Safety
Service
Sustainability

In the event of an emergency, you will be directed to one of the designated assembly areas by supervision. Remain at the designated assembly area for an official accounting of personnel, and issuance of further instructions.

Legal Terms & Privacy

1) Introduction

This policy describes how TraPac collects and uses your personal information. TraPac:

• recognizes and respects the importance of your privacy
• processes your personal information in accordance with this policy and applicable laws, including but not limited to, the California Privacy Act of 2018 (“CCPA”) and the General Data Protection Regulation (“GDPR”) where appropriate
• may change this policy at any time at our discretion and at any time without prior notice.

When we make changes to this Privacy Policy, we will update the policy on our website at www.trapac.com and update the policy’s effective date. Please visit our website regularly to find out whether any changes have been made to this policy, which will be noted by the version date listed in the header. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

You may register and set up a profile on our website, which will allow you to change your information any time, or request your profile be deleted. Go to www.trapac.com and click “Login” to register.

If you are a California Resident, you have certain rights as set out in the CCPA. This Privacy Policy constitutes TraPac’s notice provided pursuant to the CCPA. This Privacy Policy is intended to provide notice and acknowledge those rights afforded under the CCPA and other applicable laws. It is not intended to, and does not, afford anyone additional rights not otherwise granted by law. The CCPA defines “Personal Information” as information that identifies, relates to, or could reasonably be linked directly or indirectly with a particular California Resident. The CCPA, however, does not apply to certain information or uses of certain information. For example, Personal Information does not include

• publicly available information from government records
• de-identified or aggregated consumer information
• health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPPA) and the California Confidentiality of Medical Information Act (CMIA or clinical trial information, or
• personal information covered by certain sector-specific privacy laws, including the Fair Credit Report Act (FRCA), Gramm-Leach-Bliley Act (GLBA) or the the California Information Privacy Act (FIPA).

The information that TraPac collects, uses, and discloses relating to California residents covered by the CCPA may vary depending on our relationship or interaction with that individual resident.

2) Personal Information and Collection Processes

This privacy policy applies to individuals whose personal information is processed by TraPac, such as:

• website visitors
• job seekers, applicants, and candidates
• contractors
• visitors to various TraPac locations, including truck drivers

More details are provided below describing how personal information is processed for each category.

1. TraPac website visitors
   We may collect your personal information for the following purposes when you visit and use our website:
   • provision of TraPac services and products
   • to accommodate your requests and inquiries
   • provision of newsletters offered by TraPac
   • evaluating the use of our websites for
     • statistical purposes
     • compliance with any laws to which TraPac observes
   • the purposes listed in our cookie policy

On our websites, we may collect information about:

• name
• postal address
• email address
• other contact information
• IP addresses
• information about your activities on our website, e.g.:
  • what pages you visit
  • how long you are on the website
  • what you click to review

  Our websites are intended for a general audience, and TraPac does not knowingly collect personal information about any person under 13 years of age.

  We process your personal information based on your consent and to pursue our legitimate interests, which include:

  • transmitting your personal information to our affiliates for administrative purposes, and
  • ensuring network and information security and our commercial company interest
    • including direct marketing

    If you choose not to share the requested personal information with us, we cannot meet some of our purposes, as described in this privacy policy.

    • Assessing your candidacy for our available positions;
    • HR and personnel administration purposes;
    • Evaluating the use of our websites for statistical purposes and for compliance with any laws to which TraPac is subject.

    All recruitment information is stored in ADP. California law requires retention for 3 years. Federal law requires retention for 1 year.

    1. Candidate Group The Candidate Group is a shared community for candidates to release their CareerProfiles and share their information in the database for future job opportunities with TraPac. If you decide to release your Career Profile in the Candidate Group, you explicitly consent to share personal information:
       • during your online or paper application process
       • collected by TraPac as part of the recruitment process, and
       • collected by TraPac as part of a previous employment process
         • including but not limited to potential:
           • assessment tests results
           • interview conclusions, and
           • an overview of previous applications
             • whether they are in process, rejected, etc.
         • made available and disclosed to authorized HR professionals around the world
           • including in territories other than your preferred employment location
         • The authorized HR professionals may access your profile when recruiting for:
           • a specific position
           • statistical information
           • operational purposes
           • other legitimate business purposes

    You may change your Career Profile:

    • Click “My Profile”
    • check, change and update your personal information

    You may withdraw your Career Profile from our Candidate Group:

    • Log in to your Career Profile
    • Uncheck the relevant box

    TraPac reserves the right to cancel or delete your Career Profile and/or account at any time at its complete discretion.

    If you have established a Career Profile or otherwise applied for a position within TraPac we consider you to be a job applicant for the purpose of the CCPA.

    • name
    • email address
    • mobile phone number
    • resume or CV

    We may also request that you provide additional information, such as your

    • address
    • cover letter
    • relevant education
    • any other relevant information required for TraPac to evaluate your application

    Depending on the position, and in compliance with applicable law, we may also (a) require that you participate in one or more assessment tests; (b) require that you undergo a health examination; and/or (c) verify information relating to your criminal history record, credit report, or visa/work permit.

    You will be informed prior to any collection of your personal information if required according to applicable local law.

    TraPac is an equal opportunity employer in accordance with applicable law, and makes all employment-related decisions based entirely on merit and qualifications.

    • visitors
    • vendors
    • truck drivers
    • inland shipping crew members

    Please note that we have placed CCTV cameras on and around our physical sites. These cameras may occasionally make recordings of you as you pass the areas that are covered by the CCTV cameras. These recordings may qualify as your personal information and are managed by this privacy policy. The camera recordings are typically removed after 4 weeks. However, the recordings may be kept for a longer period, for example, in case of an accident investigation or other valid reasons.

    Furthermore, please note that the TraPac terminal facilities are subject to various laws governing safety and security of the premises, which may require that TraPac collect certain personal data.

    When you access a TraPac location, we may collect your:

    • name
    • postal address
    • email address
    • other contact information
    • company name
    • driver’s license number or other identification number
    • job title
    • visiting purpose and hours
    • CCTV camera images that are recorded on sites, and
    • biometric information for access purposes.

    We may also require that you provide identification documentation, which may include a Transportation Worker Identification Credential (“TWIC”), driver’s license, and/or other form of government issued identification depending on the location.

    In this context, we may process your personal information

    • to execute a contract between you (or your employer) and TraPac
    • to meet our legal obligations
    • by transferring it to our affiliates for administrative purposes
    • for human resources and management purposes
    • to ensure network and information security
    • to safeguard access, control and security on TraPac sites
    • to protect the safety of TraPac and those present at its sites
    • to deter damage and criminal acts as well as actions that are prohibited by TraPac’s internal policies and procedures
    • to conduct internal investigations of suspected criminal or prohibited behavior
    • to safeguard access, control and security on TraPac sites
    • to protect the safety of TraPac and those present at its sites
    • for human resources and management purposes
    • to execute a contract between you (or your employer) and TraPac
    • to meet our legal obligations
    • by transferring it to our affiliates for administrative purposes
    • for business process execution
    • to deter damage and criminal acts as well as actions that are prohibited by TraPac’s internal policies and procedures, and
    • to conduct internal investigations of suspected criminal or prohibited behavior

    Please note that we have placed CCTV cameras on and around our physical sites. These cameras may occasionally make recordings of you as you pass the areas that are covered by the CCTV cameras. These recordings qualify as your personal information and are managed by this privacy policy. The camera recordings are removed after 4 weeks. However, the recordings may be kept for a longer period, for example, in case of an accident investigation or other valid reasons.

    We may also require that you provide identification documentation, which may include a Transportation Worker Identification Credential (“TWIC”), driver’s license, and/or other form of government issued identification depending on the location.

    When you contract with TraPac, we may collect your

    • Name
    • postal address
    • email address
    • other contact information
    • company name
    • Driver’s license number or other identification number
    • job title
    • working hours, and
    • criminal records, to the extent permitted by applicable law, including criminal records in the context of background checks
    • clients and their representatives
    • individuals who show an interest in TraPac or our products and services
    • individuals who are connected in another way with a business or organization with which we have, want to have, or have had a business relationship
    • security providers
    • potential clients

    In this context, we process your personal information for the following purpose:

    • to enter into a business relationship and agreement with you
    • to perform agreements and carry out instructions
    • to protect your security and integrity as well as the security and integrity of the TraPac and others
    • to help develop and improve products and services
    • for account management, promotional and marketing purposes
    • to enter agreements with suppliers and other parties we work with
    • to comply with legal obligations
    • to carry out business processes and for the purpose of management reports and internal management

    If your business or organization transfers any personal information concerning employees or other representatives to us, we also expect your employees, executive directors or other representatives to be informed about this. You can give this privacy policy to them so that they can learn how we deal with their personal information.

    For the purposes listed above, we may collect your:

    • name
    • postal address
    • email address
    • other contact information
    • information relating to or used for agreements / contracts or financial statements
    • financial, payment and/or transaction information
    • conversations we have with you in person, by telephone, e-mail, text message, or other electronic transmission
    • camera images that we take in our premises
    • information we receive from other parties (e.g. Chamber of Commerce)
    • information we require to:
      • combat fraud
      • ensure your security and ours
      • prevent money laundering and the financing of terrorism

      We process your personal information for the following purposes:

      • Access control and safeguarding security
      • Deter damage and criminal acts as well as actions that are prohibited by TraPac’s internal policies and procedures, and
      • To conduct internal investigations of suspected criminal/prohibited behavior

      If you would choose not to share the requested personal information with us, we would not be able to meet some of our purposes, as described in this privacy policy.

      3) Using your personal information for any other purpose

      As discussed in greater detail above, TraPac may use or disclose the personal information we collect for several business purposes, including but not limited to, to process a payment or transaction, to support our Website, to support our services, to create, maintain and customize your account with us, to maintain the safety and security of our facility as well as our Website, to respond to requests from law enforcement or other legal processes, court orders, or governmental regulations, and for administrative and management purposes.

      We will not use the personal information we collected for materially different, unrelated or incompatible purposes without updating this Privacy Policy. If provided by applicable law, you may withdraw your consent at any time.

      4) Sharing your personal information

      We may share your personal information to a third party for a business purpose. This includes:

      • Divisions within TraPac
      • parent companies, subsidiaries, members, joint venture partners, and/or other affiliated companies
      • contractors or vendors retained by TraPac to perform services, such as payment processing, IT support, or other business functions
      • professional service providers and advisors such as, lawyers, auditors and accountants
      • judges, arbitrators, mediators, and other judiciaries
      • governmental bodies, authorities, regulators, as required by law or regulation.

      Access to your personal information will be limited to those parties that require access for the performance of their tasks. When we share personal information for a business purpose, we will exercise care to protect the information from further disclosure.

      TraPac does not currently sell personal information about California residents to any third parties and has not done so in the past twelve months.

      5) Security and retention

      We have implemented technological and organizational measures to safeguard your personal information. We will store your personal information as required for the purposes for which it was initially collected, which may vary depending on the type of personal information collected and its purposes.

      We may use information storage (commonly known as cookies) to allow you to more easily use our site and to enhance performance. We use cookies for multiple purposes. Third parties (for example, external services like web traffic analysis services) may use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies. Following are the list of third party companies that may set cookies on our website:

      Third Party

      Type of Cookie

      More Information

      This cookie provides anonymized data to allow us to understand user behavior and marketing performance.

      These cookies allow us to properly regulate the use of our Authenticated Transactions. The site will not work without them.

      7) Your rights

      1. Introduction You have the right to request TraPac to provide you with access to your personal information, or potentially, to rectify or delete it. You may also have the right to object to the processing of your personal information or to request restriction to the processing of that information, as well as information portability. Please email your questions and complaints concerning our processing of your personal information using our address listed below in the next section. If you are not satisfied with our response, solution, or both, you have the right to withdraw consent at any time, and the right to submit a complaint with your local supervisory authority.
      2. CCPA The CCPA provides consumers who are California residents with specific rights regarding their personal information. Access to Specific Information and Information Portability Rights You may have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months, subject to certain exemptions. Once we receive and confirm your verifiable consumer request and absent an exemptions, we will disclose to you:
         • The categories of personal information we collected about you
         • The categories of sources for the personal information we collected about you
         • Our business or commercial purpose for collecting or selling that personal information
         • The categories of third parties with whom we share that personal information
         • The specific pieces of personal information we collected about you (also called a information portability request)
         • If we sold or disclosed your personal information for a business purpose.

      Consistent with the CCPA, we do not provide the foregoing rights for business to business personal information.

      Deletion Request Rights

      You may have the right to request that we delete personal information that we collected from you and retained, subject to certain exemptions. Once we receive and confirm your verifiable consumer request and absent an exemption, we will delete (and direct our service providers to delete) your personal information from our records.

      We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

      • Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
      • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
      • Debug products to identify and repair errors that impair existing intended functionality.
      • Exercise free speech, ensure that the right of another consumer to exercise their free speech rights, or exercise another right provided by law.
      • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et seq).
      • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
      • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
      • Comply with a legal obligation.
      • Make another internal and lawful use of that information that is compatible with the context in which you provided it.

      Consistent with the CCPA, we do not provide these rights for business to business personal information.

      Non-Discrimination

      We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not deny you goods or services, charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties, provide you a different level or quality of goods or services, or suggest that you may receive different price or rate for goods or services or a different level or quality of goods or services.

      8) Contact details

      If you have any questions or comments or wish to exercise your rights under applicable laws, please contact our privacy team by emailing us at Privacy@trapac.com , by creating a profile on our website at www.TraPac.com, or by calling 1-877-387-2722.

      Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or information portability twice within a 12-month period. The verifiable consumer request must:

      • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
      • Describe your request with sufficient detail that allows us to properly understand, evaluate and respond to it.

      We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

      We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

      For all requests made pursuant to the CCPA, we will endeavor to respond to a verifiable consumer request within forty-five (45) days of is receipt. If we require more time, we will inform you of the reason and extension period. Any disclosures that we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. For information portability requests, we will also explain the reasons we cannot or will not comply with a request, if applicable.