Introduction

Welcome! We are Kargo Technologies, Corp. This Privacy Notice explains how Kargo, Inc. (“Kargo”, “we”, “us” or “our”) collects, uses, discloses, and otherwise processes personal data (as defined below) in connection with our websites, including https://mykargo.com (the “Sites”), and other websites we own and operate that link to this Privacy Notice, and the related content, platform, services, products, and other functionality offered on or through our services (collectively, the “Services”). It does not address our privacy practices relating to Kargo employees and other personnel.

Kargo is the controller of the personal data we hold about you in connection with your use of the Services. This means that we determine and are responsible for how your personal data is used.

When our customers use our Services to submit, manage, or otherwise use content relating to our customers’ data (“Customer Data”), we have contractually committed ourselves to only process such personal data on behalf of and under the instruction of the respective customer, who is the “data controller”. This Privacy Notice does not apply to such processing, and we recommend you read the privacy notice of the respective customer if their processing concerns your personal data.

Our collection and use of personal data

We collect personal data in a variety of ways. For example, you may provide us your personal data when you place an order, register for an account, submit a job application, post a review, send us messages, subscribe to our mailing lists, newsletters or other forms of marketing communications, or use some other feature of our Services.

We may link or combine your activities and information collected from you on our Sites with information we receive from third parties, as well as information we collect automatically through tracking technologies (defined below). This allows us to provide you with a personalized experience regardless of how you interact with us.

Personal Data Collected from You

We may collect the following categories personal data submitted to us by individuals through the Services:

• Inquiry and Communications Information, including information provided in custom messages sent through the forms, in chat messages, to one of our email addresses, or via phone. This also includes contact information provided on our Services, any requests for demo on our Sites, or other communications with our customer support. We use this information to investigate and respond to your inquiries, and to communicate with you, to enhance the services we offer to our users and to manage and grow our organization.
• Newsletter, Marketing Emails, and Blog Information, including email address and applicable interests and communication preferences. We use this information to manage our communications with you and send you information about products and services we think may be of interest to you. If you wish to stop receiving email messages from us, simply click the “unsubscribe link” provided at the bottom of the email communication. Note that you cannot unsubscribe from certain services-related email communications (e.g., account verification, confirmations of transactions, technical or legal notices).
• Feedback Information. We may also collect feedback and ratings you provide relating to our Services or products. We use this information to communicate with you, to conduct market research, inform our marketing and advertising activities and improve and grow our business.
• Business Representatives: We collect professional personal data about representatives of third-party businesses, including representatives of our customers and business partners, in connection with our services and the operation of our business, which may include contact information, professional information including job title, job function, and company name, and any inquiry information including contents of communications via email or call recordings (where permitted by law).
• Employment Application Information, including your contact and demographic information, educational and work history, employment interests, information obtained during interviews and any other information you choose to provide, if you apply for employment.

Personal Data Automatically Collected

As is true of many digital properties, we and our third-party partners may automatically collect certain information from or in connection with your device when visiting or interacting with our Services, such as the list below and in the sub-sections here:

• Log Data, including internet protocol (IP) address, operating system, device type and version, browser type and version, browser id, the URL entered and the referring page/campaign, date/time of visit, other user agent string data, the time spent on our Services, and any errors that may occur during the visit to our Services). Log data may overlap with the other categories of data below.
• Analytics data, Including the electronic path you take to our Services, through our Services and when exiting our Services, UTM source, as well as your usage and activity on our Services, such as the time zone, activity information (first and last active date and time), usage history (flows created, campaigns scheduled, emails opened, total log-ins) as well as the pages, links, objects, products and benefits you view, click or otherwise interact with. We may also analyze the interaction between you and your customer using our Services.
• Location data, such as coarse geographic location we or our third-party providers may collect or derive from your IP address.

We and our third-party providers may use (i) cookies or small data files that are stored on an individual’s computer and (ii) related technologies, such as web beacons, pixels, embedded scripts, location-identifying technologies and logging technologies (collectively, “cookies”) to automatically collect this personal data. We may also use this information to distinguish you from other users of our Services. This helps us monitor and analyze how you use and interact with our Services. It also helps us and our partners to determine products and services that may be of interest to you. For more information about these practices and your choices regarding cookies, please see the Control Over Your Information section.

Personal Data from Third Parties

We also obtain personal data from third parties, which we often combine with personal data we collect either automatically or directly from an individual.

We may receive the same categories of personal data as described above from the following third parties:

• Kargo Entities: We may receive personal data from other companies and brands owned or controlled by Kargo, and other companies owned by or under common ownership as Kargo for purposes and uses that are consistent with this Privacy Notice.
• Your Employer / Company: If you interact with our Services through your employer or company, we may receive your information from your employer or company, including another representative of your employer or company. We use this information to operate, maintain, and provide to you the features and functionality of the Services.
• Social Media: When an individual interacts with our Services through various social media networks, such as when someone “Likes” us on Facebook or follows us or shares our content on Google, Facebook, Twitter, or other social networks, we may receive some information about individuals that they permit the social network to share with third parties. The data we receive is dependent upon an individual’s privacy settings with the social network, and may include your profile information, profile picture, gender, username, user ID associated with your social media account, age range, language, country, and any other information you permit the social network to share with third parties. Individuals should always review and, if necessary, adjust their privacy settings on third-party websites and social media networks and services before sharing information and/or linking or connecting them to other services. We use this information to operate, maintain, and provide to you the features and functionality of the Service, as well as to communicate directly with you, such as to send you email messages about products and services that may be of interest to you.
• Service Providers: Our service providers that perform services solely on our behalf, such as survey and marketing providers and payment processors, collect personal data and often share some or all of this information with us. The information may include contact information, demographic information, payment information, information about your communications and related activities, and information about your orders. We may use this information to administer and facilitate our Services, your orders, and our marketing activities.
• Other Sources: We may also collect personal data about individuals that we do not otherwise have from, for example, publicly available sources, third-party data providers, brand partnerships, or through transactions such as mergers and acquisitions. We use this information to operate, maintain, and provide to you the features and functionality of the Service, as well as to communicate directly with you, such as to send you email messages about products and services that may be of interest to you.

Additional Uses of Personal Data

We may use personal data we collect to:

• Fulfill or meet the reason the information was provided, such as to fulfill our contractual obligations, to deliver the Services you have requested and to process transactions, including providing you with a white paper you have requested or an online product demonstration;
• Manage our organization and its day-to-day operations;
• Verify your identity and entitlement to products or Services, when you contact us or access our Services;
• Communicate with individuals, including via email or telephone calls;
• For marketing and advertising purposes, including to market to you or offer you through email, direct mail, phone or text message information and updates on products or services we think that you may be interested in);
• Administer, improve and personalize our Services, including by recognizing an individual and remembering their information when they return to our Services;
• Process payments for our Services;
• Facilitate customer benefits and services, including customer support;
• Identify and analyze how individuals use our Services;
• Conduct research and analytics on our customer and user base and our Services;
• Improve and customize our Services to address the needs and interests of our user base and other individuals we interact with;
• Test, enhance, update and monitor the Services, or diagnose or fix technology problems;
• Help maintain the safety, security and integrity of our property and Services, technology assets and business;
• To enforce our Terms of Use, to resolve disputes, to carry out our obligations and enforce our rights, and to protect our business interests and the interests and rights of third parties;
• Prevent, investigate or provide notice of fraud or unlawful or criminal activity;
• Comply with contractual and legal obligations and requirements;
• To fulfill any other purpose for which you provide personal data; and
• For any other lawful purpose, or other purpose that you consent to.

Where you choose to contact us, we may need additional information to fulfill the request or respond to inquiries. We may provide you with additional privacy-related information where the scope of the inquiry/request or personal data we require fall outside the scope of this Privacy Notice. In that case, the additional privacy notice will govern how we may process the information provided at that time.

Disclosure of personal data

Our Disclosure of Personal Data

We may also share, transmit, disclose, grant access to, make available, and provide personal data with and to third parties, as follows:

• Kargo Entities: We may share personal data with other companies owned or controlled by Kargo, and other companies owned by or under common ownership as Kargo, which also includes our subsidiaries (i.e., any organization we own or control) or our ultimate holding company (i.e., any organization that owns or controls us) and any subsidiaries it owns, particularly when we collaborate in providing the Services.
• Your Employer / Company: If you interact with our Services through your employer or company, we may disclose your information to your employer or company, including another representative of your employer or company.
• Marketing Providers: We coordinate and share personal data with our marketing providers in order to communicate with individuals about the Services we make available.
• Customer Service and Communication Providers: We share personal data with third parties who help us provide our customer services and facilitating our communications with individuals that submit inquiries.
• Other Service Providers: In addition to the third parties identified above, we engage other third-party service providers that perform business or operational services for us or on our behalf, such as website hosting, infrastructure provisioning, IT services, analytics services, payment processing services, and administrative services.
• Business Transaction or Reorganization: We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose personal data to a third-party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal data may also be disclosed in the event of insolvency, bankruptcy or receivership.
• Legal Obligations and Rights: We may disclose personal data to third parties, such as legal advisors and law enforcement:
  in connection with the establishment, exercise, or defense of legal claims;
  to comply with laws or to respond to lawful requests and legal process;
  to protect our rights and property and the rights and property of others, including to enforce our agreements and policies;
  to detect, suppress, or prevent fraud;
  to protect the health and safety of us and others; or
  as otherwise required by applicable law.
• With Your Consent or Direction: We may disclose personal data about an individual to certain other third parties or publicly with their consent or direction. For example, with an individual’s consent or direction we may post their testimonial on our Sites or service-related publications.

Third-party data collection and online advertising

We may participate in interest-based advertising and use third party advertising companies to serve you targeted advertisements based on your browsing history. We permit third party online advertising networks, social media companies and other third-party services, to collect information about your use of our Services over time so that they may play or display ads on our Services, on other websites or services you may use, and on other devices you may use. Typically, though not always, the information used for interest-based advertising is collected through tracking technologies, such as cookies, web beacons, embedded scripts, location-identifying technologies, and similar technology, which recognize the device you are using and collect information, including click stream information, browser type, time and date you visited the Sites, AdID, precise geolocation and other information. We may share a common account identifier (such as a hashed email address or user ID) with our third-party advertising partners to help identify you across devices. We and our third-party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics and market research. We may also use services provided by third parties (such as social media platforms) to serve targeted ads to you and others on such platforms. We may do this by providing a hashed version of your email address or other information to the platform provider.

We may engage in interest-based advertising through the following:

• Social Media Widgets and Advertising. Our Services may include social media features, such as the Facebook “Like” button, Pinterest, Instagram, Twitter or other widgets. These social media companies may recognize you and collect information about your visit to our Services, and they may set a cookie or employ other tracking technologies. Your interactions with those features are governed by the privacy policies of those companies.
• Social Media Platforms. We may display targeted advertising to you through social media platforms, such as Facebook, Twitter, Instagram, LinkedIn, and other social media forums. These companies have interest-based advertising programs that allow us to direct advertisements to users who have shown interest in our services while those users are on the social media platform, or to groups of other users who share similar traits, such as likely commercial interests and demographics. We may share a unique identifier, such as a user ID or hashed email address, with these platform providers or they may collect information from our website visitors through a first-party pixel, in order to direct targeted advertising to you or to a custom audience on the social media platform. These advertisements are governed by the privacy policies of those social media companies that provide them. If you do not want to receive targeted ads on your social networks, you may be able to adjust your advertising preferences through your settings on those networks.
• Third Party Partners. We work with a variety of third-party partners to provide advertising services. For example, we use Google Analytics to recognize you and link the devices you use when you visit our Services on your browser or mobile device, log in to your account on our Services, or otherwise engage with us. We share a unique identifier, like a user ID or hashed email address, with Google to facilitate the service. Google Analytics allows us to better understand how our users interact with our Services and to tailor our advertisements and content to you. For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, review Google's website, “How Google uses data when you use our partners’ sites or apps” located at  www.google.com/policies/privacy/partners/. You can learn about Google Analytics’ currently available opt-outs, including the Google Analytics Browser Ad-On here: https://tools.google.com/dlpage/gaoptout/.
• We may also utilize certain forms of display advertising and other advanced features through Google Analytics. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick advertising cookie) or other third-party cookies together to inform, optimize, and display ads based on your past visits to the Services. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences, or by visiting NAI’s online resources at http://www.networkadvertising.org/choices.

For more information about these practices and your choices regarding interest-based advertising, please see the Online Ads in the Control Over Your Information section below.

Control over your information

You may control your information in the following ways:

• Email Communications Preferences. You can stop receiving promotional email communications from us by clicking on the “unsubscribe” link provided in such communications. You may not opt out of service-related communications (e.g., account verification, transactional communications, changes/updates to features of the Services, technical and security notices).
• Modifying or Deleting Your Information. If you have any questions about reviewing, modifying, or deleting your information, you can contact us directly at privacy@mykargo.com. We may be unable to modify or delete your information in all circumstances.
• Cookies: If you would prefer not to accept cookies, most browsers will allow you to change the setting of cookies by adjusting the settings on your browser to: (i) notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies. Be aware that disabling cookies may negatively affect the functionality of this and many other websites that you visit, as disabling cookies will usually result in also disabling certain functionalities and features of the Services. Depending on your device and operating system, you may be unable to delete or block all cookies. In addition, if you want to reject cookies across all your browsers and devices, you will need to do so on each browser on each device you actively use. You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and performed certain functions with it.
• Online Ads: To learn more about interest-based advertising and how you may be able to opt out of some of this advertising, you may wish to visit the Digital Advertising Alliance’s (DAA) resources and the Network Advertising Initiative’s (NAI) online resources, at www.aboutads.info/choices or http://www.networkadvertising.org/choices/. [or if you are in the European Economic Area, United Kingdom or Switzerland: https://youronlinechoices.eu/]. You may also be able to limit interest-based advertising through the settings menu on your mobile device by selecting “limit ad tracking” (iOS) or “opt-out of interest-based ads” (Android). You may also be able to opt out of some — but not all — interest-based advertising served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the mobile AppChoices app.
  Please note that when you opt-out of receiving interest-based advertisements, this does not mean you will no longer see advertisements from us or on our Services. It means that the online ads that you do see from DAA program participants should not be based on your interests. We are not responsible for the effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs. In addition, third parties may still use cookies to collect information about your use of our Services, including for analytics and fraud prevention as well as any other purpose permitted under the DAA’s Principles.

Children's personal data

Our Services are not directed to, and we do not intend to, or knowingly, collect or solicit personal data from children under the age of 16. If an individual is under the age of 16, they should not use our Services or otherwise provide us with any personal data either directly or by other means. If a child under the age of 16 has provided personal data to us, we encourage the child’s parent or guardian to contact us to request that we remove the personal data from our systems. If we learn that any personal data we collect has been provided by a child under the age of 16, we will promptly delete that personal data.

Links to third-party websites or services

Our Services may include links to third-party websites, plug-ins and applications. Except where we post, link to or expressly adopt or refer to this Privacy Notice, this Privacy Notice does not apply to, and we are not responsible for, any personal data practices of third-party websites and online services or the practices of other third parties. To learn about the personal data practices of third parties, please visit their privacy notices.

Updates to this privacy notice

We may update this Privacy Notice from time to time. When we make changes to this Privacy Notice, we will change the date at the beginning of this Privacy Notice. If we make material changes to this Privacy Notice, we will notify individuals by email to their registered email address, by prominent posting on our Services, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided.

Contact us

If you have any questions or requests in connection with this Privacy Notice or other privacy-related matters, please send an email to privacy@mykargo.com.