Privacy Policy

Last Updated: January 31, 2023

SPI Logistics, Inc. (“SPI,” “we,” “us,” or “our”) respects your privacy. We provide this website privacy policy (“Privacy Policy”) to describe how we collect, use, disclose, or otherwise process such data (including personal data) that we and our suppliers collect through our website (“Collected Information”) and our other websites on which this Privacy Policy is posted, on our mobile application(s) on which this Privacy Policy is posted, as well as the services made available through such websites (collectively referred to as the “Sites”). This Privacy Policy also describes your choices regarding the use of your Collected Information and how we communicate changes to this Privacy Policy.

CHANGES TO THIS PRIVACY POLICY

We reserve the right to update this Privacy Policy at any time. All updates will be effective immediately upon posting of the updated Privacy Policy on the Site. Material changes will be clearly posted on the Site or otherwise communicated to you.

INFORMATION YOU SUBMIT

Personal Information. You can visit the Site without submitting your personal information to us but you will be required to provide your personal information in order to sign up for an account on the Site (where that option is available), to order or purchase products or services using the Site (where that option is available), and to use certain other tools and features of the Site. We will collect any personal information from or about you that you choose to provide to us, which may include, without limitation, your first and last name, physical address, telephone number, email address, and payment information. To sign up for an account on the Site, where that option is available, you may be required or given the opportunity to provide additional types of information (as described below). Any such information that you choose to submit will be collected by SPI. We will use your personal information as described below in this Privacy Policy, including to set up and administer your account and to communicate with you.

Phone Numbers. If you provide a mobile or other telephone number to us, you consent to receiving text messages and telephone calls from us at that telephone number as described below, but only to the extent permitted by applicable law.

Registration and Logins. To sign up for an account, you must provide specific information, including without limitation, personal information, such as financial and payment information to facilitate purchase you make through the Site. Once you are registered (where that option is available), when you login to your account, we will collect your login username, password, and email address (if applicable).

Order & Payment Information. We request information from you when you fill out an order form or otherwise purchase products or services through the Site.

Job Applications. If you submit a resume, job application, or related materials or other information to us, we may use that information to evaluate your qualifications and consider or respond to your inquiry or application. Your submission of a resume, job application, or related information does not in any way require SPI to review that information or consider you for employment. To view career opportunities at SPI or to submit a job application, you may be redirected to an online career portal operated by a third party. We encourage you to review any terms and privacy policies posted on that portal (if applicable).

Contact Form, Quotes, Requests for Support. To contact us for more information, quotes for our applicable products and services, or to request support via the Site, you will need to provide your contact information (as discussed above) as applicable, details of the products or services, the company you work for, and the subject matter in which you are interested.

Marketing Communications. If you sign up or otherwise opt in to receive promotions or other communications from us, you will need to provide your email address. We will use this information to send you SPI updates and promotional and other electronic communications. You may opt out of receiving updates and other emails from us at any time by following the unsubscribe instructions in the applicable email or by contacting us using the contact information provided below under “Contact Us.” Note that, even if you opt out of receiving promotional communications from SPI, you may still receive administrative communications from us with respect to your use of the Site. We may use third-party email providers to deliver these communications to you.

OTHER INFORMATION COLLECTED

As you navigate and use the Site, certain information can be passively collected—that is, gathered without the user actively providing the information or being concurrently made aware of the collection of information—using various technologies. We passively collect a variety of types of information in a variety of ways, including:

IP Addresses and Related Data. The servers used to operate and provide the Site may collect data pertaining to you and the equipment, software, and communication methods you use to access the Internet and the Site, including Internet protocol (“IP”) addresses assigned to the computers and other devices from where you access the Internet, your Internet service provider (ISP), device ID numbers and unique identifiers, your media access control (MAC) address, your operating system, your computer screen resolution, your web browser type, the pages you access on the Site, the websites you access before and after visiting the Site, the length of time you spend on the Site, date and time stamps, clickstream data, your approximate geographic location, performance statistics, and usage data. SPI may use this information to administer the Site and its servers, to generate statistical information, to monitor and analyze Site traffic and usage patterns, to monitor and help prevent fraud, to investigate complaints and violations of our policies, and to improve the Site.

We may combine this information with other Collected Information (including personal information) and information obtained from third parties for security reasons and to protect our rights or the rights of others. The suppliers that we use to provide the Site may collect information about your visits to the Site and other websites. Some of this information may be collected using cookies and similar tracking technologies as explained below under “Cookies and Tracking Technologies.”

Analytics. The Site uses third-party analytics tools (e.g., Google Analytics) to collect and process data about your use of the Site, including when you visit the Site, URLs of the websites that you visit prior to visiting the Site and when you visit those websites, and IP addresses assigned to the devices from where you access the Internet. Our analytics providers may set and read cookies to collect this data and your web browser will automatically send data collected by those cookies to our analytics providers. Our analytics providers use this data to provide us with reports that we will use to improve the Site’s structure and content.

For more information on how Google uses this data, visit Google’s Privacy Policy and Google’s page on How Google uses data when you use our partners’ sites or apps. To prevent this data from being used by Google Analytics, follow the instructions to download and install the Google Analytics Opt-out Browser Add-on for each browser you use. Using the Google Analytics Opt-out Browser Add-on will not prevent SPI from using other analytics tools and will not prevent data from being sent to the Site itself or to Google. For more information about how Google Analytics uses cookies to measure user interactions on websites, visit Google Analytics Cookie Usage on Websites. You may disable cookies as discussed below, but that may impact your use and enjoyment of the Site.

Advertising Networks, Personalized Advertising, Remarketing, & Retargeting. From time to time the Site may use or participate in advertising networks and related advertising services that are managed and provided by third-party advertising servers, advertising agencies, technology vendors, and research firms, including, without limitation, Google Ads and advertising services provided by Adobe and LinkedIn. These services collect information about your visits to and interactions with the Site and other websites and will use that information to target advertisements for goods and services and to display those advertisements on other websites. The information collected may be associated with your personal information.

Advertising networks often gather data about consumers who view advertisements to make inferences about a consumer’s interests and preferences, which enables their computers to deliver advertisements directly targeted to the consumer’s specific interests. This practice is often referred to as “online behavioral advertising.” For example, a third-party advertising network might collect the type of web browser you use, the type of computer operating system you use, the domain name of a website you visit, whether or not you visit specific pages of the Site and other websites, the location of your Internet service provider, the date and time of a visit to a website, and other interactions between you and a website.

Through Google Ads, Google uses your Internet searches, cookies, and similar identifiers (e.g., pixel tags) to collect information about your visits to the Site and your interaction with our products and services to generate targeted advertisements to you on other websites that you visit across the Internet.

We may also enable and implement the following Google Analytics Advertising Features on the Site: Remarketing with Analytics, Demographics and Interest reporting, Campaign Manager integration, Display & Video 360 integration, Google Display Network (“GDN”) Impression Reporting, and Segments. Remarketing with Analytics uses Google Analytics cookies to serve advertisements to you across the Internet based on your visits to the Site. Demographics and Interest reporting uses a third-party cookie to collect information about our Site traffic by tracking users across websites and across time, which generates a report for us to better understand Site users. Campaign Manager integration allow us to view, analyze, and create remarketing lists using our Campaign Manager data in Google Analytics. Display & Video 360 integration allows us to create remarketing lists in Google Analytics and have those lists available in Display & Video 360. GDN Impression Reporting allows us to measure the impact of unclicked GDN Display ad impressions on website behavior and conversions. Segments allows us to isolate and analyze subsets of Site users by sorting our Google Analytics data.

To opt out of remarketing advertising provided through Google, to customize your ad preferences, or to limit Google’s collection or use this information, visit Google’s Safety Center and Google’s Ad Settings and follow Google’s personalized ad opt-out instructions. Opting out will not affect your use of the Site.

To change your preferences with respect to certain online ads and to obtain more information about third-party ad networks and online behavioral advertising, please visit the National Advertising Initiative Consumer opt-out page or the Digital Advertising Alliance Self-Regulatory Program. Please remember that changing your settings with individual web browsers or ad networks will not necessarily carry over to other browsers or ad networks. As a result, depending on the opt-outs you request, you may still see our ads from time to time. Your device may also include a feature (“Limit Ad Tracking” on iOS or “Opt Out of Interest-Based Ads” on Android) that allows you to opt out of having certain information collected through apps used for behavioral advertising purposes.

Cookies and Tracking Technologies. We use “cookies” on the Site. A cookie is a piece of data stored on a Site visitor’s hard drive by the visitor’s web browser. We use cookies to help us improve your access to the Site (for example, by remembering your contact and other information when you access or use the Site), to identify repeat visitors to the Site, to track how you access and use the Site, to learn when and how users visit the Site, to learn whether our Site and/or its pages are popular, to learn which search terms are used to find the Site, to learn which websites direct you to the Site, to help display certain information on the Site, and to improve your enjoyment of the Site.

The Site may use both cookies that we implement, and cookies implemented by our suppliers and other third parties. “First-party” cookies allow your browser to talk to the actual website that you are visiting, whereas “third-party” cookies allow your browser to talk to third-party websites, such as the source of an ad that appears on the website you are visiting or a third-party analytics provider.

Most browsers automatically accept cookies. Browsers generally also allow users to manage cookies in the browser’s settings. For example, a browser may allow you to reject cookies from certain websites, reject certain types of cookies regardless of the website, reject or disable all cookies from all websites, and/or delete cookies stored previously. Some browsers also give you the option of being notified every time a cookie is sent to your browser by a website. You can disable or limit cookies but doing so may impact your use and enjoyment of the Site and other websites. For example, the Site may not be able to be personalized for you, may no longer capture or remember your preferences or other choices you have made on the Site in the past, and may not remember your name or contact information.

Changing your cookie preferences in one browser will not necessarily carry over to other browsers, so you may need to adjust your preferences each time you get a new computer, install a new browser, upgrade an existing browser, or alter or delete a browser’s cookie file.

Our suppliers may use cookies and tracking technologies, such as pixel tags, to track Site visitors across the Internet to understand how you get to the Site and for the analytics purposes disclosed in this Privacy Policy. We do not have access or control over these cookies and this Privacy Policy does not cover the use of third-party cookies.

The types of information collected by a cookie and the purposes for which that information is used depends on the type of cookie. By way of illustration, the types of cookies used, the types of information collected by those cookies, and the purposes for which that information are used are described below. We may combine information collected by cookies with other Collected Information.

• Operationally necessary cookies (also called essential cookies). These are cookies that are required for the operation of the Site. For example, these cookies are required to identify irregular website behavior, prevent fraudulent activity, and improve security. They also allow users of the Site to make use of its functions. Without these cookies, features and services you have requested will not be able to be provided.
• Functional cookies. These cookies allow us to offer you enhanced functionality when accessing or using the Site. This may include to remembering choices you make, for example, remembering your preferences or settings, remembering if you reacted to something on or through the Site so that you are not asked to react to it again, remembering if you have used any feature of the Site before, remembering your username or preferences, remembering if you have used any feature of the Site before, restricting the number of times you are shown a particular advertisement, and enabling social media components. If functional cookies are disabled, various functions of the Site may be unavailable to you or may not work the way you want them to.
• Performance cookies (also called analytical cookies). These cookies assess the performance of the Site, including as part of our analytic practices to help us understand how visitors use and interact with the Site, for example, which pages on our websites users visit most often. These cookies also enable us to personalize content and remember your preferences. These cookies help us improve the way our websites work and provide a better, personalized user experience.
• Advertising or targeted cookies. These cookies record your visits to the Site, the pages you visit on our websites, and the links you have clicked. They gather information about your browsing habits and remember that you have visited a particular website. SPI and its third-party advertising platforms or networks may use this information to make the Site and its content more relevant to your interests (this is sometimes called “behavioral” or “targeted” advertising and is further discussed above). These cookies are also used to limit the number of times you see an advertisement and to help measure the effectiveness of advertising campaigns. To find out more about interest-based ads and your choices, please visit the Digital Advertising Alliance, the Network Advertising Initiative, the Interactive Advertising Bureau (IAB) Europe, http://www.allaboutcookies.org, and http://www.youronlinechoices.com.

A cookie can either be a “session” cookie or a “persistent” cookie. Session cookies exist only for so long as you are visiting the applicable website. Session cookies are typically deleted or removed when you exit or quit your browser application. Persistent cookies exist for a set period of time, for example, six months or one year. Each time you visit a website that has implemented a persistent cookie, that cookie will remain active until its predetermined expiration date. You can also manually delete persistent cookies as discussed above.

The Site may also use the following types of tracking technologies: web beacons (also called clear GIFs), flash cookies, and pixels (also called pixel tags). Web beacons are tiny graphics with unique identifiers that functions similar to how cookies function but, in contrast to cookies, web beacons are embedded invisibly on websites. Flash cookies collect and store information about your use of a website and are commonly used for advertisements and videos. Pixel tags can be placed on websites or within emails to track your interactions with those websites and when emails are opened.

How We Respond to Do-Not-Track Signals. Due to the automatic collection of data using cookies as described above, we do not honor “do not track” requests. For this reason, your selection of the “Do Not Track” option provided by your browser may not have any effect on our collection of information using cookies and other tracking technologies.

Information from Other Sources. We may obtain data about Site users from various third-party companies and public sources, whether offline or online (such as publicly available social media profiles), and we may combine that data with Collected Information. This enhances our existing information about our users and customers and improves our ability to contact you and our marketing’s relevancy.

HOW WE USE AND SHARE YOUR INFORMATION

In addition to and consistent with the purposes identified above, SPI and our suppliers may use or disclose Collected Information for the following purposes:

• Sharing with our Service Providers. We may disclose Collected Information to our suppliers and service providers as necessary for us to provide the Site and our products and services to you, to engage in the use and sharing of Collected Information as permitted by this Privacy Policy, and as may be otherwise required or permitted by applicable law. These third parties include, without limitation, our affiliates and related entities, website and software management and hosting suppliers, support service providers, third-party payment processors, cloud storage providers, information technology security providers, marketing and public relations service providers, and email service suppliers.
• Data Aggregation. To the extent permitted by applicable law, we may aggregate personal information, user-generated content, and other Collected Information and use that aggregate data for our business purposes.
• Lawful Processes, Security & Protection of Rights. We may use and share Collected Information as required or permitted in accordance with subpoenas, court orders, valid law enforcement requests, governmental agency requests, and other legal processes. We may use Collected Information if we believe doing so is necessary or appropriate to protect our rights or the rights of others.
• With Your Consent. With your consent, we may use and share your personal information and other Collected Information in ways not specifically described in this Privacy Policy.

Disclosures to Third Parties.

We do not share personal data with third parties. Additionally, any involvement of third parties or affiliates in handling personal data will occur only with explicit consent from the individuals concerned.

RETENTION

SPI will retain personal information for as long as it is needed for or otherwise serves the purposes outlined in this Privacy Policy, subject to applicable law. Further, personal information is retained in accordance with our policies and practices, applicable law, and contractual obligations.

Personal information collected for the purposes related to the performance of a contract or agreement between you and SPI will be retained until such contract or agreement has been fully performed. We may be required to retain personal information for a longer period of time where required to do so under applicable law or government order.

CHOICES AND RIGHTS

Personal information is collected, stored, processed, and transmitted in accordance with our policies and applicable federal, state, local, and foreign laws, rule and regulations.

ADDITIONAL INFORMATION

Rights. To the extent certain data privacy laws apply to you (based on your country of residence) and subject to all applicable exceptions and exemptions granted under such applicable laws, you may have the following rights with regard to our processing of your personal information:

• Right to Access, Correct and Delete Your Personal Information: We will use reasonable measures designed to ensure that all personal information is accurate and up to date. You also have a responsibility to ensure that changes in your personal information are notified to SPI so we can ensure your personal information is up to date. You have the right to request access to any of your personal information that we hold and to request correction of any inaccurate personal information relating to you that we hold. You furthermore have the right to request deletion of personal information we hold about you.
• Right to Withdraw Consent: In the event your personal information is processed on the basis of your consent, you have the right to withdraw consent at any time with effect for the future.
• Data Portability: To the extent that we use your personal information on the basis of consent or for the performance of a contract, and that personal information is processed by automatic means, you have the right to receive all such personal information about you from SPI in a structured, commonly used and machine-readable format, and also to require us to transmit it to another data controller where this is technically feasible.
• Right to Restrict Personal Information Use and Right to Object: You have the right to restrict our use of your personal information where (i) you contest the accuracy of the personal information; (ii) the use is unlawful but you do not want us to erase the personal information; (iii) we no longer need the personal information for the relevant purposes, but you require it for the establishment, exercise or defense of legal claims; or (iv) you have objected to our personal information use justified on our legitimate interests pending verification as to whether SPI has compelling interests to continue the relevant personal information use.
• Lodge a Complaint: You also have the right to lodge a complaint with a supervisory authority, in particular in your country of residence, if you consider that the collection and use of your personal information violates this Privacy Policy or applicable law.

Legal Bases We Rely on When Processing Personal Information. We process your personal information for the purposes set forth in this Privacy Policy under the following legal bases (as applicable):

• Our Contract With You: Our processing is necessary to perform our obligations under a contract with you or to perform steps requested by you prior to entering into a contract with you: (e.g., to verify the information you have provided to us).
• Our Legitimate Interests: Our processing is necessary for our legitimate interests, including to protect the security of our services; to protect the health and safety of you or others; to establish, protect and defend our legal rights and interests; to prevent fraud and verify identity and authorization of clients; to understand and analyze usage trends; and to improve our products and services.
• Legal Compliance: Where our processing is required to comply with applicable law (for example, to maintain your payment transaction history for tax reporting purposes) e.g., in response to subpoenas, court orders and other lawful requests by regulators, courts and law enforcement agencies, or related to national security requests.
• Your Consent: When we have your express consent as defined by applicable law.

ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS

This section of our Privacy Policy supplements the information contained throughout the Privacy Policy and applies solely to visitors, users, and others who reside in the State of California. We adopt this notice to comply with the California Consumer Privacy Act of 2018, as amended, (“CCPA”) and other California privacy laws.

Collection. Consistent with the “Information You Submit” and “Other Information Collected” sections above, we collect certain categories of personal information about you. We collect the following types of categories of personal information:

Purposes. We collect personal information for the business and commercial purposes set forth under the “How We Use and Share Collected Information” section above as further expanded on in the above table.

Sources. Consistent with the Privacy Policy above, we collect certain categories of personal data directly from you and, in some circumstances, third parties. The categories of sources that we collect personal data from in the prior 12 months includes the following:

• Our third party service providers;
• Third party websites and mobile applications;
• Social media companies;
• Our websites; and
• Your communications with us.

The CCPA grants individuals that are California residents, certain rights (subject to all exemptions and exceptions as may be set forth in the CCPA or its applicable regulations) in regard to our collection of your personal information. These rights include, only to the extent applicable and to the extent granted to you under the CCPA:

• The right to request the disclosures of (1) what personal information has been collected; (2) the categories of sources from which your personal information was collected; (3) the business or commercial purpose for collection or selling your personal data; (4) the categories of third parties with whom we disclose personal information; and (5) the specific pieces of personal information we have collected about you (also called data portability);
• The right to request the deletion of your personal information that we have collected;
• The right to request the correction of your personal information that we have collected;
• The right to opt-out of the sharing of your personal information that we have shared for cross-contextual behavioral advertising purposes;
• The right to opt-out of the sale of your personal information;
• The right to limit our processing of sensitive information to what is necessary; and
• The right to not be discriminated against due to your exercise of your rights under the CCPA. We do not discriminate based on an individual’s exercise of the rights granted to them under the CCPA.

The above rights are only exercisable by you where the CCPA grants you the right being exerted and where no exception or exemption under the CCPA applies. You may also have a registered agent (if and only as permitted under applicable law) that you authorize to act on your behalf. If you have a registered agent act on your behalf, we have the right to authenticate such agent’s authority to act.

We do not sell your personal information to third parties, nor do we share your information for purposes of cross-contextual behavioral advertising as defined under the CCPA. In the event we begin selling personal information (1) this Notice will be updated to reflect that fact and you will be notified of such update and (2) if required under the CCPA, you will be provided the ability to opt out of the sale of your personal information or the sharing of your personal information for cross-contextual behavioral advertising purposes (as may be applicable).

To exercise the rights described herein (only to the extent applicable), you may submit a verifiable request to us by through the methods set forth under the “Exercise Your Rights” section below. We will respond to all requests that we receive from you about your personal information in accordance with applicable data protection laws and to the extent permissible under any other applicable laws.

ADDITIONAL INFORMATION FOR CANADIAN RESIDENTS

The following section of this Privacy Policy only applies to Canadian residents. Under various Canadian laws and regulations, you have certain rights in regard to our collection of personal information. These rights include:

• The right to request access to your personal information;
• The right to request corrections to your personal information;
• The right to lodge a complaint with the Office of the Privacy Commissioner of Canada and/or the applicable Canadian provincial regulatory body if you consider that the collection and use of your personal information violates this Privacy Policy or applicable law.

The above rights are only exercisable by you where applicable law in the jurisdiction in which you reside actually grant you the right being exerted.

EXERCISE YOUR RIGHTS

If this Privacy Policy expressly stated above that you have certain rights or applicable law grants you certain rights as it relates to this Privacy Policy and Collected Information, you may submit a verifiable request to us by

Telephone: 1-866-744-7774
Visiting: https://spi3pl.com/connect/

Only you or a registered agent (if and only as permitted under applicable law) that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. If you have a registered agent act on your behalf, we have the right to authenticate such agent’s authority to act. Without limiting the foregoing, the verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.  Making a verifiable consumer request does not require you to create an account with us.  We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

We will respond to your request within the applicable timeframe required under applicable law. If we deny your request, you can appeal such denial by contacting feedback@spi3pl.com.

ACCURACY AND SECURITY

Personal data you provide to us should be relevant to the purposes for which it is to be used, and, to the extent necessary for those purposes, should be accurate, complete, and up to date.

We have in place reasonable and appropriate technical, physical, and organizational procedures and security measures designed to safeguard and secure personal information from unauthorized loss, alteration, access, disclosure, and processing, taking into account the cost of implementing such measures commensurate with the risks posed by the particular type of processing, the nature of the personal information, and in accordance with applicable law. We value your trust in providing us your information; however, no method of transmission over the Internet, or method of electronic storage is 100% secure and reliable. We cannot guarantee the security of Collected Information.

We limit access to our systems that hold personal information to authorized personnel and such access is limited to those personnel who have a need to know such information for the purpose of performing their job function or as otherwise permitted under this Privacy Policy.

CHILDREN

The Site is not directed at children under 16 years of age. SPI does not knowingly collect or use information from children under 16 through the Site.

THIRD PARTY WEBSITES

The Services may link to, or be linked to, websites, or services not maintained or controlled by Slice. Slice is not responsible for the privacy policies or practices of any third parties or any third-party websites, applications, or services. This Privacy Policy does not apply to any third-party websites, applications, or services or to any personal or other information that you may provide to such third parties. We encourage you to read the privacy policy for each website, application, and service you visit, use, or interact with.

CONTACT US

If you have any questions about this Privacy Policy or our collection, use, or disclosure of information, please contact us via telephone at 1-866-744-7774 via mail at feedback@spi3pl.com.