Privacy Policy

GDPR PRIVACY STATEMENT – ECU360

Last date of revision: 1st November, 2019

1. WHAT IS COVERED BY THIS ECU360 PRIVACY STATEMENT?

1.1 ECU Worldwide (“ECU Worldwide” or “We”) is a multi-national freight forwarding company headquartered in Belgium. We are a global leader in LCL (“Less than Container Load”) consolidation.

1.2 ECU Worldwide has more than 300 offices in over 160 countries. Our group consists of several companies (“the ECU Worldwide Companies”) that process personal data [an overview of ECU Worldwide companies can be provided upon your request to dataprivacy@ecuworldwide.com].

1.3 ECU Worldwide offers to its customers a personalised digital customer portal: the ECU360 tool. This platform enables the customers to avail a host of integrated services like getting a quote, converting that quote immediately into online bookings, downloading global sailing schedules, track and trace technology to follow-up the shipment and generating online invoices, all in a digital way.

By using the ECU360 tool, our customers can access all detailed information about their export and import shipments including its various operational and financial aspects. The ECU360 tool contains, among other things, the following tools and functionalities:

• Quote tool, including a fully functional rate calculator;
• Booking tool, enabling you to manage bookings;
• Shipping instructions, enabling you to manage shipping instructions;
• Shipments overview, enabling you to consult all export and import related shipments;
• Tariff view, enabling you to consult all tariff data;
• Receivable invoices;
• Report Scheduler view, enabling you to create and schedule reports on any entity;
• Document archive view, enabling you to upload, share and consult documents.

You can login to the ECU360 tool by navigating to the ECU360 login page on our website www.ecuworldwide.com.

1.4 This ECU360 Privacy Statement explains how and why we process your personal data, how we protect them and how long we keep them, when you use the ECU360 tool. For more information about why and how we process your personal data when we perform our business activities or when you use our website https://www.ecuworldwide.com/, please read our general GDPR Privacy Statement.

1.5 Please follow the below points for further information:

What is the purposes for processing your personal data?
What are the legal grounds for processing your personal data?
What are your rights with respect to the processing of your personal data?
Which categories of personal data will be processed?
Who will have access to your personal data?
Will your personal data be transferred to countries outside the EEA?
Do we use any cookies or similar technologies?
Will we make use of automated decision-making?
How long will your personal data be retained?
Are your data safe and secure?
Who can you contact?
Changes to this ECU360 privacy statement?

2. WHO WILL PROCESS YOUR PERSONAL DATA

2.1 The ECU Worldwide Companies jointly determine the purposes and means of the processing of personal data in the context of the ECU360 tool. Consequently, they act as joint controllers with respect to this tool.

2.2 The ECU Worldwide Companies have determined their respective responsibilities with respect to the ECU360 tool. You can always contact us in order to obtain more information about the essence of this arrangement.

3. WHAT ARE THE PURPOSES FOR PROCESSING YOUR PERSONAL DATA?

3.1 In the context of the ECU360 tool, we only process your personal data in the framework of the execution of our contractual relationship and for legitimate business reasons. These purposes include but are not limited to:

• providing you with the services of the ECU360 tool;
• the good organisation of our services, including invoicing;
• customer management;
• dealing with enquiries, requests and complaints;
• gaining external professional advice;
• dispute management;
• user management and administration;
• Statistics and analysis.

4. WHAT ARE THE LEGAL GROUNDS FOR PROCESSING YOUR PERSONAL DATA?

4.1 In the context of the ECU360 tool, we will mainly process your personal data based one of the following legal grounds:

• because it is necessary for the performance of a contract to which you are party (“Contract“);
• for the purposes of our legitimate interests, including (but not limited to) our business activities, customer and supplier management etc. In this respect, we will always determine case by case whether our interests are not overridden by your interests, fundamental rights and freedoms (“Legitimate interests“).

4.2 For each specific purpose for which we process your personal data, we will rely on one single legal ground. In the table below, you can find an overview of the applicable legal grounds for the purposes mentioned above:

4.3 If we have the legal obligation to obtain your free, informed, specific and unambiguous consent to process your personal data for certain purposes, we will only process your data for such purposes to the extent that we have obtained such consent from you.

5. WHAT ARE YOUR RIGHTS WITH RESPECT TO THE PROCESSING OF YOUR PERSONAL DATA?

5.1 You have several rights concerning the information we hold about you. We would like to inform you that you have the right to:

• obtain confirmation that we are processing your personal data and request a copy of the personal data we hold about you;
• ask that we update the personal data we hold about you, or correct such personal data that you think is incorrect or incomplete;
• ask that we delete personal data that we hold about you, or restrict the way in which we use such personal data if you believe that there is no (longer a) lawful ground for us to process it;
• withdraw consent to our processing of your personal data (to the extent such processing is based on consent);
• receive a copy of the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and to transmit such personal data to another party (to the extent the processing is based on consent or a contract);
• object to our processing of your personal data for which we use legitimate interest as a legal basis, in which case we will cease the processing unless we have compelling legitimate grounds for the processing.

5.2 In order to exercise any of your rights, you can send us a request, indicating the right you wish to exercise by e-mailing us at dataprivacy@ecuworldwide.com.

5.3 If you are unhappy with the way we have handled your personal data or any privacy query or request that you have raised with us, you have a right to complain to the Data Protection Authority (“DPA”) in your jurisdiction. If you would like to be directed to the appropriate DPA, please contact us.

6. WHICH CATEGORIES OF PERSONAL DATA WILL BE PROCESSED?

6.1 If you register for using the ECU360 tool, you may be asked to provide us with the following personal data:

• Name;
• Language;
• Job title and department;
• E-mail address;
• Mobile number;
• Your company;
• Whether you require access to other branches from your organisation
• The ECU Worldwide Office you want to be connected with.
• Before using the ECU360 tool, you will always have to login by entering your email / mobile number and your password.

6.2 For the purposes mentioned above, we may also process the following personal data:

• electronic identification data (e.g. IP addresses, browser type, cookie identifiers,…);
• financial specifics (e.g. bank account number, creditworthiness…);
• data about the use of the ECU360 tool (e.g. the products and services you order);
• data about how you interact with us (e.g. when you contact us) and other similar information;
• identification data (e.g. name, address (private/work), phone number (private / work), e-mail address (private / work), country of residence) of other individuals than users (e.g. other contact persons within your company, contact persons of shipping parties etc.)
• all other personal data which are communicated to us in the framework of the use of the ECU 360 tool (e.g. when you share documents with our booking desk).

6.3 We may obtain these data in the context of the use of the ECU 360 tool. In particular, we may obtain these data because you give them to us (e.g. by completing the registration form), because others give them to us (e.g. your employer) or because they are generated by the system.>

7. WHO WILL HAVE ACCESS TO YOUR PERSONAL DATA?

7.1 Employees and representatives of the Ecu Worldwide companies which are involved in the functioning of the ECU360 tool and/or the services provided on this platform (e.g. employees of our booking desk) and this on a strict need-to-know basis.

7.2 NINtec BV, the software solution provider which has developed the ECU360 tool, may have access to your personal data as well for technical purposes (e.g. bug fixing). However, NINtec BV will not transfer any personal data to its own local environment.

7.3 Hotjar Ltd., is a technology service that provides an analytics tool in order to better understand ECU 360 users’ needs and to optimize the service and experience. It helps us better understand our users experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behaviour and their devices (in particular device’s IP address (captured and stored only in anonymized form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), preferred language used to display our website). Hotjar stores this information in a pseudonymized user profile. Neither Hotjar nor we will ever use this information to identify individual users or to match it with further data on an individual user. For further details, please see Hotjar’s privacy policy by clicking on this https://www.hotjar.com/legal/policies/privacy

7.4 Google Analytics, a web analytics service offered by Google that tracks and reports ECU360 traffic.

7.5 Bing Map, a web mapping service provided by Microsoft that allows users to share maps and embed maps into their websites.

7.6 Furthermore, we may disclose your personal data to affiliated companies, third parties that provide services to us that reasonably require access to personal data relating to you for one or more of the purposes mentioned above.

7.7 We also reserve the right to disclose your personal information as required by law, or when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, request from a regulator or any other legal process served on us.

8. WILL YOUR PERSONAL DATA BE TRANSFERRED TO COUNTRIES OUTSIDE THE EEA?

Please note that some of the recipients of your personal data referenced above may be based in countries outside of the European Economic Area whose laws may not provide the same level of data protection. In the latter case, we will adopt appropriate safeguards to ensure compliance with data protection requirements. If you need any clarification about your personal data being shared with a company located in a third country outside of the EEA, please contact dataprivacy@ecuworldwide.com.

9. DO WE USE ANY COOKIES OR SIMILAR TECHNOLOGIES?

9.1 This Site uses Cookies. Cookies are small text files that are stored by your browser onto your computer or mobile device when you visit this Site.

They are used to provide you with a good experience when you browse this Site and allow us to improve this Site. With your consent, they can also be used to personalise the content of this Site based on your previous browsing behaviour and to gather statistics in order to improve this Site.

You can find more information about cookies by visiting the following website: www.allaboutcookies.org.

9.2 Cookies can be categorized according to the following characteristics:

Whether they are “session cookies” or “persistent cookies”:

• Session cookies
  A session cookie is used each time you visit our website to give you a session ID. We use this type of cookie to link your actions on our website and each session cookie will only last for a browser session, at the end of which it will expire. Each browser session will start when you open your browser window and finish when you close your browser window. After your visit to our website all session cookies are deleted. Each time you visit our website you will have a different session ID.

• Persistent cookies
  A persistent cookie allows the preferences or actions of the user across a site (or across different sites) to be remembered. It has a longer lifetime than a session cookie and lasts for the period of time specified in the cookie (this will vary from cookie to cookie). This type of cookie will not be deleted when you close your browser window and will be stored on your computer or mobile device. It will be activated every time you visit a website which created that particular persistent cookie.
  Whether they are “first party cookies” or “third party cookies”:

• First party cookiesA first party cookie is a cookie set by us or any of our processors.

• Third party cookies
  A third party cookie is a cookie set by a data controller that does not operate this site.

Please note that we do not have access or control over the cookies placed on this Site by third parties and use of their cookies is subject to their own privacy policies.

9.3 The types of cookies used on the Sites can be classified into the following categories, namely:

9.4 You can enable, disable and/or delete cookies as you wish. You can delete all cookies that are already on your device and you can set most browsers to prevent them from being placed.

The ability to enable, disable and/or delete cookies can be completed at browser level. These settings are usually found in the “options” or “preferences” menu of you internet browser. In order to understand these settings, the following links may be helpful. Otherwise you should use the “Help” option in your internet browser for more details:

• Cookie settings in Internet Explorer
• Cookie settings in Firefox
• Cookie settings in Chrome
• Cookie settings in Safari

10. HOW LONG WILL YOUR PERSONAL DATA BE RETAINED?

10.1 Your personal data will not be retained longer than necessary for the purposes described above.

10.2 As a general rule, records in the framework of the ECU360 tool that may contain personal data (e.g. online bookings, invoices, shipment records etc.) are stored for a period of 10 years.

10.3 Depending on the specific situation and the applicable national legislation, we may however retain your personal data for a longer period. This will in particular be the case if any of the following periods is longer : (i) as long as is necessary for our daily business; (ii) any retention period that is required by law; or (iii) the end of the period in which litigation or investigations might arise.

11. ARE YOUR DATA SAFE AND SECURE?

11.1 The data of the ECU360 tool are stored at ECU Worldwide’s data centers which are highly secured. We employ strict technical and organizational (security) measures to protect the information in the ECU360 tool from access by unauthorised persons and against unlawful processing, accidental loss, destruction and damage both online and offline.

These measures include:

• training to relevant staff to ensure they are aware of our privacy obligations when handling personal data;
• administrative and technical controls to restrict access to personal data on a ‘need to know’ basis (roles and rights
• training to relevant staff to ensure they are aware of our privacy obligations when handling personal data;
• administrative and technical controls to restrict access to personal data on a ‘need to know’ basis (roles and rights mechanisms, passwords);
• technological security measures (including fire walls, encryption and anti-virus software, monitoring of access, customer-specific controls, regular review of user accounts, regular back-ups etc.);
• incident management (strict procedures for incidents, bug fixing, personal data breaches etc.);
• physical security measures, such as staff security badges to access our premises.
• mechanisms, passwords);
• technological security measures (including fire walls, encryption and anti-virus software, monitoring of access, customer-specific controls, regular review of user accounts, regular back-ups etc.);
  incident management (strict procedures for incidents, bug fixing, personal data breaches etc.);
• physical security measures, such as staff security badges to access our premises.

11.2 Although we use appropriate security measures once we have received your personal data, the transmission of data – especially over the internet (including by e-mail) – is never completely secure. We endeavor to protect personal data, but we cannot guarantee the security of data transmitted to us or by us.

12. WILL WE MAKE USE OF AUTOMATED DECISION-MAKING?

12.1 Automated decisions are defined as decisions about individuals that are based solely on the automated processing of data and that produce legal effects that significantly affect the individuals involved.

12.2 As a rule, your personal data will not be used for automated decision-making. We do not base any decisions about you solely on automated processing of your personal data.

13. WHO CAN YOU CONTACT?

13.1 We hope that this ECU360 Privacy Statement helps you understand, and feel more confident about, the way we process your data. If you have any further queries about this GDPR Privacy Statement and this Site in general, please contact dataprivacy@ecuworldwide.com .

14. CHANGES TO THIS ECU 360 PRIVACY STATEMENT

14.1 We may modify or amend this ECU360 Privacy Statement from time to time. Any changes we may make to this ECU360 Privacy Statement in the future will be posted on this page. To let you know when we make changes to this ECU360 Privacy Statement, we will amend the revision date at the top of this page. The new modified or amended ECU360 Privacy Statement will apply from that revision date. Please check back periodically to see changes and additions.