Privacy Policy

Customer privacy is important to FirstMile. While we go to great lengths to protect our customer's privacy, we are not responsible for any personal information that you may provide to third-party vendors or applications.

Last Updated: January 1, 2020

CONTENTS


1. WHAT THIS PRIVACY POLICY COVERS

This Privacy Policy explains how International Fulfillment Solutions, LLC dba FirstMile (“FirstMile,” “we” or “us”) collects, uses, and discloses information about businesses that use our fulfillment and warehouse distribution services (collectively referred to as “Services”) or access or use our website located at https://www.firstmile.com (collectively, the “Site”). FirstMile is part of the Rakuten Group, which includes the affiliates and subsidiaries of our parent company, Rakuten, Inc., based in Tokyo, Japan.

This Privacy Policy applies to all users of our websites, apps, features, or other services anywhere in the world. This Privacy Policy specifically applies to visitors to the Site, our business clients and partners who use our services (“Clients”). Our use the Services to provide order fulfillment and distribution to their end users and customers (“Client Customers”). We describe what information we receive from Clients about Client Customers in Section 2(A)(2) below.

2. COLLECTION OF INFORMATION
A. Information You Provide to Us
1. Our Clients

We collect information from our Clients to provide them with our Services.

We collect information you provide directly to us as our Client. For example, we collect information from you when you:

  • Utilize any of our Services (e.g., client information, including name, postal address, telephone number, email address, and company name). In addition, we may collect your customer information if you provide it to us directly to enable us to provide you with Services;
  • Create an account through our online portal on the Site (“Account”) in order to receive our Services. We may collect information in association with your use of our Services, such as standard information relating to your information requests, and any customer service requests and notes or details explaining what you asked for and how we responded.
  • Send us a message through the Site, request a quote from us, fill out a form or enter information through the Site, or otherwise communicate with us. We may collect information such as your name, telephone number, postal address, email address, and any other information you choose to provide; or
  • Provide us with any other information in order for us to deliver our Services.
2. Our Client Customers

We refer to the information we receive from our Clients about their Client Customers in the course of us providing Services to Clients as “Client Customer Information.” We receive Client Customer Information from Clients to facilitate the processing of Client Customer orders by Clients. Client Customer Information we receive from Clients may include name, email address, mailing address, telephone number, order details and other information needed to facilitate the shipment of orders. This Privacy Policy does not apply to any information beyond the Client Customer Information furnished to us by a Client to allow us to support the Client’s fulfillment and distribution orders place by a Client Customer (“Client Services”). We are acting on behalf of the Clients, and we are not responsible for our Clients’ handling of information related to Client Services. Our Clients have their own policies regarding the collection, use and disclosure of Client Customers’ personal information. To learn about how a Client handles Client Customers’ personal information, we encourage you to read the Client’s privacy statement. Our use of Client Customer Information provided by our Clients in connection with our Services is subject to the written agreement between us and Clients.

B. Automatically Collected Information and Other Information We Collect When You Use Our Site

When you access or use our Site, we automatically collect information about you, including:

  • Log Information: We collect information related to your access to and use of the Site, including the type of browser you use, app version, access times, pages viewed, your IP address, and the page you visited before navigating to our Site.
  • Device Information: We collect information about the computer or mobile device you use to access our Site, including the hardware model, operating system and version, unique device identifiers, and mobile network information.
  • Information Collected by Cookies and Similar Tracking Technologies: We (and our service providers) use different technologies to collect information, including cookies and web beacons. Cookies are small data files stored on your hard drive or in device memory that help us improve our Site and your experience, see which areas and features of our Site are popular, count visits and times visited, see what products and services are displayed and searched, and collect server log information other than the above. Web beacons (also known as “pixel tags” or “clear GIFs”) are electronic images that may be used in our Site or emails and help deliver cookies, count visits, and understand usage and campaign effectiveness. For more information about cookies and how to disable them, see Section 8(B) below.
3. USE OF INFORMATION

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

A. To Provide Our Services

We use your information to improve and optimize the user experience, operation and performance of our Services, and to manage and maintain your Account. We use Client Customer Information to facilitate our Clients’ provision of Client Services to Client Customers. For example, we use Client Customer Information (e.g. name and address) to support the fulfillment and shipment of orders.

B. To Communicate with Clients

If you are a Clients, we may contact you directly or through our partner service providers regarding our Services in order to deliver transactional or service-related communications. We use your information in order to respond appropriately to your inquiries, complaints, or requests in relation to the Site or our Services. Further, we may use your email address to communicate service-related messages to you, such as changes to this Privacy Policy, system updates or any updates on terms of use applicable to the Site or your Account.

C. Marketing

We may use your information to understand your preferences better and to appropriately personalize the marketing messages we send to Clients. We may also use your information to send marketing communications about the Services and other products, services, and information that may be of interest to Clients. See Section 8(C) below for more information about how to opt-out of these communications at any time.

D. For Customer Service

We may use your information in order to respond appropriately to your inquiries, complaints, or requests in relation to the Site or our Services. Further, if you are acting as a Client, we may use your email address to communicate service-related messages to you, such as changes to this Privacy Policy, system updates or any updates on terms of use applicable to the Site or your Account.

E. For Site Improvement

We may use your information for our everyday business operations such as auditing, administration of the Site, and analytics. Your information may also be used to improve the content and/or functionality of the Site.

F. For Research, Development, and Analytics

We may use your information for business purposes including providing analytic services and for other strategic purposes.

G. To Prevent or Mitigate Fraudulent or Illegal Activities

We may use your information to prevent, identify, and investigate scams, cyber-attacks, and other potentially illegal or fraudulent activities, or in relation to any other activities necessary to protect the legal rights of FirstMile and/or the rights of third parties.

H. Exercising or Defending Legal Claims

We may use your personal information to exercise our legal rights or defend against legal claims, for example, to detect, prevent and respond to fraud claims, intellectual property infringement claims or violations of law or our terms and conditions.

I. For Other Business Purposes

We may use your information for any other purpose disclosed to you at the time we collect or receive the information, or otherwise with your consent.

4. SHARING OF INFORMATION

We may share information about you as follows or as otherwise described in this Privacy Policy.

A. With Our Subsidiaries and Affiliates

We may share information about you with our subsidiaries and affiliates or other FirstMile related entities in order to perform analytics, for strategic purposes, or to provide other services.

B. With Our Vendors

We disclose your personal information with vendors, service providers, and third parties that perform services for us, including business operation related services such as providing us with shipping services, order tracking services, and IT services.

C. To Comply with Law

In response to a 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.

D. To Protect FirstMile or Others

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.

E. In Connection with a Business Transaction

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 takes on the role of centrally collecting, using or disclosing personal information in accordance with this Privacy Policy, that subsidiary or affiliate will handle your information in accordance with this Privacy Policy in place of FirstMile.

F. With Your Consent or at Your Direction

We may share your information when authorized by you or to provide you with a service you have requested.

With our Clients

We only share Client Customer Information with the Client that furnished or made such information available to us to provide Services to that Client or as otherwise directed by that Client.

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. LINKS TO THIRD PARTY SITES

Our Site may contain links to other web sites, including but not limited to affiliated web sites. Other web sites which are not controlled by FirstMile may reference or link to our Site. We encourage you to review the privacy policies of every web site that you visit that our Site may link to or that may link to our Site. We are not responsible for the privacy practices or content of such other web sites or mobile applications.

6. ADVERTISING AND ANALYTICS SERVICES PROVIDED BY OTHERS

We may allow others to provide analytics services and serve advertisements on our behalf across the web and on the Site. These entities may use cookies, web beacons, device identifiers and other technologies to collect information about your use of the Site and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages, links clicked, and conversion information. This information may be used by FirstMile and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Site and other websites, and better understand your online activity. For more information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit www.aboutads.info/choices.

7. YOUR PRIVACY RIGHTS

You have the right to privacy in line with the local laws that applies to you. For example, consumers residing in California are afforded certain additional rights with respect to their personal information under the California Consumer Privacy Act or (“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.

A. Additional Disclosures Related to the Collection, Use, Disclosure, and Sale of Personal Information

The following table summarizes our personal information collection, use, and sharing practices in the preceding 12 months since we last updated this Privacy Policy on January 1, 2020.

<Site Visitors or Clients>
Category of Personal Information Sources of Personal Information Why We Collect Personal Information? Who We Share Personal Information With? Did We Disclose the Personal Information for a Business or Commercial Purpose? Did We Sell the Personal Information?
Identifiers, e.g., email address, account information, name, address or phone number The sources stated in Section 2, including:
• Our Clients
The purposes stated in Section 3, including:
• Providing our services
• Communicating with you
• Providing customer service
The entities stated in Section 4, including:
• Our subsidiaries and affiliates
• Vendors, and service providers, and third parties that perform services for us
Yes No
Internet or Other Electronic Network Activity Information, such as domain information, pages visited, cookie information, session information such as time spent on certain pages and page interaction information The sources stated in Section 2, including:
• You, your mobile device or
• Our Clients
The purposes stated in Section 3, including:
• Providing our services
• Communicating with you
• Providing customer service
The entities stated in Section 4, including:
• Our subsidiaries and affiliates
• Vendors, and service providers, and third parties that perform services for us
Yes No
Information under California Civil Code 1798.80, e.g. payment information, phone number, email address The sources stated in Section 2, including:
• Our Clients
The purposes stated in Section 3, including:
• Providing our Services
The entities stated in Section 4, including:
• Our subsidiaries and affiliates
Yes No
Commercial information, such as records of services obtained or considered The sources stated in Section 2, including:
• Our Clients
The purposes stated in Section 3, including:
• Providing our Services
• Providing customer service
The entities stated in Section 4, including:
• Our subsidiaries and affiliates
• Vendors, and service providers, and third parties that perform services for us
Yes No
<Client Customers>
Category of Personal Information Sources of Personal Information Why We Collect Personal Information? Who We Share Personal Information With? Did We Disclose the Personal Information for a Business or Commercial Purpose? Did We Sell the Personal Information?
Identifiers, such as name and address.  The sources stated in Section 2, including:
• Our Clients
The purposes stated in Section 3, including:
• Providing the Service
• Other purposes as instructed by our Clients 
The entities stated in Section 4, including:
• Vendors, and service providers, and third parties that perform services for us
Yes No
Commercial information such as your order details.  The sources stated in Section 2, including:
• Our Clients 
The purposes stated in Section 3, including:
• Providing the Service
• Improving the Service
• Research, development and analytics
• Other purposes as instructed by our Clients 
The entities stated in Section 4, including:
• Vendors, and service providers, and third parties that perform services for us 
Yes No
B. Your Privacy-Related Rights

This Section lists the privacy-related rights (“Rights”) that California users have under the CCPA regarding their personal information. This Section describes your Rights and how to exercise those Rights.

Right to Know and Access: You 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. 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 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 data portability request)
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
    • sales, identifying the personal information categories that each category of recipient purchased; and
    • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
C. How To Exercise Your Right 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:

You may only make a request to know or access twice within a 12-month period.

Your request must be verifiable. In order for us to verify your identity, we will match two or three data points that you provide with data points that we maintain and have determined to be reliable for the purposes of verification. 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.

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

D. Authorized Agent

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 the agent to provide a written permission from you to submit a request on your behalf and to verify their identity, or demonstrate that he or she has power of attorney in connection with a request to know, access or delete.

E. 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 direct marketing purposes.

F. California Do Not Track Disclosure

California Business & Professions Code Section 22575(b) (as amended effective January 1, 2014) provides that California residents are entitled to know how FirstMile responds to “Do Not Track” browser settings. 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 review new technologies and may adopt a standard once one is created.

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 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 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.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
8. YOUR CHOICES
A. Account Information

You may update and correct certain Account information you provide to us at any time by logging into your account or emailing us, or [insert any other methods available to users]. If you wish to [delete or deactivate] your Account, [please email us at [insert email address]] [or describe other method, such as through settings on the Site], but note that we may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of information about you for a certain period of time.

B. Cookies

Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Site.

C. Communications with FirstMile

If you no longer wish to receive emails you may click on the hyperlink titled “Unsubscribe” at the bottom of any marketing related email sent to you by FirstMile, and then follow the directions to unsubscribe from email, or you can modify your preferences in your Account settings located in the Site. Please note that if you opt out of receiving promotional communications from us, we may still send you transactional communications, including emails about your Account or the Services.

9. RETENTION

We may retain information about you for as long as it is necessary to fulfill the purposes described above in Section 3. Some of your information may be retained in our systems even after you request your information to be deleted in order to comply with our obligations under applicable 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.

10. 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 it continues to maintain and apply an appropriate level of security.

11. 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 or sending you a notification). 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.

12. CONTACT US

If you have any questions about this Privacy Policy, please contact us at:

International Fulfillment Solutions, LLC dba FirstMile
2080 Industrial Rd C,
Salt Lake City, Uta 84104, U.S.A
Email: support@firstmile.com
Tel: 888-993-8594

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