Privacy Policy

1. WHAT THIS PRIVACY POLICY COVERS

This website, located at https://www.firstmile.com (the “Site”), is operated by International Fulfillment Solutions, LLC d/b/a FirstMile (“First Mile,” “we” or “us”).

FirstMile provides e-commerce shipping services (collectively referred to a “Services”) to our business clients and partners (“Clients”), who use our Services to provide e-commerce order services to their end users and customers (“Client Customers”). In the course of providing our Services to our Clients, FirstMile receives and processes personal information such as delivery addresses and order or return information, about Client Customers on behalf of our Clients. As to the personal information we collect and use about Client Customers, we act as a Service Provider on behalf of our Clients and do not use, retain, or disclose this information except in relation to providing the Services to our Clients. FirstMile is not responsible for the privacy or security practices of our Clients, which may differ from those set forth in this privacy policy, so please check with individual businesses of which you are a Client Customer about the policies they have in place to govern their collection, use, processing, and sharing of your personal information, and to exercise your consumer privacy rights under applicable privacy laws.

This Privacy Policy explains how FirstMile collects, uses, and discloses personal information about you as a business on our own behalf, either as our Client or as a Site visitor, including when you use this Site to discover information about FirstMile or to request a quote, or when you otherwise communicate with us. This Privacy Policy also explains your privacy rights in relation to your personal information and how you can exercise them. As used in this policy, “personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

2. COLLECTION OF INFORMATION

Types of Information We May Collect
Site Visitors: When you visit our Site or otherwise interact with us as described above, we may collect the following types of information about you:

Identifiers, such as your name, address, email address, IP address, or unique online identifiers;

Commercial information, such as information about products or services you purchased or considered;

Internet or other network activity information, including online browsing or search history, or information about your interaction with our website;

Professional or employment-related information, including the company for which you work and your job title.

Business Clients: for our Clients who create accounts with us or log in to our Client portal via the Site, we may collect the following types of information about you as a representative of your business:

Identifiers, such as name, address, email address, username, password, IP address, or unique online identifiers;

Customer Record Information such as your signature (on a contract), your telephone number, credit card or other payment information;

Commercial information, such as information about products or services you purchased, considered, or consumed;

Internet or other network activity information, including online browsing or search history, or information about your interaction with our website, including the Client portal;

Professional or employment-related information, including the company for which you work and your job title.

Sources of Collection
We may collect the above types of information in various ways, as described below:

Information You Provide to Us Directly
We collect information you provide directly to us, such as when you fill out a form, or otherwise submit, send, or provide your information to us yourself.

Information We Collect Automatically When You Use Our Site
When you access or use our Site, we also automatically collect certain information about you, including:

Log and Device Information: We systematically collect standard information related to your access to and use of the Site and the device you used to access the Site, such as the type and version of your browser and operating system, access dates and times, pages viewed, IP address and the referrer web page from which you linked to our Site.

Information Collected by Strictly Necessary, Performance, or Analytics Cookies and Similar Tracking Technologies:
We (and our service providers) may also use technologies like cookies (small data files related to your Site visit that are stored on your hard drive or in device memory) and web beacons (embedded electronic images that help deliver cookies and detect events) to automatically collect information, for the purposes described in the next section. Some cookies are strictly necessary to the operation of our Site and some enhance the Site performance or capture information for analytics about Site use and campaign effectiveness. You can clear most cookies in your browser settings to eliminate previously collected or stored information. We do not enable third parties to set cookies from our Site in a way that would constitute a “sale” of information to them under the California Consumer Privacy Act (“CCPA”).

3. USE OF INFORMATION

We may use the information we collect about you for the purposes listed below:

To Provide our Site and Services - We use strictly necessary information that is collected automatically to provide you our Site and a method for you to request that we contact you or provide you a quote for services. For Clients, we also use your collected information to provide our Services, maintain your accounts, send you invoices for services and process payments.

To Authenticate your Identity - We may use your username, password, and/or browser cookies to recognize you when you re-visit our Site or when you log in to our Client portal with your account credentials.

To Communicate with You - We use your collected information like email address, phone number or address to communicate with you if you requested a quote or other information, or if you signed up to receive our newsletter. If you are a Client, we may contact regarding our Services in order to deliver transactional or service-related communications.

For Marketing - We may use your email address (subject to your unsubscribe options under applicable law), mailing address, or phone number (subject to your opt-in or out options under applicable law) or other collected information to send or show you marketing messages or offers for First Mile. You may unsubscribe from these communications at any time by following the opt-out instructions in the message.

To Provide You Customer Service - We use your information in order to respond appropriately to your inquiries, complaints, or requests communicated to us through our Site or otherwise, including to provide you information about our Services.

To improve our Site, Services, and marketing campaigns - We use information about your use of our Site and Services, your interaction with our marketing and social media, as well as your feedback to analyze, evaluate and make improvements to our product and Services offerings, our Site, including content and functionality, and assess the effectiveness of our marketing.

To comply with legal obligations - We may use your information as necessary to comply with obligations we have under applicable laws to compile, maintain, and file required records or reports, to cooperate with regulators or law enforcement agencies as to official investigations or respond to legal processes.

To exercise or protect our rights - We may use your information to exercise or protect our legal rights, such as prosecuting or defending against intellectual property (copyright, trademark, patent, trade secret, counterfeiting) actions, fraud claims, or violations of our or third parties’ rights.

To Protect You, Others, and Our Business - We may use collected information to limit spam, malware, and other malicious online activities and security risks, and to improve and enforce our Site security measures, or otherwise as necessary to protect the safety, security, and legal rights of persons and/or FirstMile or to enforce our agreements or policies.

4. SHARING OF INFORMATION

We may share all categories of collected information about you for our business purposes, as follows:

With Our Affiliates and Subsidiaries
We may share information that we collect about you with our affiliates and subsidiaries or related entities in order redirect or resolve inquiries from you regarding services that they provide.

Disclosure to Vendors who Provide Us Services
We may disclose your personal information as necessary to vendors and other third parties that perform services for us, for a business purpose, including business operations-related services such as platform support, other IT services, and analytics.

To Comply with Law
We may disclose information about you in response to an official request for information, if we believe disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements.

To Protect First Mile or Others
We may disclose your information if we believe your actions are inconsistent with our user agreements or policies, if we believe you have violated the law, or to protect the rights, property, and safety of FirstMile or others.

In Connection with a Business Transaction
We may disclose your information in confidence in connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company. If there are changes to the internal structure of our parent company so that another FirstMile affiliate or subsidiary takes on the role of centrally collecting, using or disclosing personal information in accordance with this Privacy Policy, that affiliate or subsidiary will handle your information in accordance with this Privacy Policy in place of First Mile.

In addition to the above listed disclosures of personal information, we may also share aggregated or de-identified information that cannot reasonably be used by recipients to identify you.

In addition to the above listed disclosures, we may also share aggregated or de-identified information that cannot reasonably be used by those third parties to identify you.

5. YOUR CALIFORNIA PRIVACY RIGHTS

Consumers residing in California are afforded certain additional rights with respect to their personal information under the California Consumer Privacy Act of 2018 (“CCPA”) (California Civil Code Section 1798.100 et seq.) and the “Shine the Light” Law (California Civil Code Section 1798.83). If you are a California resident, this section applies to you.

Description of Your Privacy-Related Rights
If you are a California resident who meets the CCPA’s definition of “Consumer,” you are entitled to the following rights:

Right to Know and Access: You have the right to request that we provide certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Right to Know, Access, and Delete below), we will disclose to you:

• The categories of personal information we have collected about you.
• The specific pieces of personal information we collected about you (also called a data portability request).
• The categories of sources from which we collected your personal information.
• The categories of third parties with whom we shared your personal information, including:
• If we disclosed your personal information for a business purpose, which categories of your personal information we disclosed to which categories of recipients, and
• If we sold your personal information, which categories of your personal information we sold to which categories of recipients.
• Our business or commercial purpose for collecting or selling that personal information.

Right to Request Deletion: You have the right to request that we delete any personal information we have collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

Right to Opt-Out of Sale of Your Personal Information: We do not sell your personal information.

Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA rights. Unless otherwise 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 a different price or rate for goods or services or a different level or quality of goods or services

because you request to know, access, or delete your information or opt out of its sale.

How To Exercise Your Rights to Know, Access, and Request Deletion
To exercise your right to know, access, or delete as described above, you may submit a request to us by either:
• Completing the webform located at https://firstmile.com/ccpa/
• Calling us toll-free at 1-866-847-0674.

You may not make a request to know or access your information under CCPA more than twice within a 12-month period.

Your request must be verifiable. In order for us to verify your identity, we will need to match particular information that you provide in your request with data that we maintain and have determined to be reliable for the purposes of verification. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. If your request is to know or access specific pieces of personal information, you will be required to sign a declaration under penalty of perjury that the you are the consumer whose personal information is the subject of the request.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. We may require any agent making a request on your behalf to provide a written permission from you to submit a request on your behalf and to verify their identity and authorization to do business in California, or demonstrate that he or she has power of attorney in connection with your request to know, access or delete your personal information.

For transparency, metrics on the consumer requests we received and acted upon in the previous year are shown below, regardless of whether we met the CCPA’s threshold requiring disclosure of such metrics for that year:

*Regarding requests designated as “Denied,” such category is comprised of requests that, by law, we could not grant or were not required to act upon, such as when the identity of the requester could not be verified, the request was not made by a consumer, the requester asked for an exempted action or information that was prohibited from disclosure, or the request was duplicative or excessive

6. ADDITIONAL NOTICES

Shine the Light
California law permits residents of California to request certain details about how their information is shared with third parties for direct marketing purposes. We do not share your information with third parties for their direct marketing purposes.

Do Not Track Disclosure
FirstMile does not currently take actions to respond to Do Not Track signals because a uniform technological standard has not yet been developed. We continue to monitor and review new technologies and will modify this policy accordingly in the event of a change.

Notice regarding information of minors
This Site and any related services are intended for adults over 16 years of age, and we do not knowingly collect or sell personal information of minors under 16 years of age without affirmative authorization or without affirmative, verifiable consent from a parent for those under age 13.

7. RETENTION

We may retain information about you for as long as it is necessary to fulfill the purposes described Section 3. Some of your information may be retained in our systems even after you request your information to be deleted in accordance with purposes permitted under applicable privacy laws, such as in order to comply with our obligations under law, collect fees owed, resolve disputes, enforce our legal rights, otherwise use internally in a lawful manner that is reasonably aligned with the expectations of the consumer or compatible with the context in which the information was provided, and to undertake any investigations necessitated by the foregoing.

8. INFORMATION SECURITY

We have implemented technical and organizational measures to provide a level of security appropriate to the risk to the Personal Information that we process. These measures are aimed at preserving the ongoing integrity and protecting the confidentiality of users’ Personal Information. We evaluate these measures on a regular basis to confirm that they continue to maintain and apply an appropriate level of security.

9. CHANGES TO THE PRIVACY POLICY

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of the policy and, in some cases, we may provide you with additional notice (such as adding a statement to our website homepage). We encourage you to review the Privacy Policy whenever you access the Site or otherwise interact with us to stay informed about our information practices and the choices available to you.

10. CONTACT US

If you have any questions about this Privacy Policy, please contact us at:
International Fulfillment Solutions, LLC
2080 Industrial Rd C
Salt Lake City, Uta 84104, U.S.A
Email: info@firstmile.com
Tel: 866-847-0674