Vanguard Privacy Statement
At Vanguard, we value the privacy of those who provide personal information to us.
When we refer to Vanguard, us, we or our, we mean the Vanguard company or companies that is responsible for any personal information collected about you. That will predominantly be the Vanguard company in your jurisdiction, or the Vanguard company which is providing services to you or to which you are providing services.
1. What is the purpose and scope of this privacy statement?
Vanguard is a global business that handles personal information relating to its customers, suppliers and contractors all over the world. The nature of our business (and of the logistics industry as a whole) means that we won't necessarily have direct relationships with all of those individuals; for example, information about our customers may be provided to us by an agent or another third party.
We have considered our obligations under data protection laws (including in Europe) and have prepared this privacy statement in the interests of being transparent about our use of personal information. In this privacy statement, we describe what personal information we collect about our customers, suppliers, vendors and contractors (whether from them directly or from third party sources), how we use that information, the legal basis upon which we process it, with whom it is shared, and how it is stored.
This privacy statement applies to our collection and use of personal information:
- through the Vanguard websites (our Websites);
- when you become a customer of ours and/or we provide services to you; and / or
- if you are (or work for) one of our customers, suppliers, vendors or contractors or provide services to us.
Not all of this privacy statement will necessarily be relevant to all of our customers, suppliers, vendors and contractors, depending (in part) on the country in which you are based. If you have any questions or comments on this privacy statement, you can contact us by email at VLSprivacy@vanguardlogistics.com at any time.
Please read this privacy statement carefully to understand how we handle your personal information.
2. Information collection
We may collect and use any of the following information about you and we refer to this as “personal information” throughout this statement:
2.1 Personal information you give us. You may give us personal information through our Websites or by contacting us by phone, email or other means. This includes, for example, when you provide your personal information to us in order to receive our services, or to provide goods or services to us.
The personal information you give us may include:
(a) your name;
(b) your job title;
(c) company name;
(d) email address;
(e) your telephone number;
(f) account information;
(g) your and/or your company's address;
(h) other information provided when you correspond with us; and
(i) any updates to the information provided to us.
We may obtain personal information from third party sources, such as agents.
Please note that we need certain types of personal information so that we can provide our services or receive goods or services from you. If you do not provide us with such personal information, or ask us to delete it, you may no longer be able to access and use our services, or to provide goods or services to us.
2.2 Personal information we collect about you. Each time you visit our Websites, we may automatically collect any of the following information:
(a) technical information, including the Internet protocol (IP) address used to connect your computer to the internet, domain name and country which requests information, the files requested, browser type and version, browser plug-in types and versions, operating system and platform; and
(b) information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time), time and length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, traffic data, location data, weblogs and other communication data and information provided when requesting further service or downloads.
(c) Email addresses and passwords associated with logins to Vanguard Websites and/or web applications.
3. Use of information
We collect, use and store the personal information listed above for the following reasons:
3.1 Providing services (if you are a customer):
(a) to provide services to you, your company or your or your company’s customers;
(b) to verify your identity;
(c) to resolve claims, including for cargo damage;
(d) to pursue debt from our customers and/or other responsible parties;
(e) to notify you about changes to our services and to keep you informed about our fees and charges; and
(f) for business development and marketing purposes, to contact you (including by email or post) with information about our services which we feel will be of interest to you or your customers (you can opt out or let us know at any time if you would no longer like to hear from us).
3.2 Receiving services (if you are a supplier or contractor)
(a) to enable us and/or our customers to receive goods or services from you;
(b) to verify your identity;
(c) to resolve claims, including for cargo damage;
(d) to pay debts; and
(e) for business development and marketing purposes, to contact you (including by email or post) with information about our services which we feel will be of interest to you (or your customers) (you can opt out or let us know at any time if would no longer like to hear from us).
3.3 Visiting our Websites:
(a) to allow you to access and use our Websites;
(b) to provide technical support;
(c) to provide you with the information and services that you request from us;
(d) to ensure the security of our services and Websites;
(e) to store information about your preferences, and to allow us to customize the Websites according to your individual needs;
(f) to recognize when you return to our Websites; and
(g) to improve and maintain our Websites and prepare reports or compile statistics in order to improve our services. Such details will be anonymised as far as is reasonably possible.
3.4 To comply with any procedures, laws and regulations which apply to us, to comply with our legal obligations or, otherwise, where it is necessary for our legitimate interests or the legitimate interests of others; and
3.5 To establish, exercise or defend our legal rights where it is necessary for our legitimate interests or the legitimate interests of others or to comply with a legal obligation.
4. Legal basis for use of your personal information
4.1 Data protection and privacy laws require us to have a legal justification for collecting, using and otherwise handling your personal information. We consider that our legal basis for using your personal information as set out in this privacy statement:
(a) is necessary to perform our obligations under any contract with you (for example, to comply with our contract to provide services to you), to provide services to you, your company and/or customers, or to receive goods or services from you or your company);
(b) is necessary to comply with our legal obligations; or
(c) where use of your personal information is not necessary for performance of a contract, to provide services, to receive goods or services or to comply with our legal obligations, use of your personal information is necessary for our legitimate interests or the legitimate interests of others; for example, to ensure the security of our Websites.
4.2 In the future, other uses of your personal information may require us to obtain your consent (which can be withdrawn at any time, as described below). Where this is the case, that need for consent will be identified in this privacy statement.
6. Disclosure of personal information
6.1 We may share your personal information with any company that is a member of our group, where it is in our legitimate interests to do so for internal administrative purposes (for example, to perform services for our customers).
6.2 We will also share your personal information with certain third parties who handle personal information on our behalf; including:
(a) our service providers, suppliers, sub-contractors and any other vendors we use to provide services, including but not limited to payment processors, third party data processors, suppliers of technical and support services and cloud service providers; and
(b) companies that may assist us in marketing, advertising and promotional activities. Any third parties who handle your personal information on our behalf are limited (by law and/or by contract) in their ability to use your personal information for any purpose other than to provide services to or for us.
6.3 We may also share your personal information with third parties:
(a) if we sell or buy any business or assets, we may disclose your personal information to the prospective seller or buyer of such business or assets;
(b) if substantially all of Vanguard's or any of its affiliates' assets are acquired by a third party, in which case personal information held by Vanguard may be one of the transferred assets;
(c) if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, any lawful request from government or law enforcement officials and as may be required to meet national security or law enforcement requirements or prevent illegal activity;
(d) in order to enforce or apply our terms and conditions or any other agreement or to respond to any claims, to protect our rights or the rights of a third party, to protect the safety of any person or to prevent any illegal activity; or
(e) to protect the rights, property, or safety of Vanguard, our customers or other persons. This may include exchanging personal information with other organisations for the purposes of fraud protection and credit risk reduction.
6.4 We may also disclose and use anonymised, aggregated reporting and statistics about users of our services and / or our Websites for the purpose of internal reporting or reporting to our group or other third parties, and for our marketing and promotion purposes. None of these anonymised, aggregated reports or statistics will enable our users to be personally identified.
6.5 Save as expressly detailed above, we will not share, sell or rent any of your personal information to any third party without notifying you and, where necessary, obtaining your consent.
7. Retention of personal information
7.1 We keep your personal information for no longer than necessary for the purposes for which the personal information is processed and as required by applicable law.
7.2 We currently store personal information for the following periods of time pursuant to our Electronic Data Retention and Destruction Policy:
(a) Data that resides on Vanguard user desktops/laptops shall be retained for 4 years;
(b) E-mails that reside on Vanguard mail backup platforms shall be retained for 4 years;
(c) Data that resides on Vanguard provisioned storage (shared network drives and file locations) shall be retained for 7 years;
(d) Data that resides in Vanguard operational systems shall be retained for 7 years; and
(e) Data that resides in Vanguard financial systems shall be retained for 7 years.
8. Your rights
8.1 In some countries (for example, in Europe), you have certain rights in relation to your personal information. You may have the right to request that we:
(a) provide access to any personal information we hold about you;
(b) prevent the processing of your personal information for direct-marketing purposes;
(c) update any personal information which is out of date or incorrect;
(d) delete any personal information which we are holding about you;
(e) restrict the way that we process your personal information; or
(f) provide your personal information to a third party provider of services.
8.2 When you make a request to us in relation to your personal information, we may ask you to provide certain additional information for us to confirm your identity.
8.3 We will consider all requests and provide our response within the time period stated by applicable law.
8.4 Please note, however, that those rights will only apply in certain countries. Even where they do apply, there are certain exemptions to them; for example, we may not need to comply with a request from you to delete your personal information if we still need that information for our legitimate interests or to comply with a legal obligation.
8.5 If you would like further information in relation to these rights or would like to exercise any of them, please contact us by email at VLSprivacy@vanguardlogistics.com at any time.
9. Transfers of personal information
9.1 European data protection laws apply to us in certain circumstances; for example, they will apply to our European group companies and (in some cases) to our non-European group companies when handling personal information about European customers and / or users of our Websites in Europe. European data protection laws require us to take certain measures before transferring personal information outside of the European Economic Area (EEA).
9.2 Personal information which is subject to European data protection laws may be used, stored and/or accessed by us outside the EEA (for example, when we share personal information within the Vanguard group of companies) and by some of the third parties with whom we share your personal information (such as, our suppliers, sub-contractors and service providers), who may also be based outside the EEA. By providing us with your personal information you acknowledge any such transfer, storage and use.
9.3 In those circumstances where we consider that European data protection laws apply to us and there is a transfer of personal information outside the EEA, we will take steps:
(a) in respect of transfers of personal information to the U.S.A, to enter into European Commission approved standard contractual arrangements, or to ensure that the recipient of your personal information has signed up to the EU-US Privacy Shield (see further https://www.privacyshield.gov/welcome); or
(b) in respect of transfers of personal information to other countries outside the UK or EEA, to ensure that the country to which your personal information is transferred has been deemed "adequate" by the European Commission or – if not – that the recipient of your personal information enters into European Commission approved standard contractual arrangements with us.
9.4 Further details on the steps we take to protect your personal information in these cases are available from us on request by contacting us by email at VLSprivacy@vanguardlogistics.com at any time.
10.1 Vanguard is committed to protecting personal information from loss, misuse, disclosure, alteration, unauthorised access and destruction and takes reasonable precautions to safeguard the confidentiality of personal information. Because the transmission of information over the internet is not completely secure, you acknowledge and accept that we cannot guarantee the security of your personal information transmitted to our Websites and that any such transmission is at your own risk.
10.2 Where we have given you (or where you have chosen) a password which enables you to access your online account, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
11. Third party websites
Our Websites may, from time to time, contain links to websites operated by third parties including partner networks and other Vanguard companies. Please note that this privacy statement only applies to the personal information that we collect through our Websites and we cannot be responsible for personal information collected and stored by third parties. Third party websites have their own terms and conditions and privacy policies, and you should read these carefully before you submit any personal information to these websites. We do not endorse or otherwise accept any responsibility or liability for the content of such third party websites or third party terms and conditions or policies.
12. Changes to our privacy statement
We may update our privacy statement from time to time. Any changes we make to our privacy statement in the future will be posted on this page. Please check back frequently to see any updates or changes to our privacy statement. By continuing to use our Websites and / or our services, or by continuing to provide goods or services to us, you are confirming that you have read and understood the latest version of our privacy statement.
13. Further questions or making a complaint
13.1 If you have any queries or complaints about our collection, use or storage of your personal information, or if you wish to exercise any of your rights in relation to your personal information, please contact VLSprivacy@vanguardlogistics.com. We will investigate and attempt to resolve any such complaint or dispute regarding the use or disclosure of your personal information.
13.2 To the extent that our processing of your personal information is subject to European data protection laws, you may also make a complaint to the relevant data protection authority. If you are unsure which data protection authority to contact, please contact VLSprivacy@vanguardlogistics.com who will advise you.
The practices described in this privacy statement are our current as of May, 2018.