Nuvocargo Inc. Privacy Policy

1. Nuvocargo Inc., including its parent companies, owners, and affiliated entities under ultimate common ownership, including, but not limited to, Oncarriage, LLC (“Nuvocargo”, “us”, “we”, or “our”) respects your privacy. This Privacy Policy describes the types of information we may collect from users, including you, and our practices for collecting, using, maintaining, protecting and disclosing that information. This Privacy Policy applies to information we collect via Nuvocargo’s website at www.nuvocargo.com (the “Site”). This Privacy Policy does not apply to information that we collect offline or that you provide to or is collected by any third party. Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. By accessing or using the Site, you represent and warrant that you have read and understand this Privacy Policy and that you accept and consent to the privacy practices (including any uses and disclosures of information about you) described in this Privacy Policy. If you do not agree with all of the provisions of this Privacy Policy, do not access or use the Site.

2. Information we collect and how we collect it

   We collect information directly from you when you provide it to us and automatically when you use the Site.

   1. Information you provide to us

      You do not have to give us personal information to visit our Site. If, however, you access or use the Site, you may be required to specifically and knowingly provide certain information that will allow us to facilitate such access or use. For example, parts of our Site allow you to purchase products and services. If you wish to purchase such products or services, we will request and collect from you the information needed to fulfill your order or request, just as though your order or request had been made on paper. Information that we request may include, without limitation, personal information such as your name, email address, and other unique identifiers. You acknowledge that your access and use of certain portions of the Site is conditioned on your provision of certain information, including personal information. You may decline to share information with us, in which case we may not be able to provide to you some of the features and functionality of the Site.

3. Information we collect automatically

   If you simply browse through the Site without actively and voluntarily providing us information in response to direct and explicit prompts for the same (e.g., you merely read Site pages or download information), we will nevertheless automatically gather and store certain information about your visit. This information does not identify you personally.

   1. Types of information we collect

      Such information that we automatically collect and store may include but is not limited to the following information about your visit:

      • The internet domain (for example, “xcompany.com” if you use a private internet access account, or “yourschool.edu” if you connect from a university's domain) from which you access our Site and IP address (an IP address is a number that is automatically assigned to your computer, smartphone, or other device used to access whenever you are surfing the web) assigned to the device you use to access our Site.

      • The type of browser and operating system you use to access our Site.

      • The date and time you access our Site.

      • The Site pages you visit.

      • If you linked to the Site from another website, the internet address of that website.

   2. Technologies we use for collection

      The technologies we use for automatic information collection may include:

      1. Cookies

         We and our service partners may use cookies (a file placed by a website on the hard drive of your computer, smartphone, or other device used to access or use the website that allows the website to monitor your use of the website) for limited purposes that enable your use of as well as improve the functionality of our Site. If you do not want information to be collected through the use of cookies, you may be able to refuse to accept cookies by activating the appropriate setting on your computer, smartphone, or other applicable device. However, if you select this setting you may be unable to access certain features of the Site.

      2. Web beacons

         Pages of the Site may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit us to, for example, count users who have visited those pages and for other related statistics (for example, recording the popularity of certain Site pages or content and verifying system and server integrity).

      3. Analytics services

         We may use third party services such as Google Analytics that collect, monitor and analyze the information we collect automatically.

4. How we use your information

   We use the information that you provide to us, including personal information, and which we collect from and about you to:

   • Operate, maintain, and provide the Site and the products and services provided thereon;

   • Process registration with the Site and open, maintain, and close accounts;

   • Fulfill your order or request for services;

   • Respond to your electronic inquiries;

   • Provide you with information, communications, etc. relevant to your use of the Site and products and services provided thereon in which you have expressed interest;

   • Improve, expand, and troubleshoot the Site and the products and services provided thereon;

   • Make the Site more useful to visitors and learn about the number of visitors to the different sections of the Site, what information is of most and least interest, and technical information that will enhance ease of use, such as the types of technology our visitors use and system performance or problem areas;

   • Analyze user behavior in order to measure customer interest in the various areas of the Site, and for statistical purposes;

   • Use for internal business purposes;

   • Conduct billing and collection;

   • Fulfill any other use disclosed at the time you provide your information or as described in this Privacy Policy.

5. Disclosure of your information.

   We may disclose aggregated information about our users, and information that does not identify any individual or device, for business purposes without restriction. In addition, we may disclose information that we collect from you or you provide, including personal information:

   • To contractors, service providers and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them;

   • To our subsidiaries and affiliates, for the purpose of providing the Site and any related products or services, any purpose described in this Privacy Policy or the Terms and Conditions, or for any other lawful purpose;

   • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of Nuvocargo’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by Nuvocargo about our Site users is among the assets transferred;

   • To fulfill the purpose for which you provide it;

   • For any other purpose disclosed by us when you provide the information;

   • With your consent;

   • If required to do so to comply with any court order, law or legal process (including to respond to any government or regulatory request), or in the good-faith belief that such disclosure is so required;

   • To enforce our rights arising from any contracts entered into between you and us, including the Terms and Conditions, and for billing and collection; and

   • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Nuvocargo, our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

6. Data security

   We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure. The safety and security of your personal information also depends on you. You are responsible for maintaining the confidentiality of the login credentials (including your account login username and password) we have given you (or you have chosen) to access to certain parts of the Site. Do not to share your password with anyone, and we urge you to be careful about giving out information in any public areas of the Site. Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although we have implemented measures designed to secure your personal information, we cannot guarantee the security of your personal information transmitted through our Site. Any transmission of personal information is at your own risk. If your communication is very sensitive, or includes information such as your bank account, charge card, or social security number, you should send it by mail unless our Site indicates the particular transmission is secured. We are not responsible for circumvention of any privacy settings or security measures we provide.

   For Site security purposes and to ensure that the Site and related products and services remains available to all users, Nuvocargo employs software programs to monitor network traffic to identify unauthorized attempts to upload or change information, or otherwise cause damage.

7. Children's privacy

   Our Site and the related services and products are not directed to or intended for use by individuals under the age of eighteen (18). We do not knowingly collect, keep or maintain personal information from individuals under the age of eighteen (18). If you are under the age of eighteen (18), you may not access or use the Site or the related services and products. If you are aware of any use of the Site by an individual under the age of eighteen (18), please inform us immediately so that we can terminate such usage.

8. Changes to our privacy policy

   We may update this Privacy Policy from time to time. If we modify the Privacy Policy, we will make it available through the Site. All such modifications, updates, and amendments are effective immediately upon notice thereof, which we may give by any means, including, but not limited to, by posting a revised version of this Privacy Policy or other notice on the Site. You should view this Privacy Policy often to stay informed of changes that may affect you, as your continued use of the Site signifies your continuing consent to this Privacy Policy. This Privacy Policy is not intended to and does not create any contractual or other legal right in or on behalf of any party.

9. Acknowledgement

   BY ACCESSING OR USING THE SITE, OR ANY PORTION THEREOF, YOU ACKNOWLEDGE THAT YOU HAVE READ AND UNDERSTAND THIS PRIVACY POLICY.

10. Contact us

    To ask questions or comment about this Privacy Policy and our privacy practices, contact us at info@nuvocargo.com.

4837-1390-9935, v. 3

Equal Employment Opportunity Policy

1. Purpose

   Nuvocargo has established and maintains various corporate policies and practices which collectively are intended to promote the ethical and lawful behavior of its employees, and to deter wrongdoing and improper conduct. Nuvocargo’s Code of Business Conduct and Ethics sets forth the mission, vision and values of the company and its general policies.

   This policy defines the guidelines to be followed concerning nondiscrimination in the workplace, and Nuvocargo’s commitment to diversity and equal opportunities and to prevent and eliminate any type of discrimination in the company. Nuvocargo strives for an inclusive environment where all its employees are valued and to create a level playing field for its employees’ success by maximizing their abilities and potential. Local Nuvocargo markets may establish policies with additional requirements to comply with local laws relating to these topics, however it is our intent that the company’s policies comprise international standards and go beyond what is commonly required by international and local treaties and laws.

   No actions or omissions that involve homophobia, misogyny, xenophobia, racism, antisemitism, or any other type of discrimination will be tolerated.

   Merit and excellence of qualifications are the basic principles regarding employee recruitment, hiring, retention, training, and promotions.

   Non-discrimination is a human right fundamental to all individuals. Discrimination shall be prevented by promoting values like respect, tolerance and equality.

   Nuvocargo has a “Zero Tolerance” policy for discrimination or harassment.

   It is a violation of this policy to retaliate against Nuvocargo’s employees, applicants, or other individual who has supported this policy, filed a complaint, testified, or assisted in any proceeding under this policy and the necessary actions will be taken against any such individual. If you know or become aware of any violation, say it.

   All applicants and employees have the right to file complaints alleging discrimination which shall be filed with the corresponding Legal & Compliance office.

2. Scope

   This policy covers all activities and locations of Nuvocargo Inc. and its subsidiaries and applies to all employees and stakeholders to ensure a work environment free from all types of discrimination and harassment. Nuvocargo strives to maintain a diverse workforce and to provide equal employment opportunities to all applicants and employees regardless of their race, religious creed, color, national origin, ancestry, age, disability, medical condition, marital status, gender, sexual orientation, or political affiliation.

3. Responsibility

   3.1 Interpretation and Administration. Shall be the joint responsibility of the Legal & Compliance and People teams and includes all investigations and complaints.

   3.2 Implementation. Shall be the joint responsibility of the joint responsibility of the Legal & Compliance and People teams.

   3.3 Work environment. It is the responsibility of each member of management and supervisors to create an atmosphere free of direct or indirect discrimination and unlawful harassment of any type, whether by action or omission in the workplace. In addition, it is the responsibility of each employee to respect the universal human rights and all other local rights of co-workers, customers, and visitors to our facilities. Any employee who is found violating this policy shall be subject to discipline, up to and including discharge. Managers and supervisors shall take all corrective actions required when a violation to this policy occurs, including notifying the Legal & Compliance office. All employees shall strive together to create a work environment free from retaliation for anyone who has complied and supported this policy.

   3.4 Training. Shall be the responsibility of the People team.

   3.5 Employees, Applicants and Business Partners. Shall: i) ensure that all co-workers, business partners, customers and any third parties with whom they have contact are treated with dignity and respect and a work environment free from discrimination and harassment.; ii) report immediately any alleged violations to this policy to their supervisor or manager, iii) cooperate fully in any investigation process of a complaint or disciplinary action.

4. Procedures

   Nuvocargo is strongly committed to provide equal opportunity to all employees and applicants, without regard to race, color, sex, religion, sexual orientation, national origin, culture, age, economic or social condition, physical appearance, political affiliation or identity, marital status, family status, language, criminal back-ground, disability, health condition, or any other reason in each country in which Nuvocargo has employees. In addition, it is the policy of Nuvocargo Inc. to comply with all applicable federal and local laws governing non-discrimination in employment.

   Nuvocargo is also committed to create a diversified workforce and provide equal opportunities for all employees to reach their full potential in pursuit of corporate objectives.

   Nuvocargo will take all necessary actions to promote a safe and inclusive environment in the workplace, as well as to provide training and workshops to all its employees to prevent any actions or practices that may be contrary to this policy, as well as to create awareness about what is expected from them in matters related to equal opportunities, diversity and non-discrimination and their right to a life free from any type of discrimination. Nuvocargo will implement the procedures required to provide, if necessary, the resources to any employee who may be a victim of discrimination, including but not limited to actions to prevent future breaches to this policy, measures to allow the victim to face any adverse effects occurred due to an act of discrimination, administrative actions to inhibit and prevent any acts, omissions or social practices that may be considered discriminatory.

   When possible, Nuvocargo will take all necessary actions to cause that any employee who acts in a discriminatory manner against any other co-worker or applicant issues a private or public apology, considering the circumstances in which the discriminatory act occurred and any other measure that may be required under law or company policy.

5. Filing Instructions

   This policy can be found in the “Policies” section of the company’s website.

6. Contact

   Questions regarding this policy should be directed to the Legal & Compliance Lead (josefina.blanco@nuvocargo.com) or the Head of People (lauren.burdick@nuvocargo.com).