When We Disclose Your Personal Information
Except with your consent, we will not sell, license, trade or rent your Personal Information to or with third parties.
- Public Comments and Posts. Any information that you post in publicly accessible areas of the sites might be read, collected, and used by others who access it. To request removal of such Personal Information from our sites, contact us at email@example.com. We will make commercially reasonable efforts to remove your Personal Information from our sites, and will let you know if we are unable to do so and why.
- Service Providers. We may share information about you with third-party vendors, consultants and other service providers (data processors) who use this information to perform services for us, such as payment processors, hosting providers, auditors, advisors, consultants, customer service and support providers. We obtain appropriate contractual and technical protections to limit these service providers’ use and disclosure of any information about you that we share with them.
- As Required by Law. We release information about you if we believe we must do so to comply with the law or a subpoena, bankruptcy proceeding, or similar legal process.
- To Protect Rights. We may disclose information where we believe it necessary to respond to claims asserted against us or, comply with legal process (e.g., subpoenas or warrants), enforce or administer our agreements and terms, for fraud prevention, risk assessment, investigation, and protect the rights, property or safety of GHY, you, or others.
- Business Transfers. If GHY is involved in a merger, acquisition, or sale of all or a portion of its assets, we may disclose or transfer information, including Personal Information, as part of any merger, sale, and transfer of our assets, acquisition or restructuring of all or part of our business, bankruptcy, or similar event, in order for you to continue to receive the same products and services from the third party in accordance with applicable law.
- Aggregate and Anonymized Information. We may share aggregate or anonymized information about users with third parties for marketing, advertising, research or similar purposes provided such information does not identify a particular individual. For example, if we display advertisements on behalf of a third party, we may share aggregate, demographic information with that third party about the users to whom we displayed the advertisements.
Transfers of Your Personal Information
If we transfer your Personal Information or make it accessible to other GHY affiliates or to third-party service providers located outside Europe or the European Economic Area (“EEA”), including but not limited to, the United States, India, China, Mexico and Brazil, that may not provide adequate levels of data protection as your home country, we will take certain reasonable steps to ensure that your Personal Information receives the same level of protection as if it remained within the EU. Such steps may include entering into data transfer agreements using the European Commission approved Standard Contractual Clauses, or relying on certification schemes such as the EU – US Privacy Shield. For transfers of Personal Information among GHY affiliates, the transfers will be subject to the European Commission-approved Standard Contractual Clauses, or a similar adequate mechanism. You have the right to obtain details of the mechanism under which your Personal Information is transferred outside of the EU/EEA by contacting firstname.lastname@example.org.
In addition, GHY may share any information that you provide to us which is not deemed Personal Information or is not otherwise subject to contractual restrictions.
Your Choices and Rights
Subject to applicable laws, you have the right to access, correct or request the deletion of your Personal Information at any time. In certain circumstances, you may have the right to object to the processing of your Personal Information. In such case, please contact email@example.com.
- Content. Requests to access, delete, or modify content will be directed to the client who owns the account. If you wish to request access to Personal Information contained in content to delete, modify or limit use, please provide us with the name of the client who submitted your information to our Services. We will refer your request to that client, and will support them as needed.
- Access and Correction. You can help us maintain the accuracy of your Personal Information by notifying us of any changes to this information. You may contact GHY in any one of the ways described below to request access to or correct or update of your Personal Information.
- Direct Marketing Choices. Clients can always opt-out of being contacted by us for direct marketing or promotional purposes by following the opt-out instructions located in the e-mails we send. Please note that if you opt-out of marketing communications, GHY will continue to send you transactional or service-related communications, such as service announcements and administrative messages.
- Complaints. We will take steps to try to resolve any complaint you raise regarding our treatment of your Personal Information. You also have the right to raise a complaint with the privacy regulator in your jurisdiction.
Additional Information for Individuals from the EU/EEA. Individuals in the EEA may have one or more of the following rights with respect to their Personal Information:
- Rectification. You can ask us to rectify inaccurate Information. We may seek to verify the accuracy of the information before rectifying it.
- Erasure. You can ask us to erase your Personal Information, but only where: it is no longer needed for the purposes for which it was collected; you have withdrawn your consent (where the data processing was based on consent); following a successful right to object (see below); it has been processed unlawfully; or to comply with a legal obligation to which we are subject. We are not required to comply with your request to erase your Personal Information if the processing of your Personal Information is necessary: for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims. There are certain other circumstances in which we are not required to comply with your erasure request, although these two are the most likely circumstances in which we would deny that request.
- Restriction. You can ask us to restrict (i.e. store but not use) your Personal Information, but only where: its accuracy is contested (see ‘Rectification’ above), to allow us to verify its accuracy; the processing is unlawful, but you do not want it erased; it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise or defend legal claims; you have exercised the right to object, and verification of overriding grounds is pending. We can continue to use your Personal Information following a request for restriction, where: we have your consent; to establish, exercise or defend legal claims; or to protect the rights of another natural or legal person.
- Portability. You can ask us to provide your Personal Information to you in a structured, commonly used, machine-readable format, or you can ask to have it ‘ported’ directly to another data controller, but only where our processing is based on your consent and the processing is carried out by automated means.
- Withdrawal of Consent. You can withdraw your consent at any time, subject to legal restrictions and where applicable reasonable notice. If you wish to withdraw your consent, please contact us as described below under “Contacting Us”. We will not, as a condition of the supply of a product or service, require you to consent to the collection, use or disclosure of information beyond that required to fulfill the explicitly specified and legitimate purposes for which the information is being provided.
- Right to object to processing (including profiling) based on legitimate interest grounds – where we are relying upon legitimate interests to process Personal Information, you have the right to object to that processing. If you object, we must stop that processing unless we can demonstrate compelling legitimate grounds for the processing that override your interests, fundamental rights and freedoms, or we need to process the Personal Information for the establishment, exercise or defence of legal claims. Where we rely upon legitimate interest as a basis for processing we believe that we can demonstrate such compelling legitimate grounds, but we will consider each case on an individual basis.
- Right to object to direct marketing (including profiling) – you have the right to object to our use of your Personal Information (including profiling) for direct marketing purposes, such as when we use your Personal Information to invite you to our promotional events.
- Automated Decision-Making. You have the right not to be subject to a decision when it is based on automatic processing if it produces a legal effect or similarly significantly affects you, unless it is necessary for entering into or performing a contract between us.
Please contact us as indicated below if you wish to exercise your rights, or if you have inquiries or complaints regarding the processing of your Personal Information. We do not charge you but may ask for proof if identity. If we do not intend to comply with your request, we will notify you and provide an explanation as to why we cannot comply with your request.
How We Protect Your Personal Information
GHY makes commercially reasonable efforts to ensure that Personal Information collected from you is protected against loss, theft and unauthorized access, disclosure, copying, use, or modification. This protection applies in relation to information stored in both electronic and hard copy form. Access to your Personal Information is restricted to selected employees or representatives. In addition, GHY employs generally accepted information security techniques, such as firewalls, access control procedures and cryptography, to protect Personal Information against loss and unauthorized access. Please note that no transmission over the Internet is 100% secure or error-free, and that processes, systems, and technologies used and maintained by GHY may be subject to compromise. You acknowledge that we cannot be held responsible for any unauthorized or unintended access that is beyond our control.
Links to Third-Party Sites
GHY is not responsible for how such third parties collect, use or disclose your Personal Information, so it is important to familiarize yourself with their privacy policies before providing them with your Personal Information.
Retention and Storage of Your Personal Information
Use or Disclosure for Marketing Purposes
If you have subscribed to receive GHY’s updates, we may also use your Personal Information to send you relevant information based on your subscription preferences (for example, GHY latest trade updates, service and information updates from us in the areas of trade compliance consulting, customs brokerage, vehicle transportation, freight forwarding, trade software and trade management, and up-coming webinar topics and registration information), including by means of direct marketing. We may also disclose your Personal Information to our affiliates so that they can send you promotional materials directly.
To change or update your preferences, visit Subscribe to our Communications. Note, however, that clients of GHY will continue to receive periodic e-mails that relate to their business relationship with us. You can also choose not to allow us to use your Personal Information for marketing purposes by contacting us as outlined below in “Contacting Us”.
Please review our Cookies Policy.