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Privacy Policy

Last updated 10/1/2024

This Privacy Notice for Winchester Cold Storage Co. (“we,” “us,” or “our”), describes how and
why we might access, collect, store, use, and/or share (“process”) your personal information
when you use our services (“Services”), including when you:

  • Visit our website at http://www.wcslogistics.com, or any website of ours that links to this Privacy Notice
  • Engage with us in other related ways, including any sales, marketing, or events

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services.

SUMMARY OF KEY POINTS

This summary provides key points from our Privacy Notice, but you can find out more
details about any of these topics by clicking the link following each key point or by using
our table of contents below to find the section you are looking for.

What personal information do we process? When you visit, use, or navigate our Services,
we may process personal information depending on how you interact with us and the Services,
the choices you make, and the products and features you use. Learn more about personal
information you disclose to us.

Do we process any sensitive personal information? Some of the information may be
considered “special” or “sensitive” in certain jurisdictions, for example your racial or ethnic
origins, sexual orientation, and religious beliefs. We do not process sensitive personal
information.

Do we collect any information from third parties? We do not collect any information from
third parties.

How do we process your information? We process your information to provide, improve, and
administer our Services, communicate with you, for security and fraud prevention, and to
comply with law. We may also process your information for other purposes with your consent.
We process your information only when we have a valid legal reason to do so. Learn more
about how we process your information.

In what situations and with which parties do we share personal information? We may
share information in specific situations and with specific third parties. Learn more about when
and with whom we share your personal information.

How do we keep your information safe? We have adequate organizational and technical
processes and procedures in place to protect your personal information. However, no electronic
transmission over the internet or information storage technology can be guaranteed to be 100%
secure, so we cannot promise or guarantee that hackers, cybercriminals, or
other unauthorized third parties will not be able to defeat our security and improperly collect,
access, steal, or modify your information. Learn more about how we keep your information safe.

What are your rights? Depending on where you are located geographically, the applicable
privacy law may mean you have certain rights regarding your personal information. Learn more
about your privacy rights.

How do you exercise your rights? The easiest way to exercise your rights is by submitting
a data subject access request, or by contacting us. We will consider and act upon any request
in accordance with applicable data protection laws.

Want to learn more about what we do with any information we collect? Review the Privacy
Notice in full.

TABLE OF CONTENTS

  1. WHAT INFORMATION DO WE COLLECT?
  2. HOW DO WE PROCESS YOUR INFORMATION?
  3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
  4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
  5. HOW LONG DO WE KEEP YOUR INFORMATION?
  6. HOW DO WE KEEP YOUR INFORMATION SAFE?
  7. DO WE COLLECT INFORMATION FROM MINORS?
  8. WHAT ARE YOUR PRIVACY RIGHTS?
  9. CONTROLS FOR DO-NOT-TRACK FEATURES
  10. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
  11. DO WE MAKE UPDATES TO THIS NOTICE?
  12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
  13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
  14. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you express an interest
in obtaining information about us or our products and Services, when you participate in activities
on the Services, or otherwise when you contact us.

Sensitive Information. We do not process sensitive information.

All personal information that you provide to us must be true, complete, and accurate, and you
must notify us of any changes to such personal information.

  1. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services,
communicate with you, for security and fraud prevention, and to comply with law. We may also
process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you
interact with our Services, including:

  1. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with
the following third parties.

We may need to share your personal information in the following situations:
Business Transfers. We may share or transfer your information in connection with, or
during negotiations of, any merger, sale of company assets, financing, or acquisition of
all or a portion of our business to another company.

  1. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your
information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to gather
information when you interact with our Services. Some online tracking technologies help us
maintain the security of our Services, prevent crashes, fix bugs, save your preferences, and
assist with basic site functions.

We also permit third parties and service providers to use online tracking technologies on our
Services for analytics and advertising, including to help manage and display advertisements, to
tailor advertisements to your interests, or to send abandoned shopping cart reminders
(depending on your communication preferences). The third parties and service providers use
their technology to provide advertising about products and services tailored to your interests
which may appear either on our Services or on other websites.

To the extent these online tracking technologies are deemed to be a “sale”/”sharing” (which
includes targeted advertising, as defined under the applicable laws) under applicable US state
laws, you can opt out of these online tracking technologies by submitting a request as described
below under section “DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?”

Specific information about how we use such technologies and how you can refuse certain
cookies is set out in our Cookie Notice.

Google Analytics

We may share your information with Google Analytics to track and analyze the use of the
Services. To opt out of being tracked by Google Analytics across the Services,
visit https://tools.google.com/dlpage/gaoptout. For more information on the privacy practices of
Google, please visit the Google Privacy & Terms page.

  1. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in
this Privacy Notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set
out in this Privacy Notice, unless a longer retention period is required or permitted by law (such
as tax, accounting, or other legal requirements).

When we have no ongoing legitimate business need to process your personal information, we
will either delete or anonymize such information, or, if this is not possible (for example, because
your personal information has been stored in backup archives), then we will securely store your
personal information and isolate it from any further processing until deletion is possible.

  1. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and
technical security measures.

We have implemented appropriate and reasonable technical and organizational security
measures designed to protect the security of any personal information we process. However,
despite our safeguards and efforts to secure your information, no electronic transmission over
the Internet or information storage technology can be guaranteed to be 100% secure, so we
cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties

will not be able to defeat our security and improperly collect, access, steal, or modify your
information. Although we will do our best to protect your personal information, transmission of
personal information to and from our Services is at your own risk. You should only access the
Services within a secure environment.

  1. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly collect, solicit data from, or market to children under 18 years of age, nor
do we knowingly sell such personal information. By using the Services, you represent that you
are at least 18 or that you are the parent or guardian of such a minor and consent to such minor
dependent’s use of the Services. If we learn that personal information from users less than 18
years of age has been collected, we will deactivate the account and take reasonable measures
to promptly delete such data from our records. If you become aware of any data we may have
collected from children under age 18, please contact us at __.

  1. WHAT ARE YOUR PRIVACY RIGHTS?

In Short:  You may review, change, or terminate your account at any time, depending on your
country, province, or state of residence.

Withdrawing your consent: If we are relying on your consent to process your personal
information, which may be express and/or implied consent depending on the applicable law, you
have the right to withdraw your consent at any time. You can withdraw your consent at any time
by contacting us by using the contact details provided in the section “HOW CAN YOU
CONTACT US ABOUT THIS NOTICE?” below.

However, please note that this will not affect the lawfulness of the processing before its
withdrawal nor, when applicable law allows, will it affect the processing of your personal
information conducted in reliance on lawful processing grounds other than consent.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If
you prefer, you can usually choose to set your browser to remove cookies and to reject cookies.
If you choose to remove cookies or reject cookies, this could affect certain features or services
of our Services.

  1. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-
Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to
have data about your online browsing activities monitored and collected. At this stage, no
uniform technology standard for recognizing and implementing DNT signals has been finalized.
As such, we do not currently respond to DNT browser signals or any other mechanism that
automatically communicates your choice not to be tracked online. If a standard for online
tracking is adopted that we must follow in the future, we will inform you about that practice in a
revised version of this Privacy Notice.

California law requires us to let you know how we respond to web browser DNT signals.
Because there currently is not an industry or legal standard for recognizing or honoring DNT
signals, we do not respond to them at this time.

  1. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana,
Iowa, Kentucky, Montana, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, or
Virginia, you may have the right to request access to and receive details about the personal
information we maintain about you and how we have processed it, correct inaccuracies, get a
copy of, or delete your personal information. You may also have the right to withdraw your
consent to our processing of your personal information. These rights may be limited in some
circumstances by applicable law. More information is provided below.

Sources of Personal Information

Learn more about the sources of personal information we collect in “WHAT INFORMATION DO
WE COLLECT?”

How We Use and Share Personal Information

Learn about how we use your personal information in the section, “HOW DO WE PROCESS
YOUR INFORMATION?”

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written
contract between us and each service provider. Learn more about how we disclose personal
information to in the section, “WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL
INFORMATION?”

We may use your personal information for our own business purposes, such as for undertaking
internal research for technological development and demonstration. This is not considered to
be “selling” of your personal information.

We have not disclosed, sold, or shared any personal information to third parties for a business
or commercial purpose in the preceding twelve (12) months. We will not sell or share personal
information in the future belonging to website visitors, users, and other consumers.

Your Rights

You have rights under certain US state data protection laws. However, these rights are not
absolute, and in certain cases, we may decline your request as permitted by law. These rights
include:

  • Right to know whether or not we are processing your personal data
  • Right to access your personal data
  • Right to correct inaccuracies in your personal data
  • Right to request the deletion of your personal data
  • Right to obtain a copy of the personal data you previously shared with us
  • Right to non-discrimination for exercising your rights
  • Right to opt out of the processing of your personal data if it is used for targeted advertising (or sharing as defined under California’s privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects (“profiling”)


Depending upon the state where you live, you may also have the following rights:

  • Right to obtain a list of the categories of third parties to which we have disclosed personal data (as permitted by applicable law, including California’s and Delaware’s privacy law)
  • Right to obtain a list of specific third parties to which we have disclosed personal data (as permitted by applicable law, including Oregon’s privacy law)
  • Right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including California’s privacy law)
  • Right to opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature (as permitted by applicable law, including Florida’s privacy law)

How to Exercise Your Rights

To exercise these rights, you can contact us by submitting a data subject access request, by
emailing us at info@wcslogistics.com, or by referring to the contact details at the bottom of this
document.

Under certain US state data protection laws, you can designate an authorized agent to make a
request on your behalf. We may deny a request from an authorized agent that does not submit
proof that they have been validly authorized to act on your behalf in accordance with applicable
laws.

Request Verification

Upon receiving your request, we will need to verify your identity to determine you are the same
person about whom we have the information in our system. We will only use personal
information provided in your request to verify your identity or authority to make the request.
However, if we cannot verify your identity from the information already maintained by us, we
may request that you provide additional information for the purposes of verifying your identity
and for security or fraud-prevention purposes.

If you submit the request through an authorized agent, we may need to collect additional
information to verify your identity before processing your request and the agent will need to
provide a written and signed permission from you to submit such request on your behalf.

Appeals

Under certain US state data protection laws, if we decline to take action regarding your request,
you may appeal our decision by emailing us at info@wcslogistics.com. We will inform you in
writing of any action taken or not taken in response to the appeal, including a written
explanation of the reasons for the decisions. If your appeal is denied, you may submit a
complaint to your state attorney general.

California “Shine The Light” Law

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our
users who are California residents to request and obtain from us, once a year and free of
charge, information about categories of personal information (if any) we disclosed to third
parties for direct marketing purposes and the names and addresses of all third parties with
which we shared personal information in the immediately preceding calendar year. If you are a
California resident and would like to make such a request.

  1. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by
an updated “Revised” date at the top of this Privacy Notice. If we make material changes to this
Privacy Notice, we may notify you either by prominently posting a notice of such changes or by
directly sending you a notification. We encourage you to review this Privacy Notice frequently to
be informed of how we are protecting your information.

  1. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may contact us by post at:

Winchester Cold Storage
PO Box 45
Winchester, VA 22604

  1. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country or state of residence in the US, you may have the
right to request access to the personal information we collect from you, details about how we
have processed it, correct inaccuracies, or delete your personal information. You may also have
the right to withdraw your consent to our processing of your personal information. These rights
may be limited in some circumstances by applicable law. To request to review, update, or delete
your personal information, please fill out and submit a data subject access request.