Effective Date: October 1, 2022
All references to the Company include not only TI Intermediate Holdings, LLC, located at 400 Northridge Road, Suite 1000, Atlanta GA 30350, but also Transportation Insight, LLC, FreightPros, LLC, Nolan Transportation Group, LLC, and our other wholly owned subsidiaries, unless expressly stated otherwise.
2. INFORMATION WE COLLECT
The Company collects data to provide the Services you request, ease your navigation on our website, communicate with you, and improve your experience using our Services. Some of this information is provided by you directly, such as when you create an account on our website, or purchase a service from us. Some of the information is collected through your interactions with our Services. We collect such data using technologies like cookies and other tracking technologies, error reports, and usage data collected when you interact with the Company’s websites.
We also obtain data from third parties or use third parties to assist us with data collection. For example, we may supplement the data we collect as described in this section by purchasing demographic data from other companies. We also use services from other companies to help us determine a location based on your IP address notably to customize certain services to your location. In addition, we utilize third-party services to collect usage data.
Below are some examples of the Personal Information and Sensitive Personal Information we may collect through our Services. There may be some overlap between the personal information in each category:
- Identifiers. Such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.
- Individual Records. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), such as name, signature, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Individual Records may include the following Sensitive Personal Information: government identifiers (social security, driver’s license, state identification card, or passport number), complete account access credentials (user names, account numbers, or card numbers combined with required access/security code or password), or mail, email, or text messages contents not directed to us.
- Commercial information. Such as records of personal property, products or Services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
- Internet or other similar network activity. Such as browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
- Geolocation data. Such as physical location or movements.
Geolocation data may include the following Sensitive Personal Information: precise geolocation.
- Inferences drawn from other personal information. Such as profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
3. HOW WE USE INFORMATION
We will only use personal information when the law allows us to. We will only use personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
Please note that we may process personal information about you without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
The Company uses information that we collect from customers and visitors for the purposes of:
- Providing our Services;
- Providing ongoing support;
- Evaluating you for a job or internship;
- Communicating with you, including promotional communications and customer relationship management (“CRM”);
- Providing information about other Services;
- Helping us run our company, for example to improve our Services or our security, train staff or perform marketing activities, including CRM;
- Complying with our legal obligations; and
- Accounting and other administrative purposes.
Examples of the uses of information include:
Providing Services. We use data to carry out your transactions with us and to provide Services. Often, this includes personal information such as email, name, job title, company, and address. We may collect additional information when you register to use the Services, including contact information and credentials. We may use this data to diagnose and address problems and provide other Services.
Improving Product and Services. We use data to continually improve our Services, including adding new features or capabilities. Data is collected throughout your interactions with our Services that enable us to understand customer usage and tailor future capabilities.
We track general, non-personalized information (e.g., operating system, browser version and type of device being used) to know how many people visit specific pages of our Services or utilize specific areas of our Services so that we may improve those Services. We may use your IP address to customize services to your location, such as the language displayed on our Services.
To facilitate our understanding of how individuals use our Services, the Company also may collect usage data through mouse tracking technology; currently provided by our third-party provider Mouseflow. Such technology tracks your mouse movement and clicks throughout the Services. The Company uses this information to better understand how visitors interact with the Services and improve usability. For more information on Mouseflow’s privacy practices please visit: https://mouseflow.com/privacy-overview/. If you wish to opt-out of the use of Mouseflow tracking please visit: https://mouseflow.com/opt-out/.
Please note that we use IP addresses on a highly restrictive basis to analyze trends, to administer the site, and to collect general information for aggregate use.
Chat sessions. If you use the Chat Feature of the Services to chat with a customer service representative, we will have access to a transcript of the chat session. We use information provided though the Chat Feature to provide you with customer assistance.
We use a third party vendor to provide the Chat Feature (the “Chat Provider”)). The information you provide through the Chat Feature is collected by and stored on the Chat Provider’s systems. We do not control and are not responsible for the Chat Provider or its collection or use of your information.
Content. We may collect the content of messages you send to us, such as feedback or questions you ask our support representatives, when necessary to provide you with the Services you use. When you contact us, phone conversations or chat sessions with our representatives may be monitored and recorded in order to improve our services, facilitate the processing and resolution of your request or complaint.
Surveys and Studies. We may ask you to participate in a survey or study; and may request information from you. Participation is voluntary, and you have the choice of whether to disclose any requested information.
Marketing and event communication: We use personal information to deliver marketing and event communications to you across various platforms, such as email, direct mail, social media, and online via our Services.
If we send you a marketing email, it will include instructions on how to opt out of receiving these emails in the future. For information about managing email subscriptions and promotional communications, please visit the Your Rights Regarding Personal Information section of this privacy statement. Please remember that even if you opt out of receiving marketing emails, we may still send you important Service information related to your accounts and subscriptions.
Processing Payments: If you make a payment to the Company, we will ask for payment Information and other information requested for processing your payment.
4. HOW WE SHARE INFORMATION
We may provide personal information to:
- Company-controlled affiliates and subsidiaries, located in and outside your country or region;
- outsourced service providers who perform functions on our behalf, located inside or outside of your country or region. For example, when you provide payment data to make a purchase, we will share payment data with banks and other entities that process payment transactions or provide other financial services, and for fraud prevention and credit risk reduction;
- our authorized agents and representatives, located inside or outside of your country or region, who sell products or provide services on our behalf;
- anyone expressly authorized by you to receive personal information; and
- anyone to whom we are required by law to disclose personal information, upon valid and enforceable request thereof.
We will access, disclose and preserve personal information when we have a good faith belief that doing so is necessary to:
- comply with applicable law or respond to valid legal processes, including from law enforcement or other government agencies, upon valid and enforceable request thereof; or
- operate and maintain the security of our Services, including to prevent or stop an attack on our computer systems or networks.
Please note that some of our Services may direct you to services of third parties whose privacy practices differ from the Company’s. If you provide personal information to any of those services, your data is governed by their privacy statements or policies. The Company and its affiliates are not responsible for the privacy practices of these other websites. Please review the privacy policies for these websites to understand how they process your information.
You can generally opt-out of receiving personalized ads from third-party advertisers and ad networks who are members of the Network Advertising Initiative (NAI) or who follow the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising (DAA) by visiting the opt-out pages on the NAI website (http://optout.networkadvertising.org) and DAA website (http://www.aboutads.info/choices/).
Marketing preferences: If you have provided us with your contact information, we may, subject to any applicable Spam Act or similar regulation, contact you via e-mail, postal mail or telephone about the Company products, services and events that may be of interest to you, including our newsletter.
E-mail communications you receive from the Company will generally provide an unsubscribe link allowing you to opt-out of receiving future e-mail or to change your contact preferences. Please remember that even if you opt out of receiving marketing emails, we may still send you important Service information related to your accounts and subscriptions.
You can also request changes to your account and marketing preferences by emailing the Company at email@example.com.
5. HANDLING OF PERSONAL INFORMATION
Security of Personal information
The Company is committed to protecting the security of personal information. Depending on the circumstances, we may hold your information in hard copy and/or electronic form. For each medium, we use technologies and procedures to protect personal information. We review our strategies and update as necessary to meet our business needs, changes in technology, and regulatory requirements.
These measures include, but are not limited to, technical and organizational security policies and procedures, security controls and employee training.
You are responsible for maintaining the security of your account credentials for the Services. The Company will treat access to the Services through your account credentials as authorized by you. Unauthorized access to password-protected or secure areas is prohibited and may lead to criminal prosecution. We may suspend your use of all or part of the Services without notice if we suspect or detect any breach of security. If you believe that information you provided to us is no longer secure, please notify us immediately using the contact information provided below.
If we become aware of a breach that affects the security of personal information about you, we will provide you with notice as required by applicable law. To the extent permitted by applicable law, the Company will provide any such notice that the Company must provide to you at your account’s email address. By using the Services, you agree to accept notice electronically.
Storage and Transfer of Personal Information
The Company also collaborates with third parties such as cloud hosting services and suppliers located around the world to serve the needs of our business, workforce, and customers. In some cases, we may need to disclose or transfer personal information within the Company or to third parties in areas outside of your home country. When we do so, we take steps to ensure that personal information is processed, secured, and transferred according to applicable law.
If you would like to know more about our data transfer practices, please contact our Legal Department at firstname.lastname@example.org.
Retention of Personal Information
The Company retains personal information for as long as necessary to provide the Services and fulfill the transactions you have requested, or for other business purposes such as complying with our legal obligations, resolving disputes, and enforcing our agreements. We are required by law to keep some types of information for certain periods of time (e.g. statute of limitations). If personal information is no longer necessary for the legal or business purposes for which it is processed, we will generally destroy or anonymize that information.
6. ACCESSING AND UPDATING PERSONAL INFORMATION
You may request access to personal information about you or correct an error or omission in personal information about you by contacting us at email@example.com or write us at: TI Intermediate Holdings, LLC, Attention: Legal Department, 400 Northridge Road, Suite 1000, Atlanta, GA 30350. We will make good faith efforts to resolve requests to correct inaccurate information except where the request is unreasonable, requires disproportionate technical effort or expense, jeopardizes the privacy of others, or would be impractical. Residents of some jurisdictions may have additional rights concerning personal information; please see Section 9 – “Additional State Rights and Disclosures for California Residents (Your California Privacy Rights)” regarding these rights.
California Shine the Light Law: California Civil Code Section 1798.83 permits users who are California residents to obtain from us once a year, free of charge, a list of third parties to whom we have disclosed personal information (if any) for direct marketing purposes in the preceding calendar year. If you are a California resident and you wish to make such a request, please send an e-mail with “California Privacy Rights” in the subject line to firstname.lastname@example.org or write us at: TI Intermediate Holdings, LLC, 400 Northridge Road, Suite 1000, Atlanta, GA 30350.
7. COOKIES & SIMILAR TECHNOLOGIES
We may combine the information we collect via Cookies with personal information that we have collected from you to learn more about how you use our websites to improve them.
Types of Cookies
We use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your device until you delete them). To make it easier for you to understand why we need them, the Cookies we use on our websites can be grouped into the following categories:
- Strictly Necessary: These Cookies are necessary for the websites to work properly. They include any essential authentication and authorization cookies for our websites.
- Functionality: These Cookies enable technical performance and allow us to “remember” the choices you make while browsing our websites, including any preferences you set. They also include sign-in and authentication cookies and IDs that enable you to return without additional sign-in.
- Performance/Analytical: These Cookies allow us to collect certain information about how you navigate the websites or utilize the Services or products running on your device. They help us understand which areas you use and what we can do to improve them.
- Targeting: These Cookies are used to deliver relevant information related to our websites to an identified machine or other device (not a named or otherwise identifiable person) which has previously been used to visit our websites. Some of these types of Cookies on our websites are operated by third parties with our permission and are used to identify advertising sources that are effectively driving customers to our websites.
Cookies Set by Third Party Services
To enhance our content and to deliver a better online experience for our users, we sometimes embed images and videos from other websites on the websites. We currently use, and may in future use content from websites such as Facebook, LinkedIn and Twitter. You may be presented with Cookies from these third-party websites. Please note that we do not control these Cookies. The privacy practices of these third parties will be governed by the parties’ own privacy statements or policies. We are not responsible for the security or privacy of any information collected by these third parties, using cookies or other means. You should consult and review the relevant third-party privacy statement or policy for information on how these cookies are used and how you can control them.
Other Similar Technologies
Company web pages may use other technologies such as web beacons to help deliver cookies on our websites and count users who have visited those websites. We also may include web beacons in our promotional email messages or newsletters to determine whether you open and act on them as well as for statistical purposes.
In addition to standard cookies and web beacons, our services can also use other similar technologies to store and read data files on your computer. This is typically done to maintain your preferences or to improve speed and performance by storing certain files locally.
How to Control and Delete Cookies
Cookies can be controlled, blocked or restricted through your web browser settings. Information on how to do this can be found within the Help section of your browser. All Cookies are browser specific. Therefore, if you use multiple browsers or devices to access websites, you will need to manage your cookie preferences across these environments.
If you are using a mobile device to access our websites, you will need to refer to your instruction manual or other help/settings resource to find out how you can control cookies on your device.
Please note: If you restrict, disable or block any or all Cookies from your web browser or mobile or other device, the websites may not operate properly, and you may not have access to our Services or materials available through the websites. The Company shall not be liable for any impossibility to use the websites or degraded functioning thereof, where such are caused by your settings and choices regarding cookies.
To learn more about cookies and web beacons, visit www.allaboutcookies.org.
Do Not Track: Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) incorporate a “Do Not Track” (“DNT”) or similar feature that signals to websites that a user does not want to have his or her online activity and behavior tracked. If a website that responds to a particular DNT signal receives the DNT signal, the browser can block that website from collecting certain information about the browser’s user. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, many website operators, including the Company, do not respond to DNT signals.
8. CHILDREN’S PRIVACY
SERVICES ARE NOT INTENDED FOR CHILDREN
You must be at least the age of majority in your place of residence to use the Services. The Services are not directed to or intended for use by minors. Consistent with the requirements of the U.S. Children’s Online Privacy Protection Act, if we learn that we received any information directly from a child under age 13 without his or her parent’s verified consent, we will use that information only to inform the child (or his or her parent or legal guardian) that he or she cannot use the Services.
California Minors: While the Services is not intended for anyone under the age of 18, if you are a California resident who is under age 18 and you are unable to remove publicly-available content that you have submitted to us, you may request removal by contacting us at: email@example.com. When requesting removal, you must be specific about the information you want removed and provide us with specific information, such as the URL for each page where the information was entered, so that we can find it. We are not required to remove any content or information that: (1) federal or state law requires us or a third party to maintain; (2) was not posted by you; (3) is anonymized so that you cannot be identified; (4) you don’t follow our instructions for removing or requesting removal; or (5) you received compensation or other consideration for providing the Content or information. Removal of your content or information from the Services does not ensure complete or comprehensive removal of that content or information from our systems or the systems of our service providers. We are not required to delete the content or information posted by you; our obligations under California law are satisfied so long as we anonymize the content or information or render it invisible to other users and the public.
9. ADDITIONAL STATE RIGHTS AND DISCLOSURES FOR CALIFORNIA RESIDENTS (YOUR CALIFORNIA PRIVACY RIGHTS)
The following section applies to individuals who reside specific jurisdictions that provide additional privacy rights.
Data Collection – Right to Know
In the last twelve (12) months we may have collected the categories of personal information as described in the Section 2 – “Information We Collect” above.
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the business purposes indicated in Section 3 – “How We Use Information” above.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information
We may disclose personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. We share personal information with the categories of third parties listed in Section 4 – “How We Share Information” above.
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
- Individual records
- Commercial information
- Internet or other similar network activity
- Geolocation data
- Inferences drawn from other personal information
Your Rights and Choices
Certain state laws, including the California Consumer Privacy Act (CCPA)/California Privacy Rights Act (CPRA), may provide residents with specific rights regarding their personal information in addition to those addressed above. This section describes the rights you may have and explains how to exercise those rights.
Right to Access Specific Information and Data Portability Right. You have the right to request that we disclose certain information to you about our collection and use of personal information over the past twelve (12) months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
- If we disclosed personal information for a business purpose, the business purpose for which personal information was disclosed, and the personal information categories that each category of recipient obtained.
Right to Correct Information. You have the right to request we update personal information about you that is incorrect in our systems.
Right to Delete. You have the right to request that we delete any personal information about you that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) the personal information from our records, unless an exception applies.
Right to Opt-out of sharing Personal Information for Cross-Contextual Behavioral Advertising. We do not share Personal Information for cross-contextual behavioral advertising.
Right to Limit Sensitive Personal Information Use. You have the right to limit the use of sensitive personal information regarding you.
Non-Discrimination. We will not discriminate against you for exercising any of your rights.
Exercising Your Rights
To exercise the access, data portability and deletion rights described above, please complete and email us a copy of this Verifiable Consumer Request Form to firstname.lastname@example.org or call us at: (877) 226-9950.
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to personal information about you. You may also make a verifiable consumer request on behalf of your minor child.
You may only make such a request for access or data portability twice within a 12-month period. 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, and 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 endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response electronically. Any disclosures we provide will only cover the 12-month period preceding the receipt of the verifiable consumer request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide the personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
11. QUESTIONS OR COMPLAINTS HANDLING
Mail: TI Intermediate Holdings, LLC
Attention: Legal Department
400 Northridge Road, Suite 1000, Atlanta, GA 30350