Privacy Notice for Carriers

Please Read Carefully. 
Last updated:  May 1, 2023

At Onward Delivery Corp., (“Onward”, “Company”, “we”, “our” or “us”), we value your trust. We are committed to acting responsibly when we collect, use and protect your non-personal and personal information. 

We believe in being clear and open about how we collect data related to you when you visit our website at https://www.onwarddelivery.com (“Website”), download, access and/or use the mobile application named Onward Delivery (“App”), for solutions that provide moving, transportation and logistics providers (“you”, “your” or “Carriers”) for “Shippers” (persons that contract with Onward and/or you directly for the shipment of freight and goods) and “Consignees” (persons designated by the applicable Shipper to receive such freight and goods). Our Website and App allow you to accept and fulfill requests for transportation services from third-party shippers for the transportation of freight and household goods to Consignees and to use the order tracking, routing and delivery tools located within the Site and App to track and document deliveries (collectively, the “Onward Platform”). In addition to your use of the Onward Platform, this Privacy Notice (“Privacy Notice”) also applies to the information collected for the transportation brokerage services provided by Onward pursuant to an executed order form (“Order Form”) and the transportation services provided by you or your authorized representatives to Shippers and/or Consignees (collectively “Carrier Services”) and anytime we collect information when you interact with us, subscribe to our newsletter, participate in our surveys, advertisements or marketing emails, opt-in to receive SMS mobile messages or engage with any other websites, pages, features, or content we now and/or in the future operate and/or provide (collectively with the Website and App the “Services”) that direct you to this Privacy Notice. 

Federal and state laws say that we must tell you how we collect, share and protect your personal information. This Privacy Notice is designed to help you understand how we collect, use, share and safeguard the information you provide to us and to assist you in making informed decisions when using our Services. Please read this Privacy Notice very carefully.

By accessing and using the Services, you consent to our collection, storage, use and disclosure of your Personal Information as described in this Privacy Notice.  The Services are intended for users located in the United States only, and you hereby expressly acknowledge and agree that if you are accessing and/or using the Services that you reside in the United States and will only access and/or use the Services in the United States. The use of the Services is subject to the Terms of Service for Carriers located at https://www.onwarddelivery.com/terms-and-conditions.

Please click on the below links to go directly to that section of the Privacy Notice: 
1. Types Of Data We Collect
2. Children’s Online Privacy Protection Act (“COPPA”)
3. Information you Provide to Us
4. Collected via Technology
5. Use of Your Personal Information
6. Use of Non-Personal Information
7. How We Share Your Personal Information
8. Integrations and Third-Party Service Providers
9. Process Payments
10. Business Transfers
11. Other Disclosures
12. Links to Third Party Websites and Third-Party Providers
13. Your Rights Regarding the Use of Your Personal Information
14. Your Rights and Choices
15. Security of Your Personal Information and Personal Data
16. How we Retain Your Personal Information
17. Accessibility Changes to This Privacy Notice
18. Other JurisdictionsContact Information

1. Types of Data We Collect

We collect “Non-Personal Information” and “Personal Information” and the information we collect from you depends on how you use the Services. “Non-Personal Information” includes information that cannot be used to personally identify you, such as anonymous usage data, general demographic information we may collect, referring/exit pages and URLs, platform types, preferences you submit and preferences that are generated based on the data you submit and number of clicks. “Personal Information” means data that allows someone to identify or contact you, including, for example, your name, address, telephone number, email address, as well as any other non-public information about you that is associated with or linked to any of the foregoing data. In this Privacy Notice “Consignee” means the person or business to which you are shipping the goods through our Services. This includes: 

Context

Types of Data that we may process

Primary Purpose for Collection and Use Data

User Information

We collect your:
• first and last name and email address of our users if you schedule a chat with one of our representatives. 
• your email address and any other information that you include if you email us. 
• your first and last name if you call us.
• your first and last name and your email address if you choose to set up a Zoom call with us.

We have a legitimate interest in contacting our customers and communicating with them in relation to the Services.

Account Information

We collect your: 
• first and last name
• company address, phone number and email address
• Vehicle and registration information 
• Driver’s Driver License information
• Proof of coverage/insurance information for the vehicles that will be used to make the deliveries
• Form W-9  

if you download and set up an account through the Services.

We have a legitimate interest in contacting our customers and communicating with them in relation to the Services.

Your account information is needed for contractual obligations for transportation of goods through the Onward Platform pursuant to an applicable Order Form.

If you opt-in to receive text messages from us, we may send you a text message that contains promotional information that may be of interest to you. You can opt-out of receiving future text messages by replying "STOP."

Form W-9 is needed for invoicing purposes.

Cookies and First Party Tracking

We use Cookies and clear GIFs. “Cookies” are small pieces of information that a website sends to a computer’s hard drive while a website is viewed. 

We use first party Cookies to make the Services operate efficiently and to analyze Website performance for the purpose of improvement.  

You can enable, disable or delete Cookies via your browser settings. To do this, follow the instructions provided by your browser, usually located within the “Help”, “Tools” or “Edit” settings of your browser. Please be aware that if you set disable Cookies on your browser, you may not be able to access secure areas of the Services and parts of the Services may also not work properly (e.g., referral links, preferences, etc.).

The following links are provided for your convenience. Click on the relevant link below to access detailed information regarding Cookie settings. Should your browser not be listed here, you should review the help pages for your specific browser to see what features are offered for adjusting your Cookie settings:

• Microsoft Internet Explorer
Google
• Chrome
• 
Safari
• 
Firefox

If you use a different browser than those listed above, please refer to your specific browser’s documentation or check out http://www.allaboutcookies.org/browsers/index
.html
to learn more about different browsers. You can also find out more information about how to change your browser Cookie settings at www.allaboutcookies.org.

Note that if you disable, limit or delete cookies, the Services may not function properly, and this may prevent you from using our Services.

Cookies and Third-Party Tracking

We participate in behavior-based advertising, this means that a third party uses technology (i.e.: a cookie, pixel or ‘LAL’) to collect information about your use of Services so that they can provide advertising about products and services tailored to your interests.

Google Analytics is an analytics service provided by Google LLC. (US). You can learn more about Google Analytics here:
https://support.google.com/analytics/answer
/7318509?hl=en
https://policies.google.com/technologies
/partner-sites
https://support.google.com/analytics/ans
wer/6004245
 

You may opt-out of Google Analytics for display advertising or customize Google display network ads by managing your privacy controls on Google’s website. 

We have a legitimate interest in capturing Website and App analytics and engaging third parties to assist with providing Services to you.

Any Cookies that are placed on your browsing device by a third party can be managed through your browser (as described above) or by checking the third party’s website for more information about cookie management and how to “opt-out” of receiving cookies from them. You can learn more at the following third-party websites:

• AllAboutCookies: http://www.allaboutcookies.org/
• Network Advertising Initiative: http://www.networkadvertising.org/
• Wikipedia: https://en.wikipedia.org/wiki/HTTP_cookie

Deliveries to Carrier’s Consignee

When you use the Onward Platform to dispatch your own trucks, or track deliveries for your own Consignee, we collect:

• your Consignee’s name, company name if applicable, phone number, time frame availability for delivery and delivery address. 

Additional information about our privacy practices for Shippers can be found here. Terms of Service for Shippers can be found here.

This information is necessary to create and complete deliveries as requested by you.

This information is also necessary for the mutual fulfillment of contractual obligations.

Email Interconnectivity

If you receive email from us, we may use certain tools to capture data related to when you open our message, click on any links or banners it contains and make purchases.

We have a legitimate interest in understanding how you interact with our communications to you.

Feedback/Support

We collect Personal Information from you contained in any inquiry you submit to us regarding the Services, such as completing our online forms, calling or emailing for the purposes of general inquiries, support requests, or to report an issue.When you communicate with us over the phone, your calls may be recorded and analyzed for training, quality control and for sales and marketing purposes. During such calls we will notify you of the recording via either voice prompt or script and advise you of our privacy policies.

We have a legitimate interest in receiving, and acting upon, your feedback, issues, or inquiries.

E-mailing List

When you sign up for one of our e-mailing lists, we collect your first and last name, company name if applicable, and email address.

We share information about our products and
Services with individuals that consent to receive such information.  We also have a legitimate interest in sharing information about our products and Services.

Transactional Information

We collect transactional information, including information about the products and services you purchase or download or about which you make an inquiry.

We have a legitimate interest in our customers' transactional information to fulfill contractual obligations related to Services. We also have a legitimate interest in understanding your preferences and interests so we could select offerings that you might find most useful.

Mobile Devices

We collect information from your mobile device such as unique identifying information broadcast from your device when using the Services. 

We have a legitimate interest in identifying unique visitors, and in understanding how users interact with us on their mobile devices.

Website and App Interactions

We use technology to monitor how you interact with the Services. This may include: IP addresses, preferences, web pages you visited prior to using the Services, information about your browser, network or device (such as browser type and version, operating system, internet service provider, preference settings, unique device IDs and language and other regional settings), information about how you interact with the Services (such as timestamps, clicks, scrolling, browsing times, searches, transactions, referral pages, load times, and problems you may encounter, such as loading errors).

We have a legitimate interest in understanding how you interact with the Services to better improve the Services, and to understand your preferences and interests and to select offerings that you might find most useful.  We also have a legitimate interest in detecting and preventing fraud.

Logs

We collect information, including your browser type, operating system, Internet Protocol (“IP”) address (a number that is automatically assigned to a computer when the Internet is used), domain name, click-activity, referring website, and/or a date/time stamp for visitors.

We have a legitimate interest in monitoring networks and the visitors to our Website and App and access and use of the Services to provide the Services and enhance the Services.

Demographic Information

We collect Personal Information, including your location when you are using the Services.  

We have a legitimate interest in understanding our users and providing tailored Services.

Employment

If you apply for a job posting, or become an employee, we collect information necessary to process your application or to retain you as an employee.  This may include, among other things, your social security number.  Providing this information is required for employment.

We use information about current employees to perform our contract of employment, or the anticipation of a contract of employment.  In some contexts, we are also required by law to collect information about our employees.  We also have a legitimate interest in using your information to have efficient staffing and work force operations, and provide the Website and App to our customers.

Geolocation Information

When you use our Website or App, and Services we collect your location from the GPS, Wi-Fi, and/or cellular technology in your device to determine your location to better serve you.We also use real time tracking of users using the App for deliveries via the Onward Platform.  

We have a legitimate interest in understanding our users and providing tailored Services, which may include improving our marketing efforts.  In some contexts, our use is  based upon your consent to provide us with geo- location information. The tracking and documenting of the status of deliveries is also necessary to fulfil our contractual obligations and services to Shippers.

Surveys

When you participate in a survey available on the App, we collect information that you provide through the survey.  If the survey is provided by a third-party service provider, the third party’s privacy policy applies to the collection, use, and disclosure of your information.

We have a legitimate interest in understanding your opinions and collecting information relevant to our organization and the Services.If you opt-in to receive text messages from us, we may send you a survey that may be of interest to you. You can opt-out of receiving future text messages by replying "STOP."

2. Children’s Online Privacy Protection Act (“COPPA”)

Our Services are not designed for children under 13, and we do not intentionally or knowingly collect Personal Information from users who are under the age of 13 or from other websites or services directed at children. If we discover that a child under 13 has provided us with Personal Information, we will delete such information.

3. Information You Provide to Us

• 
We collect the name of Carrier’s company, its headquarters’ and/or billing address, if applicable, and information about the vehicle that is used to make the deliveries.

• We collect Personal Information from you such as carrier driver’s first and last name, e-mail address, contact phone number, Driver License, proof of coverage/insurance for the vehicle that will be used to make the delivery, username and password when you choose to set up an account through the Services.

• We use real time tracking of users using the App for deliveries via the Onward Platform. We also collect your consignee’s name and delivery address, and if applicable warehouse information, if you use the Onward Platform to dispatch your own trucks, or track deliveries.

We may also collect proof of worker’s compensation insurance; proof of general liability insurance; and auto related information.

• When you engage us to provide Services, our payment processor will collect all information necessary to complete the transaction, including your name, credit card information, billing information, and if applicable, direct deposit/ ACH information.

• If you provide us feedback or contact us via email, we may collect your name, if stated, and email address, as well as any other content included in the email, in order to send you a reply. 

• When you or the Consignee participate in one of our surveys, we may collect additional information that you knowingly provide. 

• We will maintain the information you send via email in accordance with applicable federal law. Please do not include sensitive information in your email communications to us.

• In compliance with the CAN-SPAM Act, all emails sent from our organization will clearly state who the email is from and provide clear information on how to contact the sender. In addition, all email messages will also contain concise information on how to remove yourself from our mailing list so that you receive no further e-mail communication from us. 

4. Collected via Technology

• 
In an effort to improve the quality of the Services, we reserve the right to track information provided to us by your browser or by our software application when you view or use the Services, such as the website you came from (known as the “referring URL”), the type of browser you use, the device from which you connected to the Services, the time and date of access, and other information that does not personally identify you. We track this information using Cookies. Cookies are sent to a user’s browser from our servers and are stored on the user’s computer hard drive or mobile device. Sending a Cookie to a user’s browser enables us to collect Non-Personal information about that user and keep a record of the user’s preferences when utilizing our Services, both on an individual and aggregate basis.

“Cookies” are small data files that are placed on your computer or mobile device when you visit a website. Cookies are widely used by website owners in order to make their websites function, to work more efficiently, as well as to provide reporting information.

We use both first-party and third-party cookies on our Services. First-party Cookies are Cookies that are placed on your device by us, while third-party Cookies are set by parties other than Onward. Third-Party Cookies enable third party features or functionality to be provided on or through the Services (for example advertising, interactive content, interaction with social media sites, and analytics). The parties that set these third-party Cookies can recognize your computer or mobile device both when you visit the Services, and also when you visit certain other websites. Onward does not control how third-party Cookies are used, and we encourage you to check the websites of any third-party Cookie providers for more information about how they use cookie information.

Generally, information collected by Cookies and other tracking technologies does not constitute Personal Information as defined by the General Data Protection Regulation and other applicable privacy laws. However, if exceptionally such collected information does constitute Personal Information (such as ‘IP’ addresses or similar identifiers), we will treat it as Personal Information in accordance with the Privacy Notice.

Our retention periods for Cookie information depend on whether the Cookie is a “persistent” or “session” Cookie.

We use “persistent Cookies” to save information about you for longer periods of time, while “session” Cookies are deleted when you close your browser or after a short period of time. Persistent Cookies are stored for varied lengths of time depending on the purpose of the Cookie collection and tool used. You can delete Cookie data as described herein. 

• We may also use third party analytics services such as Google Analytics to collect information about how you use and interact with our Services. Such third-party analytics services may use Cookies to gather information such as the pages you visited, your IP address, a date/time stamp for your visit and which website referred you to the Website or App.

Google Analytics is an analytics service provided by Google LLC. (US). To learn more about Google Analytics, please click on the links below.
https://support.google.com/analytics/answer/7318509?hl=en
https://policies.google.com/technologies/partner-sites
https://support.google.com/analytics/answer/6004245

You may opt-out of Google Analytics for display advertising or customize Google display network ads by managing your privacy controls on Google's website.

• Our Website and App use social media connectors. They are social media buttons, such as Facebook, Instagram, Twitter and LinkedIn, you see on our Website and App or blog posts that allow you to connect and learn more about us and interact with us, our users and marketing partners. We reserve the right to use technological equivalents of Cookies, including social media pixels. These pixels allow social media sites to track visitors to outside websites so as to tailor advertising messages users see while visiting that social media website. We reserve the right to use these pixels in compliance with the policies of the various social media sites. 

These social media third-party providers may combine your information with other information they have about you. The Personal Information that is shared with them will be governed by the third-party provider’s privacy policy and will apply to any Personal Information Onward may access through the third-party provider.

• Some content or applications on the Services are served by third parties, including advertisers, ad networks, “Chat with a Rep” service, servers, content providers, and application providers. These third parties may use Cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Services. The information they collect may be associated with your Personal Information or they may collect information, including Personal Information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. We do not control these third parties' tracking technologies or how they may be used and we are not liable for any third party providers, acts or omissions. If you have any questions about an advertisement or other targeted content, you should contact the third party provider directly.

• We do not control interest-based advertising Cookies on the Services. However, many advertising companies that collect information for interest-based advertising are members of the Digital Advertising Alliance (“DAA”) or the Network Advertising Initiative (“NAI”), both of which maintain websites where people can opt out of interest-based advertising from their members.

To opt-out of website interest-based advertising provided by each organization’s respective participating companies, visit the DAA’s opt-out portal available at http://optout.aboutads.info/ or visit the NAI’s opt-out portal available at http://optout.networkadvertising.org/?c=1

5. Use of Your Personal Information

In general, Personal Information you submit to us is used either to respond to requests that you make, or to aid us in serving you better. We use your Personal Information in the following ways: 

• to facilitate the creation of and secure your account;
• to provide you Services as you requested;
• to provider Shippers with shipping and delivery related services;
• to identify you as a user in our system;to establish an account on the Website and/or App; 
• to provide improved administration of the Services;
• to improve the quality of experience when you interact with the Services;to send you administrative email notifications, such as security or support and maintenance advisories;
• to respond to your inquiries related to employment opportunities or other requests;
• to periodically send newsletters, surveys, offers, and other promotional materials related to our Services and for other marketing purposes including those of third parties; 
• to perform marketing or data analysis; to comply with legal obligations, as part of our general business operations, and for other business administration purposes; and
• in very limited circumstances where we believe necessary to investigate, prevent or act regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person or violations of this Privacy Notice.

6. Use of Non-Personal Information

In general, we use Non-Personal Information to help us improve the Services and customize the user experience. We also aggregate Non-Personal Information in order to track trends and analyze use patterns on the Services. This Privacy Notice does not limit in any way our use or disclosure of Non-Personal Information and we reserve the right to use and disclose such Non-Personal Information to our partners, advertisers and other third parties at our discretion.

7. How We Share Your Personal Information

As a general rule, we do not sell, rent, lease or otherwise transfer any information collected either automatically or through your voluntary action. We may disclose your Personal Information as described below and as described elsewhere in this Privacy Notice. 

8. Integrations and Third-Party Service Providers

We integrate third-party products and Application Programming Interface (“API”) in connection with the Services that we offer. User data collected via the API is subject to the privacy policies of those third parties and Onward does not own or control those third parties.  

We may also share your Personal Information with third party service providers to provide you with the Services that we offer you; for hosting of the Website and App; for data warehouse purposes; for SMS and email communication; for delivery and routing services; to conduct quality assurance testing; to perform marketing; to run data analysis; to facilitate creation of accounts; to provide technical support; and/or to provide future services to you.

9. Process Payments

We transmit your Personal Information via an encrypted connection to our payment processor, Stripe. To learn more about the payment processor we use and their policies related to privacy, learn more at https://stripe.com/privacy

10. Business Transfers

If (i) Onward is acquired by, merges with, or receives investment from another company or (ii) if any of Onward’s assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may transfer the information we have collected from you to the other company. As part of the business transfer process, we may share certain of your Personal Information with lenders, auditors, attorneys and consultants.

11. Other Disclosures

Regardless of any choices you make regarding your Personal Information (as described below), we may disclose Personal Information if it believes in good faith that such disclosure is necessary (a) in connection with any legal investigation; (b) to comply with relevant laws or to respond to subpoenas or warrants served on us; (c) to protect or defend our rights or property, or the rights or property of users of the Services; (d) to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person and/or (e) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Notice, or any agreements you may have with us, as applicable.

13. Your Rights Regarding the Use of Your Personal Information

We may send periodic promotional emails to you. You have the right at any time to prevent us from contacting you for marketing purposes. When we send a promotional communication to a user, the user can opt out of further promotional communications by following the unsubscribe instructions provided in each promotional email. If applicable, you can also indicate that you do not wish to receive marketing communications from us in the “Notifications” section of your Account. Please note that notwithstanding the promotional preferences you indicate by either unsubscribing or opting out in the Notification section of your Account, we may continue to send you administrative emails including, for example, periodic updates to our Privacy Notice. You may unsubscribe to promotional emails by following the opt-out instructions contained in the email. If you unsubscribe from receiving promotional emails, we may still send you emails about the Services.

14. Your Rights and Choices

If applicable privacy laws allow, you may have rights over your Personal Information. This includes, but is not limited to:

Right to Know. You have the right to request disclosure about our Personal Information collection practices during the prior 12 months, including the categories of Personal Information we collected, the sources of the information, our business purposes for collecting or sharing the information and the categories of third parties with whom we shared such information. You may request a copy of the specific pieces of Personal Information we may have collected about you in the last 12 months.

Right to Delete.  You may request that we delete (and direct our service providers to delete) your Personal Information, subject to certain exceptions.

Right to Opt-Out.  You have the right to opt-out of any ‘sales’ of your Personal Information, if a business is selling your information. For clarity, we do not sell your Personal Information. If, in the future, we enter into arrangements that fall within the definition of a ‘sale’ under applicable privacy and data protection laws, we will update this Privacy Notice.

Non-Discrimination. You have the right to not be discriminated against for exercising these rights.

You can make the following choices regarding your Personal Information:

1. Access To Your Personal Information. You may request access to your Personal Information by contacting us at the address below. If required by law, upon request, we will grant you reasonable access to the Personal Information that we have about you.  We will provide this information in a portable format, if required.  Note that California residents may be entitled to ask us for a notice describing what categories of Personal Information (if any) we share with third parties or affiliates for direct marketing.  

2. Changes To Your Personal Information. We rely on you to update and correct your Personal Information. Please contact us at the address below immediately if there are any changes to your Personal Information. Note that we may keep historical information in our backup files as permitted by law.  

3. Deletion Of Your Personal Information.  Typically, we retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Notice, unless a longer retention period is required or permitted by law, or as otherwise described in this Privacy Notice. You may, however, request information about how long we keep a specific type of information, or request that we delete your Personal Information by contacting us at the address below. If required by law we will grant a request to delete information, but you should note that in many situations we must keep your Personal Information to comply with our legal obligations, resolve disputes, enforce our agreements, or for another one of our business purposes.  

If you decide to delete your in-App account, you may do so by selecting “Delete My Account” on your profile page. Deleting your Onward account in-App will:
1. Sign you out immediately
2. Remove or anonymize any identifiable user information
3. Remove your email from our mailing lists.

You will receive an email when account deletion is completed.

4. Objection to Certain Processing.  You may object to our use or disclosure of your Personal Information by contacting us at the address below.  

5. Online Tracking.  We do not currently recognize automated browser signals regarding tracking mechanisms, which may include ‘Do Not Track’ instructions. 

6. Promotional Emails. You may choose to provide us with your email address for the purpose of allowing us to send free newsletters, surveys, offers, and other promotional materials to you, as well as targeted offers from third parties.  You can stop receiving promotional emails by following the unsubscribe instructions in e-mails that you receive.  If you decide not to receive promotional emails, we may still send you communications related to your use of the Services and administrative purposes for reasons such as providing you with updates to this Privacy Notice.

7. Revocation Of Consent. If you revoke your consent for the processing of Personal Information, you should not access the Services. In some cases, we may limit or deny your request to revoke consent if the law permits or requires us to do so, or if we are unable to adequately verify your identity. You may revoke consent to processing (where such processing is based upon consent) by contacting us at the address below.

15. Security of Your Personal Information and Personal Data

We implement security measures designed to protect your information from unauthorized access, alteration, disclosure and/or destruction. Because the internet is not a completely secure environment, we cannot warrant the security of any information a user transmits to us or guarantee that information on the Services may not be accessed, disclosed, altered, and/or destroyed by breach of any of our physical, technical and/or managerial safeguards. Any account you have on our Website or App is protected by your account password and we urge you to take steps to keep your Personal Information safe by not disclosing your password and by logging out of your account after each use. We further protect your information from potential security breaches by implementing certain technological security measures; however, these measures do not guarantee that your information will not be accessed, disclosed, altered or destroyed by breach of such firewalls and secure server software. While we use reasonable efforts to protect your Personal Information, we cannot guarantee the Services are absolutely secure.

16. How we Retain Your Personal Information

We will retain your Personal Information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. The precise periods for which we keep your Personal Information vary depending on the nature of the information and why we need it. To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use and/or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements.  

In some circumstances we may anonymize your Personal Information (so that it can no longer be associated with a user) for research or statistical purposes in which case we may use this information indefinitely without further notice.  We may retain information (including without limitation your personally identifiable information) for a commercially reasonable time for backup, archival, audit purposes, and/or to comply with legal obligations, resolve disputes and enforce agreements. In some cases, if you choose not to provide us with requested information, you may not be able to use the Services. You can request further details of retention periods for different aspects of your Personal Information by contacting us. 

Please note that in the course of providing the Services, we collect and maintain aggregated, anonymized, or de-personalized information which we may retain indefinitely.

17. Accessibility

If you are visually impaired, you may access this Privacy Notice through your browser’s audio reader.

18. Changes to This Privacy Notice

We reserve the right to change this Privacy Notice or any agreement you entered into with Onward from time to time. We will notify you of significant changes to this Privacy Notice by placing a prominent notice on the Website and App.Significant changes will go into effect thirty (30) days following such notification. Non-material changes or clarifications will take effect immediately. You should periodically check the Website and/or App and this Privacy Notice for updates.

19. Other Jurisdictions

Onward is located in the United States. The Services are hosted in, provided from the United States, and intended for those that reside in the United States.  Personal information that you submit through the Services may be transferred outside of the jurisdiction in which you live.  We also store Personal Information locally on the devices you use to access the Services. Your Personal Information may be transferred to other jurisdictions that do not have the same data protection laws as the jurisdiction in which you initially provided the information. The following provisions may apply to you depending on where you are located.

Nevada.  This notice is provided to you pursuant to state law. Nevada state privacy laws permit us to make marketing calls to existing users, but if you prefer not to receive marketing calls, you may be placed on our internal opt-out list by emailing us at privacy@onwarddelivery.com privacy@onwarddelivery.com or you may also contact the Nevada Bureau of Consumer Protection, Office of the Nevada Attorney General, 555 E. Washington St., Ste 3900, Las Vegas, NV 89101; telephone 702-486-3132; email: AGCinfo@ag.nv.gov.

Vermont. In accordance with Vermont law, we will not share information we collect about you with companies outside of Onward except as described herein, or otherwise required or permitted by law.

Virginia. This Section is only applicable to you if you are a resident of the state of Virginia (“Virginia Residents”).  If you have a complaint, first contact us at privacy@onwarddelivery.com.  We will respond within 45 days after receipt of your request, and such time may be extended for an additional 45 days if it is reasonably necessary.  We will notify you of any extension within the initial 45-day period. If you are not satisfied with our responses, you have the right to appeal.  We will respond within 60 days of receipt of your appeal.  If you still have an unresolved complaint, please direct your complaint to the Virginia Attorney General at service@oag.state.va.us or call (804)786-2071.

California. At this time, California Privacy laws (California Consumer Privacy Act, California Privacy Rights Act) do not apply to us, but we will still protect your Personal Information as outlined in this Privacy Notice. If you feel this is incorrect, please contact us at privacy@onwarddelivery.com.

20. Contact Information

If you have any questions, comments, or complaints concerning our privacy practices, please contact us by sending an email to privacy@onwarddelivery.com or send correspondence via mail to:

Onward Delivery Corporation
4350 Kearney ST SE A
Denver, CO 80216 

We will attempt to respond to your request and to provide you with additional privacy-related information.