, 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 national security or law enforcement requirements.
Members located in Switzerland, United Kingdom, and the EEA are subject to our Data Processing Addendum.
(iii) Members, Contacts and Visitors located in Australia
If you are a Member, Contact or Visitor who accesses our Service in Australia, this section applies to you. We are subject to the operation of the Privacy Act 1988 ("Australian Privacy Act"). Here are the specific points you should be aware of:
- As stated in our Acceptable Use Policy, sensitive personal information is not permitted on In & Out Customs’s platform and Members are prohibited from importing or incorporating any sensitive personal information into their In & Out Customs accounts or uploading any sensitive personal information to In & Out Customs’s servers.
- Please note that if you do not provide us with your Personal Information or if you withdraw your consent for us to collect, use and disclose your Personal Information, we may be unable to provide the Service to you.
- Where we collect Personal Information of our Visitors, the Personal Information we ask you to provide will be information that is reasonably necessary for, or directly related to, one or more of our functions or activities.
- Where we say we assume an obligation about Personal Information, we will also require our contractors and subcontractors to undertake a similar obligation.
- We will not use or disclose Personal Information for the purpose of our direct marketing to you unless:
- you have consented to receive direct marketing;
- you would reasonably expect us to use your personal details for marketing; or
- we believe you may be interested in the material but it is impractical for us to obtain your consent.
- Our servers are located in the United States. In addition, we or our subcontractors may use cloud technology to store or process Personal Information, which may result in storage of data outside Australia. It is not practicable for us to specify in advance which country will have jurisdiction over this type of offshore activity. All of our subcontractors, however, are required to comply with the Australian Privacy Act in relation to the transfer or storage of Personal Information overseas.
- We may also share your Personal Information outside of Australia to our business operations in other countries. While it is not practicable for us to specify in advance each country where your Personal Information may be disclosed, typically we may disclose your Personal Information to the United States, Canada and the European Union.
- You may access the Personal Information we hold about you. If you wish to access your Personal Information, please contact us directly by emailing us at email@example.com. We will respond to all requests for access within a reasonable time.
- If you are unsatisfied with our response to a privacy matter, you may consult either an independent advisor or contact the Office of the Australian Information Commissioner for additional help. We will provide our full cooperation if you pursue this course of action.
We retain Personal Information where we have an ongoing legitimate business or legal need to do so. Our retention periods will vary depending on the type of data involved, but, generally, we'll refer to these criteria in order to determine retention period:
- Whether we have a legal or contractual need to retain the data.
- Whether the data is necessary to provide our Service.
- Whether our Members have the ability to access and delete the data within their In & Out Customs accounts.
- Whether our Members would reasonably expect that we would retain the data until they remove it or until their In & Out Customs accounts are closed or terminated.
When we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymize it or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible.
The California Consumer Privacy Act (“CCPA”) provides consumers with specific rights regarding their Personal Information. You have the right to request that businesses subject to the CCPA (which may include our Members with whom you have a relationship) disclose certain information to you about their collection and use of your Personal Information over the past 12 months. In addition, you have the right to ask such businesses to delete Personal Information collected from you, subject to certain exceptions. If the business sells Personal Information, you have a right to opt-out of that sale. Finally, a business cannot discriminate against you for exercising a CCPA right.
When offering services to its Members, In & Out Customs acts as a “service provider” under the CCPA and our receipt and collection of any consumer Personal Information is completed on behalf of our Members in order for us to provide the Service. Please direct any requests for access or deletion of your Personal Information under the CCPA to the Member with whom you have a direct relationship.
Consistent with California law, if you choose to exercise your applicable CCPA rights, we won’t charge you different prices or provide you a different quality of services. If we ever offer a financial incentive or product enhancement that is contingent upon you providing your Personal Information, we will not do so unless the benefits to you are reasonably related to the value of the Personal Information that you provide to us.
Do not Track
Changes to this Policy
Questions & Concerns
If you have any questions or comments, or if you have a concern about the way in which we have handled any privacy matter, you may contact us by postal mail or email at:
For EEA, Swiss and UK Residents:
For the purposes of EU data protection legislation, In & Out Customs, LLC is the controller of your Personal Information. Our Data Protection Officer can be contacted at firstname.lastname@example.org.
For any other Residents:
In & Out Customs, LLC
Attn. Privacy Officer
10120 Two Notch Road
Ste. 2, Unit 151
Columbia, SC 29223