This Privacy Policy (“Policy”) sets out how we handle your personal data. This Policy applies to all users of the Warehut website and app.


Warehut is committed to protecting your privacy. This is our plain English commitment to all users:

• We do not sell your data.

• We do not use your data for any purpose other than the core purpose of Warehut: to match shippers with businesses who want to outsource their pick and pack needs.


If you have any questions about the content of this Policy, please contact us at hi@warehut.io.



  1. Scope of this Policy and Definition of Personal Data


This Policy outlines the Personal Data we collect and process when a user uses the Warehut website and the Warehut app. It also outlines the purposes for which Warehut collects and processes personal data, how Warehut uses personal data, and the features we provide to allow users to access and update their Personal Data.


Personal data refers to any information that can be used to identify an individual either directly or indirectly. This can include, but is not limited to, a person's name, email address, postal address, photograph or video image, IP address and location data.



  1. Acceptance and Modification of the Privacy Policy


By accepting the Warehut Terms and Conditions, the user confirms that they have read and fully understand this Policy. If the user does not agree with any part of, or any change in, this Policy, they must not use the Warehut website or the Warehut app.


The Policy may be updated or modified, but any changes that reduce the user's rights will not be implemented without the user's consent. The updated Policy will be made available on the application and website, and users will be notified either through a pop-up window when they open the application, via an email sent to the address they provide, or another method of directly notifying the user of the change.



  1. Identity of the Data Controller


Warehut, Inc. is the Controller of your Personal Data.


As a data processor, Warehut is committed to following relevant laws and regulations and to handling users' personal data in a lawful, fair, and transparent manner. Warehut will also ensure that the processing of personal data is carried out only for the explicit and legitimate purposes specified in the privacy policy. The processing of personal data will not extend beyond the necessary time required to achieve the stated purposes for which the data was collected and processed.



  1. Categories of Personal Data Processed When Using the Application


4.1 What Personal Data do we Process?

To enable access to the platform and its services, Warehut may collect different types of personal data from you for different purposes, on different legal bases, and for different retention periods. A summary of this information is provided in the table below.

Personal data we process Legal ground for processing the data Reason for processing Retention period
Mandatory profile data (e.g. name and phone number/email address (depending on signup method used) Performance of contract between You and Warehut Account creation, user identification and account management Duration of the use of the services, plus 3 years after the user’s last connection to the service or until the user explicitly requests removal
Optional profile data (e.g. biography, profile content, email address) Consent Account creation, user identification and account management Duration of the use of the services, plus 3 years after the user’s last connection to the service or until the user explicitly requests removal
Data related to your activity on Warehut, communications with Warehut, data related to devices and equipment used Data Controller's legitimate interests Proper functioning of platform and services 2 years from collection date
Data related to your business (if applicable), including, but not limited to, order information, customer information and product information. Consent Proper functioning of platform and services Duration of the use of the services, plus 3 years after the last connection or until the withdrawal of consent
Data sent by your phone's camera and photos stored on your phone, geolocation data Consent Proper functioning of platform and services Duration of the use of the services, plus 3 years after the last connection or until the withdrawal of consent
Content data, communications with Warehut Data Controller's legitimate interests Administrative management of the platform, complaints and reports from users, moderation of content in accordance with our ToU Duration of the use of the services, plus any applicable statutory limitation/s
Content data, data about activity on Warehut To comply with our legal obligations Moderation of content in accordance with the law (prevention of illegal activities, fraud, harassment, etc.) 1 year from collection for metadata; 5 years for data retained for dispute prevention purposes
Contact data from your device Consent To connect you with other users Duration of use of service or until withdrawal of consent
Geolocation Consent To connect you with other users Duration of use of service or until withdrawal of consent

4.2 Details on the Personal Data we Collect and Process

We collect two different types of Data:


i. Data that you provide to us, including:

• Profile data: this refers to the information that is required when you create an account, such as your phone number or email address (depending on signup method used) and name.

• Optional data: this includes your profile picture, biography and other optional profile content, including images and data relating to your Warehut (if applicable). If you have a business account, this also includes data relating to your business, including business information, order information, customer information and product information.

• Communications with Warehut: When you communicate with Warehut, for example by reporting a problem with the platform, taking a survey, requesting assistance, or exercising your rights, we may record the information you provide or that is necessary to respond to your request.


ii. Data we collect when you use our Services. This includes but is not limited to:

• Connection data such as your IP address and the dates of your registration and last connection;

• Device and Equipment Data: We collect information about and from the devices and equipment you use to access Warehut, such as your IP address, device type, application crashes, operating system version, and language.

• Cameras and Photos: Our services may require access to your phone's camera and/or photo library in order to allow you to select photo(s) to accompany your profile, verify your account or add to a support ticket. If you do not allow access to these features, you will still be able to use Warehut, but you will not be able to use some of the features of the app.

4.3 Details of the legal bases and purposes of the data processing

We process the data described above for various purposes and on the following legal bases:


i. Performance of contract, where the processing is necessary for Warehut to provide the services as described in our Terms of Service. This includes

• enabling access to the platform and related services,

• ensuring the proper functioning of user accounts,

• providing notifications and user support,

• administering the platform, and

• providing services for sharing user content and interacting with other users.


ii. Legitimate interests, where the processing allows us to provide a bug-free, efficient and responsive platform. This includes:

• monitoring user content, comments, messages and associated metadata for administrative purposes and to verify their compliance with our Terms of Service;

• verifying compatibility with different device types;

• understanding how the platform is used so that we can develop, improve and promote the platform;

• ensuring the stability and security of the platform;

• identifying criminal or fraudulent activities and/or illegitimate use of the platform; and

• requesting feedback on our services.


iii. Compliance with legal obligations, where our processing of Data is necessary to prevent and combat illegal, fraudulent or abusive activities.


iv. Consent, where the processing involves geolocation or phonebook data. This includes

• using geolocation to allow us to match you with other users in the correct area.


4.4 Cookies

A cookie is a small text file that is stored on your device (computer, tablet, or smartphone) when you access an online service. It allows the issuer to identify your device for the duration of the cookie's validity or storage. Cookies do not personally identify you; they are used to track your browsing activity on the Warehut website. When you connect to the Warehut website, information about your browsing may be stored in cookies installed on your device, depending on your cookie preferences, which can be modified at any time. These cookies enable personalised navigation and are also used for analytical purposes, such as audience measurement.

You will be notified of the presence of cookies and their purpose when you connect to the platform through an information banner displayed at the bottom or top of the homepage. The use of cookies generally requires your consent, which is obtained by clicking "I accept." This consent is valid for 13 months. After this period, we will ask you to renew your agreement.

If you refuse cookies, object to the default cookies, or delete the cookies, you may not be able to access certain features that are necessary for navigating some areas of the Warehut website. In such cases, Warehut is not responsible for any consequences related to the reduced functionality of its services resulting from our inability to record or access the cookies that are necessary for the proper functioning of the Warehut website.


Warehut uses the following cookies and trackers:

i. On the app:

• Cookies that are required for you to use the app, such as those that allow you to remain logged in to your account;

• Cookies and trackers that analyse your use of the app to generate statistical reports and provide us with information about app crashes and bugs for the purpose of improving your user experience and responding to your feedback (Google Analytics)

• Cookies necessary for the proper and efficient operation of the Application, for example by saving your user preferences.

ii. On our website https://warehut.io:

• cookies used to analyse your use of the website and to generate statistical reports that do not identify you (Google Analytics and Google Crashlytics)


4.5 Usage for Other Purposes and Retention Periods

Our use of Personal Data for any purpose other than those outlined in this Privacy Policy requires the explicit, prior consent of the user.


Warehut will only retain Personal Data for as long as is necessary for the specified processing purposes or to protect our legal rights. At the end of these periods, Warehut will delete the Personal Data from its databases. If a user requests the deletion of their account, it will be processed within 30 days. Our backups are automatically deleted after 90 days.


In order to fulfil legal, accounting, and tax obligations, and to prevent potential illegal activity after the deletion of a user account (such as the reuse of an old account by another party), Warehut may retain certain information for a period of time after the closure of the user's personal account. In such cases, the Personal Data will not be accessible online.


4.6 Sharing of Information with Third Parties

No disclosure of Personal Information to third parties

• Warehut will not disclose any information or Personal Data provided by users to third parties, with the exception of content that has been licensed to us in accordance with the Terms of Use. This information and Personal Data will only be used by Warehut’ internal services and will not be transferred or sold to third parties without the user's prior consent.


Disclosure of Personal Data for external processing purposes

• If appropriate, your information and Personal Data may be transmitted to third party contractors involved in the provision of the Services. This may include publishing and sharing content, user tracking and satisfaction surveys, technical and hosting providers, sending notifications, management of security incidents or fraudulent activity.

• Warehut will only share Users' Personal Data with authorised and reliable service providers who process the data on our behalf, following our instructions and in accordance with this Privacy Policy and appropriate security and confidentiality measures.


Disclosure of Personal Data outside the USA

• Processing Personal Data in the manner described in this Privacy Policy may involve transferring your Data to one or more other countries located inside or outside of the USA.


Disclosure for Legal Purposes

• Warehut may share information and Personal Data with a third party if required by law, regulation, or court order, or if necessary for an investigation, to comply with a court order, or as part of a legal proceeding, either domestically or abroad.

• Warehut may also share information and data with third party companies, consultants, or individuals for the purpose of:

• enforcing or identifying violations of the Privacy Policy and the Terms of Use; and

• protecting the rights, property, or safety of our users in accordance with the law.

Security and Inherent Risk

We have implemented technical and organisational measures, such as encrypting data or limiting access to authorised personnel, to ensure that your Personal Data is processed securely in accordance with the Privacy Policy. However, the transmission of information over the internet carries inherent risks that prevent us from guaranteeing the perfect security of the information transmitted through the platform. As a result, you transmit your Personal Data at your own risk.


Rights of Users


You have the following rights in relation to your Personal Data:

• Right of access: This allows you to access your Personal Data free of charge.

• Right of rectification: This allows you to update or correct the accuracy of your Data. You can do this directly from your account settings.

• Right of deletion: This can be exercised when the processing of your Personal Data is no longer necessary for the purposes for which it was collected, or if you withdraw your consent.

• Right to object to the collection and processing of all or part of your Personal Data: This right is not absolute and only applies to Personal Data collected for commercial prospecting purposes. If you choose to object to this processing, we will ask you to provide the reasons for your objection so that we can consider your request against our legitimate interests.

• Right to limit the processing of your Personal Data: This right is not absolute and can only be applied in the following situations:

• You have made a request for rectification under the right of rectification described in 8.2, and you request that the processing of your Personal Data be stopped while the accuracy of the requested rectification is verified;

• You object to the deletion of your Personal Data whose processing was unlawful;

• Warehut no longer needs your Personal Data for processing purposes, but they are still necessary for legal purposes;

• You object to the processing of your Personal Data and request that the processing be stopped while our legitimate interests are considered against your request.

We may need to verify your identity before we can respond to a request to exercise one or more of your rights.


Information Regarding Children


Warehut is not intended to be used by persons under the age of 18. If you believe that we have Personal Information about or provided by a child, you may alert us by reporting the content or the user account to hi@warehut.io.


Information About Users Located In the USA


This clause applies to Personal Information (as defined by relevant regulations) provided to Warehut by the User and is specifically intended for users in the United States, including California and Virginia residents. This clause applies only if you are a party to the Warehut Terms of Service.


In accordance with the California Consumer Privacy Protection Act of 2018 (“CCPA”), we are providing this information as a service provider that is required to process your Personal Information and confirm that we have appropriate contractual terms in place. “Applicable law” refers to all laws, regulations, standards, regulatory guidance, and self-regulatory guidelines that may apply in relation to the management of your Data, including, but not limited to, the California Consumer Privacy Protection Act (Cal. Civ. Code §1798.100 - 1798.199) and the Virginia Consumer Data Protection Act (SB 1392).


As a service provider, we will collect, hold, use, disclose, and process your personal information only for the purpose of fulfilling our obligations to you under our agreement and for the operational purposes stated in this Policy, and not for any other purpose.

We will not sell your personal information or disclose it for commercial purposes.


We certify that we understand and comply with the restrictions and obligations outlined in Cal. Civ. Code § 1798.140(w)(2) and Va. SB 1392.


If you have any questions about the CCPA or other U.S. regulations, or if you wish to exercise your rights under them, you may contact us as set forth in clause 11.


Contact


You can contact us by email at: hi@warehut.io.

Warehut will respond to your request as soon as possible and no later than any statutory deadlines.