1. Introduction and scope

RSL Logistics, its subsidiaries, and affiliates (collectively “RSL Logistics,” “RSL,” “We,” “Us,” or “Our”) respects the privacy of you (“Users”) of our Services and the visitors of our digital properties, and we are committed to protecting it through our adherence to this Privacy Policy. Our mission as a courier and logistics provider and package delivery service is to combine reliable technology with local expertise to deliver efficiency, reliability and trust.

This Privacy Policy describes how RSL Logistics collects, stores, uses and safeguards your personal information when you use our website such as https://rsl-logistics.com/ (the “Website”), our owned and operated RSL Logistics-branded mobile applications (“RSL Apps”), and through any other websites, pages, features or content owned and operated by RSL Logistics that direct to this Privacy Policy (“Content,” and, collectively, including the Website and RSL Apps, the “Services”). This Policy applies to all Users of RSL Logistics Services within the territories of the United States.

By using our Services, you acknowledge that we will collect and process your personal information in accordance with this Privacy Policy, and you consent to the practices and terms set forth in our Terms of Use, available at https://rsl-logistics.com/terms-of-use. If you do not feel comfortable with any part of this Privacy Policy or our Terms of Use, please discontinue use of the Services or engaging with RSL Logistics immediately.

Table of Contents

1. Introduction and scope

2. Personal information we collect about you and how we collect it

3. The types of personal information we collect

4. How we use your personal information

5. Cookies and similar tracking technologies

6. Sharing and disclosure of your personal information

7. Data security

8. Personal information retention

9. Storing and transferring your personal information

10. Your privacy rights and choices

11. Notice to California residents

12. Children’s privacy

13. Links to other websites

14. Updates to this Privacy Policy

15. Contact Us

2. Personal information we collect about you and how we collect it

RSL Logistics collects personal information when you interact with our Services. The definition of personal information (used interchangeably in this Privacy Policy with the term “personal data”) depends on the applicable law based on your place of residence or physical location, but for purposes of this Privacy Policy, personal information generally is any information that identifies or makes a unique individual identifiable. Only the definition that applies to your residence or physical location will apply to you under this Privacy Policy.

a. We collect your personal information that you provide to us;

•When you create or update an online account with us;

•When you submit any form or application, including but not limited to, application forms relating to any of our RSL Logistics Services whether online or offline;

•When you use or interact with the RSL Logistics Services;

•When you directly communicate with us including our customer support, through phone calls (which may be recorded), emails, leave a comment, and other interactive features on the Website; and

•When you grant access to device features, such as to provide us access to your device’s location information.

b. We also collect personal information automatically when you visit or use our Website through the use of cookies, tracking pixels, data analysis tools and any other technologies, as further described in Section 5 below and in our Cookie Notice available at https://rsl-logistics.com/cookie-policy.

c. We additionally collect personal information about you from third parties and other sources, including:

•Personal information from third parties, including our business partners, service providers, and other third parties we have contracted with in connection with the delivery of the Services.

•Personal information provided to us via the Website including the RSL App by individuals or entities that are engaged in connection with RSL Logistics’ delivery services (“Delivery Drivers”). The RSL App is intended to assist in facilitation of the delivery services, by providing Delivery Drivers with information and services related to the delivery services, and by enabling the exchange of information between Delivery Drivers and us or our delivery service providers.

3. The types of personal information we collect

The types and examples of personal information we collect or receive includes:

Account Information

Name (first, middle and last name), email, phone number, login name and password, address, payment or banking information.

Location Information

Precise or approximate location data collected from users’ devices; physical location or movements, including the time and date of registration, arrival, and departure related to performance of Delivery Drivers.

Usage Information

Access dates and times, app features or pages viewed, browser type, and app caches and other system activity.

Transaction Information

Delivery services requested and provided, including delivery details such as date and time, shipper’s and recipient’s names, addresses, email addresses and telephone numbers; and payment transaction information (including amount for payment and payment method).

Other information we collect relating to shipments and delivery services includes shipment tracking number, shipment routing information, location data, status of a shipment, delivery location, packaging type, number of pieces, weight, prices, picture of the parcel, and proof of delivery and receipt of the package.

Device Information

The hardware models, device IP address or other unique device identifiers, operating systems and versions, software, device motion data, mobile network data, internet and electronic network activity such as browsing and search history, advertising identifiers, marketing and communication preferences.

Communications Information

Communication type (phone, leave a comment, email or in-app message), date and time, and content (including recordings of phone calls).

Personal Information from Other Resources

Personal information from or in connection with:

•Claims or disputes

•RSL Logistics’ business partners or service providers through which users including Delivery Drivers create or access their individual accounts

•Vendors who help verify users or detect fraud

•Insurance, vehicle or financial service providers

•Partner transport companies

•Publicly available sources

•Marketing service providers

•Law enforcement officials, public health officials, and other government authorities

You agree not to submit any personal information to us that is false, inaccurate, or misleading, and you agree to inform us of any inaccuracies or changes in such personal information. We reserve the right, at our sole discretion, to request further documentation to verify the personal information provided by you. By requesting RSL Logistics Services, you agree to voluntarily provide the personal information to us for us to provide the requested services.

4. How we use your personal information

We take your personal information seriously, and personal information shall only be collected, used, stored or otherwise processed, when necessary, within the framework of responsible, efficient and effective business management of RSL Logistics. RSL Logistics processes personal information for the following lawful, business purposes:

•To provide you with our Services and to perform agreements. This includes shipping services, tracking RSL Logistics services, communication with our contractual customer, shipper and other parties regarding services, responding to requests for further information, dispute resolution and preparing agreements (e.g., link the shipment tracking number to your account to enable you to follow your shipment).

•Product development, research and improvement of RSL Logistics products and/or services. RSL Logistics processes personal information as necessary for the development and improvement of RSL Logistics products and/or services, research and development (e.g., analyze information related to the shipment and services to improve our services).

•Relationship management and marketing for commercial activities. In general, RSL Logistics processes personal information as necessary for the development and improvement of RSL Logistics products and/or services, account management, marketing and the provision of customer services to establish a relationship with a customer and/or maintaining as well as extending a relationship with a customer or business partner and for performing analyses with respect to personal information for statistical purposes.

•Business process execution, internal management and management reporting. This includes addressing activities such as managing company assets, conducting internal audits and investigations, finance and accounting, implementing business controls, provision of central processing facilities for efficiency purposes, managing mergers, acquisitions and divestitures and processing personal information for management reporting and analysis.

•Security and Protection. The processing of data for processes such as those related to safety, protecting RSL Logistics and its customers, or business partners, and authenticating the status and access rights (e.g. providing secure services for online and offline transactions) of customers or business partners to combat spam, malware or security risks as part of our ongoing maintenance and enforcement of security measures.

•Protecting the vital interests of individuals. This includes processing data when necessary to protect your vital interests or those of other individuals (e.g., for urgent safety reasons).

•To enforce our agreements or policies. This includes processing personal information to enforce rights arising from a contract entered into between you and us, including for billing and collection.

•Furthering workforce operations. This includes evaluating hiring applications and promotion requests, benefits and payroll administration, and performing employee evaluations. We may also collect data points that may be considered “sensitive personal information” under applicable law from employees and members of our workforce, such as Social Security Numbers, driver’s license numbers, precise geolocation, and biometric information, for the purpose of uniquely identifying you and for the security of our facilities.

•Compliance with legal obligations. This addresses the processing of personal information as necessary for compliance with laws and regulations to which RSL Logistics is subject (e.g., checking the names of customers and business partners against blacklists to avoid conflicts of interest, compliance with trade regulations, anti-money laundering and anti-corruption regulations and other policies, paying taxes, compliance with employment and recruitment laws, and following required procedures and regulations).

•With your consent. We process your personal information for any other purpose disclosed to you prior to you providing us your personal information or which is reasonably necessary to provide the Services or other related products and/or services requested, with your permission or upon your direction.

5. Cookies and similar tracking technologies

We use cookies and other analytical or identification technologies on our apps, website, and emails for purposes described in this Policy. Through these cookies and other technologies, we automatically obtain certain personal information as described in this Policy when you visit or use our Website. To learn more about the cookies and similar technologies, please consult our Cookie Notice available at https://rsl-logistics.com/cookie-policy.

Your browser may provide you with the option to refuse some or all browser cookies. You may also be able to remove cookies from your browser. You can exercise your preferences in relation to cookies served on our Website by taking the steps outlined below.

•First-Party Cookies. You can use the browser with which you are viewing this Website to enable, disable or delete cookies. To do this, follow the instructions provided by your browser (usually located within the “Help”, “Tools” or “Edit” settings). Please note, if you set your browser to disable cookies, you may not be able to access secure areas of the Website. Also, if you disable cookies, other parts of the Website may not work properly. You can find more information about how to change your browser cookie settings at http://www.allaboutcookies.org.

•Third-Party Cookies. Many advertising companies that collect information for interest-based advertising are members of the Digital Advertising Alliance (DAA) or the Network Advertising Initiative (NAI), both of which maintain websites where people can opt out of interest-based advertising from their members. To the extent our Website contains third-party cookies from DAA or NAI advertisers, to opt-out of website interest-based advertising provided by each organization’s respective participating companies, visit the DAA’s opt-out portal available at http://optout.aboutads.info/, or visit the NAI’s opt-out portal available at http://optout.networkadvertising.org/?c=1.

To opt-out of data collection for interest-based advertising across mobile applications by participating companies, download the DAA’s AppChoices mobile application opt-out offering here: https://youradchoices.com/appchoices.

6. Sharing and disclosure of your personal information

Certain disclosures described below (e.g., to analytics or marketing service providers) may constitute “selling, sharing or disclosing” as broadly defined under applicable privacy laws, including the CCPA/CPRA, but we do not sell your personal information to third parties for any monetary or other valuable consideration. You may opt out of such sharing as described in Section 10.

We may share or disclose your personal information to a third party for a business purpose related to the performance of the RSL Logistics Services. We generally make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract.

We may share or disclose your personal information in the following circumstances:

a. Within Our Corporate Organization. We may share your personal information with any subsidiaries and affiliates in order to provide you with the Services and take actions based on your requests, as well as for the purpose of management and analysis.

b. Service Providers. We may employ other companies and individuals to facilitate our Services, provide services on our behalf, perform service-related business activities, or assist us in analyzing how our Website or RSL Apps are used. These service providers provide us support services such as payment processing, location mapping, analytics services, website hosting, customer relationship management, order fulfillment and shipping, benefits and payroll administration, email and postal delivery, analytics, marketing services, videoconferencing, and calculating duties and taxes. The service providers have access to your personal information only to perform these tasks on our behalf and are required to process such information for specified business purposes in accordance with applicable privacy laws.

c. Corporate Transactions. We may disclose personal information to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Services users is among the assets transferred. You agree to and do hereby consent to our assignment or transfer of rights to your personal information unless you contact us as described below with your request to opt-out of such transfer/assignment.d. As Required by Law and to Protect Lawful Interests. We may disclose your information if we believe that the disclosure is required by law, if we believe that the disclosure is necessary to enforce our agreements or policies, in response to valid requests by public authorities (e.g., a court or a government agency), or if we believe that the disclosure will help us protect the rights, property, or safety of RSL Logistics or our customers. Additionally, for users who are employed by us, we have shared your personal information relating to your employment to third party vendors for benefits administration purposes.

e. With Your Consent. We may disclose your personal information for any purpose with your consent.

7. Data security

We have implemented what we believe to be appropriate technical, physical and organizational measures intended to ensure the confidentiality and security of your personal information from accidental loss and from unauthorized access, use, alteration and disclosure.

However, no security measure can guarantee against compromise. You also have a significant role in protecting your personal information. You should not share your username and password with anyone, and you should not re-use passwords across more than one website. If you have a reason to believe that your personal information has been compromised, please contact us immediately.

8. Personal information retention

Except as otherwise permitted or required by applicable laws or regulations, we will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, as required to satisfy any legal, accounting, or reporting obligations, or as necessary to resolve disputes. To determine the appropriate retention period for personal information, we consider applicable legal requirements, the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes we process your personal information for, and whether we can achieve those purposes through other means.

Under some circumstances we may anonymize your personal information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.

9. Storing and transferring your personal information

Generally, services relating to the Website are performed in the U.S. and are intended for U.S. customers and consumers. Your personal information collected by RSL Logistics within the territory of the United States of America will be stored in the territory of the United States of America.

If you are physically located in one of the European Union Countries, please do not submit any personal information to us. If you believe you may have disclosed personal information to us, please contact us immediately and we will remove it. If you are a consumer accessing the Website from Asia, or any other region with laws or regulations governing personal information collection, use and disclosure that differ from the U.S. laws, your continued use of our Website or Services, which are governed by the U.S. laws and these terms, indicates your consent to transfer of your information to the U.S.

10. Your privacy rights and choices

Depending on applicable law where you reside or are located, you may be able to assert certain rights identified below with respect to your personal information. If any of the rights listed below are not provided to you under the law that governs the processing of your personal information, we have absolute discretion in providing you with those rights. Please refer to the table below to determine the rights you have in your jurisdiction.

Your rights in relation to your personal information are not absolute. Depending upon the applicable law, access to your rights under the applicable law may be denied: (a) when denial of access is required or authorized by law; (b) when granting access would have a negative impact on other individuals’ privacy; (c) to protect our rights and properties; or (d) where the request is frivolous or vexatious, or for other reasons.

Privacy rights include the following:

a) Right to Know/Access. You may have the right to obtain a copy, or a list of categories of the personal information that we hold about you, as well as other supplementary information, such as the purposes of processing, and the entities to whom we disclose your personal information.

b) Right to Correct. You may have the right to correct any of your personal information in our records and systems. You may request us to rectify, correct or update any of your personal information held by us that is inaccurate. In addition to the methods described below, you can correct your personal information through your account settings.

c) Right to Delete. Under certain circumstances, you may have the right to request that we delete the personal information that we hold about you. This right is not absolute, and we may refuse such a request if there are compelling legitimate grounds for keeping your personal information, for legitimate purposes, or as required by law. In addition, in the event your deletion request is honored, we may retain a record of your deletion request as required under applicable laws and their exceptions.

d) Right to Portability. You may have the right to receive a copy of the personal information we have collected about you in a structured, commonly used and machine-readable format.

e) Right to Opt-Out Sale / Right to Opt-Out of Sharing for Targeted Advertising. You may have the right to opt-out of: (i) the sale of your personal information; and (ii) the sharing of your personal information for targeted advertising. Certain disclosures to analytics or marketing service providers (see Section 6) may constitute “selling, sharing or disclosing” as broadly defined under applicable privacy laws, including the CCPA/CPRA, but we do not sell your personal information to third parties for any monetary or other valuable consideration, and you may opt out as described below.

f) Right to Limit Use and Disclosure of Sensitive Personal Information. If you are a California resident, to the extent your sensitive personal information, as that term is defined under California privacy law, is used to infer characteristics about you, you have the right to object to our processing of your sensitive personal information. To the extent we collect any sensitive personal information, we process it to perform our Services, such as verifying RSL Logistics Driver applicants or following the location status of a package. We do not disclose your sensitive personal information except as necessary to provide these features and we do not draw inferences about you from it.

g) Right to Opt-Out of Automated Decision-making or Profiling. You may have the right not to be subject to a decision which significantly impacts your rights that is based solely on automated processing (where a decision is taken about you using an electronic system without human involvement). No decision will be made by us about you solely on the basis of automated decision making which has a significant impact on you.

h) Right Against Discrimination. You may have the right not to be discriminated against for exercising any of the rights described in this section. We will not discriminate against you for exercising your rights.

i) Right to Appeal. In certain jurisdictions, you may have the right to appeal if we refuse to take action on your rights request. Instructions on how to appeal will be provided to you upon such a denial, but in any event, such instructions will be substantially similar to those provided below for submitting requests.

j) Right to Obtain Third-Party List. You may have the right to request a list of specific third parties to which we have disclosed personal data.

k) Right to Object. You may have the right to object to processing of your personal information for direct marketing purposes or if we are processing your personal information on the basis of our legitimate interest under applicable law. For the avoidance of doubt, you have the right to object to continued processing and opt-out of communications-related processing, as described in the “Marketing Communications” section directly below.

l) Right to Restrict. In some jurisdictions, applicable law may give you the right to restrict or object to us processing or transferring your personal information under certain circumstances. This means you can limit the way that we use your data, as an alternative to requesting deletion. In many cases, restriction of personal information processing is not indefinite, but rather, will result in a suspension of processing in place for a certain period of time. We may continue to process your personal information if it is necessary for the defense of legal claims, or for any other exceptions permitted by applicable law.

m) Right to Withdraw Consent. In certain jurisdictions, to the extent the processing of your personal information is based on your consent, you may withdraw your consent at any time. Your withdrawal will not affect the lawfulness of our processing based on consent before your withdrawal.

n) Marketing Communications. You may choose to provide us with your email address to send free newsletters, surveys, offers, and other promotional materials to you. You can stop receiving promotional emails by following the unsubscribe instructions in emails that you receive. If you decide not to receive promotional emails, we may still send you service-related communications.

o) Right to Lodge a Complaint. You may have the right to lodge a complaint with your local privacy regulator about our processing of your personal information.

Please note that “unsubscribe” requests may not take effect immediately and may take a reasonable amount of time to receive, process, and apply, during which time your information shall remain subject to this Privacy Policy. Additionally, you should be aware that any information provided to third-parties prior to your election to unsubscribe will not be retrieved or rescinded, unless required by applicable law.

Table of Jurisdictions. As mentioned above, depending on where you reside or are located, you may be able to assert certain rights with respect to your personal information. To determine which rights you have, please refer to the table below that references the rights as described above in the “Your Privacy Rights and Choices” section. Any places that are not listed either do not have a law providing such rights, or their law does not apply to our operations.