toncarton Privacy Notice

Introduction

At toncarton, sas. (“toncarton,” “we,” “our,” or “us”), we understand and respect our users’ need for privacy. We provide logistics management software and route optimization platform for enterprises (collectively, our “Customers”) to enable the delivery of goods and services to others (“Recipients”). This Privacy Notice (“Notice”) describes how we collect, use, share, and process personal information; what rights and choices you may have with respect to your information; how you may contact us; and how we protect your personal information when you:

1. Visit toncarton’s websites, such as www.toncarton.com (our “Sites”);

2. Access or use the products, services, and related applications offered by toncarton, engage directly with us, or use third party partners, products, or interfaces that employ toncarton technology, including our web-based and mobile applications, (collectively, the “Services”) as a Customer, Recipient, driver, or dispatcher (collectively “Authorized Users”) to:

   1. Manage and receive deliveries;
   2. Dispatch and assign tasks to drivers;
   3. Optimize deliveries and routes;
   4. Interact with drivers and Recipients;
   5. Analyze delivery metrics and driver feedback; and
3. Interact with us in any way, including registering for, attending, or otherwise partaking in our events, tutorials, or webinars (collectively, “Marketing Activities”).

This Notice does not cover:

• Job applicants – To learn more about our privacy practices related to personal information collected and used for recruiting purposes
• toncarton employees – Please contact privacy@toncarton.com to learn more about our privacy practices regarding the personal information of toncarton employees.

About toncarton Products and Services

toncarton is a logistics management software and route optimization platform for businesses offering last-mile delivery. Our web-based and mobile applications toncarton Driver provide Customers route planning optimization, end-to-end communication tools, assignment automation, and delivery feedback and metrics.

Information We Collect

The information that we collect depends on the context of your interactions with us and the choices that you make, the products and features you use, your location, and applicable law. In some cases, we receive information directly from you, such as your name and email address when you or your organization sign up for our Services. In other cases, we receive information through your use of our Services, such as tasks fulfilled by drivers and driver vehicle routes.

1. Information You Provide Directly to Us
   We collect the following information through your use of our Sites and Services.

   • Contact information – We collect your contact information when you use, inquire about, or purchase our Services or engage in our Marketing Activities. This information includes your full name, email address, and phone number.
   • Professional information – We collect professional information about you, including your company name, company website, and industry.
   • Account information – We collect information about your toncarton account. This information includes email address, password, User ID, date of account creation and details for Services purchased or subscribed to. You provide this information to us directly during the account registration process, and when you log into the Services for the first time, we automatically receive this information.
   • Transactional information – We collect payment and other transactional information related to our Services, such as hashed payment card values and billing address.
   • Delivery and logistics information – Through certain features in our Services, we collect delivery and logistics information. This information includes the vehicle type, delivery region or city, delivery product type, delivery time windows, monthly delivery volume, and other delivery logistics that you choose to provide when interacting with our driver job board.
   • Marketing information – When you engage with our Marketing Activities, we collect information that you provide, including through form submissions, email communications, or phone calls to inquire about toncarton and our Services. We also collect information you provide to us when participating in a survey, interacting with us virtually or in person at an event or via a phone call with one of our sales or customer support representatives (e.g., the nature of your communication, of your communication, your contact preferences, and any information you choose to provide to us when completing any “free text” boxes in our forms).
   • Office visitor information – We collect information about you if you visit our offices, including name, date and time of visit, reason for visit, and other visitor screening and registration information.
   • Social media information – We use social media features, such as the Twitter “Tweet” button and other sharing widgets (“Social Media Features”), and we receive information about you if the Social Media Features are hosted directly on our Site. Your interactions with Social Media Features are governed by the privacy and user policies of the companies that provide them, and we are not responsible for how those companies collect, use, or disclose your information. We encourage you to review the privacy notices of those companies before connecting to or using their Social Media Features to learn more about their privacy practices.
   • Troubleshooting and support information – We collect information about your account preferences or data you provide when you contact us for help, such as the solution you use, the content of chats and other communications with toncarton, and other details that help us provide support. We may remotely log in to the application, with your permission, to resolve an issue if our application crashes.
   • Any information you voluntarily provide to us, such as when you submit an inquiry through our support portal (e.g., contents of a message or attachments that you send to us), upload a photo of yourself on your account profile, or provide feedback on your delivery experience.

2. Information We Collect from Third Parties
   We receive information about Customers and Authorized Users from third parties or toncarton partners that provide services or support our business operations. We limit our use of your personal information to the purposes described in this Notice. Personal information that we receive from third parties includes:

   • Organization information, such as company name, job title, and company address when a partner refers you to us;
   • Order and delivery information, such as Recipient name and location when responding to a support request; and
   • Social Media and contact information related to our Marketing Activities, such as name, email, URLs, profile pictures, and profile ID.

3. Information We Collect from Customers
   We receive information about Authorized Users from our Customers. Personal information that we receive from our Customers includes:

   • Contact information, such as full name and email address when a Customer invites you to use our Services or when you are designated as an Authorized User on a Customer’s account;

4. Information We Collect Automatically
   When you use or interact with our Sites and Services, we automatically collect or receive certain information about you, your device, and your usage of our Site and Services. This information includes:

   • Usage information – We collect information about your usage and behavior on our Sites and Services. This information includes browser type and settings, usage details (e.g., timestamps, frequency, and use pattern), language preferences, and device event information (e.g., system activity and hardware settings, application version, and amount of time spent on our mobile application or our Sites), information about how you interact with our Services, Marketing Activities and Sites, (e.g., clicks, scrolls, mouseovers, internal links, pages viewed, searches, page response times, download errors, and date/time stamps associated with your usage), request information (e.g., speed, frequency, the site from which you linked to us (“referring page”), and the name of the website you choose to visit immediately after ours (“exit page”), and information about other websites you have recently visited and the web browser used.
   • Device information – We collect information about your device when you use our Sites and Services. This information includes device type, operating system, IP address, location, mobile network, system configuration information, model, model number, push notification tokens, and unique device identifiers such as your device ID.
   • Driver behavioral and delivery fulfillment information – We collect information about how drivers drive the vehicle and fulfill delivery requests. This information includes traffic patterns, vehicle speeds and accuracy of deliveries, assigned tasks, task activity, mobile device battery level, and driver status (such as on- or off-duty).
   • Geolocation information – When you use certain Services, we use GPS (or other similar sensor technology) to collect sensor data and the precise geographic location of you or your vehicle. We collect location information to determine vehicle trips (e.g., where the car drives over time), date/time, speed, altitude, travel direction, and insights that can be derived from this Notice (e.g., average speed). We also collect and use GPS data to determine estimated drive time. We do not access, collect, or store location information from a driver's mobile device when they are off-duty or offline.
   • Application usage information – We collect application usage information for support purposes and improve our Services. This information includes application crash reports or usage analytics for drivers who are not online or who are off-duty and engage with the chat function.
   • Anonymized statistical information – We collect anonymized statistical information and aggregated, de-identified information about how you use our Sites and Services for market research and to train our machine learning models.

   Some information collected within the Services, whether alone or together with other data, may personally identify you, such as optional features enabled by the Customer to collect photos of a Recipient’s package for proof of delivery. Depending on the Services provided, we collect this information on behalf of our Customers and/or requested by the Customer and under the direction of our Customer.

How We Use Information

toncarton uses collected information in the following ways:

• Communicate with you about our Services – We use your personal information to enable you to access and use our Services, including sending you technical notices, updates, security alerts, and support and administrative messages via email, SMS, push notifications, and in-app notifications.
• Provide our Sites and Services – We use your information to operate and administer our Sites and to provide, operate, monitor, and maintain our Services. We only use Recipient data to provide our Services (i.e, facilitate deliveries and complete Customer orders).
• Provide and improve necessary functionality – We use your information to provide you with the necessary functionality required during your use of our Sites and Services. We also analyze how Customers, dispatchers, and drivers use our Sites and Services to deliver the Sites and Services, develop new features, and improve functionality, quality, and user experience. For example, we track geolocation and driver vehicle information to improve our route optimization features.
• Transactional purposes – We use your information to complete transactions and send you related information, including purchase confirmations, receipts, invoices, recall notices, and customer experience surveys.
• Handle contact and support requests – We use your information to fulfill your requests and communicate with you via email, chat, or phone. toncarton employees are prohibited from viewing the content of data you import into your toncarton account, except when necessary to resolve your support issues. Access is limited to the data required to resolve your support issues.
• Develop and improve our Marketing Activities – We use Customer, dispatcher, and driver personal information to review and analyze trends, usage, and interactions with our Services, Site, and to personalize and improve our Marketing Activities. We also use Customer, dispatcher, and driver information to provide content and/or features that match your interests and preferences or otherwise customize our Marketing Activities and your experience with the Services. To learn more about how we track and use your information, see our Cookie Notice.
• Send marketing communications – We use your personal information for marketing purposes according to your preferences, such as to communicate with you via email, SMS, in-app messages, surveys, newsletters, promotions, trainings, or events that we think may be of interest to you and/or provide other news or information about toncarton and/or our select partners. Please see the “Your Privacy Choices and Rights” section below to learn how to manage your communication preferences
• Promote the security of our Sites and Services – We use your information to investigate and prevent fraudulent transactions, unauthorized access to the Services, and other malicious, deceptive, fraudulent, or illegal activity.
• Legal, regulatory, safety, and compliance purposes – We use your information for purposes of compliance with laws or regulations and to review compliance with applicable usage terms.
• Other purposes – We process your information for other purposes about which we notify you in advance or for which we receive your consent (such as in the event of a corporate sale, merger, or acquisition).

How We Share Information

toncarton shares your personal information with third parties as required by law and as part of our business practices. We do not sell personal information to third parties for their independent business use. For example, we do not sell personal information to third parties for their own marketing and advertising purposes. We only share personal information on a need-to-know basis where appropriate safeguards and contractual arrangements are in place and as described below.

1. Customers
   We share information with our Customers and Authorized Users when using certain Services. For example, when a driver interacts with a dispatcher during a delivery, we share the driver’s details (such as name and phone number) with that dispatcher. If you register or access our Services through an toncarton Customer, certain information about you including your name, contact information, photograph, and past use of your account may become accessible to that Customer and other individuals with whom the Customer shares access. If you are a Customer managing a particular group of Authorized Users within our Services, such as dispatchers and drivers, we may share your contact information with current or past Authorized Users for the purpose of facilitating Services-related requests.

2. Third-Party Service Providers
   We share your information with third-party service providers that require access to your information to support our operations and delivery of Services. The third parties that toncarton shares your information with include:

   • Professional services advisors to protect and manage our business interests;
   • Billing and payment providers to authorize, record, settle and clear transactions;
   • Cloud hosting providers to provide data storage and processing services;
   • Customer support providers to respond and resolve Customer inquiries and support requests;
   • Corporate and information technology services to facilitate business operations and communications;
   • Analytics companies to perform analysis on our Marketing Activities and Services; and
   • Any other suppliers, sub-contractors, partners, vendors, and other service providers acting on our behalf.

   These service providers are authorized to use your personal information only as necessary to provide Services to toncarton. We may use and disclose aggregate information that does not identify or otherwise relate to an individual for any purpose unless we are prohibited from doing so under applicable law.

3. Legal or Public Authorities
   We only disclose personal information when disclosure is:

   • Reasonably necessary to comply with any applicable law or regulation;
   • Required by law to comply with a legal process, or government request;
   • Necessary to enforce our agreements and this Notice;
   • Necessary to protect the security or integrity of our Sites and Services;
   • Necessary to protect against harm to the rights, property, or safety of toncarton, you, or the public as required or permitted by law; or
   • Necessary to respond to an emergency which we believe in good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person.

   Where required or permitted by applicable law, toncarton protects personal information by requesting protective orders or confidentiality agreements, redacting personal information from documents prior to production or disclosure, or other legally permissible means.

4. Corporate Affiliates
   We may share or transfer information to any person or entity which directly or indirectly controls, is controlled by or is under common control with toncarton, whether by ownership or otherwise (“Corporate Affiliate”), in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company. Any information relating to you that we provide to our Corporate Affiliates will be treated by those Corporate Affiliates in accordance with the terms of this Notice. Personal information may be part of the transferred assets. You may be notified thereafter of any such change in ownership or control through email or other means as applicable.
5. Corporate Partners
   We engage with several partners, such as third-party advertising networks, driver delivery networks, and integration services partners. We may share personal information with them to support our Services, such as Recipient contact information related to delivery fulfillment and driver behavioral information for analytics and to conduct Marketing Activities. Please see our Cookie Notice for more information about how you can turn off tracking technologies for our advertising partners.

Cookies and Other Tracking Technologies

When you visit our Sites or interact with our Marketing Activities, we use cookies and similar technologies such as web beacons, alone or in conjunction with cookies, to automatically collect certain technical information from your browser or device. For more information about how we use cookies and to learn how to manage cookies, please see our Cookie Notice.

How We Transfer and Store Information

We use data hosting service providers in the United States to store your information, and we use reasonable technical measures to secure that information. toncarton may transfer, process, or store your personal information outside of your country of residence, which may have different data protection laws than the country in which you initially provided the information, to provide our Services. To the extent required by applicable law, whenever we transfer your information, we take the appropriate steps to protect your information. This includes the use of standard contractual data protection clauses or other appropriate legal mechanisms to safeguard the transfer.

How Long We Retain Information

We retain Customer information for the minimum necessary period to fulfill our legal and contractual obligations; support business operations; develop our Sites and Services; resolve disputes; enforce our rights; for legitimate business purposes outlined in this Notice; and as recommended by industry standards.

How We Protect Your Information

We use reasonable and appropriate administrative, technical, and physical safeguards to protect the information that we have about you from loss, theft, and unauthorized use, access, modification, or destruction. We also require partners and third-party service providers acting on our behalf or with whom we share your information to maintain security measures in accordance with industry standards.

Notwithstanding our security safeguards, it is impossible to guarantee absolute security in all situations. If you have any questions about the security of our Sites and Services, please contact us as described in the “Contact Us” section. For your own security, please do not send any confidential personal information to us outside of our Services.

Third-Party Services, Applications, and Websites

Our Sites and Services may contain links to other websites not operated or controlled by toncarton. Certain third-party services, applications, or websites used to navigate to and from our Sites and Services have separate user terms and privacy notices that are independent of this Notice.

toncarton requires partners and third-party service providers acting on our behalf or with whom we share your information to provide appropriate security measures in accordance with industry standards and in compliance with this Notice, contractual obligations, their privacy and security obligations, and any other appropriate confidentiality and security measures. However, we are not responsible for the content, accuracy or opinions expressed in such websites, or the privacy and data security practices of third parties outside of the personal information we receive from or transfer to them. We do not investigate, monitor, or check these websites for accuracy or completeness. We recommend carefully reviewing the terms and privacy notices of each third-party service, website, and/or application prior to use.

Your Privacy Choices and Rights

1. Privacy Choices
   You have certain choices and rights available when it comes to how we collect and use your personal information. Below is a summary of those choices and rights and how to exercise them.

• Opt-out of marketing communications: You may opt-out of receiving any marketing communications from us in the following ways:

• Email: Click the “Unsubscribe” link within each email or by contacting us as provided in our "Contact Us" section. If you are a Customer and opt out of receiving marketing messages, you will continue to receive transactional communications from us regarding our Services.

• SMS: Certain features with our Services provide Customers the option to enable SMS communications. You may opt-out of receiving SMS communications from us by following the opt-out process described in the SMS communications. If you opt-out of receiving SMS messages, you will continue to receive transactional communications from us regarding our Services.

• Account preferences: You may update and correct certain account information at any time by logging into your account or emailing us at privacy@toncarton.com. If you wish to delete your account, please email us at privacy@toncarton.com with your account information, but note that we may retain certain information as required by law or for our legitimate business purposes.
• Push notifications: You can opt-out of receiving push notifications on your mobile device through your device settings. Please note that opting out of receiving push notifications may impact how our Services function.
• Mobile application information: You can stop toncarton from collecting information by uninstalling the mobile application on your device. Use the standard uninstall processes available on your mobile device or via the mobile application marketplace or network. Please note that uninstalling the mobile application impacts our ability to provide you Services.
• Managing cookies and other tracking technologies: Relevant browser-based cookie controls are described in our Cookie Notice.

1. Privacy Rights
   Depending on where you are located, you may have certain rights in connection with your personal information that we obtain. These rights vary depending on your jurisdiction. To learn more about your rights, see:

• Appendix B for GDPR rights if you are an EEA or UK resident.

Minimum Age Requirements to Use Our Services

toncarton’s Site and Services are not directed to children under 13. To use toncarton’s Sites and Services, you must be old enough to consent to the processing of your personal information in your jurisdiction. We do not knowingly collect personal information from anyone under the age of 13. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us. If we become aware that we have collected personal information from anyone under the age of 13 without verification or parental consent, we take steps to remove such information.

Changes to Our Privacy Notice

We periodically review and update this Notice to describe new Services or changes to our practices. You can determine when this Notice was last revised by referring to the “Updated” date at the top of this Notice. We encourage you to review the Notice whenever you interact with us to stay informed about our privacy practices and the ways that you can help protect your privacy.

If we make significant changes to this Notice, we will notify you through a prominent notice on our Services or via email address or phone number associated with your account. If you do not agree with the privacy practices disclosed in the Notice, we recommend you stop using our Sites and Services.

Contact Us

To submit questions about this Notice or to update or request changes to your personal information, please contact us at privacy@toncarton.com or write to us at:

toncarton, SAS
9 rue anatole de la forge Paris, 75017 France

Appendixes

• GDPR Notice

Other versions of this document

• Privacy Policy (Current)