Privacy Policy

Freight Exchangers Ltd (“Freight Exchangers”, “we”, “us” or “our”) respects your privacy and is committed to protecting personal information.

This Privacy Policy explains how we collect, use, store and share personal information when you visit, register for or use the Freight Exchangers website and freight exchange platform (“Platform”), or otherwise communicate with us.

Freight Exchangers is primarily a business-to-business service. However, information relating to people who represent or work for businesses is still personal data and is protected under applicable data protection law.

1. Who we are

The controller responsible for personal information processed through the Platform is:

Freight Exchangers Ltd

Company No. SC899966

Registered in Scotland

Registered office:

Suite F25-26 Grierson House

The Crichton

Bankend Road

Dumfries

United Kingdom

DG1 4ZE

Email: support@freightexchangers.co.uk

2. Who may use Freight Exchangers

Freight Exchangers is intended for business use and is not intended for children.

Users must be 18 years of age or older to register for or use a Freight Exchangers account.

3. Personal information we collect

Depending on how you interact with Freight Exchangers, we may collect and process the following categories of information.

Account and contact information, such as:

• name;
• email address;
• telephone number;
• login and account information;
• your role or association with a company; and
• communications with Freight Exchangers.

Company information, which may include:

• company or trading name;
• company address;
• registration number;
• VAT number, where applicable;
• company contact information;
• Accounts Email;
• company description; and
• other information supplied as part of a company profile.

Some company information may not itself constitute personal data. However, it may be personal data where it identifies or relates to an individual, such as a sole trader or named company contact.

Company verification information and documents.

Businesses may be asked to provide documentation or other evidence to support their application and demonstrate that they are a genuine trading business. This may include, for example:

• company registration documentation;
• VAT documentation, where applicable;
• insurance documentation; and
• other reasonable evidence relating to the business.

Verification documents are not publicly displayed. They are accessible only to authorised users of the relevant company where applicable and authorised Freight Exchangers administrators for legitimate verification and administration purposes.

Platform activity, such as:

• Loads posted;
• Trucks posted;
• listing information;
• reviews;
• account activity;
• membership information;
• company/user access status; and
• information associated with use of Platform features.

Membership and billing information, such as:

• membership plan;
• membership period;
• agreed membership price;
• subscription status;
• invoice status;
• renewal information; and
• records relating to suspension or cancellation where applicable.

Freight Exchangers membership is currently paid by invoice. Payment is not processed through the Platform and users are not asked to provide payment card or online banking details through the Freight Exchangers website.

Communications and alerts, including:

• emails you send to Freight Exchangers;
• support enquiries;
• account and membership communications;
• verification communications;
• security-related messages; and
• Load and Truck alerts.

When members contact another business using contact information made available through Freight Exchangers, the subsequent communication may take place using the businesses' own email, telephone or other communication systems. Freight Exchangers does not currently provide members with a Freight Exchangers-hosted email account for those communications.

Technical and usage information.

When you access the Platform, certain technical information may be processed automatically. This may include:

• session identifiers;
• date and time of access;
• browser and user-agent information;
• language or locale;
• approximate country or geographic region;
• referring webpage, where available;
• pages visited;
• page URLs;
• IP address and related network/security information where processed by our hosting or security infrastructure; and
• information necessary for authentication, security and operation of the Platform.

We also use basic first-party website usage analytics to understand visits to and use of the Platform.

4. How we collect personal information

We may collect personal information:

• directly from you when you register, complete or update a profile, contact us or use the Platform;
• from another authorised person within your company;
• through Loads, Trucks, reviews and other information submitted through the Platform;
• through company verification;
• automatically when you access and use the Platform;
• through cookies and similar storage/access technologies; and
• where appropriate, from legitimate public or business sources for verification, security or administration purposes.

5. How we use personal information

We may process personal information to:

• create and administer accounts;
• register and manage companies;
• verify businesses applying to use Freight Exchangers;
• provide access to Platform features;
• display appropriate company and member information to other members;
• enable businesses to advertise and discover Loads and Trucks;
• enable members to find and contact relevant businesses;
• operate the review system;
• manage membership plans and authorised users;
• issue and administer membership invoices;
• maintain subscription and billing records;
• send operational emails and notifications;
• provide Load and Truck alerts;
• respond to enquiries and provide support;
• investigate complaints, suspected fraud, abuse or breaches of our Terms;
• moderate Platform content;
• suspend or restrict accounts where appropriate;
• protect accounts, users and the Platform;
• prevent or investigate misuse and security incidents;
• understand how the website and Platform are used;
• maintain, troubleshoot and improve the Platform;
• establish, exercise or defend legal claims;
• comply with our legal and regulatory obligations; and
• otherwise operate Freight Exchangers legitimately and securely.

6. Our lawful bases for processing

UK data protection law requires us to have a lawful basis for processing personal data.

Depending on the circumstances, we may rely on:

Contract

where processing is necessary to provide the membership or Platform service requested, administer an account or perform our agreement with a member, or to take steps at their request before entering into an agreement.

Legitimate interests

where processing is necessary for our legitimate business interests or those of another person, provided those interests are not overridden by the individual's rights and freedoms.

These interests may include:

• operating and improving Freight Exchangers;
• administering business accounts;
• facilitating legitimate B2B freight exchange activity;
• protecting the Platform and its members;
• preventing fraud and misuse;
• maintaining appropriate business records;
• resolving complaints and disputes;
• understanding use and performance of the Platform; and
• maintaining network and information security.

Where we rely on legitimate interests, we consider whether the processing is necessary and proportionate and balance our interests against the interests, rights and freedoms of affected individuals.

Legal obligation

where processing is necessary for us to comply with an obligation imposed by law.

Consent

where we specifically ask for consent for a particular processing activity where consent is the appropriate lawful basis.

We may rely on more than one lawful basis where different processing activities apply to the same information.

7. Company profiles and information visible to other members

Freight Exchangers is designed to allow businesses to discover and communicate with one another.

Certain company information may therefore be visible to other authorised members of the Platform where necessary for the service.

This may include appropriate company profile information, business contact information, Loads, Trucks and reviews.

Users should not upload unnecessary personal or confidential information to fields intended to be visible to other members.

Company verification documents are not public profile information and are handled separately as described in this Policy.

8. Verification documents

Verification documents supplied to Freight Exchangers are used to assess or administer a company's application or continued use of the Platform and to help protect the integrity of the service.

They are not intended to be accessible to unrelated Freight Exchangers members.

Access is restricted to authorised persons within the relevant company where applicable and authorised Freight Exchangers administrators who require access for legitimate administration or verification purposes.

Verification by Freight Exchangers does not mean that we guarantee a company's reliability, creditworthiness, performance or suitability for any particular transport arrangement.

9. Membership, invoices and payments

Freight Exchangers records information necessary to administer memberships and invoices.

Membership is currently paid by invoice. Freight Exchangers does not currently process membership payments through the Platform or require users to enter payment card or online banking details into the website.

If online payment functionality is introduced in the future, this Privacy Policy will be updated as appropriate to explain the processing involved and any payment providers used.

10. Emails, notifications and alerts

We may use contact details to send communications necessary to operate the service, including:

• registration and account messages;
• verification communications;
• membership and invoice communications;
• security messages;
• support responses;
• important service announcements; and
• Load and Truck alerts where applicable.

These operational/service communications are separate from promotional marketing.

We do not currently use member contact details for a general promotional email programme.

If Freight Exchangers introduces promotional marketing in the future, we will comply with applicable UK data protection and electronic marketing requirements and provide appropriate choices and opt-outs.

11. Analytics and technical information

We use limited technical and usage information to understand how the Platform is being used, maintain the service and identify problems.

At the date of this Policy, the Platform uses basic first-party page-hit analytics which may process information including:

• a session identifier;
• timestamp;
• browser/user-agent;
• locale;
• approximate country;
• referrer;
• page path; and
• page URL.

We do not currently knowingly use this analytics system for behavioural advertising or cross-site advertising profiles.

If we introduce additional analytics, advertising or tracking services in the future, we will update our disclosures and obtain consent where required.

12. Cookies and similar technologies

Freight Exchangers uses cookies and similar storage/access technologies for purposes including authentication, session management, security, operation of the Platform and limited usage measurement.

Further information is provided in our separate Cookie Policy.

Where consent is required for a cookie or similar technology, we will obtain that consent in accordance with applicable law.

13. Who we may share personal information with

We may share personal information where reasonably necessary with:

• other Freight Exchangers members where information is intended to form part of a company profile, Load, Truck, review or other member-facing feature;
• service providers that help us host, secure, maintain or operate the Platform;
• email and communications service providers;
• hosting, infrastructure and database providers;
• professional advisers such as accountants, solicitors or insurers where necessary;
• law enforcement, courts, regulators or public authorities where disclosure is legally required or otherwise lawful;
• parties involved in investigating fraud, security incidents or serious misuse where appropriate; and
• a buyer, investor or successor organisation in connection with a legitimate sale, merger, restructuring or transfer of all or part of our business, subject to appropriate safeguards.

We do not sell members' personal information to advertisers.

Service providers processing personal information on our behalf are expected to handle that information appropriately and only for authorised purposes.

14. International transfers

Some of the technology and service providers used to operate an online platform may process or store information outside the United Kingdom.

Where personal information is transferred internationally, we will take appropriate steps required by applicable data protection law to protect it, which may include relying on applicable adequacy regulations or appropriate contractual safeguards.

15. How long we keep information

We keep personal information only for as long as reasonably necessary for the purposes for which it was collected, including providing the Platform and satisfying legal, accounting, security and dispute-resolution requirements.

Retention periods may vary according to the type of information and why it is held.

For example:

• active account and company information may generally be retained while the membership/account remains active;
• subscription, invoice and transaction-related business records may be retained for an appropriate period after the relevant membership ends where required for accounting, tax, legal or dispute purposes;
• verification records and documents will be reviewed and retained only for as long as reasonably necessary for verification, administration, security and legal purposes;
• security and technical records may be retained for a limited period appropriate to their purpose; and
• information relevant to a complaint, dispute, investigation or legal claim may be retained while that matter remains relevant.

We may delete, anonymise or securely archive information when it is no longer required.

16. Security

We take reasonable technical and organisational measures designed to protect personal information against unauthorised access, disclosure, alteration, loss or destruction.

These measures may include:

• authentication and access controls;
• restricting administrative functionality;
• limiting access to verification documents;
• security monitoring;
• database access controls;
• account suspension or restriction mechanisms; and
• appropriate hosting and infrastructure security measures.

No internet-based service can guarantee absolute security, and users are also responsible for keeping their account credentials secure.

17. Your data protection rights

Depending on the circumstances, UK data protection law may give you rights including:

• the right of access to personal information held about you;
• the right to rectification of inaccurate or incomplete personal information;
• the right to erasure in certain circumstances;
• the right to restrict processing in certain circumstances;
• the right to object to certain processing, including certain processing based on legitimate interests;
• the right to data portability in certain circumstances;
• the right to withdraw consent where processing is based on consent; and
• rights relating to certain types of automated decision-making, where applicable.

These rights are not absolute and may depend on the circumstances and applicable law.

To exercise a data protection right, contact:

support@freightexchangers.co.uk

We may need to verify your identity before fulfilling a request.

18. Automated decision-making

Freight Exchangers does not currently intend to make decisions producing legal or similarly significant effects about individuals solely through automated processing.

Some Platform processes may operate automatically, such as applying dates or statuses to listings or memberships. This does not necessarily constitute automated decision-making of the type regulated by UK data protection law.

19. Complaints

If you have a concern about how Freight Exchangers handles your personal information, please contact us first at:

support@freightexchangers.co.uk

You also have the right to complain to the UK's independent data protection regulator, the Information Commissioner's Office (ICO).

20. Links and communications with other businesses

The Platform may enable members to access another company's contact information or follow links to external websites or services.

Freight Exchangers is not responsible for the privacy practices of independent businesses or external websites.

Once you provide information directly to another member or communicate with them outside Freight Exchangers, that business may become independently responsible for how it handles that information.

21. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect:

• changes to the Platform;
• changes to the information we process;
• new service providers or technologies;
• changes to our business practices; or
• legal or regulatory requirements.

The current version will be made available through the Platform and will show its most recent update date.

Where appropriate, we may notify members of material changes.

22. Contact us

For questions about this Privacy Policy, requests concerning your personal information or other privacy enquiries, contact:

Freight Exchangers Ltd

Company No. SC899966

Registered in Scotland

Registered office:

Suite F25-26 Grierson House

The Crichton

Bankend Road

Dumfries

United Kingdom

DG1 4ZE

Email: support@freightexchangers.co.uk