PRIVACY POLICY

Last Updated: 11/23/2022

Your privacy is important, so COFC Logistics, LLC (“COFC”) has created the following Privacy Policy (“Policy”) to let you know what information we collect when you visit www.cofclogistics.com (the “Site”) or otherwise interact with us, why we collect it and how it is used and disclosed by us. The terms “you,” “your,” and “yours” refer to you, the individual using our Site or interacting with us. The terms “COFC”,” “we,” “us,” and “our” refer to COFC Logistics, LLC and its subsidiaries and affiliates. Your use of our Site is governed by our Terms and Conditions and this Policy.

By using this Site, you consent to the data practices detailed in this Policy, as they may be amended from time to time in accordance with this Policy.

What Information Does COFC Collect?

The information that we collect from you depends upon your interactions with us and the information that you choose to provide to us in connection with any interaction as detailed below.

• If you choose to contact us by e-mail or telephone, we will collect your name, company name (if applicable), telephone number, mailing address, email address, and any other information that is pertinent to your inquiry of us or that you provide to us (collectively, “General Inquiry Information”).

• Our Site contains functionality that enables you to chat with one of our sales representatives and if you choose to do so, we will collect your first name, last name, email address, and the subject of your inquiry (collectively, “Chat Inquiry Information”).

• Access to our operating system, pricing portal, and customer service portal requires registration for an account on our Site. If you choose to create an account, we will collect your first name, last name, email address, company name, city, state/province, whether you desire access to the pricing and/or customer service portal, and we will ask you to confirm that you are not a robot, utilizing Google’s reCAPTCHA service (collectively, “Account Registration Information”).

• The News page on our Site contains posts from COFC approved authors regarding developments at COFC, logistics, and other transportation related matters, which you have the option to comment on. Should you choose to post a comment, we will collect your name and your comment (collectively, “Comment Information”).

• In the event that you choose to become a customer of COFC, we will collect your name, company name, physical address, mailing address, telephone number, a customer contact, billing information, and any other pertinent information necessary to provide you with the desired services (collectively, “Customer Information”).

Our Site collects information from cookies as detailed more fully in the Section titled Internet Cookies.

Internet Cookies

Our Site utilizes internet cookies, which are small data files that are transmitted from our web server to your computing device. These internet cookies allow us to collect certain information from you and enable us to manage web traffic to our Site and to enable you to log into our operating system, pricing portal, and customer service portal, if you have registered for an account. The information that we collect from internet cookies includes your browser type, computing device type, operating system type, internet protocol address, and browsing history for the website you visited prior to arriving on our Site and the pages that you visit while browsing the Site (collectively, “Browsing Information”).

We use the Browsing Information that we collect to: (i) detect, identify, and troubleshoot any issues with our Site, (ii) improve and optimize the Site based on the devices and browsers most utilized by our users, (iii) combat fraud, malicious, and criminal activity on our Site, (iii) understand where our users originate and are referred to our Site, (iv) enable you to access your account, if applicable, (iv) identify the content and features most popular among our users.

Depending upon your internet web browser or computing device, you may have the option to block or reject internet cookies. For more information about the options available to you regarding internet cookies, please consult your internet web browser’s or computing device’s help file. Please note that if you block or reject internet cookies, certain features and functions of the Site may no longer operate properly.

How Does COFC use the Information that it Collects?

We use the information that you provide to us or that we collect, as outlined in the foregoing Sections of the Policy for the following purposes:

• We use General Inquiry Information for purposes of responding to your particular question of us, including providing customer and technical support, as applicable.

• Chat Inquiry Information is used to forward your comment to one of our sales or customer service representatives for purposes of contacting you about your inquiry or otherwise providing you with the specific information that you have requested.

• We use your Account Registration Information for purposes of creating and providing you with access to the desired operating system, pricing portal, or customer service portal, as applicable. We also use Account Registration Information to administer customer, technical, and account support to you as requested or required. For example, we send email communications to you if there is an issue with your account, if you choose to reset your password, or contact us with a question or issue. We use your email address to send you email communications about our products and services that might be of interest to you, which you may opt-out of by following the instructions contained in such email communications.

• General Inquiry Information and Account Registration Information is stored in a relationship management database that we use for internal business purposes.

• Comment Information is used to publish your comment to a particular post on the News page of our Site for other users to the Site to see and comment on.

• Customer Information is used to render the desired services or provide you with a requested product. We use Customer Information to generate invoices, provide the specific product or services to any location(s) you specify, to provide account, customer, technical, billing, and any other support that you request. Customer Information is used for internal business purposes, including internal analysis and education of our customers, their industries, business types, and the freight for which are services are utilized.

• We use Browsing Information as summarized in the Section entitled Internet Cookies.

Does COFC Share or Disclose the Information it Collects?

COFC contracts with third party service providers in order to make our services and this Site available to you. Our third party service providers render services including data and web hosting, software, payment card processing, marketing, and technology services. We do not permit our third party service providers to use any information that they collect from you on our behalf for any purpose other than rendering their services to COFC.

The information that we disclose or share with our third party service providers, to the extent applicable to the work they perform for us, includes contact details, such as first and last name, company name, email address, mailing address, telephone number, and payment information where such third party service provider processes payment transactions.

Except for third party service providers as noted above, COFC does not rent, sell or share any personal information that it collects about you to third parties. Unless otherwise prohibited by applicable law, we will also disclose the information that we have collected from you under the following circumstances:

Legal Requirements

We will disclose the information that we have collected from you if we are required to do so by applicable law, including in response to a subpoena, court order, or other legal demand from an administrative, judicial, or governmental authority. COFC reserves the right, in our sole discretion, to lawfully challenge any legally required disclose. Further, we reserve the right to disclose the information that we have collected from you (unless prohibited by applicable law) to the extent that we determine that such disclosure is necessary in order to protect or defend our rights, property, or the safety of our employees or third parties.

Business Reorganization, Merger, or Sale

If we choose to restructure or reorganize our business, merge with another entity, or sell all or substantially all of our assets to a third party, the information that we have collected from you, including your personal information, will be among the assets that are transferred to an acquiring or merging entity in connection with the transaction unless otherwise provided under applicable law.

Insolvency or Bankruptcy

In the unexpected event that we are forced to seek the protection of or are otherwise placed into bankruptcy, our assets may be subject to a sale to a third party under the supervision of a federal bankruptcy court. Under such a scenario, the information that we have collected from you, including any personal information, may be sold to a third party, unless (1) any such sale of your personal information is prohibited by applicable law, or (2) you have exercised any applicable data rights available to you that would prohibit the sales of such information.

Revisions to this Policy

COFC reserves the right to revise this Policy from time to time in our sole discretion. When we revise our Policy, we will update the Last Updated date that is shown at the top of this document. Updates to this Policy will become effective upon their posting. It is your responsibility to check this Policy on a regular basis for revisions. If you do not agree with any change to a term or condition in this Policy, then you must immediately cease your use of the Site. Your use of the Site after a revision has been posted shall be deemed to constitute your acceptance to the revision.

Do Not Track Signals or Requests from Web Browsers

Our Site does not honor Do Not Track signals and does not share or sell personal information.

Children’s Online Privacy

COFC does not knowingly market to or otherwise solicit Personal Information from children who are under the age of thirteen. For purposes of this Section, the term “Personal Information” includes first and last name, home or other physical address, email address, telephone number, social security number, and other identifiers as determined by the Federal Trade Commission in the promulgation of regulations under the U.S. Children’s Online Privacy Protection Act, which is set forth in Title 15, United States Code, Section 6501, et al. and its regulations. The term “Personal Information”.

You must be eighteen (18) years of age to use our Site. If you are a child who is under the age of eighteen, please do not provide us with any Personal Information. If you are the parent or legal guardian of a child who is under the age of eighteen and you believe that your child may have provided us with Personal Information, please contact us using the information included at the bottom of this Policy and we will promptly remove your child’s information from our system.

Options Regarding Your Information

If you would like to update or deletion any personal information that you have provided to us, you may contact us via email at info@cofclogistics.com to make your request. Please include the subject line “Data Request” in the message and describe your data request as clearly as possible to enable us to locate and carry out your wishes. Please note that we reserve the right to verify the authenticity of any request and to reject those that cannot be reasonably verified. .

The Security of Your Information

COFC Logistics, LLC protects the security of your information during transmission by using Secure Sockets Layer (SSL) software, which encrypts the information you input.

CALIFORNIA PRIVACY DISCLOSURES

California Consumer Privacy Act Notice

The California Consumer Privacy Act (“CCPA”), as amended, requires us to provide consumers in California with certain privacy disclosures as detailed in this Section.

NOTICE OF COLLECTION PRACTICES

The table below contains details about the categories of personal information that we have collected about consumers during the preceding twelve (12) months, the reasons for the collection of that personal information, and the category of sources that the personal information has been collected from.

Specific Business or Commercial Purpose for Collection of Personal Information

COFC collects personal information for purposes of: (1) responding to any inquiry that you make of us, (2) fulfilling any request by you to create a user account for access to a portal, (3) posting any comment that you make on our News page, (4) providing you with requested products or services should you become a customer, and (5) fulfilling our internal business purposes in collecting information from cookies that is used to detect and troubleshoot our Site, understand where our users originate, the content and features most commonly used by such users, and to optimize and improve our Site by virtue of the most commonly utilized devices and systems.

Categories of Personal Information Shared

COFC does not share or sell your personal information, as those terms are defined under the CCPA.

Selling or Sharing Personal Information of Consumers Under 16

We do not sell or share personal information of consumers that are under the age of 18.

Categories of Personal Information the Business Has Disclosed for a Business Purpose to Third Parties

We have disclosed your first name, last name, email address, telephone number, company name, physical and mailing address, city, state/province, and any other information that you have provided to us or that is necessary to carry out a given request from you to our third party service providers for purposes of providing you with the information, products, or services that you have requested.

Identification of Specific Business or Commercial Purpose for Disclosing Consumer’s Personal Information

We disclose your personal information to third party service providers to the extent necessary to create your user account, to establish you as a customer of COFC, to send marketing or promotional email messages about COFC products or services that might be of interest to you, to administer technical, billing, or other account support that you request, and to carry out the specific services that you have requested.

Statement Regarding Whether Business Uses or Discloses Sensitive Personal Information

COFC uses Sensitive Personal Information in the form of a user’s account username and password for purposes of authenticating the user’s credentials for the Site, but does not otherwise share or use any Sensitive Personal Information

California Data Rights

Pursuant to the CCPA, California residents are afforded certain data rights, including the right to know what personal information the business has collected about the consumer, the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling or sharing personal information, the categories of third parties to whom the business discloses personal information and the specific pieces of personal information the business has collected about the consumer.

The Right to Know and Instructions for Submitting a Verifiable Consumer Request to Know

Under the CCPA, California consumers have a right to know the specific pieces of personal information that COFC has collected about that consumer. If you would like to exercise your right to know, you may submit a request to us by email at info@cofclogistics.com, or you may make a request over the telephone to us at (419) 725-0700. Within ten (10) business days of receiving a request from you, we will provide you with an email confirmation that we have received your request.

If you maintain a password-protected account, which is the case for our portal users, we ask that you log into the system before submitting your request in order to assist us in verifying the authenticity of the request. We will collect your first and last name and email address in connection with your Request to Know and we will match this data with your Account Registration Information. If the information that you have provided us matches the information that we have on file, then we will notify you when your information is available to access and we will require that you log into your account to access this information.

If you do not maintain an account with us, we will request your first and last name, email address, mailing address and telephone number. We will also request a signed declaration from you under penalty of perjury that the requestor is the consumer whose personal information is subject to the request.

We will respond to your request with the applicable information within forty-five calendar days of your request; provided, however, that if we cannot verify your identity, we may contact you to extend the period of our response for an additional forty-five calendar days.

Please note that we reserve the right to deny Requests to Know under circumstances where we are unable to verify the requestor’s identity, are unable to match the data points provided by the requestor against those in our system, or if we reasonably believe the request is fraudulent. In each such instance, we will provide the requestor with the appropriate rationale for why a specific request is not being fulfilled.

The Right to Request Deletion of Personal Information

The CCPA grants California consumers the right to request deletion of their personal information that a business maintains about that consumer. In the event that you would like to exercise your right to deletion, you may submit a request to us via email at info@cofclogistics.com, or you may make a request over the telephone to us at (419) 725-0700. Within ten (10) business days of receiving your request for deletion, we will provide you with an email confirmation that we have received your request.

If you maintain a password-protected account with us, we will request that you log into the system before submitting your request for deletion to assist us in verifying the authenticity of the request. We will collect your first and last name and email address in connection with your Request to Delete and we will match this data with your Account Registration Information. If the information that you have provided us matches the information that we have on file, then we will provide you of notification that your information has been deleted.

We will respond to your request with the applicable information within forty-five calendar days of your request; provided, however, that if we cannot verify your identity, we may contact you to extend the period of our response for an additional forty-five calendar days. If your request for deletion conflicts with an applicable state or federal legal obligation imposed on us to retain certain information, then we will specify this rationale in denying your request.

Right to Request Correction of Inaccurate Personal Information

The CCPA grants California consumers the right to request to correct inaccurate information that the business maintains about that consumer. In the event that you would like to exercise your right to correct, you may submit a request to us via email at info@cofclogistics.com, or you may make a request over the telephone to us toll-free at (419) 725-0700. Within ten (10) business days of receiving your request to correct, we will provide you with an email confirmation that we have received your request.

We will respond to your request with confirmation that the information has been corrected within forty-five calendar days of your request; provided, however, that if we cannot verify your identity, we may contact you to extend the period of our response for an additional forty-five calendar days.

Right to Opt-Out of Sharing or Selling Personal Information

COFC does not share or sell personal information as those terms are defined under the CCPA.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

The CCPA prohibits us from discriminating against any consumer who may choose to exercise that consumer’s privacy rights as outlined in this Policy.

COFC is not subject to the data reporting requirements set forth in Section 7102 of the Regulations.

Contacting COFC Logistics, LLC

All comments, feedback, requests, questions, and other communications regarding this Policy should be directed to:

COFC Logistics, LLC
7015 Spring Meadows West Drive
Suite 202
Holland, Ohio 43528
Email: info@cofclogistics.com
Phone: (419) 725-0700