Definition: The terms “we”, “us” and “our” are used to refer to APL Logistics Ltd and its Affiliates1 (collectively “APLL Group”).
We are committed to maintaining the privacy of users who access our website (the “Site”). This Privacy Policy explains the types of information we gather and what we do with it. By using the Site, you agree to the terms and policies described in this Privacy Policy.
For the purposes of applicable data protection law, including the EU General Data Protection Regulation (Regulation (EU) 2016/679) APLL Group is the data controller of information collected through this Site.
1. Information Collected on the Site
We collect personal information only from those users who choose to conduct business transactions on the Site and who have registered on the Site (“Registered Users”). We also use cookies, please see our Cookie Policy.
Personal information means information about an identifiable individual and may include your name, address, telephone and fax number, e-mail address, financial information, such as a credit card number, and employment-related information, such as may be found on a resume or job application. Personal information does not include business contact information (e.g., office address, switchboard telephone number) in those jurisdictions which do not recognize such information as being personal information.
We collect the following kinds of personal information through this Site:
a) Information about you, such as your name, address, email and other contact details, your account details when you register with us and any bank account or other payment details you give us, jobs you are interested in and your relevant experience, qualifications and salary when you apply for a job with us;
b) Information about your use of our services, such as details of your bookings;
c) Details about services we have provided to you in the past;
d) Information about your use of the Site; and
e) Any other information you provide us when you contact us, including when you use our inquiry form, telephone number, email address or write to our postal address, or which you provide to us through our ethics reporting resource.
You are responsible for maintaining the confidentiality of any User ID which may be assigned to you, as well as any account number, account name, or passwords, if applicable, for the services you utilize through the Site.
2. How we use your personal information and our lawful basis for doing so
We process your personal information for the following purposes and in accordance with the following lawful grounds:
a) to identify you and to verify your identity, for our legitimate interest of fraud detention and protection and to enable us to carry out our contract with you (if applicable);
b) to allow us to contact you for service(s) or opportunities as requested by you, such as customer service or information about the provision of our services, in accordance with our legitimate interest to communicate with customers and potential customers about our services;
c) to allow you to apply for employment and to provide you with information about a job opportunity if you have submitted a resume on-line, in accordance with our legitimate interest to hire new staff;
d) to make improvements to materials or products offered on the Site and to the Site in general, in accordance with our legitimate interest to do so;
e) to enable Registered Users to access the functionalities described on the Site, including without limitation, tracking shipments, and viewing outstanding charges, in order to fulfil our contract with you;
f) to obtain other user-specific information where we need more information to provide you with services you have requested in order to enter into or carry out a contract with you;
g) where legally required or where it is in our legitimate interest to do so, to comply with requests from law enforcement and regulatory authorities;
h) to obtain legal advice in accordance with our legitimate interest to do so, or in order to establish, exercise or defend legal claims, depending on the circumstances;
i) to consult our professional advisors, for example for audit purposes, in accordance with our legitimate interest to operate our business efficiently and transparently;
j) to investigate violations of either the Privacy Policy or the “Terms of Use” in accordance with our legitimate interest to do so; and
k) to notify Registered Users about important changes to the Site or promotions or opportunities. For this processing we rely on our legitimate interest to contact you about our services. You may always decline to receive these messages by following the process to Opt Out as described below or as described within a particular message;
l) When ordering products or services on the Site, you may be asked to provide a credit card number. Depending on the activity, some of the information that we ask you to provide is identified as mandatory and some as voluntary. If you do not provide the mandatory data with respect to a particular activity, you will not be able to engage in that activity. We process this payment information in order to carry out a contract with you.
Your e-mail address is collected to send you an e-mail message confirming your new member registration as well as confirmations for other services you transact with us on-line.
We will deactivate accounts of Registered Users that have been inactive for an extended period of time.
Registered Users may access and change their information at any time via the Site as described in Section 10 below.
3. International Transfers
When you submit personal information through this Site, you understand that this information may be transferred across national boundaries and may be stored and processed in any of the countries in which we transact business. Where we transfer personal data within the APLL Group, we have a robust agreement in place to protect your personal data and your rights, which incorporates the European Commission’s approved model clauses.
In certain countries or with respect to certain activities, the collection, transferring, storage, and processing of your information may be undertaken by our trusted third party service providers. Such third party service providers are bound by contract not to use your personal information for their own purposes and to treat the information as confidential. Where appropriate, our contracts with such third parties incorporate the European Commission’s approved model clauses to ensure that your rights are protected if we transfer your personal information outside of the European Economic Area.
4. How we share your Personal Information with Third Parties
We have established relationships with various service providers whose services are available to you from this Site or from websites that are linked to this Site or who support us by providing services which are transparent to you. Typically, these providers offer services that you might find useful, such as those that can be used in conjunction with our services and products. In order to use those services, you may be required to provide personal information to the providers.
These include, for example, providers of:
- website support and other IT services;
- payment support services;
- transport services;
- warehousing services;
- freight forwarding services;
- consolidation services;
- custom clearance services;
- ports and terminals–related services;
- legal advisors, auditors and accounts;
- ethics reporting resource; and
- all other logistics services not already mentioned above.
If we sell assets (or the assets of a division or subsidiary) to another entity, or we (or a division or subsidiary) are acquired by, or merged with, another entity, we may provide to such entity your personal information that is related to that part of our business that was sold to or merged with the other entity without your consent.
Other than as described in this Privacy Policy or as otherwise specifically communicated to you by us, we do not provide information supplied by you to any third parties, except where law, court order, or governmental authority requires or based upon the good faith belief that disclosure is necessary including, without limitation, to protect our rights when we have reason to believe that disclosing the information is necessary to identify, contact or bring legal action against someone who may be causing interference with our rights or causing harm to third parties.
5. How long we keep your Information
We hold your personal information for as long as we need to for legitimate legal or business reasons, including to comply with any regulatory obligations. How long we keep your information depends on the record types and our relationship with you.
6. Links to Third Party Websites
The Site may contain links to websites other than our own and for which we are not responsible. Such websites may collect personal information from you. These websites may send their own cookies to you, and may collect information and use it in a way inconsistent with this Privacy Policy.
When you use such websites, unless expressly provided to the contrary, the collection and use of your personal information will be governed by the privacy policy applicable to that website which should identify the entity that is collecting your personal information. Unless we explicitly state otherwise, such references in no way indicate our endorsement, recommendation or preference of any such products, services or information contained on any other site.
In some cases the third party websites are our service providers. You should be aware that our agreements with these service providers often provide that they will share with us personal information collected from you. In such instances, we may use this information in a manner consistent with this Privacy Policy.
7. Use of Cookies and Log Files
The Site does not use persistent or stored cookies; however, it does use temporary or session cookies.
Temporary or session cookies act as a randomly generated session ID; they last only while the Registered User is logged onto the Site, and are cancelled at the end of the session (i.e., the Registered User logs out of the Site or closes their Web browser program).
The Site uses temporary cookies for security purposes. Each time a Registered User logs onto the Site, the Site server generates a temporary session ID, which it associates with the user’s login name, password and device, such as a computer or mobile phone, during that particular session.
This allows the Registered User to move from page to page in the Site during a specific session, without having to re-enter the user login name and/or password. The temporary cookie allows the Site server to continuously verify that the user is a permitted user as the user moves from page to page during a specific session.
When the Registered User logs out of the Site, the temporary session ID is cancelled, and is removed from the temporary memory of the user’s device; and the association in the Site server between the temporary session ID and the specific user login name and password is also terminated.
We also use log files for anonymous site usage analysis. A “log file” is a data file that records a Registered User’s activity while using the Site.
For detailed information about cookies and how we use the cookies on our Site, see our Cookie Policy.
8. Security
We store information received from Registered Users on secure computers. Only a small number of our employees and/or contractors have physical access to these computers. We use firewalls and other security technology to prevent our computers from being accessed by unauthorized persons.
While we have taken measures to protect Registered Users’ information, please know that (i) no computer system is immune from intrusion; and (ii) information transmitted to the Site may need to pass through many systems in order to process such information. Therefore, we cannot guarantee the absolute security or confidentiality of information transmitted to the Site.
9. Changes to this Privacy Policy
We may alter, update or otherwise change this Privacy Policy at any time to reflect material changes in the way we use your information. Any such changes will be posted on this page. You should periodically check this Privacy Policy to review the current terms and guidelines applicable to your use. Your continued use of the Site following the posting of such changes will indicate your full acceptance of those changes.
10. Your Rights, and Updating Your Personal Information
At any time, you can access and correct your personal information and update your privacy preferences, including exercising your right to unsubscribe as a Registered User of the Site, by sending an e-mail to Global_Marketing@apllogistics.com.
As a Registered User, you will occasionally receive e-mail messages from us about products and services we offer which we think you might be interested in. If you would prefer not to receive these messages you may opt out by following the instructions within the e-mail message or by contacting us. We reserve the right to limit certain services to Registered Users who will accept e-mail messages.
Where European Union or EU Member State law applies, depending on the lawful grounds which we are using to process the personal information in question and on your reasons, you also have the rights to ask us to:
a) delete your information,
b) correct (rectify) it,
c) restrict it (i.e. stop us from using it),
d) object to us using it for marketing or other purposes, and
e) to ask us to transfer it to an alternative service provider.
Our response will depend on our justification for processing the personal information and on the lawful grounds we are relying on for processing that information.
Please use the contact details below when you contact us to exercise your rights. In your communication to us, please provide proof of your identification (such as a copy of your passport, driving licence or other valid ID card and a proof of address such as a recent utility bill).
In the European Economic Area (EEA) you also have the right to complain to your local data protection supervisory authority if you feel that we have not respected your data protection rights under EEA data protection law. You can rel=”noopener noreferrer” find a list of European rel=”noopener noreferrer” supervisory authorities here.
11. Contact Us
If you have any inquiries or concerns with respect to your personal information or you have other related inquiries or concerns, you may write to either of our Data Protection Officers:
Mr. Nicolas Reinheimer (located in Germany) Email: n.reinheimer@fkc-gmbh.de
Mr. Eric Lee (located in U.S.) Email: Eric_Lee@apllogistics.com
In your communication to us, please describe in as much detail as possible the nature of your inquiry or the ways in which you believe that this Privacy Policy has not been complied with so that we may investigate your inquiry.
Please note that if you provide us with inconsistent privacy preferences (for example, by indicating on one occasion that third parties may contact you with marketing offers and indicating on another occasion that they may not), we cannot guarantee that your most recent privacy preference will be honored.
1“Affiliate” means any entity within APLL Group from time to time which is directly or indirectly controlled by APL Logistics Ltd, or is in a joint venture with APL Logistics Ltd. The amount of controlling interest of any Affiliate must be at least fifty percent (50%) of the voting power, or a smaller interest that is the maximum interest permitted in a jurisdiction.