Privacy Policy

Last updated: 17 October 2023

  1. INTRODUCTION

Thank you for using Floship! Your trust is important to us and we’re committed to protecting the privacy and security of your personal information. The information that’s shared with us helps us to provide a great experience with Floship

This Privacy Policy describes how Floship Limited (together with any affiliated entities, “Floship”, “we”, “us”, “our” or “Data Controller”) collects, uses, processes, and discloses personal information of our clients (“Clients”, “you” or “your”), in conjunction with your access to and use of the Floship Portal and our website www.floship.com (“Website“). This Privacy Policy describes our privacy practices for all websites, platforms and services that link to it.

By registering for any of the services or products available through the Floship Portal using our Website, managing shipments via the Floship Portal (“Shipments“), or receiving a Shipment, you confirm that you have thoroughly reviewed and comprehended this Privacy Policy, along with the details regarding information collection and management as described herein. If you do not agree to the terms of this Privacy Policy, you must immediately cease using the Website and/or our Floship Portal.

We will make every reasonable effort to maintain the accuracy and updating of your personal information based on the latest updates you provide to us. If you desire to gain access to your personal information, to the extent permitted by law, we will provide you with the requested disclosure.

1.1 Definitions

If you see an undefined term in this Privacy Policy (such as “Floship Portal” or “Client”), it has the same definition as in our Terms of Service (“Terms”).

  1. INFORMATION WE COLLECT

There are three general categories of information we collect.

2.1 Information You Give to Us.

2.1.1 Information that is necessary for the use of the Floship Portal.

We ask for and collect the following personal information about you when you use the Floship Portal. This information is necessary for the adequate performance of the contract between you and us and to allow us to comply with our legal obligations. Without it, we may not be able to provide you with all the requested services.

  • Account Information. When you sign up for a Client account, we require certain information such as your first name, last name, mobile number, email address, company name and physical address etc.
  • Identity Verification Information. To help create your account and maintain a trusted environment, we may collect identity verification information (such as images of your government issued ID, passport, national ID card, or driving license, as permitted by applicable laws) or other authentication information if required, considered sensitive personal information under certain privacy laws.
  • Payment Information. To use certain features of the Floship Portal (such as placement of a Shipment order), we may require you to provide certain financial information (like your bank account or credit card information) in order to facilitate the processing of payments.
  • Shipment Information. Details about bout inbound and outbound shipment including delivery address and contact details to use Floship services. We store information which allows us to provide logistics services through our Floship portal. We obtain information including but not limited to:
    • Shipment contact information (such as shipping-related contact details like sender’s and consignee’s name, physical or email address, and phone or fax number)
    • Business contact information (such as job title, department and name of organization)
    • Government-issued identification documents (such as images of your government issued ID, passport, national ID card, driver’s license, social security or Tax ID or number to verify your identity for the purposes of conducting customs business on your behalf), considered sensitive personal information under certain privacy laws
    • Shipping Account details (In case if you want to use your shipping account to generate shipping labels, then necessary account details may be required to integrate your account to Floship Portal)
    • Product Details (such as product information with HS code, custom value and description etc as need for custom clearance etc.)
    • Country of origin information (from which country you are accessing the website)
    • Other information that may be provided to us to obtain Floship’s services
  • Communications with Floship. When you communicate with Floship, we collect information about your communication and any information you choose to provide.

2.1.2 Information you choose to give us.

You may choose to provide us with additional personal information in order to obtain a better user experience when using Floship Portal. This additional information will be processed based on our legitimate interest or when applicable, your consent.

  • Address Book Contact Information. You may choose to import your address book contacts, exporter/ importer addresses etc or enter your contacts’ information manually to access certain features of the Floship Portal, like using them to create orders on Floship Portal.
  • Other Information. You may otherwise choose to provide us information when you fill in a form, update or add information to your Client account, respond to surveys, post to community forums, participate in promotions, communicate with our customer care team, share your experience with us, or use other features of the Floship Portal.

2.1.3 Information We Automatically Collect from Your Use of the Floship Portal and Website.

When you use the Floship Portal and Website, we automatically collect personal information about the services you use and how you use them. This information is necessary for the adequate performance of the contract between you and us, to enable us to comply with legal obligations and given our legitimate interest in being able to provide and improve the functionalities of the Floship Portal and Website.

  • Geo-location Information. When you use certain features of the Floship Portal and Website, we may collect information about your precise or approximate location as determined through data such as your IP address or mobile device’s GPS to offer you an improved user experience. Most mobile devices allow you to control or disable the use of location services for applications in the device’s settings menu. Floship may also collect this information even when you are not using the app if this connection is enabled through your settings or device permissions.
  • Usage Information. We collect information about your interactions with the Floship Portal and Website such as the pages or content you view, your searches, orders you have made, and other actions on the Floship Portal and Website.
  • Log Data and Device Information. We automatically collect log data and device information when you access and use the Floship Portal and Website, even if you have not created a Client account or logged in. That information includes, among other things: details about how you’ve used the Floship Portal and Website (including if you clicked on links to third party applications), IP address, access dates and times, hardware and software information, device information, device event information, unique identifiers, crash data, cookie data, and the pages you’ve viewed or engaged with before or after using the Floship Portal and Website.
  • Cookies and Similar Technologies. We use cookies and other similar technologies when you use our platform, use our mobile app, or engage with our online ads or email communications. We may collect certain information by automated means using technologies such as cookies, web beacons, pixels, browser analysis tools, server logs, and mobile identifiers. In many cases the information we collect using cookies and other tools is only used in a non-identifiable without reference to personal information. For example, we may use information we collect to better understand website traffic patterns and to optimize our website experience. In some cases we associate the information we collect using cookies and other technology with your personal information. Our business partners may also use these tracking technologies on the Floship Website or engage others to track your behavior on our behalf.

Depending on your browser, you may be able to reject cookies outright or manually delete them. You should note, however, that rejecting or deleting cookies can affect how the site works and may reduce its usability or functionality. Because we cannot control browsers’ technical measures, we cannot speak to the effectiveness of any browser’s cookie management tool.

  • Pixels and SDKs. Third parties, including Facebook, may use cookies, web beacons, and other storage technologies to collect or receive information from our websites and elsewhere on the internet and use that information to provide measurement services and target ads. For apps, that third parties, including Facebook, may collect or receive information from your app and other apps and use that information to provide measurement services and targeted ads.
  • Do Not Track Signals. While you may disable the usage of cookies through your browser settings, the Floship Website currently does not respond to a “Do Not Track” signal in the HTTP header from your browser or mobile application due to lack of standardization regarding how that signal should be interpreted.
  • Payment Transaction Information. Floship collects information related to your payment transactions through the Floship Portal, including the payment instrument used, date and time, payment amount, payment instrument expiration date and billing postcode, PayPal email address, IBAN information, your address and other related transaction details. This information is necessary for the adequate performance of the contract between you and Floship and to allow the provision of the payment of Shipment orders.

2.1.4 Information We Collect from Third Parties.

Floship may collect information, including personal information, that others provide about you when they use the Floship Portal and/or Website, or obtain information from other sources and combine that with information we collect through the Floship Portal and Website. We do not control, supervise or respond for how the third parties providing your information process your Personal Information, and any information request regarding the disclosure of your personal information to us should be directed to such third parties.

  • Third Party Services. If you link, connect, or login to your Client account with a third-party service (e.g. Google, Facebook, WeChat), the third-party service may send us information such as your registration, friends list, and profile information from that service. This information varies and is controlled by that service or as authorized by you via your privacy settings at that service.
  • Testimonials. Your Testimonials will be published on our Website and/or on our digital media or on digital platforms (e.g. Facebook, Linkedin, Trustpilot).
  • Background Information. To the extent permitted by applicable laws, Floship may obtain reports from public records of criminal convictions or sex offender registrations. Further, to the extent permitted by applicable laws and with your consent where required, Floship may obtain the local version of police, background or registered sex offender checks. We may use your information, including your full name and date of birth, to obtain such reports.
  • Referrals. If you are invited to Floship, the person who invited you may submit personal information about you such as your email address or other contact information.
  • Other Sources. To the extent permitted by applicable law, we may receive additional information about you, such as demographic data or information to help detect fraud and safety issues, from third party service providers and/or partners, and combine it with information we have about you. For example, we may receive background check results (with your consent where required) or fraud warnings from service providers like identity verification services for our fraud prevention and risk assessment efforts. We may receive information about you and your activities on and off the Floship Portal through partnerships, or about your experiences and interactions from our partner ad networks.

2.2 Children’s Data.

Our websites and applications are not directed to children under 16 and we do not knowingly collect any personal information directly from children under 16. If you believe that we processing the personal information pertaining to a child inappropriately, we take this very seriously and urge you to contact us using the information provided under the “Contact Us” section below.

  1. HOW WE USE INFORMATION WE COLLECT

We may use, store, and process personal information to (1) provide, understand, improve, and develop the Floship Portal and Website, (2) create and maintain a trusted and safer environment (such as to comply with our legal obligations and ensure compliance with Floship’s Policies) and (3) provide, personalize, measure, and improve our advertising and marketing.

3.1 Provide, Improve, and Develop the Floship Portal and Website. We may use the personal information to provide, improve, and develop the Floship Portal and Website such as to:

  • enable you to access and use the Floship Portal and Website,
  • operate, protect, improve, and optimize the Floship Portal and Website experience, such as by performing analytics and conducting research,
  • provide customer service,
  • send you service or support messages, updates, security alerts, and account notifications,
  • if you provide us with your contacts’ information, we may process this information: (i) to facilitate your referral invitations, (ii) send your requests for references, (iii) for fraud detection and prevention, and (iv) for any purpose you authorize at the time of collection,
  • to operate, protect, improve, and optimize the Floship Portal and Website and experience, and personalize and customize your experience, and facilitate claims protection programs, we conduct profiling based on your interactions with the Floship Portal and Website, your search and order history, your profile information and preferences, and other content you submit to the Floship Portal, and
  • enable your use of our enterprise products.

We process this personal information for these purposes given our legitimate interest in improving the Floship Portal and Website and in improving our Clients’ experience with it, and where it is necessary for the adequate performance of the contract with you.

3.2 Create and Maintain a Trusted and Safer Environment. We may use the personal information to create and maintain a trusted and safer environment such as to:

  • detect and prevent fraud, spam, abuse, security incidents, and other harmful activity,
  • conduct security investigations and risk assessments,
  • verify or authenticate information or identifications provided by you,
  • conduct checks against databases and other information sources, including background or police checks, to the extent permitted by applicable laws and with your consent where required,
  • comply with our legal obligations,
  • resolve any disputes with any of our Clients and enforce our agreements with third parties,
  • enforce our Terms of Service and other policies, and
  • in connection with the activities above, we may conduct profiling based on your interactions with the Floship Portal, your profile information and other content you submit to the Floship Portal, and information obtained from third parties. In limited cases, automated processes may restrict or suspend access to the Floship Portal if such processes detect activity that we think poses a safety or other risk to the Floship Portal, our community, or third parties. If you challenge the decisioning based on the automated process, please contact us as provided in the “Contact Us” section below.

We process this personal information for these purposes given our legitimate interest in protecting the Floship Portal, to measure the adequate performance of our contract with you, and to comply with applicable laws.

3.3 Provide, Personalize, Measure, and Improve our Advertising and Marketing. We may use the personal information to provide, personalize, measure, and improve our advertising and marketing such as to:

  • send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences (including information about Floship or partner campaigns and services) and social media advertising through social media platforms such as Facebook or Google),
  • personalize, measure, and improve our advertising,
  • administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by Floship or its third-party partners,
  • conduct profiling on your characteristics and preferences (based on the information you provide to us, your interactions with the Floship Portal, information obtained from third parties, and your search and order history) to send you promotional messages, marketing, advertising and other information that we think may be of interest to you,
  • enrolling in an email subscription will not affect the frequency of administrative emails that we may send in connection with any Client account. No fee is charged for sending promotional emails to you, but third-party data rates may apply, and
  • invite you to events and relevant opportunities

We will process your personal information for the purposes listed in this Section given our legitimate interest in undertaking marketing activities to offer you products or services that may be of your interest.

3.4 How the Data Controller uses the Personal Information Collected. We may use the personal information as a part of payment related services such as to:

  • Enable you to access and use the Floship Services.
  • Detect and prevent fraud, abuse, security incidents, and other harmful activity.
  • Conduct security investigations and risk assessments.
  • Conduct checks against databases and other information sources.
  • Comply with legal obligations (such as anti-money laundering regulations).
  • Enforce the Payment Terms and other payment policies.
  • With your consent, send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences.
  • Provide effective customer service to Clients
  • Provide our Partners with Shipment information

3.5 Your Choices

You have choices on the promotional messages that you choose to receive.

  • You can limit the information you provide to Floship. Participation in promotions and marketing programs is voluntary.
  • You can limit the communications that Floship sends to you.
  • To opt-out of marketing emails, simply click the link labelled “unsubscribe” at the bottom of any marketing email we send you or access the notification settings in your Client account.
  • You can always update your notification settings within your Client account by visiting the Notifications section of your Client account. Please note that even if you opt-out of marketing communications, we may still need to contact you with important transactional information about your account. For example, even if you opt-out of emails, we may still send you activity confirmations or fraud alerts.
  1. SHARING & DISCLOSURE

We do not sell, rent, or lease customer data to third parties. However, we may share or disclose information collected from the Clients to third parties for commercial purposes, as described in this section. At all times, the sharing or disclosing of any information collected by Floship shall be done in accordance with the Personal Data (Privacy) Ordinance (Cap. 486) and may be transferred as set out herein:

4.1 Advertising and Social Media; Sharing With Your Consent.

Where you have provided consent, we share your information, including personal information, as described at the time of consent, such as when you authorize a third-party application or website to access your Client account or when you participate in promotional activities conducted by Floship’s Partners or third parties.

Where permissible according to applicable law we may use certain limited personal information about you, such as your email address, to hash it and to share it with social media platforms, such as Facebook or Google, to generate leads, drive traffic to our websites or otherwise promote our products and services or the Floship Portal. These processing activities are based on our legitimate interest in undertaking marketing activities to offer you products or services that may be if your interest.

The social media platforms with which we may share your personal information are not controlled or supervised by Floship. Therefore, any questions regarding how your social media platform service provider processes your personal information should be directed to such provider.

Please note that you may, at any time ask Floship to cease processing your data for these direct marketing purposes by sending an e-mail to marketing@floship.com.

4.2 Sharing with Partners

To help facilitate placement of Shipment Orders on Floship Portal, we may need to share certain information, including personal information, with the relevant Partner of Client’s choice, as it is necessary for the adequate performance of the contract between you and us. When you as a Client submit a Shipment order on the Floship Portal, certain information about you is shared with the Floship Partner of your choice, including your profile, full name, shipping details, your cancellation history, and other information you agree to share. When your Shipment is confirmed, we will disclose additional information to assist with coordinating the delivery of Shipment, like your phone number.

We don’t share your billing and payout information with Floship’s Partners.

4.3 Compliance with Law, Responding to Legal Requests, Preventing Harm and Protection of our Rights.

Floship may disclose your information, including personal information, to relevant courts, law enforcement, governmental authorities, tax authorities, or authorized third parties, if and to the extent we are required or permitted to do so by law or if such disclosure is reasonably necessary: (i) to comply with our legal obligations, (ii) to comply with legal process and to respond to claims asserted against Floship, (iii) to respond to valid requests relating to a criminal investigation or alleged or suspected illegal activity or any other activity that may expose us, you, or any other of our users to legal liability, (iv) to enforce and administer our Terms of Service, the Payment Terms or other agreements with Clients, or (v) to protect the rights, property or personal safety of Floship, its employees, its Clients, or members of the public. For example, tax information may be shared with tax authorities or other governmental agencies.

These disclosures may be necessary to comply with our legal obligations, for the protection of your or another person’s vital interests or for the purposes of our or a third party’s legitimate interest in keeping the Floship Portal secure, preventing harm or crime, enforcing or defending legal rights, facilitating the collection of taxes and prevention of tax fraud or preventing damage.

Where appropriate, we may notify Clients about legal requests unless: (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon Floship’s property, its Clients and the Floship Portal. In instances where we comply with legal requests without notice for these reasons, we will attempt to notify that Client about the request after the fact where appropriate and where we determine in good faith that we are no longer prevented from doing so.

4.4 Service Providers.

Floship uses a variety of third-party service providers to help us provide services related to the Floship Portal. Service providers may be located inside or outside of the European Economic Area (“EEA”).

For example, service providers may help us: (i) verify your identity or authenticate your identification documents, (ii) check information against public databases, (iii) conduct background or police checks, fraud prevention, and risk assessment, (iv) perform product development, maintenance and debugging, (v) allow the provision of the Floship Services through third party platforms and software tools (e.g. through the integration with our APIs), (vi) provide customer service, advertising, or payments services, or (vii) process, handle or assess insurance claims or other similar claims. These providers have limited access to your personal information to perform these tasks on our behalf, and are contractually bound to protect the personal information and only use the personal information in accordance with our instructions.

Floship will need to share your information, including personal information, in order to ensure the adequate performance of our contract with you.

4.5 Corporate Affiliates.

To enable or support us in operations of the Floship Portal, we may share your information, including personal information, within our corporate family of companies (both financial and non-financial entities) that are related by common ownership or control.

Additionally, we share your information, including personal information, with our corporate affiliates in order to support and integrate, promote, and to improve the Floship Portal, our Website and our affiliates’ services.

4.6 Government Registration.

In jurisdictions where Floship facilitates or requires a registration, notification, permit, or license application of a Client with a local governmental authority through the Floship Portal in accordance with local law, we may share information of participating Clients with the relevant authority, both during the application process and, if applicable, periodically thereafter, such as Client’s full name and contact details, address, identification number, shipment information etc.

4.7 Business Transfers.

If Floship undertakes or is involved in any merger, acquisition, reorganization, sale of assets, bankruptcy, or insolvency event, then we may sell, transfer or share some or all of our assets, including your information in connection with such transaction or in contemplation of such transaction (e.g., due diligence). In this event, we will notify you before your personal information is transferred and becomes subject to a different privacy policy.

4.8 Aggregated Data.

We may also share aggregated information (information about our Clients that we combine together so that it no longer identifies or references an individual Client) and other anonymized information for regulatory compliance, industry and market analysis, research, demographic profiling, marketing and advertising, and other business purposes.

  1. OTHER IMPORTANT INFORMATION

5.1 Analyzing your Communications.

We may review, scan, or analyze your communications on the Floship Portal for fraud prevention, risk assessment, regulatory compliance, investigation, product development, research, analytics, and customer support purposes. For example, as part of our fraud prevention efforts, we scan and analyze messages to mask contact information and references to other websites. In some cases, we may also scan, review, or analyze messages to debug, improve, and expand product offerings. We use automated methods where reasonably possible. However, occasionally we may need to manually review some communications, such as for fraud investigations and customer support, or to assess and improve the functionality of these automated tools. We will not review, scan, or analyze your messaging communications to send third party marketing messages to you, and we will not sell reviews or analyses of these communications.

These activities are carried out based on Floship’s legitimate interest in ensuring compliance with applicable laws and our Terms, preventing fraud, promoting safety, and improving and ensuring the adequate performance of our services.

5.2 Third Party Partners & Integrations

The Floship Portal may contain links to third party websites or services, such as third party integrations, co-branded services, or third party-branded services (“Third Party Partners”). Floship doesn’t own or control these Third-Party Partners and when you interact with them, you may be providing information directly to the Third-Party Partner, Floship, or both. These Third-Party Partners will have their own rules about the collection, use, and disclosure of information. We encourage you to review the privacy policies of the other websites you visit.

Parts of the Floship Portal may use third party services such as Google Maps/Earth services, including the Google Maps API(s). Use of these respective services is subject to their privacy policies such as Google Maps/Earth Additional Terms of Use, and the Google Privacy Policy.

  1. YOUR RIGHTS

You may exercise any of the rights described in this section before Floship’s Data Protection Officer by sending an email to marketing@floship.com. Please note that we may ask you to verify your identity and request before taking further action on your request.

6.1 Managing Your Information.

You may access and update some of your information through your Client account settings. If you have chosen to connect your Client account to a third-party application, like Facebook or Google, you can change your settings and remove permission for the app by changing your Client account settings. You are responsible for keeping your personal information up-to-date.

6.2 Rectification of Inaccurate or Incomplete Information.

You have the right to ask us to correct inaccurate or incomplete personal information about you (and which you are unable to or which you cannot update yourself related your Client account on Floship Portal).

6.3 Data Access and Portability.

In some jurisdictions, applicable law may entitle you to request copies of your personal information held by us. You may also be entitled to request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible).

6.4 Data Retention and Erasure.

We generally retain your personal information for as long as is necessary for the performance of the contract between you and us and to comply with our legal obligations. In certain jurisdictions, you can request to have all your personal information deleted entirely.” Please note that if you request the erasure of your personal information:

  • We may retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety. For example, if we suspend a Client account for fraud or safety reasons, we may retain certain information from that Client account to prevent that Client from opening a new Client account in the future.
  • We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, Floship may keep some of your information for tax, legal reporting and auditing obligations.
  • Because we maintain the Floship Portal to protect from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.

6.5 Withdrawing Consent and Restriction of Processing.

If we are processing your personal information based on your consent you may withdraw your consent at any time by changing your Client account settings or by sending a communication to Floship specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. Additionally, in some jurisdictions, applicable law may give you the right to limit the ways in which we use your personal information, in particular where (i) you contest the accuracy of your personal information; (ii) the processing is unlawful and you oppose the erasure of your personal information; (iii) we no longer need your personal information for the purposes of the processing, but you require the information for the establishment, exercise or defence of legal claims; or (iv) you have objected to the processing pursuant to Section 6.6 and pending the verification whether the legitimate grounds of Floship override your own.

6.6 Objection to Processing.

In some jurisdictions, applicable law may entitle you to require Floship not to process your personal information for certain specific purposes (including profiling) where such processing is based on legitimate interest. If you object to such processing Floship will no longer process your personal information for these purposes unless we can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise or defence of legal claims.

Where your personal information is processed for direct marketing purposes, you may, at any time ask Floship to cease processing your data for these direct marketing purposes by sending an e-mail to marketing@floship.com.

6.7 Lodging Complaints.

You have the right to lodge complaints about our data processing activities by filing a complaint with our Data Protection Officer who can be reached by the “Contact Us” section below or with a supervisory authority.

In compliance with the EU-U.S. Data Privacy Framework Principles, Floship commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to the DPF Principles. European Union, Swiss, and United Kingdom individuals with DPF inquiries or complaints should first contact our Data Protection Officer.

Floship has further committed to refer unresolved privacy complaints under the DPF Principles to an independent dispute resolution mechanism, Data Privacy Framework Services, operated by BBB National Programs. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://bbbprograms.org/programs/all-programs/dpf-consumers/ProcessForConsumers for more information and to lodge a complaint. This service is provided free of charge to you.

6.8 Notice to California residents.

If you are a California resident, you may be able to appoint an authorized agent to exercise your privacy rights on your behalf. Where we receive a request from an authorized agent, we may take actions to verify that the agent is appropriately authorized to act on your behalf, including by asking for written proof of authorization or confirming directly with you.

  1. OPERATING GLOBALLY & INTERNATIONAL TRANSFERS

To facilitate our global operations Floship may transfer, store, and process your information within our family of companies, Partners, and service providers based in Europe, India, Asia Pacific and North and South America. Laws in these countries may differ from the laws applicable to your country of residence. Floship endeavours to take necessary measures to ensure that any transfer of personal information complies with the applicable data protection laws and the personal information remains protected to the standards as described in this Privacy Policy. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your personal information.

  1. ACCOUNTABILITY FOR ONWARD TRANSFER

Floship remains responsible for personal information that is shared under the Onward Transfer Principle of EU-U.S. Data Privacy Framework and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework with third parties for external processing on our behalf as described in this Privacy Policy.

These transfers are also governed by the Standard Contractual Clauses as published by the European Commission. We comply with applicable legal requirements providing adequate protection for the transfer of personal information to countries outside of the EEA, UK or Switzerland including the Data Protection Directive 95/46/EC and, as of May 25, 2018, the General Data Protection Regulation (GDPR).

  1. SECURITY

We are continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unauthorized access, loss, destruction, or alteration. Some of the safeguards we use to protect your information are firewalls and data encryption, and information access controls. If you know or have reason to believe that your Client account credentials have been lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized use of your Client account, please contact us following the instructions in the Contact Us section below.

  1. CHANGES TO THIS PRIVACY POLICY

Floship reserves the right to modify this Privacy Policy at any time in accordance with this provision. If we make changes to this Privacy Policy, we will post the revised Privacy Policy on our Website and update the “Last Updated” date at the top of this Privacy Policy. We will also provide you with notice of the modification by email at least thirty (30) days before the date they become effective. If you disagree with the revised Privacy Policy, you may cancel your Client account. If you do not cancel your Client account before the date the revised Privacy Policy becomes effective, your continued access to or use of the Floship Portal and/or our Website will be subject to the revised Privacy Policy.

  1. CONTACT US

If you have any questions or complaints about this Privacy Policy or Floship’s information handling practices, you may email us at the email addresses provided in the relevant sections.