Shipito LLC（"Shipito"）は、ロジスティックスを提供し、顧客に代理購入サービスを提供し、購入された製品の国際配送を可能にしました。Shipitoは、グローバル・アクセス・グループ（LLC）の完全子会社です。Shipitoのサービスは以下を含みます：製品購入、ロジスティックス、保険、保管、再梱包、荷物転送、貨物輸送、通関、また、市場および使用分析や工業情報およびプロモーションの推奨を含む助言サービス

Shipitoは国内配達、保険、保管、再梱包、購入された製品の国際配送を提供します。製品の配送先は、弊社の顧客宛、または、弊社の顧客により提供される発送先宛の可能性もあります。Shipitoは製品の出荷可否を確認し、顧客から提供された『発送先』が米国調整当局によって輸送制限を受けていない事を確認します。Shipitoは国際配送にまつわる通関を容易にします。提供される追加サービスは、エンドユーザーであるクライアントが自分自身で小売業者から直接購入することができない製品について実際の購入をShipitoが容易にする「代理購入」プログラムです。データは、www.shipito.comを通して顧客から直接収集されます。

Shipitoは、アメリカ合衆国で会社のオフィスや倉庫を維持します。Shipitoは、ロジスティックス、支払、保険およびコミュニケーションを含むサービスを提供するために、第三者の業者を利用します。通関のための条例により、個人データを調整当局と共有することは義務づけられています。

グローバル・アクセス・グループ（LLC）の完全子会社として、弊社は世界的データプライバシーポリシーに準じます。そして、それは下のリンクにアクセスすることによってご覧いただけます：

https://www.globalaccess.com/about/Global-Data-Privacy-Policy

このプライバシーに関する声明は、直接Shipitoに関係がある特定の情報を詳述します。

Shipito（LLC）は、個人情報の収集、使用、保持に関して欧州連合からアメリカ合衆国に移行され米国商務省によって陳述される欧州‐米国プライバシー・シールド・フレームワークに準じます。Shipito（LLC）は、プライバシー・シールドの原則を厳守することを商務省に証明しました。このプライバシーポリシーとプライバシー・シールドの原則において条件が対立する場合、プライバシー・シールドの原則が優先されます。プライバシー・シールドのプログラムに関する詳細および弊社の証明については、https://www.privacyshield.gov/listをご参照ください。

Shipitoは、親会社であるグローバル・アクセス・グループ（LLC）の下で保証されます。

弊社は、(a)あなたが顧客として弊社へ活発に提出する個人情報、(b)顧客から受け取る個人情報、(c)潜在的クライアント、顧客またはその他マーケティング目的のための個人情報を収集します。弊社は、自動手段の有無にかかわらず、収集、記録、組織、構築、保管、適合または変更、検索、協議、使用、伝達による公表、普及またはさもなければ利用可能にする、あなたの個人情報の配列または組合せ、制限、抹消または破棄を含めて、あなたの個人情報を利用する可能性があります。

1. 能動的に提出されたデータ 弊社のウェブサイトを通して弊社のアカウント登録、弊社のサービスを購入、または、弊社の組織やその他との交流もしくは通信自時に、あなたは個人データを弊社に提出します。弊社は通常、名前、物理的な住所、電話番号、電子メールアドレスおよび支払情報を処理します。

   詐欺または通常の必要条件の認証可否に危険性があるかどうか確かめる場合、あなたの身分証明の認証のために、弊社は識別情報を処理する可能性があります。識別情報は、写真、パスポート番号、パスポートの写真複写または電子コピー、運転免許証の番号、運転免許証の写真複写または電子コピー、国家の個人識別番号、公共料金またはこの目的のために要請されるその他の書類の写真複写または電子コピーを含む可能性があります。識別情報は、必要に応じてのみ収集されます。要請される識別情報の提供を怠ると、あなたの弊社アカウントのステータスに影響を与える可能性があります。

   You may provide us with additional information to participate at your own initiative in surveys, feedback comments, online chat services, promotions or other activities. Participation in surveys, feedback comments, online chat services, promotion or other similar activities is optional. If you do not wish to participate in, or provide personal data in connection with such activities, this will not affect your account status or ability to use available services. In each such case you will know what personal data you provide us with because you actively and voluntarily submit the data.

   We also offer our customers registered under our Affiliate Program commissions for referring new customers to us who use our services. Upon registration in the affiliate program they are assigned a URL with a unique Affiliate ID to use in their own marketing efforts. That affiliate ID is then tied to any new account registration sourced from the affiliate's URL. The data of customers who sign-up through an Affiliate is treated the same as if the customer sought us out directly.

2. Data received from our Customers. Customers identify a 'Ship-to' party and delivery destination for packages that we ship at their request. The 'Ship-to' party and delivery address do not need to match the personal information provided by the customer upon registration. The main reasons for the personal information differing is where the customer is purchasing and shipping products on behalf of another person, as a gift for another person, or to another person who will receive the products on their behalf. The personal information collected generally includes the name, physical address and phone number of the 'Ship-to' party. Processing of this personal data is performed on behalf of the customer and for the purpose of providing the services requested by the customer. No active marketing is performed on personal data of the 'Ship-to' party.

3. Data obtained for marketing purposes for potential clients, customers or others. We obtain marketing data that we use to reach out to inform potential clients, customers and others of the services offered by our organization. The personal data collected generally includes the email address of a potential client, customer or contact and may also include their name and phone number.

4. Personal Data not actively collected or Processed. We do not actively collect or otherwise process personal data from minors and include in our Terms and Conditions a condition that the customer is not a minor and does not provide personal data of minors. The age of a minor varies by country. For the purposes of personal data collected from the European Union, the age of a minor is under age sixteen (16).

   We do not actively collect or otherwise process special categories of personal data as identified in the GDPR including data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade-union membership, or genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation.

   We do not actively collect or otherwise process personal data relating to criminal convictions and offences.

We use tracking technologies, cookies and clear GIFs to collect information. Tracking technologies are used to collect information from your web browser through our servers or filtering systems when you visit any of our sites. Cookies are small bits of data used to transfer information to your computer's hard drive or your web browser for record-keeping purposes, including recognizing your web browser when you return to our sites. A clear GIF is a transparent graphic image placed on a website. The use of clear GIFs allows us to monitor your actions when you open a web page and makes it easier for us to follow and record the activities of recognized browsers. Clear GIFs are used in combination with cookies to obtain information on how visitors interact with our websites.

Information collected may include but is not limited to your browser type, your operating system, your language preference, any referring web page you were visiting before you came to our site, the date and time of each visitor request, and information you search for on our sites. We can also track the path of page visits on a website and monitor aggregate usage and web traffic routing on our sites. We collect this information to better understand how you use and interact with our sites in order to improve your experience. We also collect this information to better understand what services and marketing promotions may be more relevant to you. We may also share this information with our employees, service providers and customer affiliates as well as between affiliated entities.

You can change your web browser settings to stop accepting cookies or to prompt you before accepting a cookie from the sites you visit. If you do not accept cookies, however, you may not be able to use some sections or functions of our sites.

To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit http://www.allaboutcookies.org.

To opt out of being tracked by Google Analytics across all websites visit https://tools.google.com/dlpage/gaoptout.

We process personal data for logistics, payment, insurance, customs, tax, other regulatory requirements, communication, customer service, marketing, web analytics, system monitoring, data security, other operational and administrative purposes, and Advisory Services, including market and use information, industry information and promotional recommendations.

We use personal data to provide logistics and other related services to enable international product purchase and delivery for our customers while meeting the regulatory requirements of the relevant countries. We may use personal data to (a) purchase product for you, (b) package and inventory product for you, (c) store product for you, (d) deliver product to you, (e) insure product, (f) submit customs or other regulatory forms on your behalf, (g) contact you, (h) create and maintain an account profile, (i) fulfill requests you make. (j) seek your voluntary feedback, (k) customize features or content on our websites and software, (l) evaluate eligibility to participate in promotions, (m) verify identity, (n) administer our services, including through use of third-party services providers, (o) provide our Advisory Services, including market and use analysis, industry information and promotional recommendations, or (p) communicate with you for marketing purposes.

In this context, the legal basis for our processing of your personal data is either the necessity to perform contractual and other obligations that we have towards you or carrying out our legitimate activities as a logistics organization.

We may also use your data to comply with applicable laws and exercise legal rights as the basis for our data processing.

We may also use your personal data for internal purposes, including auditing, data analysis, system troubleshooting, and research. In these cases, we base our processing on legitimate interests in performing the activities of the organization.

We share your personal data with other parties in the following circumstances:

1. Third-Party Providers. We may provide personal data to third parties for their processing in performing functions on our behalf (for example, logistics, insurance, payments, security, data analysis, surveys, and so forth). In such instances, the providers will be contractually required to protect personal data from additional processing (including for marketing purposes) and transfer in accordance with this Privacy Statement and applicable laws. This may include transfers or onward transfers to third parties that are outside of the EEA and outside of the United States. In these circumstances, relevant protections approved under the GDPR will be undertaken to protect your personal data. Under certain data protection laws, including the GDPR, Shipito is liable if a third-party provider that we have engaged to process personal data fails to fulfil its data protection obligations.

2. Organizational Entities. We may transfer personal data from Shipito to Global Access, LLC, in order to facilitate logistics and related services. A data sharing and processing agreement has been concluded between the two entities to ensure that Global Access, LLC, is contractually required to protect personal data from additional processing and transfer outside of the purposes stipulated by Shipito.

3. Legal Requirements. We may access and disclose your personal data to regulatory bodies if we have a good-faith belief that doing so is required under regulation. This may include screening against the Consolidated Screening List for which the United States Government maintains restrictions on certain exports, re-exports or transfers of items. This may also include submitting personal data required by local customs authorities and tax authorities. Additionally, we may disclose your personal data and other information as required by law, including in response to lawful requests by public authorities or to meet national security or law enforcement requirements. We may also disclose your personal data to exercise or defend legal rights; to take precautions against liability; to protect the rights, property, or safety of the resource, of any individual, or of the general public; to maintain and protect the security and integrity of our services or infrastructure; to protect ourselves and our services from fraudulent, abusive, or unlawful uses; or to investigate and defend ourselves against third-party claims or allegations.

We may store your personal data in data centers in the United States, cloud storage solutions, or on our premises, including corporate offices and warehouses. To ensure the adequacy of protection of data that we transfer between Shipito and Global Access, LLC, we have concluded a data transfer and processing agreement between these entities. You may be entitled to review our data sharing and processing agreements if you contact us per the contact details provided at the end of this Privacy Statement. We endeavor to utilize third-party service providers from the United States that have certified with the EU-U.S. Privacy Shield Framework.

Shipito uses technical and organizational measures to protect the personal data received against accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to Personal data transmitted, stored or otherwise processed. We regularly consider appropriate new security technology and methods as we maintain and develop our software and systems. Security measures implemented include:

1. SSL is used on all pages where personal data is collected;
2. Data requiring a higher level of protection, such as payment card account numbers and passport numbers, is encrypted prior to transmission to the database for storage;
3. Web and database servers are protected using firewalls;
4. Passwords used for account registration cannot be 'defaulted';
5. User access is tracked;
6. Role-based security is applied to system access;
7. All employees are contractually obligated to maintain the confidentiality of personal data accessible through their employment;
8. Regular system backups are made;
9. Regular maintenance is performed on systems; and
10. Systems are monitored for security.

Shipito retains collected personal data for a reasonable period of time to fulfill the processing purposes mentioned above. Personal data is then archived for time periods required or necessitated by law or legal considerations. When archival is no longer required, personal data is deleted from our records.

Shipito offers you a choice to sign up with a free Standard account or a paid Premium account. The Premium account offers either monthly or annual subscription payment options.

For Standard accounts, the account is automatically deactivated and deleted if there has not been any activity on the account for a 2-year period. The time period of 2 years is selected based upon typical customer trends, where some customers may only choose to use the services on occasion. This period is also necessary to accommodate customers who have been required to verify their identity so that this process does not have to be started over with a new account unnecessarily. If you wish us to deactivate your account sooner than this time period, please contact us. Our contact details are provided at the end of this Privacy Statement.

For Premium accounts, fees are automatically charged to the account on file per the monthly or annual subscription option selected. At any time, you may choose to change your account to a Standard account. If the account fees are unpaid, the Premium account automatically changes to a Standard account, which automatically deactivates and deletes if there has not been any activity on the account for a 2-year period. If you wish us to deactivate your account sooner than this time period, please contact us. Our contact details are provided at the end of this Privacy Statement.

We continue to retain personal data that we are required to retain in order to meet our regulatory obligations including tax records and transaction history. We comply with the Retention Policy of our parent company Global Access Group, LLC, which is regularly reviewed to ensure compliance with our obligations under data protection laws and other regulatory requirements. We regularly audit our databases and archived information to ensure that personal data is only stored and archived in alignment with the Retention Policy.

We rely upon our customers maintaining the accuracy of the personal data they provide through our website, www.shipito.com, including the ability to add, edit and delete contact, payment and delivery information. Where you are the account holder, you may view and edit the personal data you have provided by accessing your account online under the Account Profile menu online.

You may reach out to the customer that provided your personal data and request that they make any required update under the Account Profile menu of their registered account, including deletion of your personal data. This typically occurs where you have received delivery of a package that was arranged by another person.

For marketing communication an 'unsubscribe' option is provided in the footer of every marketing communication. In addition, we may be contacted directly to unsubscribe. Our contact details are provided at the end of this Privacy Statement.

You may also contact us with your personal data inquiries or for assistance in modifying or updating your personal data and to exercise additional statutory rights such as: access, rectification, data portability, objection, processing restriction, and erasure of your personal data. Our contact details are provided at the end of this Privacy Statement.

Shipito participates in the EU-U.S. Privacy Shield Framework, under Global Access Group, LLC. A list of participants can be viewed by accessing the link below:

https://www.privacyshield.gov/list.

As part of its participation in the EU-U.S. Privacy Shield Framework, Shipito is subject to the investigatory and enforcement powers of the Federal Trade Commission.

Organizations participating in the EU-U.S. Privacy Shield Framework must respond within 45 days of receiving a complaint. If you have not received a timely or satisfactory response to your question or complaint, please contact one of the independent recourse mechanisms listed below:

1. EU Data Protection Authorities ("DPAs")

   http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm

Please note that these independent dispute resolution bodies are designated to address complaints and provide appropriate recourse free of charge to the individual.

Under certain circumstances, individuals located in the European Economic Area may invoke binding arbitration to resolve a Privacy Shield related dispute. In order to invoke arbitration, you must take the following steps prior to initiating an arbitration claim: (1) raise your complaint directly with Shipito and provide us the opportunity to resolve the issue; (2) make use of the independent recourse mechanism listed above; and (3) raise the issue through your relevant Data Protection Authority to the U.S. Department of Commerce and afford the U.S. Department of Commerce an opportunity to use best efforts to resolve the issue at no cost to you. For more information on binding arbitration, see the U.S. Department of Commerce's Privacy Shield Framework: Annex I (Binding Arbitration) at: https://www.privacyshield.gov/article?id=ANNEX-I-introduction.

This document is effective May 25, 2018. This document may be amended from time to time.

Inquiries may be made to:

Organization:	Global Access Group, LLC.
Contact:	Data Protection Officer (Chris Bauer)
Address:	9815 South Monroe St, Suite 510, Salt Lake City, UT 84070
Email:	[email protected]

EU Representative

Contact:	EU Representative (Daniel Eigner)
Address:	Rastenfeld 151 Rastenfeld, 3532 Austria
Email:	[email protected]

You may also contact our customer support through our online chat option, by creating a support ticket in the customer portal or emailing customer support at [email protected].

Please note that organizations participating in the EU-U.S. Privacy Shield Framework must respond within 45 days of receiving a complaint.