KlearNow Ltd. PRIVACY POLICY

Scope of this Privacy Policy

KlearNow Ltd (company number 12070788 and registered office Isher House, Isher Business Park, Peel Cross Road, Manchester, England, M5 4DT)and its affiliates (“KlearNow,” “we,” “our,” and/or “us”) value the privacy of individuals who use our application, websites, and related services (collectively, the “Platform”). This privacy policy (the “Privacy Policy”) explains how we collect, use, and share information from users (‘You” or “Users”) of our Platform, who are comprised of individuals and companies seeking customs brokerage services (“Customers”), licensed customs brokers (“Brokers”) and users of our Trucker application software (“Truckers”).

This Privacy Policy applies to Users of KlearNow’s Platform anywhere in the world. In this Privacy Policy, we tell you what information we receive from Customers, Brokers and Truckers, and how we use that information to connect Customers, Brokers and Truckers and to improve our services.

Beyond the Privacy Policy, your use of the Platform is also subject to our Platform Terms and Conditions (www.klearnow.com/terms). Truckers using the Platform are subject to additional Terms and Conditions for the Trucker application software (“Trucker App”).

Information We Collect

 A. Information You Provide to Us

Registration Information.
When you sign up for an account on the Platform, you give us your name, email address, and phone number.

 User Profile Information.
When you join the Platform, you can create an Active Account by filling out a User profile.

For Customers, this profile includes any information you provide such as Customer’s legal entity type, estimated business size (number of shipments, etc.), shipping information such as default INCOTERMS; any preferred freight forwarders, brokers, and carriers; top origins; information relating to any bonds you or your Broker holds in connection with the Services; Customer’s Power of Attorney; Customer’s designation of users authorized to access the Customer account and their contact information; and Platform communication preferences.  Users can also add a User Payment Option to authorized individuals with access to the Active Account, which requires a designated business email address and payment method.

For Brokers, this profile includes any information you provide such as Broker’s name; address; email address; phone number; Broker ID or Filer Code, license number and status; countries and jurisdictions for which Broker is licensed to practice; experience; bonds held by Broker; and preferences, including long term customers, industries, availability for special requests and off-hour Service requests, and communication preferences.  We also collect information you provide concerning the working hours you elect for providing your Services.

For Truckers, no profile is created when downloading and using the Trucker App.  However, once the Trucker App is downloaded, the Trucker’s contact information and delivery transaction history is made available to Customers using Trucker’s services on the Platform and a TruckerScore is calculated for each Trucker based on Customer feedback and Trucker’s performance on completed delivery transactions.

Payment Method and Information.
When the User Payment Option is activated by a Customer or Broker, Customers and Brokers can add an electronic payment account, credit card and/or other payment method to their active account, and a third-party payment provider will receive and verify your payment/credit card information. To keep your financial data secure, we do not store full credit card information on our servers. However, we keep information about bank routing numbers, tax information, and any other payment information provided by Users that enable Users to make electronic payments in connection with Services provided through the Platform. Company reserves the right to change its third-party payment provider at any time.

Communications.
If you contact us directly, we may receive additional information about you. For example, when you contact our Customer Support Team, we will receive your name, email address, phone number, the contents of a message or attachments that you may send to us, and other information you choose to provide.

B. Information We Collect When You Use the Platform

Device Information. When an Application is downloaded by a User, the Company receives information from User’s devices, including IP address, web browser type, mobile operating system version, phone carrier and manufacturer, application installations, device identifiers, and push notification tokens.

Usage Information. To help us understand how You use the Platform and to help Us improve it, we automatically receive information about your interactions with the Platform, like the pages or other content you view, your actions within the Platform apps, the dates and times of your visits and the services provided through the platform.

Customer and Broker Transaction Information.
KlearNow collects the shipment information Customers provide in connection with a request for Services as well as information submitted by Brokers in connection with the provision of Services.  This information is saved in the Platform’s database, including:  data contained in Customs forms and filings such as ISF data fields; the package ID (Waybill manifest) or the good’s container ID; the Declared Value for the goods; the shipping company or carrier; information about the good being shipped including cost and type, the HTS Code, origination location, destination location; the date of customs entry and release; the Carrier’s payment status; the good’s Customs documentation and documentation status; the Customer’s designated recipient; and the revenues, calculated duties and taxes and other fees for a particular Services transaction.

Trucker/ Haulier Transaction Information.
KlearNow also allows Customers to track the delivery of their Shipments from the port of entry to their intended destination through the Trucker App which tracks and collects location, route and other trip information from a Trucker using the Trucker App. This trip information may include, without limitation, Trucker’s name together with the scheduled Shipment pick-up time and date, the Shipment drop-off time and date, the pick-up and drop-off address, trip route, distance travelled, and duration.

Information concerning Trucker’s services history is also collected by the Platform and shared with Trucker’s customers including: the Number of Trucker jobs; the Number of deliverables; Number of empty pickups; Percent delivered versus pickups; Total number of hours served; Total number of miles served; Number of delivery issues; Number of pickup issues; Total number of issues; Percent of delivery/pickup issues (“Trucker Dashboard Data”).  In addition, customers may provide feedback and rate Trucker’s performance which is then incorporated into a “TruckerScore.” Trucker’s own TruckerScoreis visible to Trucker on the Trucker App and to Trucker’s customers having an account on the Platform.

Call and Text Information/Communications Data. We work with a third-party partner to facilitate phone calls and text messages between Company and Users. We receive information about these communications including the date and time of the call or SMS message, the parties’ phone numbers, and the content of any SMS messages. For security purposes, we may also monitor and/or record the contents of emails and phone calls made on or through the Platform, such as those between Customers and Brokers or Customers and Truckers. You will be given notice that your call may be recorded, and by proceeding you agree to allow Company to monitor and/or record your call.

User Feedback.
At KlearNow, we want to make sure Users are always satisfied the Services they provide or receive. Customers may be given the opportunity from time to time to rate and review Brokers at the completion of services received. Customers may also rate and review Truckers after a delivery transaction is completed. We receive information about ratings and reviews and give subsequent Customers information about Brokers’ and Truckers’ ratings through an internally calculated BrokerScore and Trucker Score.

Information from Cookies and Similar Technologies.

Location Information. When the Trucker App is downloaded by a Trucker delivering goods from a port of entry to a designated recipient, KlearNow tracks the location of the Trucker and calculates the goods’ estimated time of arrival at its designated location. To do this, a Trucker appointed by a Customer must download the Trucker App and must give us permission through their device settings or the Trucker App. Trucker’s location information, route, duration, and distance travelled is then tracked. We may also collect and track the Trucker’s location while the app is off.

C. Information We Collect from Third Parties

Third Party Services including Third Party Payment Providers and Financial Services Providers. If you choose to register for the Platform or otherwise link your Platform account with a third party’s service (such as using the User Payment Option), we may receive the same type of information we collect from you (described above) directly from those services.

Third Party Partners. We may receive additional information about you, such as demographic data, payment information, or fraud detection information, from third party partners and combine it with other information that we have about you.

Background Information on Brokers. KlearNowworks to perform licensing checks on Brokers using publicly available information about a Broker’s current license or permit status.

Cookies and other technologies

 We collect information through the use of “cookies”, tracking pixels, and similar technologies to understand how you navigate through the Platform and interact with KlearNow, to learn what functions and features are popular, and to save your preferences. Cookies are small text files that web servers place on your device; they are designed to store basic information, to help websites and apps recognize your browser and distinguish you from other users of the Platform. This helps us to provide you with a good experience when you use the Platform and also allows us to improve the Platform.

Most web browsers automatically accept cookies and similar technologies, but if you prefer, you can change your browser to prevent that and your help screen or manual will tell you how to do this. We also give you information about how to disable cookies disable cookie. However, you may not be able to take full advantage of our website if you do so.

We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be accessed every time you use the Platform.

We use these cookies and other technologies on the basis that they are necessary for the performance of a contract with you, or because using them is in our legitimate interests (where we have considered that these are not overridden by your rights), and, in some cases, where required by law, where you have consented to their use.

We use cookies and/or other similar technologies, either alone or in combination with each other][ to create a unique device ID].

We use the following types of cookies:

  • Strictly necessary cookies. These are cookies that are required for the operation of our website and under our terms with you. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
  • Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us for our legitimate interests of improving the way our website works, for example, by ensuring that users are finding what they are looking for easily.
  • Functionality cookies. These are used to recognise you when you return to our website. This enables us, subject to your choices and preferences, to personalise our content, greet you by name and remember your preferences (for example, your choice of language or region).
  • Targeting[/Advertising]cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information subject to your choices and preferences to make the Platform and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

We may also work with advertising networks that gather information about the content on the Platform you visit and on information on other websites and services you visit. This may result in you seeing advertisements on the Platform or our advertisements when you visit other websites and services of third parties. For more information about how to turn this feature off see below or visit http://www.youronlinechoices.co.uk.

The effect of disabling cookies depends on which cookies you disable but, in general, the website may not operate properly if all cookies are switched off. [If you only disable third party cookies, you will not be prevented from making purchases on the Platform. If you disable all cookies, you will be unable to complete a purchase on the Platform].

If you want to disable cookies on our site, you need to change your website browser settings to reject cookies. How you can do this will depend on the browser you use. Further details on how to disable cookies for the most popular browsers are set out below: –

For Microsoft Internet Explorer:

  1. Choose the menu “tools” then “Internet Options”
  2. Click on the “privacy” tab
  3. Select the setting the appropriate setting

For Google Chrome:

  1. Choose Settings then Advanced
  2. Under “Privacy and security,” click “Content settings”.
  3. Click “Cookies”

For Safari:

  1. Choose Preferences then Privacy
  2. Click on “Remove all Website Data”

For Mozilla firefox:

  1. Choose the menu “tools” then “Options”
  2. Click on the icon “privacy”
  3. Find the menu “cookie” and select the relevant options

For Opera 6.0 and further:

  1. Choose the menu Files then “Preferences”
  2. Privacy

Where you have not set your permissions, we may also separately prompt you regarding our use of cookies on the Site.

Except for essential cookies, all cookies used on our site will expire after {[30 days]}.

You can find more information about the individual cookies we use and the purposes for which we use them

Cookie type Name Purpose and lawful basis More information
1.Wordpress
global page –
Website url
www.klearnow.com
www.klearnow.co.uk
Name: globaldomain
Cookies
  • Comment Cookie
  • Login Cookie
  • Remember me Cookie]
This cookie is essential for our site. If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.

If you visit our login page, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser. When you log in, we will also set up several cookies to save your login information and your screen display choices.If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed. If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited.This cookie is used by the opt-in privacy policy to remember not to ask the user to accept cookies again. This cookie is set when KlearNow gives users the choice to opt-out policy.

(Expires: 2 years)

This cookie can be set to prevent the tracking code from sending any information to HubSpot. Setting this cookie is different from opting out of cookies, which still allows anonymized information to be sent to HubSpot.

(Expires: 2 years)

This cookie is used to test whether the visitor has support for cookies enabled.

(Expires: Session cookie)

This cookie is used to consistently serve visitors the same version of an A/B test page that they’ve seen before.

(Expires: Session cookie)

This cookie is used to consistently redirect visitors to the language version of a page in the language they’ve selected on this top-level private domain in the past (if such a language version exists).

When visiting a password-protected page, this cookie is set so future visits to the page from the same browser do not require a login. The cookie name is unique for each password-protected page.

Purpose : To store visitor selection Expire : 30 Days

Depending on the cookie stated here it will last 1 year.

Login cookies last for two days, and screen options cookies last for 1 year.

It expires after 1 day. (Optional, this cookie is generated only when admin logins are used example bonoboz and KlearNow team)

2. Hubspot: Third party – hubspot.com __hs_opt_out
__hs_do_not_track
__hs_testcookie
hs_ab_test
hs_lang_switcher_choice
<id>_key
hs-messages-is-open (TTL 30 minutes
hs-messages-hide-welcome-message (TTL 1 day)
__hstc
hubspotutk
__hssc
__hssrc
messagesUtk
This cookie is used on the visitor UI side so HubSpot can determine/save whether the chat widget is open for future visits. It resets after 30 minutes to re-close the widget after 30 minutes of inactivity

(TTL 1 day)
The main cookie for tracking visitors. It contains the domain, utk (see below), initial timestamp (first visit), last timestamp (last visit), current timestamp (this visit), and session number (increments for each subsequent session).

(Expires: 2 years)

This cookie is used for to keep track of a visitor’s identity. This cookie is passed to HubSpot on form submission and used when de-duplicating contacts.

(Expires: 10 years)

This cookie keeps track of sessions. This is used to determine if Hubspot should increment the session number and timestamps in the __hstc cookie. It contains the domain, viewCount (increments each pageView in a session), and session start timestamp. (Expires: 30 min)

Whenever HubSpot changes the session cookie, this cookie is also set. We set it to 1 and use it to determine if the user has restarted their browser. If this cookie does not exist when we manage cookies, we assume it is a new session.

(Expires: None. Session cookie)

This cookie is used to recognize visitors who chat with us via the messages tool. If the visitor leaves KlearNow´s site before they’re added as a contact, they will have this cookie associated with their browser. If KlearNow has a history of chatting with a visitor and they return to our site later in the same cookie browser, the messages tool will load your conversation history with that visitor.

This cookie is used to recognize visitors who chat with us via the messages tool. If the visitor leaves KlearNow´s site before they’re added as a contact, they will have this cookie associated with their browser. If KlearNow has a history of chatting with a visitor and

HubSpot uses cookies to track your website visitors and contacts. A cookie is a small text file that is left behind on a visitor’s browser when they come to your site. When the HubSpot software runs on your website, it leaves behind a cookie on your visitors’ browsers that helps HubSpot identify them on future visits.
Functional cookies they return to our site later in the same cookie browser, the messages tool will load your conversation history with that visitor.
3. Google Analytics
Google.com
Cookie Names

__utma / 2 years
__utmb / 30 minutes
__utmc / end of session
__utmz / 6 months
__utmv / 2 years
_ga / 2 years
_gat / 10 minutes
-Utmz
_utmli

__gads

Google cookies expiry date varies between end of session or several years after. Google Analytics cookies are used to measure traffic on our website.

A unique textstring is saved to identify browser, timestamp for interactions and the browser/sourcepage that led the user to our website.

No sensitive information is saved. For more information, read the general Google Privacy policy, analytics policy or the description of Google Analytics cookies by Google.

4. Vimeo – third party
vimeo.com
__qca
__ssid
_abexps
_ceg.s
_ceg.u
_ga
continuous_play_v3
has_logged_in
is_logged_in
player
search_click_position
vimeo
vuid
Vimeo expiry date varies between end of session or several years after. Vimeo’s embeddable video player uses first-party cookies that are considered essential to the video player experience. No third-party analytics or advertising cookies are set when the video player appears on a third-party website. This may set cookies on your computer once you click on the Vimeo video player, but Vimeo will not store personally identifiable cookie information for playbacks of embedded videos using the privacy-enhanced mode. Read more at:  https://vimeo.com/cookie_policy

How We Use the Information We Collect

 We use the information we collect from all Users to:

  • Connect Customers with Brokers;
  • Provide, improve, expand, and promote the Platform;
  • Analyze how the KlearNowcommunity uses the Platform;
  • Communicate with you, either directly or through one of our partners;
  • Personalize the KlearNowexperience for you;
  • Send you text messages and push notifications;
  • Facilitate transactions and payments;
  • Provide you with customer support;
  • Find and prevent fraud; and
  • Respond to trust and safety issues that may arise, including incidents or disputes between Customers and Brokers, and requests from government authorities.

Additionally, we use the information we collect from Users for the following purposes related to the Platform:

  • Sending emails and text messages to Users who have started the user registration process regarding the status of their registration;
  • Determining a Broker’s eligibility to provide Services through the Platform;
  • Notifying Brokers about Customer demand, pricing and service updates; and
  • Calculating and analyzing usage patterns for business purposes.

How We Share the Information We Collect

 Sharing Between Users

 Sharing between Customers and Brokers.
Customers and Brokers that have been matched for the provision and receipt of Services are able to see basic information about each other, such as Broker and Customer names, Broker’s license number and BrokerScore, as well as information relating to Customer’s shipment as needed to complete the provision of Services such as Customer’s Carrier, the intended Recipient of Customer’s goods, information about Customer’s goods including cost, type, HTS Code, Declared Value, Cost of shipping, origin and destination location, and a Job ID assigned by the Platform. We de-identify the Broker ratings and feedback, but we can’t rule out that a Broker may be able to identify the Customer that provided the rating or feedback.

 Sharing between Customers and Truckers.Truckers that have been appointed by Customers to deliver Customer’s goods from a port of entry to the designated recipient’s location will receive Customer feedback on the delivery transaction once completed.  That feedback will be used in part to calculate a TruckerScore that will then be made available to other Customers that use the Trucker’s delivery services.

If you participate in the User Payment Option, we will provide the User’s account administrator with information about your use of the Platform, including transaction details such as date, time, charge, duties and taxes.

Sharing Between KlearNow and Third Parties
Service Providers. We work with third party service providers to perform services on our behalf, and we may share your information with such service providers to help us provide the Platform, including all of the things described in Section 5(b) of the Platform Terms.

Other Sharing…

We may share your information with third parties in the following cases:

  • With our group companies;

While negotiating or in relation to a change of corporate control such as a restructuring, merger or sale of our assets;

  • If a government authority requests information and we think disclosure is required or appropriate in order to comply with laws, regulations, or a legal process;
  • With law enforcement officials, government authorities, or third parties if we think doing so is necessary to protect the rights, property, or safety of the KlearNow community, KlearNow, or the public;
  • To comply with a legal requirement or process, including but not limited to, civil and criminal subpoenas, court orders or other compulsory disclosures.
  • With our insurance partners to help determine and provide relevant coverage in the event of an incident;
  • With our auditors, legal advisors and other professional advisors;
  • To provide information about the use of the Platform to potential business partners in aggregated or de-identified form that can’t reasonably be used to identify you; and
  • Whenever you consent to the sharing.
Your Choices

Email Subscriptions. Where permitted in our legitimate interest or with your prior consent where required by law, we will use your personal information for marketing analysis and to provide you with promotional update communications by text message, push notifications and email about our services. Users can opt out of promotional emails, however, KlearNow will still send you transactional and service emails about your account use of the Platform.

Text Messages. You can opt out of receiving commercial or promotional text messages by texting the word STOP to ____ from the mobile device receiving the messages. You may also opt out of receiving all texts from KlearNow(including transactional or relational messages) by texting the word STOPALL to ____ from the mobile device receiving the messages, however, opting out of receiving texts may impact your use of the Platform including automatic deactivation of the Trucker App. Truckers can also opt out of driver-specific messages by texting STOP in response to a driver SMS. To re-enable texts you can text START in response to an unsubscribe confirmation SMS.

Push Notifications. You can opt out of receiving push notifications through your device settings. Please note that opting out of receiving push notifications may impact your use of the Platform.

Profile Information. While your name will always be shared with Users in connection with the provision and receipt of services, you can delete or modify certain additional information that you added to your Profile at any time if you don’t want Users to see it. Customers will always be able to see Brokers’ names, BrokerScore, Broker license information and a Trucker’s TruckerScore and delivery transaction history.

Location Information. While Truckers delivering a Shipment on behalf of a Customer can prevent their goods from being tracked at any time through the Trucker App by turning off “location tracking” on their device, Shipment tracking and location is core to the Trucker App and without it we cannot provide map and/or GPS voice navigation services and other information to you if your “location tracking” is turned off on your device.

Editing and Accessing Your Information. You can review and edit certain account information by logging in to your account settings and profile. If would like to terminate your account, please contact us through our Help Center with your request. If you choose to terminate your account, we will deactivate it for you but may retain information from your account for a certain period of time and disclose it in a manner consistent with our practices under this Privacy Policy for accounts that are not closed. We also may retain information from your account to collect any fees owed, resolve disputes, troubleshoot problems, analyze usage of the Platform, assist with any investigations, prevent fraud, enforce our Terms, or take other actions as required or permitted by law.

Where we store information

We host personal information submitted to the Platform in the UK. We may share personal data with our group companies based in the United States in order to facilitate the operation of our group of businesses. Therefore, KlearNow transfers information of users in the EEA outside the EEA on the basis of mechanisms approved under applicable laws and regulations. Where your information is transferred outside the EEA, we will take all steps reasonably necessary to ensure that your data is subject to appropriate safeguards, such as relying on a recognised legal adequacy mechanism, and that it is treated securely and in accordance with this privacy policy.

Questions, comments and complaints about KlearNow’s data practices can be submitted to KlearNow’s data protection office through the KlearNow website or by email to Privacylegal@KlearNow.com.

Other

Data Security. We are committed to protecting the data of the KlearNow community. Even though we take reasonable precautions to protect your data, no security measures can be 100% secure, and we cannot guarantee the security of your data.

Children’s Privacy. KlearNowis not directed to children, and we don’t knowingly collect personal information from children under 13. If we find out that a child under 13 has given us personal information, we will take steps to delete that information. If you believe that a child under the age of 13 has given us personal information, please contact us at our Help Center.

Changes to Our Privacy Policy. We may make changes to this Privacy Policy from time to time. If we make any material changes, we will let you know through the Platform, by email, or other communication. We encourage you to read this Privacy Policy periodically to stay up-to-date about our privacy practices. As long as you use the Platform, you are agreeing to this Privacy Policy and any updates we make to it.

Contact Information. Feel free to contact us at any time with any questions or comments about this Privacy Policy, your personal information, our use and sharing practices, or your consent choices by contacting our Help Center or by email to Privacylegal@KlearNow.com. Our address is 3945 Freedom Circle Suite 400, Santa Clara, CA 95054, USA.

Information Retention and Deletion

SUMMARY

KlearNow requires user profile information in order to provide its services, and retains such information for as long you maintain your KlearNow account and for six years after that to identify any issues and resolve any legal proceedings.Once such information is no longer necessary to provide KlearNow’ services, enable customer support, enhance the user experience or other operational purposes, KlearNow takes steps to prevent access to or use of such information for any purpose other than compliance with these requirements or for purposes of safety, security and fraud prevention and detection.

KlearNow retains certain information, including transaction, usage, device and other information as legally required in connection with regulatory, tax, insurance or other requirements in the places in which it operates including applicable Customs regulations. KlearNow thereafter deletes or anonymizes such information in accordance with applicable laws.

Users may request deletion of their accounts at any time through the Privacy Settings in the KlearNow apps, or via KlearNow’ website Help page. Following such request, KlearNow deletes the information that it is not required to retain, and restricts access to or use of any information it is required to retain.

In certain circumstances, KlearNow may be unable to delete your account, such as if there is an outstanding credit on your account or an unresolved claim or dispute. Upon resolution of the issue preventing deletion, KlearNow will delete your account as described above.

KlearNow may also retain certain information if necessary for its legitimate business interests, such as fraud prevention and enhancing users’ safety and security. For example, if KlearNow shuts down a user’s account because of unsafe behavior or security incidents, KlearNow may retain certain information about that account to prevent that user from opening a new KlearNow account in the future.

Special Information For EU Users

SUMMARY

Beginning May 25, 2018, the processing of personal data of users in the European Union is subject to the EU General Data Protection Regulation (“GDPR”). This section summarizes KlearNow Ltd.’s grounds for processing personal information under the GDPR as controller, and the rights of EU users as relates to KlearNow’ handling of personal information, and KlearNow’ responsibilities, under this regulation.

1. EU User Rights

 If you are a KlearNowUser in the EU you have the following rights with respect to KlearNow’ handling of your personal information in certain circumstances:

a. Access to your data

(i) You have the right to request an explanation of the information that KlearNow has about you and how KlearNow uses that information.

(ii) You also have the right to receive a copy of the information that KlearNow collects about you.

b. Correction. If KlearNow has information about you that you believe is inaccurate, you have the right to request correction of your information.

c. Deletion

(i) Users may request deletion of their accounts at any time via KlearNow’ website Help page. We may retain certain information about you as required by law including applicable Customs regulations and for legitimate business purposes permitted by law.

(ii) Please see the “Information Retention & Deletion” section above for more information regarding KlearNow’s retention and deletion practices.

d. Objections and restrictions

(i) Users in the EU have the right to object to KlearNow’s processing of personal data, including for marketing purposes. KlearNow may continue to process your information notwithstanding the objection to the extent permitted under GDPR.

(ii) Users in the EU have the right to request that KlearNow restrict the processing of their personal data (while its verifies or investigate their concerns with this information, for example).

e. Data portability

Users in the EU have the right to request that their personal data be transferred to a third party.

f. Complaints

Users in the EU also have the right to file a complaint relating to KlearNow’s handling of your personal information to the appropriate Supervisory Authority in the EU(see http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.html). You may also submit a complaint to KlearNow’ Data Protection Office by email to Privacylegal@KlearNow.com.

e. To exercise these rights, please submit your request by contacting KlearNow through the KlearNow website Help page or by email to email me. Users outside the EU may also request explanation, correction, deletion or copies of their personal data through the KlearNow website.

You can also edit the profile information associated with your account through the Settings menu in KlearNow website and apps. You can also look up your transaction history on the KlearNow website and apps.

2. Grounds for Processing

 The GDPR requires that companies processing the personal data of EU users do so on the basis of specific legal grounds. As described below, KlearNow processes the information of EU users based on one or more of the grounds specified under the GDPR:

a. The processing is necessary to perform the contract with you and provide the services and features you request.KlearNow must collect and use certain information in order to provide its services.

This includes:

(i) User profile information that is necessary to establish and maintain your account, including to verify your identity; enable communications with you about your Services and accounts; and to enable you to make payments or receive earnings.

(ii) Broker Background Licensing Information which is collected from publicly available sources is necessary to enable Broker to provide Services through the KlearNowPlatform.

(iii) Transaction information, which is necessary to generate and maintain in connection with your use of KlearNow’ Platform and provision or receipt of services.

(iv) Trucker Location Information, which is necessary to determine the estimated arrival time of a delivery and to track trips while in-progress and suggest navigation.

(v) Usage information, which is necessary to provide the KlearNow’ services and the Platform, including to determine, sometimes in combination with other information, the best match between Customers and Brokers, and calculate costs of providing Services and Broker Rates. Collection and use of this information is a requirement for using the KlearNow Platform.

b. The processing is necessary to protect the vital interests of our users or of others. KlearNow may process personal information, including disclosing data with law enforcement authorities in case of threats to the safety of users or of others.

c. The processing is necessary for KlearNow’ legitimate interests (being the effective running of its services and Platform).KlearNow collects and uses personal information to the extent necessary for its legitimate interests. This includes collecting and using information:

(i) Platform. We also use usage information to better match Customers and Brokers.

(ii) To prevent, detect and combat fraud in connection with the use of our services. For example, KlearNow uses User profile, location, device and usage information, to identify and prevent circumstances when users attempt to defraud KlearNow or other users.

(iii) To inform law enforcement officials regarding criminal acts or threats to public safety.

(iv) To provide customer support.

(v) To optimize our service and develop new services. This includes, for example, identifying the best matches between Customers and Brokers, recommending (new) features, improving navigation, and enhancing pricing.

(vi) For research and analytical purposes. This includes, for example, analyzing usage trends to improve the user experience and enhance the efficiency and security of our services.

(vii) For direct marketing purposes. This includes, for example, analyzing data to identify trends and tailor features to user needs.

(viii) To enforce KlearNow’s Terms and Conditions of service including use of the Platform.

d. The processing is necessary for the legitimate interests of other persons or parties. KlearNow collects and uses personal information to the extent necessary for the interests of other persons or the general public. This includes sharing information in connection with legal or insurance claims, to protect the rights and safety of others. KlearNow to maintain and enhance our Users’ experience with the Platform and to maintain, optimize and enhance the KlearNow services and Platform. For example, we collect information on the Services you receive or provide and Broker’s Updated License Information using publicly available sources to facilitate the provision of Services through our Platform, or information about how you use and interact with the Platform. We also use personal information to prevent use of our services by users who have engaged in inappropriate or dangerous behavior, such as by retaining information of banned users to prevent their use of KlearNow may also process personal information when necessary in regards to a substantial public interest, on the basis of applicable laws.

e. The processing is necessary to fulfill KlearNow’ legal obligations.

(i) KlearNow is subject to legal requirements in the jurisdictions in which it operates that require us to collect, process, disclose and retain your personal data. For example, KlearNow is subject to laws and regulations in many cities and countries that require it to collect and retain information about your Services, to retain such information for extended periods of time, and to provide copies of such information to governmental or other authorities. KlearNow uses your information to comply with such laws to the extent they apply to your use of the KlearNow Platform.

(ii) KlearNow may also share information when legally required with law enforcement, or requests by third parties pursuant to legal processes.

f. Consent

(i) KlearNow may collect and use your information on the basis of your consent. You may revoke your consent at any time. If you revoke your consent, you will not be able to use any service or feature that requires collection or use of the information we collected or used on the basis of consent.

(ii) KlearNow relies on consent in connection with data collections or uses that are necessary to enable and enhance the User experience, to enable optional services or features, or to communicate with you.

(iii) KlearNow may also collect personal information about you through voluntary surveys. Your responses to such surveys are collected on the basis of consent, and will be deleted once no longer necessary for the purposes collected.

(iv) Device Permissions.  Most mobile platforms (iOS, Android, etc.) have defined certain types of device data that apps cannot access without your consent. And these platforms have different permission systems for obtaining your consent. The iOS platform will alert you the first time the KlearNow app wants permission to access certain types of data and will let you consent (or not consent) to that request. Android devices will notify you of the permissions that the KlearNow app seeks before you first use the app, and your use of the app constitutes your consent.

(v) After every Services and Delivery transaction, Customers are able to rate Brokers and Truckers, as well as give feedback on how the transaction went that is then factored in calculating a BrokerScore and a TruckerScore. Customer Feedback is intended to provide accountability and helps to improve the provision of services.

3. Updates To This Policy

We may occasionally update this policy. If we make significant changes, we will notify you of the changes through the KlearNow website or apps or through others means, such as email. To the extent permitted under applicable law, by using our services after such notice, you consent to our updates to this policy.

We encourage you to periodically review this policy for the latest information on our privacy practices. We will also make prior versions of our privacy policies available for review.