Privacy Policy

Last Updated: December 8, 2022

1. Introduction

This privacy policy (“Notice”) applies to Shipber Inc. and its relevant affiliates (“Shipber,” “us,” “we,” or “our”). Shipber is a smart supply chain software designed to improve Subscriber's operation efficiency. Shipber is the controller of personal data described in this Notice, unless otherwise specified.

Our Services are designed for commercial usage. Where our Services are made accessible to you via a Shipber Subscriber, that Subscriber is the data controller of your personal data, and you should direct any inquiries or requests regarding your personal data to that Subscriber. Shipber is not responsible for the privacy or security policies of our Subscribers, which may differ from this Notice.

As used in this Notice, "personal data" refers to any information that directly or indirectly identifies, characterizes, or might be used to identify an individual. Capitalized terms not defined herein (such as Website, Services, Subscriber, Agent, Agent Contact Information, and other terms) have the meaning provided in our Master Subscription Agreement located here: http://www.shipber.com/Master Subscription Agreement.html

This Notice applies to personal data that Shipber is the controller of, which may include: (i) data collected through the shipber.com website, the Shipber mobile applications, the Shipber Marketplace, the Shipber Developer Portal, our branded social media pages, and other Websites which we operate (collectively, our "Digital Properties"); (ii) data collected in a manner when we post a direct link to this notice, such as in connection with digital communications, paper communications, or paper forms;

This Notice does not apply to the information listed below:

• Personal Data on Shipber employees and recruits, as well as some contractors and agents doing similar functions.

• Personal Data is processed by Shipber on behalf of our Subscribers.

Changes:This Notice may be updated periodically to reflect changes in legal, regulatory, and operational requirements, our business practices, and other circumstances. Please check back frequently for revisions to this Notice. If any of the modifications are objectionable to you, you must terminate all communication with us. When required by applicable law, we will notify you of any changes to this Notice by publishing an update on our Website (and revising the "Last Updated" date at the top of this Notice) or in another manner that is appropriate.

2. Sources of Personal Data

We collect information about you and your interactions with us in the following ways:

• Information you provide to us directly. We collect the information you provide to us directly. This includes instances in which you register and connect with us directly through our Digital Properties, visit our offices, attend our events, or participate in our marketing and outreach efforts (including surveys, contests, promotions, sweepstakes, conferences, webinars, and events).

• Information collected from your Employer, Coworkers, or Friends. We may collect and handle the personal information of representatives (e.g., employees) of our current, former, and potential customers, suppliers, investors, and business partners, as well as other employees of these firms. As part of a recommendation, we may also acquire your name, address, phone number, and firm name from a friend.

• Information automatically collected or inferred from your interactions with us. We automatically collect technical information on your use of our Digital Properties (such as IP address, browsing preferences, and cart and purchase history). In Section 6 ("Cookies and Tracking Technologies") below ("Cookies and Tracking Technologies"), our Cookie Policy provides more information.

• Information from public sources. We may collect information from government institutions from whom public records are collected, as well as information you contribute in public forums, such as material made public on social media networks.

• Information from other third parties. We obtain information about you from various third parties, such as third-party service and content providers, businesses with which we collaborate to sell or advertise products or services, telephone and fax companies, authentication service providers, data brokers, and social media networks (including widgets related to such networks, such as the "Like" button on Facebook). Your interactions with social networking services are governed by the privacy rules of the different companies.

We may combine information obtained from the different sources specified in this Notice, including third party and public sources, and use or disclose it for the reasons outlined below.

3. Types of Personal Data Collected

The personal data we collect includes:

• Identifiers, such as your name, alias, postal address, unique personal identifier, online identifiers (such as various advertising identifiers), instant messaging ID, internet protocol (IP) address, email address, account or user name, phone number, and social media identifiers (such as your Twitter handle, Instagram name, etc.).

• Personal information, such as name, signature, address, telephone number, insurance policy number, bank account number, credit card number, or any other financial data. Some of the personal information in this category may overlap with information in other categories.

• Commercial information, such as creditworthiness records, items or services purchased, received, or pondered, and other purchasing or consumption histories or patterns.

• Internet or other electronic network activity, such as browsing history, search history, and customer engagement data with a website, application, or advertisement.

• Geolocation information, such as physical location or movements from your IP address or mobile device.

• Inferences, profile of you on any of the information we gather, which reflects your interests, attributes, and behavior.

4. How We Use Your Personal Data

Your information, including Personal Information, may be used for the following purposes:

• Account Registration. We may use your name, address, phone number, billing information, and email address to register you for particular Services and send you pertinent information. To keep correct records, we may obtain additional Personal Information about you from publicly accessible sources, such as address change information. Please note that if you establish an administrator account that others can view, they will have access to your Personal Information and the ability to alter or remove it. Please assign administrator powers with caution, since you are responsible for their actions.

• To Provide Our Services and Operate Our Business. We may use your information to operate our company, including delivering the Services you've requested, to provide you with Services-related assistance (such as Customer Service or fulfillment), and to aid us in defending our Services, including combating fraud and protecting your data.

• Customer Service and Technical Support. We may use your name, address, phone number, email address, how you interact with our Services, and information about your computer configuration to respond to any queries you may have about our services and to communicate with you about your experience. We also provide a variety of Internet chat services, such as the chance to speak with a Shipber customer service person. Internet Chat conversations are encrypted, however, you should not disclose more Personal Information than is required to handle your specific issue. It is possible to preserve a transcript of the session to address questions or issues regarding our services.

• Communicate with You and Tell You About Other Services. We may use your information to communicate with you about our Services and to provide you with information regarding products and services of third parties that we feel may be of interest to you.

• To Improve Services and Develop New Services. We will use your information to customize your experience and the Service, to develop new features and services, and to improve the overall quality of our services.

• Feedback. We may combine the information you voluntarily offer in surveys with replies from other customers in order to have a better understanding of our Services and possible areas for enhancement. Participation in any survey is entirely optional.

5. How Do We Share Personal Data

We may share your personal information with the following third parties to provide you with services and products and to operate our website:

• our subsidiaries or affiliates;

• our advisors;

• our third party service providers who process information on our behalf to help run some of our internal business operations including email distribution, IT services and marketing and events services;

• our business partners for publications and events co-organized by Shipber and them;

• law enforcement bodies in order to comply with any legal obligation or court order

Given that Shipber is a global organization, we must transfer personal information collected on the Site or through other means throughout Shipber in order to operate our business effectively. This also includes third parties located in countries outside the United States. Your personal information may be located in various countries around the world, where privacy laws vary. We only enter into these agreements or make these transfers when we are confident that adequate safeguards are in place to protect the information held in that country. Additionally, the Site is viewable and accessible from any location in the world, including countries that may not have laws governing the use and transfer of personally identifiable information. By using the Site, submitting information via this site, or otherwise submitting personal information to Shipber, you consent voluntarily to the international transfer and hosting of such information in these countries and by these parties.

6.Cookies and Tracking Technologies

Cookies, Pixels, and Similar Tracking Technologies Used: We and our authorized partners collect information through cookies, web beacons, pixels, tags, embedded scripts, session replay tools, SDKs, Local Storage such as HTML5 and Local Shared Objects ("LSOs," also known as Flash cookies), or other data retrieval and tracking technologies ("Tracking Technologies"), including your Internet Service Provider and IP address, device identifier, browser type, operating system, your device's WiFi MAC address or Bluetooth MAC address, t. Cookies are a type of technology that installs a small bit of data on the computer or other device of a user when they visit a website. Cookies enable a website, for instance, to recognize subsequent visits from the same computer or device. Some cookies live only for the duration of a single session, whilst others endure through numerous sessions. We and our partners utilize these Tracking Technologies to ensure the basic functionality of our Digital Properties; to remember user preferences (including your preferences regarding Tracking Technologies); to maximize the performance of our Digital Properties and Services; to provide you with offers that may be of interest to you; to measure the success of our Digital Properties, marketing campaigns, and email communications; and to personalize online content. These Tracking Technologies may be used to monitor your activity over time and across devices, websites, and Services.

In addition, we may use tracking pixels directly or through third parties. Tracking pixels are tiny, transparent graphics with a unique identifier, similar in function to cookies, and are used to offer analytical data regarding the user experience and to enable customized marketing activities for users of our Digital Properties. Unlike cookies, which are saved on the hard drive of a user's computer, tracking pixels are inserted invisibly on web pages. Our Digital Properties may employ tracking pixels to assist us in better managing content, such as by enhancing the user experience or enhancing our marketing programs or the marketing of our affiliates, business partners, and other third parties (including for interest-based advertising as described below). The Digital Properties may use collected data to compile tracking reports about user demographics, traffic patterns, and purchases. We may also link tracking data to personal information.

Third-Party Companies: In order to provide you with a more relevant and engaging experience, we may engage with third-party companies to show advertisements or personalize the content on our Digital Properties or through other channels of communication. These companies may use Tracking Technologies as defined in this Notice to collect information about you, including your precise location, visits to the Digital Properties, and visits to other websites on the Internet. These parties may also use your information to present you with interest-based advertising, which may include sending you an ad on another online service after you leave our Digital Properties (i.e., retargeting).

Your Choices: You have the option of receiving interest-based advertising. If you are located in the European Economic Area, Switzerland, or the United Kingdom, then essential cookies must always be used to provide you with the desired services. At the time of your first visit to the Shipber website, you will be given the option to consent to the usage and future processing of data gathered through non-essential cookies (i.e., functional cookies, analytics cookies, targeting cookies, and social media cookies). By clicking the "Cookie Settings" link in the footer of every page, you can at any time revise your decision (including withdrawing any previously granted consent with future effect). This link will also provide you with more information regarding the various types of cookies used and the specific third parties that employ them. If you are located in the European Economic Area, you can also opt in to the usage of cookies more generally by clicking here. At http://www.aboutads.info/choices and http://optout.networkadvertising.org, the Digital Advertising Alliance ("DAA") and Network Advertising Initiative ("NAI") both provide options for opting out of interest-based advertising provided by participating members. Additionally, you can visit http://www.aboutads.info/appchoices for information regarding the DAA's opt-out program for mobile apps (including use of precise location for third party ads). Opting out of interest-based advertising will not opt you out of all advertising, only from us or our agents or representatives. Additionally, cookie-based opt-outs must be conducted on every device and browser from which you desire to be excluded. For instance, if you have opted out on your computer's web browser, this opt-out may not be applicable on your mobile device. If your browser is configured to refuse cookies, if you subsequently delete your cookies, or if you use a different device or web browser, DAA/NAI browser-based opt-outs will not function or may no longer be effective. We are not responsible for the success of these or any other opt-out alternatives or programs offered by third parties.

Do Not Track. Currently, our Services are not set to respond to "Do Not Track" signals from browsers since no official "Do Not Track" standard has been implemented. However, our partners and other third-party providers may alter their practices if this functionality is utilized.

7. Security and Retention

We utilize reasonable security standards and technological and organizational precautions to prevent the unauthorized or accidental destruction, loss, disclosure, alteration, or use of your personal information.

Where Shipber is the data controller, we will typically retain your personal information for as long as is necessary to fulfill the purposes outlined in Section 4 of this Notice. This includes retaining your data to provide you with the requested Services and to interact with you, to enable your participation in an event, to maintain a business relationship with you/your organization, to improve our business over time, to ensure the ongoing legality, safety, and security of our services and relationships, or in accordance with our internal retention procedures.

Once you / your organization has terminated the contractual relationship with us or otherwise ended your relationship with us, we may retain your personal data in our systems and records to: ensure adequate fulfillment of surviving provisions in terminated contracts, or for other legitimate business purposes, such as to evidence our business practices and contractual obligations, to provide you with information about our products and services, or to comply with applicable law. Similarly, we will preserve your personal information for the applicable statute of limitations pertaining to the establishment, exercise, or defense of such legal claims.

When we no longer have a legitimate business need or legal basis to process your personal data, we will delete, anonymize, or aggregate it; if this is not possible (for instance, if your personal data has been stored in backup archives), we will secure your personal data and isolate it from further processing until deletion is possible. If you would want more information on the retention periods applicable to your circumstances, please contact us using the details provided in Section 11 below.

8. Children’s Privacy

Our Websites and Services are not intended for children under 16 years of age, and we do not intentionally collect personal information from children through the Internet. If you are the parent or guardian of a child under the age of 13 and you suspect that your child has exposed personal information to us online, please contact us at [email protected].

9. External Links

You may discover connections to external websites or other online services, including those included in third-party ads, when engaging with us. We have no control over and assume no responsibility for the privacy and data-collecting practices of such third-party websites and services. If you want further information or have concerns about their procedures, you should examine the privacy policies of such third parties.

10. Terms of Use

The Master Subscription Agreement and other conditions relevant to our interactions may be found at http://www.shipber.com/Master Subscription Agreement.html

11. How to Contact Us

if you have questions, complaints, or comments about this Notice, please contact us by email at [email protected] or at:

Adber Inc.

Attn: Private Policy

17800 Castleton St, Suite 445,

City of Industry, CA 91748

12. Your Data Protection Rights

Laws in certain jurisdictions may offer persons with the following rights pertaining to their personal data. We shall respect these rights to the degree that the law requires.

Access. You have the right to request confirmation from us as to whether or not we are processing your personal data, as well as a copy of your personal data undergoing processing.

Rectification. You may have the right to seek the correction of erroneous personal information and the completion of incomplete information.

Objection. You may have the right to object to the processing of your personal data based on compelling and legitimate grounds pertaining to your specific circumstances, unless legislative rules clearly authorize for such processing. You have the right to object to the processing of your personal data for direct marketing purposes by clicking the unsubscribe link at the bottom of the email marketing message you received or by sending an email to [email protected].

Portability. You may have the right to obtain the personal data you have submitted to us in a structured, frequently used, and machine-readable format, as well as the right to transfer it unhindered to other data controllers. This right applies only if the processing is based on your permission or a contract and is performed using automated means.

Restriction. You may have the right to restrict the processing of your personal data in certain circumstances.

Erasure. You may request the erasure of your personal data if I it is no longer necessary for the purposes for which we collected it, (ii) you have withdrawn your consent and there is no other legal basis for the processing, (iii) you have objected to the processing and there are no overriding legitimate grounds for the processing, (iv) the processing is unlawful, or erasure is required to comply with a legal obligation.

Right to lodge a complaint. You may also have the right to file a complaint with a regulatory agency in your country of residence.

Right to refuse or withdraw consent. In the event that we request your consent for processing, you are free to refuse and can withdraw your consent at any time without adverse repercussions by contacting us using the aforementioned contact information. Any processing of your personal data that occurred previous to your withdrawal of consent will continue to be lawful.

Automated decision-making. We now advise you that the sorts of automated decision-making mentioned in Article 22(1) and (4) of the GDPR do not occur on our Websites or in our Services. If this were to change, we would inform you of the change as well as the fact that you have the right not to be subject to decisions based purely on automated processing and to be given further information regarding the reasoning behind any such decision.

To exercise your rights (or any rights that may be available to you under your local data protection legislation), please use our webform or send an email to [email protected]. We endeavor to reply to all valid requests within one month of receipt, or as otherwise required by relevant law. We will contact you if the response will take longer than anticipated. If we have legitimate suspicions about your identification, we may require more information from you to verify your identity.

13. Supplemental Terms for California Residents

In accordance with the California Consumer Privacy Act ("CCPA"), this section applies to specific personal data gathered about California individuals when Shipber operates as a "business" and complements the remainder of our preceding Notice. The following information is excluded from this section:

• Information on nonresidents of California;

• Information on our own employees, contractors, agents, and job applicants. This information is subject to a separate privacy policy that we will give to individuals;

• Information we collect from persons with whom we conduct business-to-business conversations and transactions, such as information about the employees of our business partners and customers; and

• Information that we process on behalf of our business clients as a "service provider." In such instances, we treat your personal data in accordance with the instructions of the business that hired us, and you should contact that firm for further information about how your personal data is processed.

Source of persona data: See Section 2.

Uses of personal data: The business and commercial purposes for which we collect personal data are outlined in Sections 4 and 6 of this document.

Disclosing personal data: Our data disclosure practices are outlined in the table below and correspond to the information provided in Sections 3, 5, and 6 of this document. We do not sell (as the CCPA defines the word) personal information, including information on individuals under the age of 16.

Categories	Examples	Collected
Identifiers	Real name, alias, postal address, unique personal identifier, online identifiers (such as various advertising identifiers), instant messaging ID, internet protocol (IP) address, email address, account or user name, phone number, social media identifiers, or other similar identifiers.	Yes
Personal information	Name, signature, address, telephone number, insurance policy number, bank account number, credit card number, or any other financial data. Some of the personal information in this category may overlap with information in other categories.	Yes
Demographic Information	Age, race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth, and related medical conditions), sexual orientation, veteran or military status, and genetic information are prohibited from discrimination (including familial genetic information).	No
Commercial information	Creditworthiness records, items or services purchased, received, or pondered, and other purchasing or consumption histories or patterns.	Yes
Biometric information.	Genetic, physiological, behavioral, and biological characteristics or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	No
Internet or other electronic network activity	Browsing history, search history, and customer engagement data with a website, application, or advertisement.	Yes
Geolocation information	Physical location or movements from your IP address or mobile device.	Yes
Sensory Information	Audio, electronic, visual, thermal, olfactory, or similar information.	No
Non-public education information	Education documents directly pertaining to a student, such as grades, transcripts, class lists, student timetables, student identification numbers, student financial information, and disciplinary records.	No
Inferences	Profile of a person's preferences, traits, psychological tendencies, predispositions, behavior, attitudes, IQ, skills, and aptitudes.	Yes

Your Rights:

Certain California residents may exercise the following rights, subject to legal restrictions, by using our webform or by contacting us at [email protected].

- Right to Know. You may request information regarding the categories of personal data we have collected about you, the categories of sources from which we collected the data, the purposes for collecting the data, the categories of third parties to whom we have disclosed your personal data, and the purpose for which we disclosed your personal data ("Categories Report"). You may also request the specific pieces of personal information we've collected about you ("Specific Pieces Report").

- Right to Delete. You have the right to request the deletion of any personal information we have collected from you.

- Right to Opt Out. We do not sell personal information.

For exercising these rights, we shall not discriminate against you in any manner forbidden by relevant law.

Verification. Depending on the nature of the request, we will require information to locate you in our records or verify your identity in order to execute requests. Typically, we will seek information about you, such as your name, email address, and other details. If you submit a Right to Know Specific Pieces Report, we may additionally seek a signed certification that you are who you claim to be, under penalty of perjury. Under specific conditions, we may require alternative information and/or utilize third parties to authenticate your identification.

Authorized Agents. Authorized agents may exercise rights on behalf of California customers, but we reserve the right to verify the identification of the consumer directly as specified above. Authorized agents must make a request using our webform and declare that they are acting as agents. Agents must provide evidence of the agent's identity, registration with the California Secretary of State (if the agent is a business), and at least one of the following documents evidencing proof of the agent's legal authority to act on behalf of the individual consumer: I Power of Attorney that we can reasonably verify; or (ii) Consumer's signed permission.

Timing. We will reply to Requests to Delete and Requests to Know within 45 days, unless we require further time, in which case we will contact you and may take up to 90 days to respond to your request.

14. Supplemental Information for Other Regions

Canada: Shipber collect, save, use, and/or process personal data, as defined by the Personal Information Protection and Electronic Documents Act ("PIPEDA"), in line with its duties under PIPEDA.

Nevada: We do not now sell personal data. If you are a Nevada resident, you may exercise your right to opt-out of sale under Nevada Revised Statutes 603A et seq. by sending us an email at the aforementioned address.

United Kingdom. Shipber collects, stores, uses, and/or processes personal data in accordance with its obligations under the UK Data Protection Act 2018, as amended by the Data Protection, Privacy and Electronic Communications (Amendments etc.) (EU Exit) Regulations 2019, as amended, superseded, or replaced ("UK GDPR").

15. English Version Controls

Non-English versions of this notification are provided only for your convenience. In cases of uncertainty or disagreement between translations, the English version is official and prevails.