DULUTH CARGO CONNECT
PRIVACY POLICY

The Duluth Cargo Connect website is operated by Lake Superior Warehousing Company, Inc., a Wisconsin corporation (“LSW”). This LSW Privacy Policy explains our practices, defines our users’ (“you” or “your”) privacy options and describes how your information is collected and used by LSW (“we,” “us,” or “our”).

By using the Duluth Cargo Connect website or any of our applications, products, services, features, tools, or resources you agree to the terms of this Privacy Policy.

This Privacy Policy governs your use of the LSW website at www.duluthcargo.com (the “Site“). For the purposes of this Privacy Policy, we will refer to all of these access points as the LSW system (the “System“).

We reserve the right to modify this policy from time to time and will mark new versions with a corresponding effective date. We recommend you visit the Site to review any changes in our practices. Your continued use of the Site constitutes your agreement to our then-current Privacy Policy. This policy is effective as of May 16, 2016.

Our System may contain links to other websites. These websites may have privacy policies different than our Privacy Policy. Although you can view the material we have linked to, you may have to create an individual account or register to use these third-party sites. Any interaction on other sites or social media websites is governed by the terms of use and privacy policy of the particular platform.

What Information is Collected?

We may collect personal information from you on our System or through any other digital or personal communication with you in the System. Information collected by us is voluntarily provided by you and may include information such as your name, email address, phone number, and physical address in addition to any other information you choose to provide. The System may also collect general information about your technology interface or preferences (such as the type of browser used or the files requested). Additionally, we may collect information regarding the websites you visit and other information, as described in this Privacy Policy.

The information we may collect includes, but may not be limited to:

• Your contact information to register to receive information, updates, promotions and materials from us, such as your first name, last name, phone number, and email address;
• Your transaction history relating to the use of our products and services;
• Information regarding your browser, internet service provider, and other technical specifications required to use our Site;
• Computer data or files, often called “cookies,” which may be sent by your web browser and stored on an individual computer to allow our server to “recognize” you through the navigation of the Site and for us to credit your account for various online transactions;
• Websites that referred you to our System or that you visit from our System;
• Computer data files, often called “web beacons” that are collected from emails or links on third-party sites that allow our server to evaluate the popularity of those links or the information contained in emails or on third-party sites; and
• Your IP address to measure our website traffic and to help provide a more personalized experience.

Children Under the Age of 13

Our Site and System are not designed for children, and we do not knowingly collect information from any person is under the age of 13.

How is User Information Used and Shared?

We collect information about you in order to provide you with services and products and also collect information that is necessary for the System to work properly. We use personal information about our users for a variety of purposes related to our business, including but not limited to:

• Allowing you to receive information from us regarding LSW products or services;
• Tracking information about your visits to our Site or use of the System to allow us to provide better service;
• Using certain online preferences in the aggregate across all users to evaluate the System and develop additional products and services to offer;
• Sending or initiating direct marketing programs, such as newsletters or information about new products or services we are offering;
• Contacting you regarding an inquiry on the System that you have initiated;
• Using content from social media platforms where you discuss our products or use a hashtag related to our products;
• Providing information about your usage or preferences to our third-party vendors and providers; and
• Other purposes necessary to carry out our obligations under this Privacy Policy or our Terms of Use.

We may share information, in the aggregate, regarding your online browsing preferences to evaluate our products or allow third parties we work with to better serve our users. We will not share personally identifiable information in these instances, other than described in this Privacy Policy.

We may provide user information to third-party service providers or vendors for purposes of, including without limitation, initiating direct marketing programs on our behalf, data tracking, maintenance or development of our System, development of online products and services or customer service or new product development, or other contracted promotional opportunities provided to our users. We will not share your information with third parties to directly market their products to you. We may share this information with any subsidiaries, licensees, suppliers, distributors, affiliates, assigns, successors, or other related entities and their respective owners. We may also share your personal information in connection with law enforcement requests or in response to investigations, subpoenas, court orders, or other legal process to establish or exercise our legal rights or defend against legal claims or as otherwise required by law.

Behavioral Advertising

We may also use third-party vendors, such as Google Analytics, to advertise to our users online. These third-party vendors may display LSW product advertisements on other websites based on your internet usage. More specifically, these vendors use first-party cookies (such as the Google Analytic cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize, and serve ads based on your past visits to the Site or another site affiliated with LSW products or services. Any information that these third parties collect via cookies is not linked to any personally identifiable information (name, address, email address, or phone number) we collect or you provide on the website. You can opt-out of Google Analytics for Display Advertising by using Google’s Ads Settings.

How is User Information Protected?

We maintain administrative, physical and technical safeguards for all user information collected in our System.

How Can Users Limit Information Collected?

By providing information to us or using our System, you are consenting to our use of your data as outlined in this Privacy Policy.

While we work hard to use and disclose our users’ personal information only for the purposes identified above, you can choose not to provide personal information or limit the personal information obtained by us as follows:

• You may have your contact information removed from our marketing lists to inform users of new or relevant products, services, and special offers by clicking on the unsubscribe link in any communication received from us or by emailing us at info@duluthcargo.com;
• You may limit the collection of “cookies” through your browser settings. However, this may disable our ability to provide you with the most relevant products or information regarding the System; and
• You may limit the ability of Google Analytics to track your online activity, as outlined in the “Behavioral Advertising” section.

Your California Privacy Rights

California Civil Code § 1798.83 permits users that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us via the Site.

Contacting Us

For additional information pertaining to our Privacy Policy, please contact:

Lake Superior Warehousing Company, Inc.
1310 Port Terminal Drive
Duluth, MN 55802
(218) 727-6646

This Privacy Policy was prepared for Lake Superior Warehousing Company, Inc. by Fryberger, Buchanan, Smith & Frederick, P.A.