Privacy Policy

Last Updated: September 25, 2023

Thank you for visiting the Airsea Packing Group (or “ASPG”, “AirSea”, “we”, “us” or “our”). This Privacy Policy (“Policy”) details how we process your personal data as a controller in connection with our website at www.airseapacking.com, including the following:

• 1. Grounds for using your personal data;
• 2. Data we collect and our purposes;
• 3. Cookies and similar technologies;
• 4. With whom we may share the personal data;
• 5. Data retention and security;
• 6. Transfers of personal data out of the EU/EEA
• 7. Your privacy rights, choices and disclosures, including those for Europe, the United Kingdom and California;
• 8. Data of minors;
• 9. Policy changes and updates;
• 10. Arbitration; and
• 11. How to contact

This Policy does not address any offline data handling practices.

Please see the Website Terms of Use at airseapacking.com/terms-of- use/ for more information about the Airsea Packing Group entities.

“Personal data” is information relating to an identified or identifiable natural person.

1.  Grounds for Using Your Personal Data

We rely on the following legal grounds to process your personal data:

• [a] processing is necessary to perform a contract;
• [b] processing is necessary for the purposes of our legitimate interests;
• [c] compliance is necessary to comply with our legal obligations; or
• [d] you have given consent to the processing of your personal data for one or more specific purposes. Continued use of our website may constitute your consent.

2.  Data We Collect and our Purposes

• a. User Inquiries. We may receive, retain, and process email and/or phone number data contained in any inquiry you submit to us in order to help us handle and reply to your inquiry. The submission of such an inquiry constitutes your consent for us to retain and process this data.
• b. Website Usage. We may receive and process data about your use of our website and services. Such data may include your IP address, general geographic location, browser type and version, operating system, referral source, length of visit, page views, and website navigation paths as well as information about the timing, frequency, and pattern of your service use. This data is used for improving the browsing experience on our site/s and supplying relevant information to users.
• c. Use of Our Services.
  • Account Data: For certain Airsea Packing services, users are required to create a user account in order to receive services. Account data may include name, email address, login credentials, and postal address. This data is received, retained and processed for the purposes of providing our services, ensuring the security of our services, maintaining our databases, and communicating with you. This Data is retained to facilitate the performance the services you have requested and improving our service standard and/or developing more functionality for users.
  • Service Data: For our cloud or internet-based services, we may receive, retain and process the personal data you provide in the course of using our services. The service data may include your name, email address, login credentials, browser type, device ID, IP address, MAC address, system settings, network statistics, licence status, activity logs, device hardware status, and access time stamp. This data can be used, retained and/or processed for the purpose of providing our services to you as requested.
• d. Subscriptions. If you provide your opt-in consent to subscribe to marketing information from us, we will process your email address and name for the purpose of sending you marketing information about our products and services. You may withdraw your consent at any time by selecting “unsubscribe” on any email you have received from us.
• e, Social Media Icons. We operate social media pages on third party networks and have social media icons on our website. When you visit or link to our social media pages, data is processed both by us and the applicable social media provider. Social media providers are unaffiliated with us, and we are not responsible for the content or privacy practices of social media providers. Social media providers have their own terms of use and privacy policies, and we encourage you to review those policies whenever you visit their websites or interact with their

3.  Cookies and Similar Technologies

A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie

helps analyze web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

AirSea Packing use traffic log cookies to identify which pages are being used. This helps us analyze data about web page traffic and improve our website in order to tailor it to our customers’ needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Cookies help us to provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer, however this may prevent you from taking full advantage of the website.

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

4.  With Whom We Share Personal Data

We are a global provider of services, and as such may need to share information with internal personnel and our affiliates located in different geographic locations in order to perform our services. We may also share your personal data to third parties (within or outside your country of residence) who perform services on our behalf, including without limitation, technology providers and professional advisors.

We may disclose information (within or outside your country of residence) if we have a good faith belief that disclosure is necessary by law or the legal process, to protect and defend our or others’ interests or property, or to enforce agreements you enter into with us.

We may share your data with a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, liquidation or other disposition of all or any portion of our business, assets or stock with such third party.

We may share aggregated and de-identified information with third parties (within or outside your country of residence) for analytical, research or other similar purposes.

We may obtain your written consent from time to time in electronic form by using online agreements or other acknowledgements on the website or through the services, including for any other contemplated uses of your personal data not addressed in this Policy. Please read all online agreements carefully before accepting them.

5.  Data Retention and Security

Your personal data will not be retained for a period in excess of seven years after the termination or cessation of our services or purposes, except when local laws and regulations require it to be retained beyond that period.

We take reasonable administrative, physical and technical precautions to protect your personal data and communications between us. This includes, when required or as we deem appropriate and feasible under the circumstances, encryption and written commitments from third parties that may have access to your data that they will protect the data with reasonable safeguards.

No Internet or e-mail transmission is ever fully secure or error free, however. We therefore cannot guarantee absolute security of your data, and we are not responsible for processes and networks that we do not control. Users assume the risk of security breaches and the consequences resulting from them. Please be careful in deciding what information you send to us via email or over the Internet.

6.  Transfers of Personal Data from the EU/EEA

Airsea Packing Group Ltd is a UK registered company. To offer our products and services, we may need to transfer your personal data to other Airsea Packing affiliates in non-EU/EEA countries, including the United States, which is not an “adequate jurisdiction” by the European regulatory authorities.
By visiting or using our Services, you are consenting to the transfer of your information from your jurisdiction to the United States.

7.  Your Rights, Choices and Disclosures

• a. General. This section is subject to specific disclosures on privacy rights set forth We are committed to facilitate the exercise of your rights granted by the laws of your jurisdiction, which may include the right to request the correction, modification or deletion of your personal information and the right to opt out of the sale or sharing of your personal information (as applicable). We will do our best to honor your requests subject to any legal and contractual obligations.You may opt out of receiving electronic marketing communications from us by clicking on the “unsubscribe” link on the communication or contacting us at set forth below in Section 11. Some non-marketing communications may not be subject to a general opt-out, such as communications about transactions, disclosures to comply with legal requirements, software updates and other support-related information. If you do not wish to receive any service-related emails from us, you have the option to deactivate your account.Subject to local law, you may have additional rights under the laws of your jurisdiction regarding your personal data, such as the right to complain to your local data protection authority.
• b. Your Rights Under GDPR (and similar laws)If you are located in the European Union, the United Kingdom or another jurisdiction that has adopted laws substantially similar to the European Union’s General Data Protection Regulation (GDPR), your privacy rights include the following:
  • The right to access your personal data;
  • The right to correct any of your personal data that is incorrect or incomplete;
  • The right to have your personal data erased or removed (“the right to be forgotten”) if certain grounds are met;
  • The right to restrict/suspend the processing of your personal data;
  • The right to data portability;
  • The right to withdraw your consent for processing your personal data at any time (if processing is based on consent);
  • The right to object to processing of your personal data (if processing is based on our legitimate interests);
  • The right to object to the processing of your personal data for direct-marketing purposes; and
  • The right to complain to a supervisory authority if you believe that we have not handled your personal data in accordance with the GDPR.

  Some of the foregoing rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the relevant regulatory authorities for a full explanation of these rights (https://gdpr-info.eu/).

  If you have any concerns or complaints about our use of your personal data or if you wish to exercise any of the above rights, please contact our data protection representative, as listed below. We will respond to communications or requests to exercise your rights enumerated above, within thirty (30) calendar days of receiving your written (or emailed) request unless the request is particularly complex or cumbersome. In such instances, we will respond within thirty (30) calendar days of receipt of your written (or emailed) request and explain why it will require additional time to process your request(s).

• c. California DisclosuresCalifornia “Shine the Light” Information-Sharing Disclosure: California residents may request a list of all third parties with respect to which we have disclosed any information about you for direct marketing purposes and the categories of information disclosed. If you are a California resident and want such a list, please send us a written request by email to aspny@airseapackingus.com with “California Shine The Light Rights” in the subject line.California Do Not Track Disclosure: We utilize an automated tool designed to recognize Global Privacy Controls in end-user browsersCalifornia Consumer Privacy Act Disclosures. Under the California Consumer Privacy Act, as amended by the California Privacy Rights Act effective January 1, 2023 (“CCPA/CPRA”), California residents have the right to request:
  • The categories of personal information (including sensitive personal information if applicable) we have collected about you;
  • The categories of sources from which the personal information is collected;
  • The business or commercial purpose of collecting, selling or sharing personal information;
  • The categories of third parties with whom we share or sell personal information;
  • The categories of personal information about you that we have disclosed; and
  • The specific pieces of personal information we have collected about you.

  Additionally, you have the right:

  • to know the length of time we retain your personal information;
  • to request deletion of your personal information;
  • to request the correction of any inaccurate data;
  • to opt out of the sale or sharing of your information (if applicable);
  • to limit the use of sensitive personal information (if applicable); and
  • to not be discriminated against for exercising any of your CCPA/CPRA rights.

  We do not share (as defined under CCPA/CPRA) consumers’ personal information in the context of cross-context behavioral advertising.

  Please see the chart below regarding the categories of data we process from consumers in connection with providing our website and to whom we may disclose the information for business purposes.

   

  Personal Information Category	Source of Personal Information	Purpose for Collecting the Personal Information	To whom we disclose the Personal Information
  Identifiers such as a name, address, unique personal identifier, email, phone number	Information you provide to us; Information we collect automatically.	See Section 2 above	See Section 4 above
  Information described in 1798.80(e) (and not otherwise addressed in this table), including bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information	We do not collect this information on our publicly available website.
  Protected Classifications under California and federal law, including gender, age and citizenship.	We do not collect this information on our publicly available website.
  Commercial information such as records of products or services purchased, obtained, or considered, purchase histories and tendencies	We collect and store this information to comply with our legal and contractual requirements and to provide you information via the client portal.	See Section 2 above	See Section 4 above
  Biometric information	We may utilize biometric information for employee timekeeping purposes, which is beyond the scope of this Policy.
  Internet or other electronic network activity information, including browsing history and search history and interactions with an advertisement.	Information you provide to us; Information we collect automatically	See Sections 2 and 3 above	See Section 4 above
  Geolocation data that is sufficient to identify a precise physical location.	We do not collect this information.
  Sensory data, such as audio, electronic, visual, or other similar information.	We do not collect this information.
  Professional or employment- related information	We do not ask for this information via our website.
  Education Information	We do not ask for this information via our website.
  Inferences about preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and	Other than in connection with analytics cookies described above, we
  aptitudes.	do not collect this information from our website.

  We do not collect any sensitive data (as defined under CCPA/CPRA) from our website.

  We do not sell or share personal information for monetary consideration under CCPA/CPRA.

  You may opt out of Google Analytics Cookies by downloading the browser add-on

  here: https://tools.google.com/dlpage/gaoptout?hl=en.

  Our contact information is listed at the bottom of this policy. Our toll-free phone number is (866) 928-5602. You may also submit a request on our website form by clicking on the “Data Request” link at the bottom of our home page and accessible at https://airseapacking.com/data-request/ and describing your request in the “How can we help?” box. If you submit a data subject request, we will ask for your name, email address and phone number, and we will endeavor to authenticate you. We may also require that you submit your request via the Services’ standard authentication procedures (i.e., log on with username and password to submit a request) and/or provide information about any historical transactions with the Services to ensure you are the person you say you are. If this information or these processes are insufficient to verify your identity and assess your privacy request, we may need to ask for additional information. You may also designate an authorized agent to make a CCPA/CPRA privacy request.

8.  Minors

Airsea Packing does not knowingly collect information from or respecting minors, as defined by local law, and does not target our website or services to minors. If we learn that we have collected the personal data of a minor, we will take steps to delete the information as soon as possible.

9.  Policy Changes and Updates

This Policy may from time to time be updated when necessary to reflect changes in our data handling practices. We therefore reserve the right to change its contents at any time. We will publish the updated version of this Policy on this site. We suggest that you periodically re-examine this Policy to stay up to date.

10.  All Claims Are Subject To Arbitration

By continuing to use our website, you agree that to the fullest extent permitted by law within the applicable jurisdiction, that any and all claims of whatsoever kind, wheresoever arising, shall be subject to binding arbitration in accordance with the dispute resolution and governing law provisions as set forth in our Website Terms of Use.

11.  How to Contact Us

Please contact us if you have any questions about this Privacy Policy. Air-Sea Packing Group Inc.

40-35 22nd Street

Long Island City, NY 11101, USA Email: aspny@airseapackingus.com Phone: +1 718 937 6800

If you reside in the UK or an EU/EEA country, please contact: Airsea Packing Group Ltd,

Airsea House, Belvue Business Centre Belvue Road

Northolt Middlesex UB5 5QQ

Email: gdpremail@airseapacking.com Phone: +44 (0) 208 8893 3303