Last Updated:  November 21, 2023

Table Of Contents

1. About This Privacy Policy
2. What Is Personal Information?
3. Personal Information We Collect
4. How We Use Personal Information
5. How We Share Personal Information
6. Cookies And Online Tracking
7. Your Rights And Choices
8. California Residents (CCPA Statement)
9. Other Important Information
10. Changes To This Policy
11. Contact Us

 1.  About This Privacy Policy

Protecting your privacy is really important to CDL 1000 (“we” or “us”).  This Privacy Policy describes how we collect, use and share personal information in connection with providing our Services (as defined in the CDL 1000 Terms of Service).   It also explains related rights and choices you may have.

You may see other privacy notices when we collect your personal information for certain Services.  Those notices supplement this Policy.  This Policy also contains a statement specific to California consumers, see Section 8 relating to the California Consumer Privacy Act of 2018.  That statement supplements the rest of this Policy, but to the extent it differs from other parts of the Policy, the statement governs with respect to California consumers.

To the extent that CDL 1000 has links to third party websites, please note that we do not own, operate, or control those sites, and this Policy does not cover those sites, which may have their own privacy policies that you should review.

2.  What Is Personal Information?

When we say “personal information” or “personal data,” we mean your unique identifiers (full name, phone number, email address, IP address, etc.), and information about your characteristics, conditions or behavior that is associated with one of your identifiers or could reasonably be linked to you.  The law in your area may define categories of personal information differently.

“Non-personal information,” on the other hand, has been aggregated, anonymized or de-identified so that it can’t reasonably be linked to an individual.

3.  Personal Information We Collect

In order to provide our Services, CDL 1000 collects information that you share directly with us.  Also, our website and other online Services, like many online services, automatically log some information about you or your device to distinguish you from other users or to help track shipments.  Some of that information is logged using cookies and similar online tracking technologies, which you can learn more about in Section 6.  Finally, we may receive information about you from third parties, such as Geotab, that help us monitor shipments.  Where permitted by law, we may combine information received from third parties with information we have collected from you.  To the extent the information, alone or in combination, constitutes personal information, we will treat it as personal information as described in this Policy.

Generally, we collect some or all of the following categories of personal information if you contact us, visit our website, use a Service, register an account with us, sign up to receive communications from us, or share content online:

●      “Identifiers,” including contact information (such as full name, postal address, email address, phone number), government-issued identification (such as state ID number, social security number, tax ID number), and online identifiers for you, your device, or your browser (such as user name, IP address, device ID, browser cookies or cookie ID, advertising ID, and similar information)

●      “Demographic Information,” such as preferred language, age and date of birth, and similar information

●      “Professional or Employment-Related Information,” such as the name of your employer or organizations that you are a member of, your status within an organization, and similar information

●      “Financial Information,” such as payment card information

●      “Account Information,” such as account profile, purchase history, and billing information

●      “Device/Browser Information,” such as internet service provider (ISP), operating system, device type, browser type

●      “Usage Information and Browsing History,” such as usage metrics (including usage rates, occurrences of technical errors, diagnostic reports, settings preferences, backup information, and other logs), content interactions (including searches, views, downloads, prints, shares, streams, and display or playback details), and user journey history (including clickstreams and page navigation, URLs, timestamps, content viewed or searched for, page response times, page interaction information (such as scrolling, clicks, and mouse-overs), and download errors), advertising interactions (including when and how you interact with marketing and advertising materials, click rates, purchases or next steps you may make after seeing an advertisement, and marketing preferences), and similar data.

●      “User Content,” such as service ratings or reviews, content in your comments, posts, communications or responses

●      “Social Media and Online Content,” such as information in social media and online profiles, online posts, and similar data

If you are interacting with us on behalf of a shipper or carrier, we may also collect:

●      “Transaction Information,” such as the date and time of your shipment request, pick-up and delivery information, cargo description and value, shipment bid information, insurance information, and similar information

If you are one of our drivers transporting a shipment, we may also collect:

●      Other Identifiers, such as your driver’s license number, DOT number, CDL number, MC number or similar information

●      “Insurance Information,” such as policy number, coverage details, and similar information

●      “Geolocation Data,” such as the current or anticipated future location of your vehicle or mobile device, or the history of your location with respect to particular shipments you are transporting

●      “Geotab Device Data.” If you have installed the Geotab VTR device, CDL 1000 and Geotab may automatically collect the following information through the device: location data, driver status information, driving event information, vehicle data and diagnostic information, other information recorded by electric logging devices under 49 CFR § 395.26, 49 CFR Part 395 Subpart B, Appendix A, and any other information collected by the Geotab device (the “Geotab VTR Information”).  Geotab may change or increase the type or amount of information it collects without our consent. Additional information regarding Geotab VTR Information collected by the Geotab VTR can be found at these two links:Geotab GO8 Support Document and Rate Plan Feature Comparison. Please contact Geotab or CDL 1000 at solutions@cdl1000.comfor more information on this matter.

4.  How We Use Personal Information

We use personal information in connection with our Services and for other business purposes, including to:

●      Provide, operate, enhance and customize the Services

●      Recognize users and manage user accounts

●      Distribute to shippers, carriers, and drivers using the Services in relation to their use of the Services.

●      Track shipments

●      Monitor driver safety and performance

●      Fulfill our obligations and enforce our rights arising from any contracts entered into between you and us, including the Carrier Broker Agreement, Shipper Broker Agreement, or any other agreement for billing and collection.

●      Notify you about information or updates to the Services and changes to any products, services, policies, or terms and conditions associated with the Services.

●      Verify compliance with regulations that apply to shipments

●      Help maintain the safety, security and integrity of the Services.

●      Contact you about goods and services that may be of interest to you.

We may use non-personal information for any purpose.

5.  How We Share Personal Information

5.1  Our Affiliates

We may share your information with our corporate parents, subsidiaries, and other affiliated entities for a variety of purposes, including business, operational and marketing purposes.

5.2  Vendors

We may share your information with vendors that perform services on our behalf, such as hosting our online services, managing databases, performing analyses, conducting surveys, monitoring shipments, sending communications and newsletters for us, or conducting marketing campaigns.  Where necessary and appropriate, our agreements with vendors prohibit them from retaining, using or disclosing the personal information we share with them for any purpose other than performing services on our behalf.

5.3  Analytics And Advertising Partners

We may share your personal information with analytics providers, advertising networks, and social media companies to measure performance of our Services and marketing efforts or to deliver personalized advertising about our products and services.  This sharing may involve the use of “Cookies,” which are explained in Section 6, below.  Where necessary and appropriate, our agreements with these partners prohibit them from retaining, using or disclosing the personal information we share with them for any purpose other than providing us with analytics or advertising services.

5.4 Mandatory Disclosures And Legal Proceedings

We may have a legal obligation to disclose personal information to government authorities or other third parties pursuant to a valid regulatory request, subpoena or court order.  We may also need to disclose and otherwise process your personal information in accordance with applicable law to defend our legitimate interests, for example, in civil or criminal legal proceedings.

5.5 Change in Control or Merger

If we decide to sell, buy, merge or otherwise reorganize our businesses, this can involve us disclosing personal information to prospective or actual purchasers and their advisers, or receiving personal information from sellers and their advisers.

5.6  With Your Consent

We will share your personal information with other third parties as you may direct, or if you otherwise consent.

6.  Cookies And Online Tracking

6.1  What Are Cookies?

When we say “Cookies,” we mean online identification and tracking tools that include browser cookies, pixels (also known as web beacons), and similar browser and device storage technologies.

Browser cookies are small text files that are stored on your device when a website loads in your browser. Cookies are used to “remember” you and your preferences, either for a single visit (through a “session cookie”) or for multiple repeat visits (using a “persistent cookie”). Cookies ensure a consistent and efficient experience for visitors, and perform essential functions such as allowing users to register and remain logged in.

Cookies may be set by the site that you are visiting (known as “first party cookies”), or by third parties, such as those who serve content or provide advertising or analytics services to the owner of the website (“third party cookies”).

Both websites and emails may also contain pixels, which can track your activity across different sites or report how you interact with emails.  These are typically small transparent images that provide the party placing them with statistics and usage data, for similar purposes as cookies. They are often used in conjunction with cookies, though they are not stored on your computer in the same way as cookies. As a result, if you disable cookies, tracking pixels may still load, but their functionality will be restricted.

6.2  Why CDL 1000 Uses Cookies

We use Cookies for several different purposes. Some cookies are necessary for technical reasons; some enable a personalized experience for both visitors and registered users; and some allow the display of advertising from selected third party networks. Some of these cookies may be set when a page is loaded, or when a user takes a particular action on one of our Services. Many of the cookies we use are only set if you are a registered user, while others are set whenever you visit or use one of our Services (irrespective of whether you have an account). For more information on the choices you have about the cookies we use, please see Section 7, below.

We set Cookies in different locations across our Services.  These locations may include:

●      Our website, nexttrucking.com,

●      Our mobile apps;

●      The emails we send.

This list describes the types of Cookies used on our Services and their purposes:

●      Strictly Necessary Cookies.These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information.

●      Performance Cookies. These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site.              All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site, and will not be able to monitor its performance.

●      Functional Cookies. These cookies enable the website to provide enhanced functionality and personalization. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies then some or all of these services may not function properly.

●      Targeting Cookies. These cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not store directly personal information, but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.

6.3  Our Partners And Their Cookies

We partner with analytics providers, advertising networks, and social media companies to measure the performance of our services or marketing efforts and to serve personalized ads.  Some of those partners use their own (third party) Cookies on our Services.  As a result, when our site loads in your browser, your browser may automatically download content from our partner’s servers and share information about your or your device, such as IP address, other online Identifiers, Device/Browser Information, or Usage Information and Browsing History, with our partner.

Partners that may place their Cookies through our Services include, but may not be limited to:

●      Google. We use Google Analytics and Google Ads.  You can learn about Google’s own privacy practices here:  google.com/policies/privacy/partners/,

●      Facebook. We use Facebook Business Tools, such as the Facebook Pixel.  You can learn more about Facebook’s own privacy practices here:  https://www.facebook.com/policy.php

6.4  Controlling Cookies

See Section 7, below for information about how to block or limit Cookies and opt-out of interest-based advertising.

7.  Your Rights And Choices

7.1  Opt-Out Of Email Communications

You may opt-out of our email communications by using the unsubscribe link provided in the email.

7.2  Opt-Out Of Interest-Based Ads Using Industry Tools

You can opt-out from at least some interest-based advertising online by using the opt-out tools offered by these organizations:

1. www.aboutads.info/choices (U.S. under the Digital Advertising Alliance )
2. youronlinechoices.eu(EU under the European Interactive Digital Advertising Alliance)
3. youradchoices.ca/choices(Canada under the Digital Advertising Alliance of Canada)

If you use these industry options to opt out from interest-based advertising for third parties through our services, we will attempt to apply your choice to your member experience. However, we may not have enough information to do so.

7.3  Your Browser And Device Settings

At any time, you may adjust settings on your browser to refuse cookies and other tracking pixels according to the instructions related to your browser. However, if you choose to disable these technologies, some features of the website may not operate properly.

7.4  Area-Specific Rights And Choices

If you are a California resident see Section 8, you may have other rights and choices.

8.  California Residents (CCPA Statement)

This Section 8 of the Policy supplements our Policy and makes additional disclosures solely applicable to California residents (i.e., “consumers”), and describes rights they may have, under the California Consumer Privacy Act of 2018(the “CCPA”), as amended by the California Privacy Rights Act effected January 1, 2023 (the “CPRA” and referred to interchangeably with the CCPA).  For avoidance of doubt, any and all rights enumerated or disclosed herein only may apply to California residents and solely apply to the extent that they are applicable.  Some or all consumer rights described herein may not apply to certain California residents.   Certain information herein may be referenced in other Sections of this Policy. 

Development of our CCPA policies is ongoing and regulations are continuously being updated.  Thus, we may regularly update this Policy without notice.

You can learn more about the CCPA here:   https://oag.ca.gov/privacy/ccpa

8.1  Collection Of Personal Information

Section 3 of the Policy discloses the categories of personal information we currently may collect.  The following tables describes categories of non-sensitive personal information and sensitive personal information, as those categories are defined in the CCPA, that we have collected about consumers within the past 12 months.  For each category, we may have collected one or more of the examples listed.

NON-SENSITIVE PERSONAL INFORMATION

SENSITIVE PERSONAL INFORMATION

As more fully detailed in this Policy, we obtain the above-referenced categories of personal information from you, via cookies or similar online tracking technologies, and from third parties such as Geotab that help us monitor shipments.

8.2 Use, Sale, Sharing, Or Disclosure Of Personal Information

We may use, share, sell or disclose the personal information we collect for the purposes disclosed in this Privacy Policy, including those purposes stated in Section 4. The CCPA defines a “sale” of personal information to include transferring, disclosing, or otherwise making personal information available to a third party in exchange for money or something else of value. 

Within the past 12 months, we did not intend to sell personal information and consider the following information “shared” under the statute.  However, based on the definition in the CCPA, we may have sold the following categories of non-sensitive personal information as part of an exchange with a third party in which we received a non-monetary service or benefit:

●      Identifiers, including to vendors to complete transactions or for a related business purpose.

●      Internet Activity, including to vendors to facilitate your use of our services. 

Within the past 12 months, we may have sold the following categories of sensitive personal information as part of an exchange with a third party in which we received a non-monetary service or benefit:

●      Geolocation Data, including data transmitted related to certain third parties like Geotab for the purpose of monitoring shipments and other service related data. 

Within the past 12 months, we otherwise shared or disclosed the following categories of personal information for a business purpose:

●      Identifiers, including to vendors to complete transactions or for a related business purpose.

●      Internet Activity, including to vendors to facilitate your use of our services.

Within the past 12 months, we otherwise shared or disclosed the following categories of sensitive personal information for a business purpose.

●      Geolocation Data, including data transmitted related to certain third parties like Geotab for the purpose of monitoring shipments and other service related data.

●      Financial Information, including information needed to facilitate transactions or the business, with relevant third party vendors.

8.3 Data Retention Policy

In addition to the information disclosed regarding the retention of your personal information in Section 9.2, for the purposes of clarity under the CCPA, we will retain your personal information, including sensitive personal information for no longer than is reasonably necessary for the purposes stated in this Privacy Policy unless otherwise required or permitted by law. Specifically, all categories of data are retained for a period of 90 days from the date of creation and receipt. After 90 days, the data will be deleted, unless otherwise required to be retained for legal, compliance, or operational reasons. Historical data will be archived for one year and used for historical report, analysis, and compliance purposes after which it will be deleted in accordance with our data destruction policy.

8.4  Your Rights

California residents have the right to make the following requests to covered businesses.  The requests may be made by a consumer, by a consumer on behalf of the consumer’s minor child, or by a person authorized by the consumer to act on the consumer’s behalf.  Information regarding how you can utilize your rights is contained in Section 8.5.   

Right To Know About Collection, Disclosure or Sale of Personal Information                        

You have the right to request that a business disclose to you:

1. The categories and specific pieces of personal information the business has collected about you within the past 12 months,
2. The categories of sources from which the personal information is collected,
3. the business or commercial purposes for collecting or selling personal information, and
4. The categories of third parties with whom the business shares personal information.

If a business sells personal information, or discloses it for a business purpose, you also have the right to request that the business disclose the following with respect to the 12-month period preceding your request:

1. the categories of personal information that the business sold about you and the categories of third parties to whom the personal information was sold, and
2. the categories of personal information that the business disclosed about you for a business purpose.

This type of request may be referred to as a “Request to Know.”  Before we can honor a Request to Know, we need to verify that the person making it is the consumer whose personal information we have.  Our method for verifying any particular request weighs information we receive as part of the request, the sensitivity of the consumer information at issue, and the risk of harm to the consumer from unauthorized disclosure.

Right to Deletion of Personal Information

You have the right to request that a business delete any personal information that the business has collected from you.  This type of request may be referred to as a “Request to Delete.”

Before we can honor a Request to Delete, we need to verify that the person making the request is the consumer whose personal information we have.  Our method for verifying any particular request weighs information we receive as part of the request, the sensitivity of the consumer information at issue, and the risk of harm to the consumer from unauthorized deletion.

We are not required to delete personal information if we still need it in order to complete the transaction for which the information was collected, provide a good or service requested by you (or that we reasonably anticipate based on our relationship with you), perform a contract with you, comply with a legal obligation, enable internal uses that are consistent with the context in which you provided the information, or accomplish any other objective recognized as an exception to the right to deletion under applicable law.

Right to Opt-Out of the Sale or Sharing of Personal Information

You have the right to direct a business that sells personal information about you to third parties not to sell your personal information.  This type of request may be referred to as a “Request to Opt-Out.”  You may also op-out of the sharing of certain personal information for certain behavioral advertising.  We are not required to honor a Request to Opt-Out if we have reason to believe it is fraudulent.

Right to Non-Discrimination

You have the right not to receive discriminatory treatment by a business for the exercise of your privacy rights under the CCPA.  We will not discriminate against you for exercising your CCPA rights. 

Right to Correct Personal Information

You have the right to correct any inaccuracies in your personal information that is collected from you.  This type of request may be referred to as a “Request to Correct Personal Information”.  Upon receipt of such request, we will make commercially reasonable efforts to correct the inaccurate personal information within 45 days. 

Right to Opt-Out of Automated Decision Making

You have the right to opt-out of the use of your information for automated decision-making.  At this time, we do not use your information for automated decision-making under the CCPA per the current definition of automated decision making. 

Right to Limit Use and/or Disclosure of Sensitive Personal Information

You may direct us to only use your sensitive personal information for limited purposes, such as providing you with the services you requested, if it is used for purposes other than those exceptions in the applicable laws and regulations, including account servicing, processing payments, use related to security incidents, or non-personalized advertising.   This type of request may be referred to as a “Request to Limit Use or Disclosure.”

8.5  How to Exercise Your Rights Under the CCPA

You can submit requests based on your rights using this form.  Requests may include the following:

●      Request to Know

●      Request to Delete

●      Request to Opt-Out

●      Request to Correct Personal Information

●      Request to Limit Use or Disclosure

Requests must state the specific basis for the Request, and must be titled accordingly (i.e., a “CCPA Request to Know”).  Requests must also include:

●      your first and last name;

●      an email address at which you can be reached for purposes of the request;

●      the disclosure(s) you are requesting; and

●      the reason(s) you believe we have collected, disclosed or sold your personal information, specifically, within the past 12 months (for example, you used our website or received a communication from us)

If you are submitting a request on behalf of another consumer as their authorized representative, you must include the foregoing information about the consumer and attach a copy of a power of attorney appointing you as a duly authorized representative under California Probate Code sections 4000 to 4465 or written permission from the consumer to make the request.

If you prefer, you can call this toll-free number to submit your request: 855-683-2211

After confirming receipt of your request, we’ll contact you if we need more information in order to verify it.  If we can’t verify a request, we may deny it.  We will use commercially reasonable efforts to respond to you in the amount of time required by the CCPA.

9.  Other Important Information

9.1  Data Security

In order to safeguard personal information against unauthorized access, removal, theft, or disclosure, we use security measures appropriate to the nature of the information that we believe are reasonable in light of industry standards and our operations.  Unfortunately, in our increasingly connected digital world, no one can guarantee perfect data security, and we cannot promise that our measures will always prevent a breach of personal information.  Should we detect such a breach, we will promptly notify affected individuals, third parties and law enforcement agencies as required by applicable law.

We encourage you to help maximize security by applying your own personal security measures.  For more information about what you can do to protect your data, please see the tips and resources offered by the U.S. Federal Trade Commission at https://www.consumer.ftc.gov/topics/privacy-identity-online-securityand the California Attorney General at https://www.oag.ca.gov/privacy/consumer-privacy-resources.

9.2  Retention of Personal Information

We take reasonable steps to keep the personal information we possess accurate and to delete incorrect or unnecessary personal information.  We retain personal information only as long as necessary to fulfill the purposes outlined in this Privacy Policy or otherwise communicated to you, unless a longer period is required by applicable law.

9.3  Links To Third Party Sites

Our online Services may contain links to third-party websites, products or services.  If you use these links, you will leave our site. Such links do not constitute or imply an endorsement, sponsorship or recommendation by us of the third party, the third-party website or the information contained therein, and we shall not be responsible or liable for your use thereof. Such use shall be subject to the terms of use and privacy policies applicable to those sites.

9.4  Third-Party Direct Marketing

We do not disclose, and have not disclosed, personal information to third-party companies for their direct marketing purposes.

9.5  “Do Not Track” Signals

Your web browser may offer a Do Not Track (DNT) setting.  If you turn that setting on, your browser sends a signal to websites indicating that you don’t want to be tracked over time or across third party sites.  We don’t currently respond to these signals because there is not yet a common understanding of how to process them or a consensus on what “tracking” means.

9.6  Children’s Privacy

Our Services are not intended for children (individuals under the age of 16).  We do not knowingly collect, maintain, or process personal information from children without consent.  Visit the Federal Trade Commission website for more information about protecting children’s online privacy: https://www.ftc.gov/tips-advice/business-center/privacy-and-security/children%27s-privacy.

10.  Changes To This Policy

We will update this Policy from time to time as necessary to reflect changes in applicable law, our privacy practices, or our Services.  If we have your contact information, we will notify you of material changes, and you should periodically review this Policy to remain aware of our current practices.

11.  Contact Us

If you have any questions or concerns about this Policy or our practices, or wish to exercise your rights regarding your personal information under applicable law, please contact us directly at solutions@cdl1000.com.