CTG GLOBAL LIMITED

PRIVACY POLICY

 THIS PRIVACY POLICY IS AN AGREEMENT BETWEEN YOU AND CTG GLOBAL LIMITED AND ITS AFFILIATED ENTITIES (“CONFITRACK”).

BY ACCESSING OR USING THE CONFITRACK OR ENVIIE WEBSITES, DOWNLOADING, REGISTERING OR USING THE ENVIIE MOBILE APPLICATION (“THE APP”), AND/OR THE CONFITRACK/ENVIIE SERVICES OFFERED, YOU CONSENT TO AND AGREE TO ABIDE BY AND COMPLY WITH THE TERMS OF THIS PRIVACY POLICY.

At ConfiTrack, our top priority is protecting the confidentiality of Your personal data, traffic data and communications content.

This privacy policy (the “Privacy Policy”) describes how we treat information You provide to us in conjunction with Your use of the ConfiTrack (www.confitrack.com) or Enviie (www.enviie.com) websites (the “Sites”), downloading, registering, using the mobile application (“App”). and/or ConfiTrack’s eShipping and eTracking services and the Enviie Virtual Envelope (the “Services”), including how we may use such information, how we seek to protect the security of such information, and how You may change or request that we remove such information from our systems.

Except as described in this Privacy Policy, we will not, without Your consent, intentionally disclose, distribute or otherwise provide to any third party any personally identifiable information collected in connection with Your use of the Sites, the App, or the Services.

  1. WHAT IS CONFITRACK?

ConfiTrack provides electronic shipping and tracking services for all types of information, documentation, data, text, software, music, sound, photographs, graphics, video, messages, data or audio files or other materials (“Content”). BY USING THE SITES, THE APP, AND/OR THE SERVICES, REGARDLESS OF WHETHER YOU HAVE INITIATED THE DELIVERY OF CONTENT OR ARE A RECIPIENT OF CONTENT, YOU CONSENT TO THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY AND TO OUR PROCESSING OF PERSONAL INFORMATION FOR THE PURPOSES STATED BELOW. IF YOU DO NOT AGREE TO THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY, YOU ARE NOT AUTHORIZED TO USE THE SITES, THE APP, AND/OR THE SERVICES.

  1. WHAT INFORMATION DOES CONFITRACK GATHER?

ConfiTrack distributes Your Content as an independent third party service provider. Except as described in this Privacy Policy, ConfiTrack does not disclose, or review or edit, the contents of any of communications or submissions sent or received by You; and except as provided below, ConfiTrack does not share, sell, lease, rent or trade Your personal identifiable information with third parties.

ConfiTrack may gather information about You, including (but not limited to) information in the following categories:

(a)        Identification data (e.g., name, address, telephone number, cell number, email address);

(b)       Profile information (e.g., age, sex, country of residence and any information that You choose to make available to others as part of Your User Profile (as defined in Section 6 below);

(c)        Electronic identification data (e.g., IP addresses, cookies);

(d)       banking and payment information (credit or debit card information, account number), which will be encrypted and retained in accordance with commercially reasonable practices;

(e)        survey results;

(f)        information about Your usage of and interaction with Sites, the App, and/or the Services, ConfiTrack’s software, products and websites, including computer and connection information, device capability, bandwidth, statistics on page views, and traffic to and from the Sites and our websites in general;

(g)        products or services ordered and delivered;

(h)       the URL of videos or other information, materials or content that You have selected to eShip and/or eTrack;

(i)        email addresses and other contact information for Content recipients;

(j)        Your User Profile;

(k)       Your username and password for other email accounts where You have provided this information to us for the purposes of utilizing the Sites, the App, and/or the Services to eShip and/or eTrack Your Content, provided that ConfiTrack does not retain this information as part of its Sites, App, or Services or use it for any other purpose;

(l)        correspondence between You and ConfiTrack;

(m)      traffic data (e.g., data processed for the purpose of the conveyance of Content or the billing thereof, including, but not limited to, the size of the file, number of recipients and ConfiTrack features elected);

(n)       Information to validate Your identity in case You forget a password or username; and

(o)       “Non-Personal Data,” which comprises information such as the configuration details of Your correspondences and will not be used to identify or contact You, habits, characteristics, age group, preferences, general lifestyle, and other innocuous questions which may be gathered for purposes of targeted advertising for ConfiTrack/Enviie and ConfiTrack/Enviie third-party sponsors, to improve and enhance the App, Services and/or the Sites, and/or statistical and other analytic information collected on an aggregate basis for all visitors to the Sites.

  1. HOW DOES CONFITRACK USE THIS INFORMATION AND FOR WHAT PURPOSE?

When You log onto the Sites, or download the App, or use the Services, You will be able to access Your User Profile by going to Settings and selecting Account Details, which contains the information You have supplied to us. You will be able to complete, update or correct any of the information in Your User Profile. By providing, updating or accepting information in Your User Profile, You consent to our use of such information in a manner consistent with this Privacy Policy.

IF YOU DO NOT WISH TO CONSENT TO OUR USE OF THE INFORMATION IN YOUR USER PROFILE, OR IN SURVEYS CONDUCTED ON THE SITE, OR OTHERWISE BY REASON OF YOUR USE OF THE SITES, THE APP, AND/OR THE SERVICES, YOU WILL NOT BE ALLOWED TO USE THE SITES, THE APP, OR THE SERVICES AND SHOULD NOT AGREE TO THIS PRIVACY POLICY AND THE USER TERMS OF USE AGREEMENT PRESENTED AT THE TIME YOU FIRST LOG ON.

The provision of the Sites, the App, and the Services to You may also require us to store details of Your transactions, including without limitation the configuration details and characteristics of Your correspondences and the details of Your financial information.

ConfiTrack will take instructions from You regarding the Content for which You retain our Services. ConfiTrack may periodically review Your personal information, and may elect to delete personal information if You have not used the Sites, the App, or the Services for a period of time to be determined in ConfiTrack’s discretion. ConfiTrack may use Your personal information for the following purposes: (a) to enable You to access and use the Sites, the App, and/or the Services; (b) to personalize aspects of ConfiTrack’s overall services to You; (c) to communicate with You; and/or (d) to process a transaction between You and a third party.

  1. OUR DISCLOSURE OF YOUR PERSONAL INFORMATION

Except as provided below, ConfiTrack shall not sell, rent, trade, lease or otherwise transfer any of Your personal and/or traffic data or communications to any third party without Your permission, unless it is obliged to do so under any applicable law, by order of competent authority, or in the interest of public safety or security.   By way of example and without limitation, ConfiTrack/Enviie and/or its local partner or the operator or company fulfilling Your eShipping and/or eTracking service request may share Your personal information with a third party where ConfiTrack, in its sole discretion, reasonably believes that it is required to do so in order to: (1) satisfy any legal process, governmental request, applicable law, rule or regulation; (2) prevent or investigate illegal activity, (3) enforce or investigate violations of the ConfiTrack User Terms of Use Agreement; or (4) protect the rights, property or safety of ConfiTrack, its users or the public. ConfiTrack will provide reasonable assistance and information to any appropriate judicial, law enforcement or government authority lawfully requesting such information, and You hereby consent to such disclosure.

ConfiTrack may store and process Your personal information in any country in which ConfiTrack or its affiliates maintain facilities, including outside of the country from which the Content originated. By using the Sites, the App, and/or the Services, You consent to the transfer of information outside of Your country in accordance with Your eShipping and eTracking instructions. You agree that ConfiTrack has no responsibility for the accuracy or completeness of any data provided by You in Your User Profile or with respect to any intended eShipping recipients.

ConfiTrack may also access or process Your communications for technical reasons if required to properly route the communication, satisfy technical requirements or network policies, meet Your customer service requests, or prevent any disruption to the Sites, the App, or the Services. When ConfiTrack bills customers for its Services, ConfiTrack provides Your information to a credit or debit card or micro-payment processing company. ConfiTrack may also keep this information on its servers so as to be able to respond to inquiries by You and/or the credit or debit card or micro-payment processing company.

ConfiTrack reserves the right to obtain personally identifiable information about its users in order to provide the Sites, the App, and/or the Services requested by its users. For example, ConfiTrack may obtain credit reports or verify billing information for credit card transactions. All personal information obtained from third parties will be maintained in accordance with this Privacy Policy.

In order to provide You with the ConfiTrack products and services You have requested, ConfiTrack may, if necessary, share Your personal and traffic data with ConfiTrack’s affiliates, group companies, carriers, partner service providers and/or agents, Wifi access service providers, distributors of ConfiTrack software and/or ConfiTrack products, and/or third party banking organizations or other providers of payment, email delivery, analytical, customer support or hosting services. ConfiTrack will use commercially reasonable practices to require these third parties to take appropriate organizational and technical measures to protect Your personal data and traffic data.

You agree that ConfiTrack may use Your name or other personally identifying information, including without limitation, the name of Your employer or any affiliated business entity, any professional or business credentials or affiliations, for the purpose of identifying You as a User of the Sites, the App, and/or the Services in ConfiTrack promotional material for the purpose of demonstrating the identity of its clients. As a corporate User, or a User with a high-profile or name recognition, You agree that ConfiTrack is permitted to showcase Your own-branded stamp, Your logo, name or other identity on the Sites or other medium or print for the purpose of identifying ConfiTrack Users and marketing the ConfiTrack name, brand and the App and/or the Services.

As a User of the Sites, the App, and/or the Services without compensation to ConfiTrack, You agree to participate in surveys and answer questions of a personal nature which are designed to elicit Your habits, characteristics, life stage, age, attributes, preferences, other information and/or Your opinions on a variety of topics. You agree that ConfiTrack may use Your answers to such surveys or questions for its own purposes, with no consequences or obligations to You.

As a User of the Sites, the App, and/or the Services, You also affirmatively consent and permit ConfiTrack to disclose Your email address to corporate sponsors of the ConfiTrack/Enviie Services and Virtual Envelope. This disclosure may expose You to advertisements from such ConfiTrack corporate sponsors independent and separate from the ConfiTrack Services. You agree that ConfiTrack has no responsibility, liability or obligation to You in any manner or to any extent whether You are a sender or recipient of the Services on any platform, regarding the practices of any ConfiTrack corporate sponsor or third-party licensee or any other user of the ConfiTrack services and products. You agree that ConfiTrack is not responsible to ensure that the privacy policy or any business practice of any ConfiTrack corporate sponsor, third-party licensee, or advertising partner or any user of the Sites, the App, and/or the Services or ConfiTrack products is in compliance with all relevant laws, statutes, regulations, rules, of any federal, state, local, international or any other jurisdiction.

As ConfiTrack continues to develop its business, ConfiTrack might sell to or acquire other companies or business units. In such transactions, as well as in the event ConfiTrack or substantially all of its assets are acquired by a third party, personal information of ConfiTrack users will generally be one of the transferred business assets. We reserve the right to include Your personal information, collected as an asset, in any such transfer to a third party.

  1. WHAT ARE COOKIES? HOW DOES CONFITRACK USE THEM?

Cookies are pieces of information that the browser of the ConfiTrack software client or Your internet browser may store locally on Your computer. Cookies enable ConfiTrack to recognize You or Your preferences, gain information about the use of the Sites, and other ConfiTrack websites, and help ConfiTrack improve its products and websites. This information may be analyzed by third parties on our behalf.

The Help option on the toolbar of most browsers will tell You how to prevent Your browser from accepting new cookies, how to have the browser notify You when You receive a new cookie, or how to disable cookies altogether.

Please bear in mind that some personalized services may not be available if You choose to disable cookies.

ConfiTrack’s advertisements appearing on third party websites are delivered to You by its carefully selected ad-serving partners (“Ad-Serving Partners”). ConfiTrack and its Ad-Serving Partners may use non-personally identifiable information about Your relationship with ConfiTrack’s websites in order to provide ConfiTrack advertisements likely to be of greater interest to You and to help ConfiTrack measure and improve the performance of its advertising campaigns. ConfiTrack and its Ad-Serving Partners typically use a cookie or web-beacon to collect this information.

You may choose to opt-out of the use of Your information in ConfiTrack’s advertising efforts at any time by clicking on the following link: http://enviie.com/index.php/contact-us/

If You choose to opt-out, ConfiTrack’s advertisements will still be delivered to You but no information about Your relationship with ConfiTrack’s websites will be available for this purpose.

  1. YOUR USER PROFILE

ConfiTrack stores the information collected through log files, cookies, in a profile containing each user’s viewing preferences. ConfiTrack uses and continues to use this information in order to identify Your interests and improve the Sites, the App, and/or the Services. Your user profile is the information provided by You when You registered for and use the Sites, the App, and the Services. It may include Your ConfiTrack user name, full name, email address, telephone and mobile numbers, country, language, and any other information that You decide to make available (collectively, such information comprises Your “User Profile”). You can access Your User Profile from the Account Details section via www.Enviie.com, as well as the App, desktop and other App-based versions of ConfiTrack/Enviie, in order to view, correct or complete information, remove non-mandatory information and to see the privacy settings associated with Your User Profile information.

  1. LINKED WEBSITES AND THIRD PARTY APPLICATIONS

This Privacy Policy applies solely to personal information that is acquired on the Sites, the App or through Your use of the Services, ConfiTrack products and/or Your relationship with ConfiTrack. Please note the Sites and other websites may include hyperlinks to other websites neither owned nor managed by ConfiTrack. ConfiTrack is not associated with these third-party websites and does not review their privacy policies. ConfiTrack cannot guarantee the privacy of any information that may be obtained by third parties at these other websites. ConfiTrack strongly encourages You to review the privacy policies of any website You visit before supplying personally identifiable information through that website. ConfiTrack accepts no responsibility or liability for these other websites.

If You use any extras, plug-ins or third party applications together with the ConfiTrack software, the App, and/or the Services (“Applications”), the provider of such Applications may obtain access to certain personal information about You. ConfiTrack does not and cannot control how the provider of Applications may use any personal information collected in connection with such Applications. Please ensure that You review any privacy policies or other terms applicable to the use of such Application before installation.

  1. HOW DOES CONFITRACK PROTECT YOUR PERSONAL INFORMATION?

ConfiTrack uses industry standard encryption methods to prevent unauthorized access to customer documents and account information stored on its servers. ConfiTrack protects Your information off-line by restricting access to and within its facilities. Your personal and traffic data can only be accessed by authorized employees or consultants of ConfiTrack or the concerned ConfiTrack group entities that need to have access to this data in order to be able to fulfill their given duties. ConfiTrack will comply with all applicable laws, rules and regulations in handling Your transactions.

Your personal data is held on servers hosted by our Internet Service Provider, and on servers hosted by our payment processing companies. The nature of the Internet is such that we cannot guarantee or warrant the security of any information You transmit to us via the Internet. No data transmission over the Internet can be guaranteed to be 100% secure. However, we will take commercially reasonable steps (including appropriate technical and organizational measures) to protect Your personal data.

  1. CONTACTING YOU

Notification via email and other means of contact designated by You (phone call, SMS, etc.) of eShipping and eTracking are an integral part of the Sites, the App, and/or the Services. To enable such notification service, You acknowledge and agree to provide Your email address, phone number, cell number or contact means, as You may select and consent for such use in connection with the Sites, the App, and/or the Services.

When You use the Sites, the App, and/or the Services, ConfiTrack may from time to time ask You to provide information on Your experiences which will be used to measure and improve quality. You are at no time under any obligation to provide any response. Any and all information which is voluntarily submitted in feedback forms on the Sites, or the App or any survey that You agree to take part in is used for the purposes of reviewing this feedback and improving the ConfiTrack software, ConfiTrack products and websites.

ConfiTrack may contact You to send You messages about faults and service issues. Further, ConfiTrack reserves the right to use email, the ConfiTrack software or SMS to notify You of any eventual claims related to Your use of ConfiTrack software, the Sites, the App, and/or the Services, other ConfiTrack websites and/or ConfiTrack products, including without limitation claims of violation of third party rights.

ConfiTrack may send You alerts by email or SMS to notify You when someone has tried to contact You. ConfiTrack may also use email, SMS or the ConfiTrack software to keep You up to date with news about the ConfiTrack software and ConfiTrack products that You have purchased and/or to inform You about other ConfiTrack products or other ConfiTrack related information. You can opt-out of the receipt of alerts and/or promotional emails or SMS by clicking the ‘unsubscribe’ link on the email that You receive or by signing into ConfiTrack and accessing Your My Enviie page via www.enviie.com, as well as the App, desktop and other app-based versions of ConfiTrackEnviie.

If You have registered for or use co-branded ConfiTrack products, the emails or SMS that You receive may be from our partner company, acting on ConfiTrack’s behalf.

  1. CAN THIS PRIVACY POLICY BE MODIFIED?

ConfiTrack reserves the right to modify, amend, revise, update, supplement, replace or change the Site, the Services, and/or the ConfiTrack Privacy Policy from time to time, but is under no obligation to do so. We will inform You of these changes by publishing the revised Privacy Policy at http://enviie.com/index.php/privacy-policy/. Any changes to the ConfiTrack Privacy Policy shall be posted on the Sites, and the App and You are responsible for reviewing and complying at all times with the current version of the Privacy Policy. Your continued use of the Sites, the App, and/or the Services signifies Your acceptance of any modifications, amendments, revisions, updates, supplements, replacements or changes.

ConfiTrack reserves the right to communicate through the Sites, the App, and/or the Services or otherwise, from time to time, additional rules of usage that apply to specific parts of the Sites, the App, and/or the Services. Your continued use of the Sites, the App, and/or the Services, constitutes Your agreement to comply with these additional rules.

  1. WHAT RIGHTS DO YOU HAVE AND HOW CAN YOU CONTACT CONFITRACK?

You have the right to access and, where relevant, to amend Your personal information. You may inform us of any changes in Your personal data, and in accordance with our obligations under the Data Protection Acts of 1998 and 2002 we will update or delete Your personal data accordingly. Some of Your information may be viewed or edited online by signing into Your account page on www.enviie.com. We will respond to requests to view, correct, complete or remove Your personal information within a reasonable period of time and upon verification of Your identity. Please address any questions to us at privacy@confitrack.com.

ConfiTrack will exercise commercially reasonable efforts to accommodate requests to delete personal information unless it is required to be retained by law or for lawful business purposes.

  1. HOW LONG IS YOUR PERSONAL DATA KEPT BY CONFITRACK?

ConfiTrack will retain Your information for as long as it deems necessary or appropriate in order to: (1) provide You with requested Services and otherwise fulfill any of the purposes described in this Privacy Policy, and (2) comply with applicable law, rule or regulation and/or relevant orders from competent courts or other governmental agencies.

A record of Your eShipping and eTracking of Content may be stored by ConfiTrack to convey and synchronize Your messages and to enable You to retrieve Your eTracking and eShipping history. However, ConfiTrack is under no obligation to maintain or store any such historical records and You should not rely on ConfiTrack’s storage of, or ability to retrieve, any such historical records for any reason. Historical records and Your eShipping and eTracking of Content will be stored for the maximum period of time required by law from the date of the initiation of the eShipping of the Content. By using the Services, You consent to the storage of Your Content.

  1. SAFE HARBOR CERTIFICATION

To the extent required, ConfiTrack is a participant in the Safe Harbor program developed by the U.S. Department of Commerce and the European Union. We have certified that we adhere to the Safe Harbor Privacy Principles agreed upon by the U.S. and the E.U. For more information about the Safe Harbor and to view our certification, visit the U.S. Department of Commerce’s Safe Harbor web site. We also comply with all applicable privacy laws of each of the fifty states comprising the United States of America. In the event that any dispute arising out of or related to this policy is not settled by the parties, the parties will attempt in good faith to resolve such dispute by non-binding mediation in accordance with the American Arbitration Association Commercial Mediation Rules. No litigation for the resolution of such dispute may be commenced until the parties try in good faith to settle the dispute by such mediation in accordance with such rules and either party has concluded in good faith that amicable resolution through continued mediation of the matter does not appear likely. The parties to the mediation shall share the costs of mediation equally. Any settlement reached by mediation shall be recorded in writing, signed by the parties, and shall be binding on them.

ConfiTrack, to the extent required, participates in the EU Safe Harbor Privacy Framework as set forth by the United States Department of Commerce. As part of our participation, we have agreed to the resolution of disputes relating to our compliance in accordance with the Safe Harbor Privacy Framework. If You have any complaints regarding our compliance with the Safe Harbor program You should first contact us. If contacting us does not resolve Your complaint, You may raise Your complaint with ConfiTrack by contacting the American Arbitration Association at 6795 N. Palm Avenue, 2nd FL, Fresno, CA 93704, Tel: 877-528-0880, Fax: 559-490-1919; email: bishop@adr.org; internet: www.adr.org. If You are faxing or mailing the American Arbitration Association to lodge a complaint, please include the following information: the name of company, the alleged privacy violation, Your contact information, and whether You would like the particulars of Your complaint shared with the company.

  1. Governing Law; Jurisdiction; Venue

This section shall govern in the event the Safe Harbor Protocol provision referred above in Paragraph 13 of this Agreement inapplicable or rendered moot.

This Agreement and any claims or disputes for all purposes related to access and/or use of the Sites, the App, and/or the Services will be governed by and construed in accordance with the laws of England and Wales. Such laws shall exclude any conflict of law provisions. All actions or proceedings based on or relating to Sites, the App, and/or the Services, or alleging a breach of this Agreement will be subject to the exclusive jurisdiction of a competent court located in those jurisdictions; provided, however, that in ConfiTrack’s sole discretion such an action may be heard in some other place designated by it if necessary to acquire jurisdiction over third persons so that the dispute can be resolved in one action. You hereby agree to appear in any such action, consent to the jurisdiction of such courts, and waive any objections You might have as to jurisdiction or venue in any such court. You knowingly and willingly waive Your respective right to a trial by jury in any actions or proceedings under or relating to Your access and/or use of the Sites, the App, and/or the Services.

You agree that the prevailing Party in any such action or proceeding shall be entitled to recover reasonable attorneys’ fees and all costs incurred by such Party in the course of prosecuting or defending any action or proceeding brought under this Agreement.