Version: 1.1
Last Modified: 06-29-2021
Protecting the privacy of users of CartGateway inc (Company, we, us, our) services and websites (www.CartGateway.com) is important to us. This privacy policy informs you about our collection and use of personal information in our services and website. From time to time, Company will make changes to this policy so please check back and review it regularly to stay aware of current practices.

1. Cookies

This website uses cookies to aggregate information about the pages that users visit so that we can update and redesign this website, as necessary, in order to provide you with the most useful information. This will enable you to take full advantage of the services we offer. A "cookie" is an identifier that we transfer to users' computer hard drives through users' web browsers to enable our systems to recognize users' browsers and interact more efficiently with users' computers. You can generally configure your browser to accept or reject all cookies or notify you when a cookie is used. We suggest that you refer to your browser instructions or help screens to learn more about these functions, bearing in mind that if you configure your browser so as to not receive any cookies, a certain level of functionality of this website and other websites may be lost.

2. Adwords

This website may also use a remarketing feature in Google AdWords to reach out to people who previously visited our website. Remarketing involves classifying users according to how they use our website and creating an audience segment for third-party vendors, including Google, to show our targeted ads on third party websites. For example, if you access our contact form to make an enquiry about a particular product on our website, you may receive information relevant to that product within a specific time of visiting our website. This could be in the form of an ad on the Google search results page, or on a site in the Google Display Network. You can set preferences for how Google advertises to you using the Google Ad Preferences page, and if you want to, you can opt out of interest-based advertising entirely by changing your cookie settings or permanently using a browser plugin.

3. What Is Personal Information?

Personal information is non-public information that can be used to identify an individual. This includes any personal information or opinions about you, whether true or not, no matter how the information or opinions are recorded and includes information from any source. Credit information is a sub-set of personal information.

4. Collection Of Personal Information

The nature of the personal information we collect about you online is generally your name, mailing address, e-mail address, phone number, the company you represent, company address and is strictly limited to the information that you voluntarily provide to us (through our website or by contacting us by any means). Personal information may also include identification information, age, gender, financial information, credit information, bank account information, payment transaction information and other information that you provide in applying to use our services or actually using our services or those of our suppliers. If at any time you provide information about another person to us (i.e. an individual - for example, a referee, or a person to whom a payment is to be directed), you warrant that you are authorized to do so and that you will inform that person of who we are and that we will use and disclose their information as set out in this privacy policy. If you provide incomplete or inaccurate information to us, we may not be able to provide you with the services you are seeking. We do not seek to collect nor store information about anyone's ethnic origins, political or religious beliefs, trade union membership, sexual preferences or criminal record. If you provide these and other types of sensitive information to us, then by doing so, you consent to our collection of that information and to the use and disclosure of that information as set out in this privacy policy.

5. Use And Disclosure Of Personal Information

• We will use and disclose information for the primary purpose for which it was collected. We collect and hold the personal information that you supply to us on this website or through your contact with us to:
• identify and contact you so that we can provide you with the information you have requested, assess and process any application you make for services, provide services to you and administer and manage services provided to you (including charging, billing and collecting debts);
• gain an understanding of your information and communication needs in order for us to provide you with better, more personalized services that are tailored to your needs;
• inform you of ways the services provided to you could be improved;
• conduct appropriate checks for credit-worthiness and for fraud;
• research and develop our services using third party services;
• send you other information that we believe you would find interesting about Company or the services you receive (direct marketing). You may opt out of any direct marketing service at any time;
• perform our administrative operations, including accounting, risk management, record keeping, archiving, maintain and develop our business systems and infrastructure (including systems development, testing and upgrading), credit scoring and staff training; and
• validate the user's rights to view the information provided.
We also may use and hold personal information, which is provided to us in connection with services that you request, for the purposes (as relevant) of:
• complying with legislative and regulatory requirements or as otherwise permitted or authorized by law;
• considering any other application you may make to us;
• managing our rights and obligations in relation to external payment systems, e.g. credit card schemes and debit payment schemes;
• conducting market or customer satisfaction research;
• developing, establishing and administering alliances and other arrangements (including rewards programs) with other organizations in relation to the promotion, administration and use of our respective products and services;
• developing and identifying products and services that may interest you; and
• for administrative and management purposes for the Company group including without limitation, account management, data processing, data storage in support of our website and services. We may also use and disclose personal information for purposes that are related or ancillary to the primary purpose we collect it. Information collected by us is used to provide and administer the provision of services to you, managing our rights and obligations under contracts and at law, systems development and testing, in connection with alliance arrangements, and identifying and marketing the products or services provided by us, our related bodies corporate or other organizations that we think may be of interest to you and telling you about them. In common with many other businesses, we use agents and other third parties to conduct certain activities on our behalf and provide certain services to us. For this purpose, we may need to provide these third parties with your personal information. Where appropriate, these disclosures are subject to privacy and confidentiality protections. Where we engage third party contractors to perform services for us, and there is a possibility of their handling of personal information we hold, we prohibit the third party contractor from using personal information about you except for the specific purpose for which we supply it. The types of organizations to which we may disclose a customer's, consumer's or user's personal information include:
• banks, other financial institutions and processors for the purpose of processing transactions and tracing transactions;
• external payment systems operators and participants (e.g. credit card payment systems or debit payment systems);
• credit-reporting and fraud-checking agencies;
• our agents, contractors and external advisers whom we engage from time to time to carry out, or advise on, our functions and activities, including our accountants, auditors and lawyers;
• providers of other services to us;
• anyone supplying goods or services to you in connection with an alliance program associated with the services you request;
• any person or organization who introduces you to us;
• any person to the extent necessary, in our view, in order to carry out any instruction you give to us;
• regulatory agencies;
• debt collection agencies;
• organizations involved in managing our corporate risk and funding functions (e.g. securitization);
• any person considering purchasing a contract entered into by you from us and that person's advisers, persons involved in assessing the risks and funding of the purchase and, after purchase, the purchaser and any manager on an ongoing basis;
• your and our insurers or prospective insurers and their underwriters;
• other organizations including our related bodies corporate (and our agents and their agents) and organizations with whom we have alliances or arrangements (including reward programs) for the purpose of promoting our respective products and services; and
• for administrative and management purposes for the Company group including without limitation, account management, data processing, data storage, provision of internet services and webhosting;
• any of whom may be located outside of the United States. Where such disclosure occurs, we will require these third parties to keep your information confidential and use it only for the purposes for which we are permitted to use it in accordance with the principles set out in this policy.
• We may also disclose a customer's, consumer's or user's personal information to parties associated with you including:
• your agents and contractors, including your finance broker, referees and your legal or financial adviser;
• your executor, administrator, trustee, guardian or attorney; and
• your franchisor (if applicable).
In addition, we may be required or permitted by law to use and disclose your personal information.
• There may also be circumstances in which we consider a customer or user has, by their actions, released us from our duty of confidentiality or has consented to the disclosure of personal information about them without actually stating that this is the case.

6. Direct Marketing

By accepting our services you expressly permit us to use your personal information for direct marketing purposes. You agree that we may collect information about you from, and disclose it to, third party organizations including our related bodies corporate (and our agents and their agents) for the marketing of products and services. You consent to the use of your information to issue product and professional mail outs by email, fax, social media or letters and undertaking other marketing or service based activities. You may opt out of any direct marketing service at any time.

7. Commercial

Communication Company may use any electronic addresses you have provided to us or for which you are the relevant electronic account holder (both "your addresses") to send you commercial electronic communication in order to provide you with information and to tell you about products and services, including those of third parties, which we consider may be of interest to you. You warrant that you have authority either as or on behalf of the relevant electronic account holder to provide this consent. You agree that until you provide written notice or use an unsubscribe facility included with a commercial electronic message to withdraw your consent, we may continue to send commercial electronic messages to your addresses.

8. Our Services

The services that we provide are provided pursuant to commercial agreements between you and Company or one of our suppliers or both. Those agreements are separate from this policy.

9. We Protect Your Information

We limit access to your personal information to those of our employees and employees of other entities in the Company group, agents or other third parties who need your personal information to fulfil their responsibilities in relation to the services provided by us. All Company employees must adhere to our privacy policies. Employees violating these policies may be subject to disciplinary action, up to and including dismissal. Our service providers and other outside contractors are subject to contractual requirements to ensure that your personal information is safeguarded.

10. We Secure Your Information

At Company, security is a priority. We employ appropriate measures to protect personal information against unauthorized access, disclosure, alteration or destruction. These may include, among others, encryption, physical access security and other appropriate technologies. We continually review and enhance our security systems as necessary.

11. Third Party Content

We may create links to third party websites. We are not responsible for the content or privacy practices employed by websites that are linked from our website. If you visit the pages and sites of our affiliated business units, please be sure to review the privacy policies applicable to those sites. Companys privacy policies and practices do not apply to these sites. Company does not guarantee, approve, or endorse any information, material, services, or products contained on these links. Company is not responsible for any content on sites linked from or to this website. Company is providing the linked sites as a convenience, and your connection to any linked site is at your own risk. This policy applies only to the information we collect on this website. The content of other websites, services, goods or advertisements that may be linked to this website is not maintained or controlled by Company. Company is therefore not responsible for the availability, content or accuracy of other websites, services or goods that may be linked to, or advertised on, this website.

Where this website contains hyperlinks to websites operated by third parties these linked websites are not under the control of Company and Company is not responsible for the contents of any linked website. Company provides these hyperlinks to you for convenience only, and the inclusion of any link does not imply any endorsement of the linked website by Company.

12. Questions?

If you have any questions or concerns related to this policy, please contact Company at the contact information provided on its website.

Instructions

CartGateway inc ("CartGateway") needs to gather and use certain information about individuals. This information can include customers, suppliers, business contacts, employees and other people the organization has a relationship with or may need to contact. This policy describes how this personal data must be collected, handled and stored to meet the company’s data protection standards – and to comply with the law.

Why this Policy Exists

This data protection policy ensures CartGateway:

• Complies with data protection law and follows good practice
• Protects the rights of staff, customers, and partners
• Is transparent about how it stores and processes individuals personal data
• Protects itself from the risk of a data breach

The General Data Protection Regulation

The EU General Data Protection Regulation (GDPR) replaces the Data Protection Directive 95/46/EC and was designed to harmonize data privacy laws across Europe, to protect EU citizens’ data privacy and to reshape the way organizations across the world approach data privacy. The GDPR aims primarily to give control back to citizens and residents over their personal data and to simplify the regulatory environment for international business by unifying the regulation within the EU.

What is "Personal Data"?

"Personal data" is defined in both the Directive and the GDPR as any information relating to a person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that person. So in many cases online identifiers including IP address, cookies and so forth will now be regarded as personal data if they can be (or are capable of being) without undue effort linked back to the data subject.

1. Information collection and tracking

1.1. When you visit our website

You can visit our website (www.CartGateway.com) without giving away your personal information. CartGateway uses Google Analytics and Cookies in order to improve our service, user experience and analyze how our website is used. Aside from the approximate location (IP address), the information collected by Google Analytics is mostly anonymous traffic data including browser information, device information, language. We do not collect additional information, such as your age, gender, interests, bank details or clickstream. The collected information is used to provide an overview of how people are accessing and using the CartGateway website. It is not used for any additional purpose, such as to profile those who access our website.

2. When you contact us

While you can use our website without giving out your personal information, once you contact us via the CartGateway website, CartGateway collects information about you. The information you fill in (personal information such as your name, email address, organization) will be processed and stored so that it is possible for us to contact and respond to your request, and/or allow you access to our services.

2.1. Recruitment

If you apply for a job with CartGateway, we will collect, process and store the information you have sent us for recruitment-related purposes, such as contacting you. Additionally, CartGateway may keep your data for a period of time for the purpose of considering you for a different opportunity.

3. Information Security

When CartGateway collects information about you, we also make sure that your information is protected from unauthorized access, loss, manipulation, falsification, destruction or unauthorized disclosure. This is done through appropriate technical measures.

4. Data Sharing

We might share your personal information with the following third parties for the purposes of providing you with the best service possible:

• other companies within the Group
• occasionally we may receive a request to disclose information about you with law enforcement, regulators and supervisory authorities where we are legally required to do so.

All our entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

5 Where We Might Send Your Data (Geographically)

We process data within the EEA and countries deemed by the European Union as having adequate safeguards for protecting personal data. These countries are recognized by the EU as having suitable safeguards for the rights and freedoms of individuals and recourse processes by which data subjects can exercise their rights.

We will only consider transferring your data outside of the EU if the following conditions are met.

• Made with your explicit informed consent
• Necessary for the performance of an agreement between you and us
• Necessary for important reasons of public interest
• Necessary for the establishment, exercise or defense of legal claims
• Necessary to protect your vital interests or those of other persons, where you are physically or legally incapable of giving consent

6. Access to Information

You have the right to request access to the information we have on you. You can do this by contacting us at [email protected] . We will make sure to provide you with a copy of the data we process about you. In order to comply with your request, we may ask you to verify your identity. We will fulfill your request by sending your copy electronically, unless the request expressly specifies a different method. For any subsequent access request, we may charge you with an administrative fee.

7. Information Correction & Deletion

If you believe that the information we have about you is incorrect, you are welcome to contact us so we can update it and keep your data accurate. Any data that is no longer needed for the purposes specified in Information Collection and Use or for any Regulatory Reporting purposes will be deleted.

If you have any queries about the personal data that CartGateway stores, you can simply contact us at [email protected].

8. When this Privacy Policy applies

This Privacy Policy is applicable to the services offered by CartGateway directly via our website. Our website may contain links to other websites. Once redirected to another website, this Policy is no longer applicable.

This version of the Privacy Policy is effective from June 2020.

9. Changes

We reserve the right to change this Privacy Policy. We constantly review our Privacy Policy and strive towards making it better. CartGateway will not reduce your rights stated in this Policy without asking for explicit prior consent to the changes. All changes to our Privacy Policy will be available on this website. You can access the previous version of this Policy here.

10. To Sum Up

In accordance with applicable law, we only collect a limited amount of information about you that is necessary for improving our service. We do not use profiling, we do not sell or in any way spread your data to third parties, unless we permit them to process your personal data for specified purposes and in accordance with our instructions, and we do not use your data for purposes other than what we specified. We also make sure that your data is stored securely. We delete all information deemed no longer necessary. We constantly review our Privacy Policy in order to make it better and protect you more.

11. You can contact us at any time to:

• Request access to information that CartGateway has about you
• Correct any information that CartGateway has about you
• Request Deletion of any non-contractual information that CartGateway has about you

If you have any additional questions about CartGateway's collection and storage of data, please contact us at:
CartGateway
1201 N Orange Street, Suite 7461 Wilmington, DE 19801
[email protected]

Glossary of terms

Cookies

Cookies are small files or other pieces of data which are downloaded or stored on your computer or other device that can be tied to information about your use of our website (including certain third party services and features offered as part of our website).

Device

A device is what you use to reach our website, such as a smartphone, tablet or computer.

IP address

Internet Protocol (IP) address is a number that is connected to your device. An IP address can be used to determine the location of your device typically within a 40km radius, thus not being an exact determination of your location. IP addresses are basically how the Internet functions.

Personal information

Personal information is information that can identify you. This can be your name, email, contact information or other type of information that can be traced back to you.