PRIVACY POLICY

1. Introduction


We care deeply about the privacy of our visitors and users. To that end, this Privacy Policy (“Privacy Policy”) describes how our website host cargo.site, cargocollective.com and persona.co collect, use, and share your Personal Information, as well as an explanation of the data rights you may have in that Personal Information. This Privacy Policy applies to all Cargo users, including unregistered visitors, and registered users (collectively, “Users”, “you”, or “your”), and to all Cargo services, including our websites (including and any of its subdomains, the “Website”), web applications (“Cargo Apps”), mobile applications (“Mobile Apps”), and related services (collectively, the “Services”). This Privacy Policy is not intended to override the terms of any contract you have with us, nor any rights you may have under other applicable data privacy laws.

Prior to accessing or using our Services, please read this policy and make sure you fully understand our practices in relation to your Personal Information.  If you read and fully understand this Privacy Policy, and remain opposed to our practices, you must immediately leave and discontinue all use of any of our Services.  If you have any questions or concerns regarding this policy, please contact us at support@cargo.site.


2. What ‘Personal Information’ do we collect?


2.1  User information
To provide you the Services, we must collect Personal Information relating to an identified or identifiable natural person (“Personal Information”). We collect Personal Information you provide us, from your use of the Services, and from other sources. Here are the types of Personal Information we collect about you:

  1. Information you provide us. When you register for our Services, purchase and/or register domain names, use any of our Services; and/or when you contact us directly by any communication channel (e.g., Cargo’s support tickets, emails), you may provide us Personal Information, such as name, email address, phone number, payment information (for Users with Paid Services), information you include in your communications with us and with other users on our platform, and Personal Information contained in scanned identification documents.
  2. Information we collect when you use the Services. When you visit, download, and/or use any of our Services, we may collect aggregated usage Personal Information, such as Visitors’ and Users’ browsing and ‘click-stream’ activity on the Services, session heatmaps and scrolls, non-identifying Personal Information regarding the Visitor’s or User’s device, operating system, internet browser, screen resolution, language and keyboard settings, internet service provider, referring/exit pages, date/time stamps, etc.
  3. Information we collect from other sources. We may receive Personal Information about you from third-party sources, such as i) security providers, fraud detection and prevention providers for example to help us screen out users associated with fraud, ii) social media platforms, when you log-in or sign-up using your social media account, we may receive Personal Information from that service (e.g., your username, basic profile Personal Information) and in some cases, we may collect Personal Information from lead enhancement companies which help us to improve our service offering; iii) advertising and marketing partners in order to monitor, manage and measure our ad campaigns.


2.2 Users of users ‘Personal Information’
We may also collect Personal Information pertaining to visitors and users of our User’s websites or services (“Users-of-Users”), solely for and on our Users’ behalf (as further described in Section ‎6 below).


3. Why do we collect ‘Personal Information’


We use your Personal Information for the following purposes:

  1. To provide and operate the Services;
  2. To further develop, customize, expand, and improve our Services, based on Users’ common or personal preferences, experiences and difficulties;
  3. To provide our Users with ongoing customer assistance and technical support;
  4. To be able to contact our Users with general or personalized service-related notices and promotional messages (as further detailed in Section 8 below);
  5. To help us to update, expand and analyze our records to identify new customers;
  6. To facilitate, sponsor, and offer certain contests, events, and promotions, determine participants’ eligibility, monitor performance, contact winners, and grant prizes and benefits;
  7. To analyze our performance and marketing activities;
  8. To create aggregated statistical data and other aggregated and/or inferred information, which we or our business partners may use to provide and improve our respective services;
  9. To provide you with professional assistance, only upon your request;
  10. To enhance our data security and fraud prevention capabilities; and
  11. To comply with any applicable laws and regulations.


We use your Personal Information for the purposes set out in Section 3 where:

  1. Our use of your Personal Information is necessary to perform a contract or to take steps to enter into a contract with you (e.g. to provide you with a website builder, to provide you with our customer assistance and technical support);
  2. Our use of your Personal Information is necessary to comply with a relevant legal or regulatory obligation that we have; or
  3. Our use of your Personal Information is necessary to support legitimate interests and business purposes (for example, to maintain and improve our Services and the effectiveness of Cargo by identifying technical issues), provided it is conducted in a way that is proportionate and that respects your privacy rights.


4. How we share your ‘Personal Information’


We may share your Personal Information with service providers and others (or otherwise allow them access to it) in the following manners and instances:

4.1 Third Party Service Providers
Cargo has partnered with a number of selected service providers, whose services and solutions complement, facilitate and enhance our own. These include hosting services, communications and content delivery networks (CDNs), data and cyber security services, billing and payment processing services, domain name registrars, fraud detection and prevention services, web analytics, e-mail distribution and monitoring services, session recording and remote access services, performance measurement, data optimization and marketing services, content providers, and our legal and financial advisors (collectively, “Third Party Service Provider(s)”).

Cargo may share the following categories of Personal Information with Third Party Service Providers for a business purpose:
  • identifiers, including name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, or other similar identifiers
  • commercial information, for example information regarding products or services purchased, obtained, or considered


4.2 Law Enforcement, Legal Requests and Duties
Cargo may disclose or otherwise allow access to your Personal Information pursuant to a legal request, such as a subpoena, legal proceedings, search warrant or court order, or in compliance with applicable laws, if we have a good faith belief that the law requires us to do so, with or without notice to you.


5. Where do we store your ‘Personal Information’?


5.1 Storage locations
Users’ and Users-of-Users’ Personal Information may be stored in data centers located in the United States of America. We may use other jurisdictions as necessary for the proper delivery of our Services and/or as may be required by law.

Cargo is based in the United States of America and is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).

Cargo’s Third-Party Service Providers that store or process your Personal Information on Cargo’s behalf are contractually committed to keep it protected and secured, in accordance with industry standards and regardless of any lesser legal requirements which may apply in their jurisdiction.

5.2 Transfer of EU Personal data
If you are located in Europe, when we will transfer your Personal Information to the United States or anywhere outside Europe, we will make sure that (i) there is a level of protection deemed adequate by the European Commission or (ii) that the relevant Model Standard Contractual Clauses are in place.

On July 16, 2020, the Court of Justice of the European Union issued a judgmentdeclaring as “invalid” the European Commission’s Decision (EU) 2016/1250 of 12 July 2016 on the adequacy of the protection provided by the EU-U.S. Privacy Shield. As a result of that decision, the EU-U.S. Privacy Shield Framework is no longer a valid mechanism to comply with EU data protection requirements when transferring personal data from the European Union to the United States. That decision does not relieve participants in the EU-U.S. Privacy Shield of their obligations under the EU-U.S. Privacy Shield Framework.

In compliance with the Privacy Shield Principles, Cargo commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Cargo at:

William Hornaday, Esq.
Law Offices of William Hornaday
Law Email: hornaday1@sbcglobal.net
Telephone: (503) 970-3231
Address: 3310 SW 70th Avenue
Portland, OR 97225, USA

Cargo has further committed to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact or visit JAMS for more information or to file a complaint. The services of JAMS are provided at no cost to you.

The individual shall be provided, at no cost, Alternate Dispute Recourse as set forth in Privacy Shield Principles,

In the event that the dispute is not resolved by such Alternate Dispute Recourse, the individual may invoke their right to binding arbitration with regard to the dispute.


6. Users-of-users’ ‘Personal Information’


Cargo may collect, store and process certain Personal Information of Users-of-Users (“Users-of-Users Information”), solely on our Users’ behalf and at their direction. For example, where a user configures a store on their site which collects Users-of-Users Personal Information for the purpose of billing and shipping.

For such purposes, Cargo serves and shall be considered as a “Processor” and not as the “Controller” (as both such capitalized terms are defined in the European Union General Data Protection Regulation (“GDPR”)) of such Users-of-Users Information.

The Users controlling and operating such User Websites shall be considered as the “Controllers” of such Users-of-Users Information, and are responsible for complying with all laws and regulations that may apply to the collection and control of such Users-of-Users Information, including all privacy and data protection laws of all relevant jurisdictions.

The Processing of the Users-of-users’ Personal Information shall take place within the territory of the European Union or a third country, territory or one or more specified sectors within that third country of which the European Commission has decided that it ensures an adequate level of protection and such processing and transfer will be in accordance to the Data Processing Agreement – Users (“DPA"). Any transfer to and Processing in a third country outside the European Union that does not ensure an adequate level of protection according to the European Commission, shall be undertaken in accordance with the Standard Contractual Clauses (2010/87/EU) set out in Annex 1 of the DPA. For the sake of clarity, “Processing” should be understood as per the definition provided in the DPA.

You are responsible for the security, integrity and authorized usage of Personal Information about Users-of-Users’, and for obtaining consents, permissions and providing any required data subject rights and fair processing notices required for the collection and usage of such Personal Information.

Cargo cannot provide legal advice to Users or their Users-of-Users, however we do recommend that all Users publish and maintain clear and comprehensive privacy policies on their User Websites in accordance with any applicable laws and regulations, and that all Users-of-Users carefully read those policies and make sure that they understand and, to the extent required by applicable law, consent to them.

For more information on how Users-of-Users Personal Information may be handled by Cargo (which may be relevant for any specific notice you provide to and/or consent you obtain from your Users-of-Users), please see Sections 4, 12 and 13.

If you are a visitor, user or customer of any of our Users, please read the following: Cargo has no direct relationship with Users-of-Users whose Personal Information it processes. If you are a visitor, user or customer of any of our Users, and would like to make any requests or queries regarding your Personal Information, please contact such User(s) directly. For example, if you wish to request to access, correct, amend, or delete inaccurate Personal Information processed by Cargo on behalf of its Users, please direct your query to the relevant User (who is the “Controller” of such data). If Cargo is requested by our Users to remove any Users-of-Users’ Personal Information, we will respond to such requests in a timely manner upon verification and in accordance with applicable law (for example, thirty (30) days under the GDPR). Unless otherwise instructed by our User, we will retain their Users-of-Users’ Personal Information for the period set forth in Section 12 below.


7. Use of cookies and other third-party technologies


We and our Third Party Service Providers use cookies and other similar technologies (“Cookies”) in order for us to provide our Service and ensure that it performs properly, to analyze our performance and marketing activities, and to personalize your experience.
  • A cookie is a small amount of data, which often includes an anonymous unique identifier that is sent to your browser from a web site’s computers and stored on your computer’s hard drive.
  • If you reject all cookies, you may not be able to use Cargo services or products that require you to “sign in” and you may not be able to take full advantage of all offerings.
  • You can configure your browser to accept all cookies, reject all cookies or notify you when a cookie is set.
  • Cargo uses its own cookies for a number of purposes, including to:
    • Require you to re-enter your password after a certain period of time has elapsed to protect you against others accidentally accessing your account contents.
    • Keep track of preferences you specify while you are using the Cargo Sites, Products and Services.
    • Estimate and report our total audience size and traffic.
    • Conduct research to improve the content and services provided on the Cargo Sites, Products and Services.


9. Your rights in relation to your ‘Personal Information’


Cargo recognises that it is imperative that you have control over your Personal Information. Pursuant to privacy regulations worldwide, Cargo is taking steps to enable you to request access to, receive a copy of, update, amend, delete, or limit the use of your Personal Information.

Before fulfilling your request, we may ask you for additional information in order to confirm your identity and for security purposes. We reserve the right to charge a fee where permitted by law (e.g. if your request is unfounded or excessive).

You have the right to file a complaint with your local supervisory authority for data protection (but we still recommend that you contact us first).

If you are a Cargo User, and you wish to receive a copy, access and/or request us to make corrections to the Personal Information that you have stored with us (either yours or your Users-of-Users’), or wish to request a list of what Personal Information (if any) pertaining to you we disclosed to third parties for direct marketing purposes, please contact us via https://support.cargo.site/Contact.

We will make reasonable efforts to honour your request promptly (unless we require further information from you in order to fulfil your request), subject to legal and other permissible considerations.

Cargo recognises that it is imperative that you have control over your Personal Information. Pursuant to privacy regulations worldwide, Cargo is taking steps to enable you to request access to, receive a copy of, update, amend, delete, or limit the use of your Personal Information.

Before fulfilling your request, we may ask you for additional information in order to confirm your identity and for security purposes. We reserve the right to charge a fee where permitted by law (e.g. if your request is unfounded or excessive).

You have the right to file a complaint with your local supervisory authority for data protection (but we still recommend that you contact us first).

If you are a Cargo User, and you wish to receive a copy, access and/or request us to make corrections or to delete the Personal Information that you have stored with us (either yours or your Users-of-Users’), or wish to request a list of what Personal Information (if any) pertaining to you we disclosed to third parties for direct marketing purposes, please contact us via https://support.cargo.site/Contact.

We will make reasonable efforts to honour your request promptly (unless we require further information from you in order to fulfil your request), subject to legal and other permissible considerations.


10. Additional information for California residents


If you are a California resident using the Services, the California Consumer Privacy Act (“CCPA”) may provide you the right to request access to and deletion of your Personal Information.

In order to exercise the right to request access to and deletion of your Personal Information, please see the information on the section 9, above. We do not discriminate based on the exercise of any privacy rights that you might have under this Section.

Cargo does not sell user Personal Information to third parties for the intents and purposes of the CCPA.  

As informed in section 6 above, Cargo may collect, store and process certain Personal Information of Users-of-Users, solely on our Users’ behalf and at their direction.  For such purposes, Cargo serves and shall be considered as a “Service Provider” and not as the “Business” (as both such capitalized terms are defined in the CCPA. Cargo does not and will not sell your customers’ (User-of-User) Personal Information.

Users of the Services who are California residents and under 18 years of age may request and obtain removal of content they posted by emailing us at contact@cargocollective.com. All requests must be labeled “California Removal Request” on the email subject line. All requests must provide a description of the content you want removed and information reasonably sufficient to permit us to locate that content. We do not accept California Removal Requests via postal mail, telephone, or facsimile. We are not responsible for notices that are not labeled or sent properly, and we may not be able to respond if you do not provide adequate information. Please note that your request does not ensure complete or comprehensive removal of the material. For example, materials that you have posted may be republished or reposted by another user or third party.


11. Questions and complaints


If you have any questions or concerns about our collection, use or disclosure of Personal Information, or if you believe that we have not complied with this Privacy Policy or applicable data protection laws, please contact us support@cargo.site

Our team will investigate the complaint and determine whether a breach has occurred and what action, if any, to take. We take every privacy complaint seriously and will make all reasonable efforts to resolve your complaint promptly and in accordance with applicable law.

You can file a complaint with your local supervisory authority for data protection at any time, however we recommend that you contact us first so we can try to resolve it.


12. Data retention


We may retain your Personal Information (as well as your Users-of-Users’ Personal Information) for as long as your User Account is active, as indicated in this Privacy Policy, or as otherwise needed to provide you with our Services.

We may continue to retain your Personal Information after you deactivate your User Account and/or cease to use any particular Services, as reasonably necessary to comply with our legal obligations, to resolve disputes regarding our Users or their Users-of-Users, prevent fraud and abuse, enforce our agreements and/or protect our legitimate interests.

We maintain a data retention policy which we apply to Personal Information in our care.


13. Security


Cargo has implemented security measures designed to protect the Personal Information you share with us, including physical, electronic and procedural measures. Among other things, we offer HTTPS secure access to most areas on our Services; the transmission of sensitive payment information (such as a credit card number) through our designated purchase forms is protected by an industry standard SSL/TLS encrypted connection. We also regularly monitor our systems for possible vulnerabilities and attacks, and regularly seek new ways and Third Party Services for further enhancing the security of our Services and protection of our Visitors’ and Users’ privacy.

Regardless of the measures and efforts taken by Cargo, we cannot and do not guarantee the absolute protection and security of your Personal Information, your Users-of-Users’ Personal Information or any other information you upload, publish or otherwise share with Cargo or anyone else. We encourage you to set strong passwords for your User Account and User Website, and avoid providing us or anyone with any sensitive Personal Information of which you believe its disclosure could cause you substantial or irreparable harm.

If you have any questions regarding the security of our Services, you are welcome to contact cargo here or us directly via info@vinoest.dk.