WESTWOOD SHIPPING LINES

PRIVACY STATEMENT

Effective Date: August 2011 Last Updated Date: December 2019

1. About this Privacy Statement

Westwood Shipping Lines ("WSL," "us," "our," and "we") is committed to protecting the privacy of individuals who visit, use, and actively enter information into the website located at www.wsl.com (the "Site") operated by WSL (collectively, "Users"). Users may at times be referred to in this Privacy Statement as "you." This Privacy Statement describes WSL’s information practices in relation to your use of the Site. This Privacy Statement also applies to information collected by WSL through offline contacts it may have with you. If you have any questions about this Privacy Statement, please contact WSL at privacy@wsl.com.

PLEASE READ this Privacy Statement carefully before you browse and use the Site. Your usage of the Site signifies to us that you have read and understood all of the terms of this Privacy Statement. You may also be presented with additional opportunities to review this Privacy Statement when taking certain actions on the Site.

This Privacy Statement explains:

• What Personal Information we collect about you when you use the Site, why we collect it, who we disclose it to and how long we keep it for;
• How we use your Personal Information;
• How we protect your Personal Information; and
• Your legal rights in respect to your Personal Information, including how to access and update the information we hold about you.

2. Modifications to this Privacy Statement

We may need to update or revise this Privacy Statement from time-to-time in response to changing legal, technical, or business developments. We will post any new or revised Privacy Statement here, and you should review this Privacy Statement regularly to make sure that you are aware of its terms. You can determine if this Privacy Statement has been revised since your last visit to the Site by referring to the effective date or last updated date at the top of this Privacy Statement. WSL will also provide notification of significant changes to this Privacy Statement through the Site. In addition, if changes are significant, we may notify you of such changes via the Personal Information (defined below) that you have provided to us, if any. If we intend to use earlier-collected Personal Information and Automatically-Collected Information in accordance with the terms of the revised Privacy Statement and doing so would result in a use for a different purpose than stated at the time of collection, where required by law we will request your express consent prior to such use. We will keep prior versions of this Privacy Statement in an archive for your review upon request.

3. Personal Information You Voluntarily Provide to Us

When you interact with us through the Site or offline, we may ask you to voluntarily provide us with Personal Information in order enable us to respond to you, or provide the features you use to interact with us through the Site. As used herein, Personal Information refers to information that identifies, relates to, describes, is associated with, or is reasonably capable of being associated with a particular individual. Some common ways you may be asked to provide Personal Information include when you interact with us by:

• Submitting a "Contact Form" through the Site, or contacting us offline, to learn more about our business, services, or career opportunities (this also includes if you provide information to a third party that we have engaged to assist us with placements for career opportunities);
• Registering for or using a WSL account through the Site;
• Making a booking request or rate request;
• Making a payment for WSL services;
• Inquiring with us about our services, including information about our routes, fleet, and vessels;

Depending on the nature of your interaction with us, the Personal Information that we may ask you to provide to us includes the following information:

• your name, home address, email address, telephone number, and other information that could be used to contact you or identify you personally;
• business information, including your company, title, and business contact information;
• employment history and other employment-related information if you’ve inquired about career opportunities;
• Payment information; and
• any other Personal Information you enter into the Site or provide to us through offline interactions.

See additional information below regarding collection and use of your Personal Information

4. Automatically-Collected Information

WSL uses certain digital analytics tools on the Site that help us analyze site usage and performance when you visit and use the Site. The tools we use are discussed in more detail below. The information we collect automatically typically does not include any individuals’ names or contact information. Rather, as you navigate and browse the Site, these analytics tools automatically collect and store information about your visit to and use of the Site, such as: the date and time of your visit, the duration of your visit, the type of browser and browser language you use, your Internet Protocol ("IP") address, mobile device ID, type of computer or other operating device used, the actions you take on the Site (such as the web pages viewed and the links clicked), the websites (if any) from which you linked to the Site, and the website(s) you visit after visiting the Site. All such information is referred to in this Privacy Statement as "Automatically-Collected Information," and may be considered Personal Information depending on applicable privacy laws.

This Automatically Collected Information allows us to better understand the visitors to the Site, where they come from, and what ‎content on the Site is of interest to them. It also helps us to maintain the security and operation of the Site. We only ever use this Automatically Collected Information for our internal analytics purposes, to diagnose problems or vulnerabilities with our ‎servers, and to improve the quality, performance, and functionality of the Site‎.

5. How We Use Voluntarily Provided Personal Information

As described in section 3, above, you may voluntarily provide Personal Information to us in several ways. PLEASE NOTE THAT YOU DO NOT HAVE TO PROVIDE US WITH YOUR PERSONAL INFORMATION TO BROWSE THE SITE, AND YOU ARE NEVER UNDER ANY OBLIGATION TO PROVIDE YOUR PERSONAL INFORMATION. However, if you do not provide your Personal Information, you may not be able to use certain features of the Site to interact with us. When you do provide us with your Personal Information, you are authorizing us to use that information to fulfill the purposes identified herein in accordance with the terms of this Privacy Statement and to store your information on our servers located in the United States. You understand that your Personal Information may be subject to the laws of the United States, and that it may be accessible to governments, tribunals, law enforcement and regulatory agencies in the United States.

WSL uses Personal Information provided by Users to perform the services they request. For example, if you request or make a booking, WSL will use the information provided to perform the booking service, and provide you with updates and information about your booking as applicable. If you register for an account with us, the information you provide will be associated with your account. If you apply for a job, we will use the information provided to consider you for the position and to contact you regarding your application. We may also use your Personal Information to contact you regarding your use of the Site and/or to provide required notices.

WSL does not currently use Personal Information provided by Users for marketing purposes. However, if you inquire about WSL services, we may use your Personal Information that you provide to respond to your inquiry, which may include discussing your interest in WSL services and providing you with information about WSL services. In such case, you may request that we stop contacting you for such purposes by sending an email with your request to privacy@wsl.com. If in the future we use your Personal Information to send you marketing communications via email, we will provide you with an unsubscribe mechanism to opt-out of receiving future marketing communications. If you request that we not contact you for the purposes described in this section, depending on the nature of our business relationship with you, we may still contact you for non-marketing purposes relating to your use of the Site or otherwise in regard to our business relationship with you.

We may use both Personal Information and Automatically-Collected Information to help diagnose problems with the Site, to analyze site performance and security, and to improve our service offerings. We may also use your Personal Information and Automatically-Collected Information to customize and tailor your experience using the Site when you are logged-in to your account.

As described above, if you are interested in employment or career opportunities with WSL we will ask you to provide us, or any third party agency we have engaged to assist us with hiring, Personal Information required for the application and recruiting process. We will only use this Personal Information to consider your application(s) and as part of your personnel file if you are hired. WSL does not sell this Personal Information, and does not allow third parties to use this Personal Information for their direct marketing purposes , or any other purposes other than as required to assist WSL with hiring.

6. Collection and Use of Automatically-Collected Information

As described above, WSL uses commonly-used information-gathering tools to collect Automatically-Collected Information as you navigate the Site, including cookies. WSL uses Automatically-Collected Information to operate and improve the Site, including to track what Users are looking at most frequently so we can recognize and deliver more of the desired features, products, and services. This section describes in further detail the types of Automatically-Collected Information WSL may collect and how WSL may use this Automatically-Collected Information.

The Site uses temporary session "cookies" to facilitate your interactions with the Site and maintain Site security. There are two types of cookies: Session-based and persistent-based. Session cookies exist only during one session. They disappear from your computer or operating device when you close your browser software or otherwise end your session. Persistent cookies remain on your computer or operating device after you close your browser or otherwise end your session. We use session cookies to provide us information about Site features used and activities conducted while using the Site.

When you visit the Site, a temporary cookie assigns your computer or operating device a unique, random number that acts as a sort of anonymous ID during your browsing session. Standing alone, these cookies do not personally identify you. Rather, the cookie identifies the computer or operating device used to access the Site. The cookie does not read data on your hard drive. Unless you choose to identify yourself to us, such as by accessing your account or filling out a web form, you remain anonymous to WSL when browsing the Site.

Most browsers automatically accept cookies, but you can disable the acceptance of cookies at any time by changing the preferences in your browser. Most browsers also allow you to change the settings to require that the browser notify you when you receive a new cookie. Please refer to your browser for information on how to disable and control cookies. Information about managing cookies in commonly used browsers is available online from www.allaboutcookies.org. If you disable your web browser’s ability to accept cookies, you will be able to browse the Site, but you may not be able to successfully use certain features of the Site.

When you visit the Site, our digital analytics tools collect your Internet Protocol ("IP") addresses and/or mobile device IDs to track and aggregate Automatically-Collected Information. For example, WSL uses IP addresses and mobile device IDs to monitor the regions from which Users navigate the Site in order to help us to maintain the security and operation of the Site.

7. How We Share the Personal Information We Collect

WSL may share your Personal Information in the manners described in this section. In general, Westwood Shipping Lines will not share or sell your information with any person or entity other than one of its subsidiaries, affiliates and representatives unless we have your permission to do so or in accordance with the terms of this policy.

In addition, WSL may also share without restriction aggregated Automatically-Collected Information that has been de-identified or otherwise rendered anonymous to the point that it is not linked or reasonably linkable to any individual, including via a specific device.

In addition to the above, WSL may share personal information with third-parties as follows:

WSL may provide your Personal Information and Automatically Collected Information to third party service providers to perform certain services for us, including: to perform website analytics services, as described above in this Privacy Statement; and to provide other services relating to the operation of the Site (such as hosting, data storage, and security). WSL does not sell User Personal Information to any third parties. Rather, any disclosure of Personal Information to third party service providers is solely to enable the service provider to perform the requested services on WSL’s behalf. These third-party service providers are not authorized to use your information received from WSL in any way, including for their own marketing efforts, other than for the purpose of providing a service on our behalf, and are required to keep the information confidential.

We may transfer any and all Personal Information and Automatically-Collected Information to a third party if WSL is involved in a merger, acquisition, reorganization, restructuring, or other sale or transfer of all or any portion of its assets or business, whether as a going concern or as part of bankruptcy, liquidation, or similar proceedings in which information of Users is among the assets transferred. In this event, we will, if allowed, use reasonable efforts to notify you when your Personal Information and Automatically-Collected Information is transferred to any third party under this paragraph by posting such notice on the Site and/or by contacting you via the Personal Information you have provided us, if any. Unless you consent otherwise, we will require the third party to agree to only use your Personal Information in accordance with this Privacy Statement, even after the transfer. But any new information you provide after the transfer will likely be subject to a new policy, and you should review that policy.

Notwithstanding anything to the contrary in this Privacy Statement, WSL reserves the right to disclose your Personal Information and Automatically-Collected Information, without your consent and without additional notice to you, if we reasonably believe we are required by law, rule, regulation, judicial proceeding, court order, subpoena, or similar legal process to do so; if we reasonably believe that disclosure is necessary to protect, establish, or exercise our rights or property, or to defend against legal claims; or if we reasonably believe that disclosure is necessary to protect our other Users or our employees, property, or business, or to take action regarding illegal activities or suspected fraud.

8. Accessing, Correcting and Updating Your Information; Your Rights Regarding Your Information

If you have registered for an account through the Site, you may access, update or change your Personal Information associated with your account by accessing and/or editing your account profile. For all other purposes, Site Users may access, update or change their Personal Information by sending us an email request to privacy@wsl.com. If you want us to delete your Personal Information from our databases, please contact us at privacy@wsl.com. Upon receipt of your request to delete or to change your Personal Information, we will use commercially-reasonable efforts to remove your existing Personal Information from our databases, but see the Section entitled "Retention and Storage" below regarding why we may retain some information. Please note that all features of the Site may not function properly if we remove any or all of your Personal Information.

If you are based in certain jurisdictions, you may have certain rights in relation to the Personal Information we hold about you. These may include the right to request to:

• access details related to the Personal Information WSL has collected about you, for example the categories of Personal Information collected, the sources of those categories, the business or commercial purposes for collecting Personal Information, any third parties with whom Personal Information is shared, and the specific pieces of Personal Information collected about you;
• rectify any incorrect or incomplete Personal Information we hold about you
• delete, restrict, or remove the Personal Information we hold about you
• transfer the Personal Information we hold about you to another party; or
• object to the sale of your Personal Information (please note that WSL does not currently sell Personal Information, nor has it sold any Personal Information in the preceding 12 months).

We will attempt to respond to your requests within one month and free of charge. Please note that with regard to all these rights, we reserve the right to:

• verify proof of your ID to process the request, or request further information for this purpose;
• refuse your request based on the exemptions set out in any applicable data protection laws;
• charge you a reasonable administrative fee for any repetitive, manifestly unfounded, or excessive requests.

If we refuse your valid request to exercise any of these rights which you may have, we will state the reasons for our refusal and allow you to challenge our decision. If we have shared your Personal Information with others, we will inform them about your request where possible. If you ask us, where possible and lawful to do so, we will also tell you with whom we shared your Personal Information so that you can contact them directly. If you wish to exercise any data protection rights that are available to you under your local ‎data protection laws then please send ‎your request to privacy@wsl.com or call our corporate office at 253-200-3800 and we will act upon your request in accordance ‎with applicable data protection laws.‎

Your California Privacy Rights

Please note, as described above in this Privacy Statement, WSL does not sell Personal Information, nor does it disclose Personal Information to third parties for their direct marketing purposes.

Notwithstanding the above, if you are a California resident, you have the right to request information from us regarding the ‎manner in which we share certain categories of your Personal Information with third-parties. ‎Specifically, California law provides you the right to submit a request to us at the designated address in the "Contact Us" section below to ‎receive the following information:‎

• the categories of information we disclosed to third-parties for the third-parties’ direct ‎marketing purposes during the preceding calendar year;‎
• the names and addresses of third-parties that received such information; and
• if the nature of a third-parties’ business cannot be reasonably determined from the third-‎parties’ name, examples of the products or services marketed.‎

You are entitled to receive a copy of this information in a standardized format and the ‎information will not be specific to you individually.

9. Children’s Privacy

The Site is not directed at nor intended for use by children under either the age of 13. Further, WSL will never use or disclose any Personal Information of a child under either the age of 18 for marketing or advertising purposes. If you are under age 18 you should not provide WSL with Personal Information about yourself if you use the Site. If we learn that we have received Personal Information or Automatically-Collected Information from a child under either the age of 18 we will delete that information from our files.

10. Security of Collected Information

WSL uses commercially-reasonable physical, electronic, and administrative security measures to assist in protecting against the loss, misuse, and unauthorized alteration of Personal Information that is under our control. This includes the use of firewalls, encryption of data, voluntary vulnerability scans and penetration testing, workforce training and access limitations, and other security measures. In connection with any application, request or enquiry you make, some information may be made available to Westwood Shipping Lines affiliates some of which will be based in countries that do not have privacy laws. Westwood Shipping Lines advocates that people carefully consider what information they share and who they share it with. We recommend that everyone develop good security habits. These include protecting and regularly changing your password, using computer virus protection, logging off when you finish using your computer, and consider the use of file or email encryption programs. Unfortunately, no data storage system, or system of transmitting data over the Internet or wireless network, can be guaranteed to be 100% secure, and no security system can prevent all security breaches. As a result, we do not and cannot guarantee the security of our systems or any Personal Information or Automatically-Collected Information provided to us in relation to your use of the Site or when you interact with us.

11. Do Not Track

The Site does not track your online activities over time and across third-party web sites or ‎online ‎services, and so does not respond to browser "Do Not Track" signals. As described in this Privacy Statement, ‎the Site may contain links to other websites not owned or operated by WSL. These ‎websites ‎may set cookies that obtain information about the fact that a web browser visited the Site from a ‎certain IP address. These websites are not authorized to collect any other ‎personal data from the ‎Site unless you provide it to them directly.‎

12. Retention, Storage and Removal

We may retain all Personal Information and Automatically-Collected Information in our databases for long as necessary to perform the business purposes for which we’ve collected it, or until you ask us to remove your information from our databases, unless applicable laws require otherwise. When we have no ongoing business need to process your Personal Information, we will ‎either delete or aggregate it, or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible. Note that even after you ask us to remove your information from our databases, it may be impossible to remove some information, such as information tracked in our web server log files and information that may reside in backup files. This residual information is retained to preserve the integrity of our backed-up files and for business continuity purposes. We may also retain Automatically-Collected Information even after you request that we remove your information from our databases, for use in the aggregate and to analyze and improve the Site.

Further, even after you request that we remove your information from our databases, we may retain Personal Information and Automatically-Collected Information to comply with any applicable law, rule, regulation, or guideline; to prevent fraudulent activity; to protect ourselves against liability; and to allow us to enforce our contractual or other rights and to pursue available remedies and limit any damages we may sustain.

13. Links to Other Websites

This Privacy Statement applies only to Personal Information and Automatically-Collected Information collected through the Site or that you otherwise provide to WSL. The Site may contain links to other websites that are not owned or controlled by us ("Linked Sites"). We are not responsible or liable for and have not reviewed the privacy practices of the Linked Sites, or those of the owners or operators of the Linked Sites. The owners and operators of the Linked Sites may have their own policies regarding privacy and security. We advise you to review any Linked Sites for their own privacy practices to determine what information about you may be collected and used when you use such Linked Sites.

14. Severability

If any part of this Privacy Statement is determined to be invalid or unenforceable pursuant to applicable law, then the invalid or unenforceable provision will be deemed superseded by a valid, enforceable provision that most closely matches the intent of the original provision, and the remainder of the Privacy Statement shall continue in full force and effect.

15. Contacting Us

Questions regarding this Privacy Statement or the information practices pertaining to the Site, including our information practices related to our use of or disclosures to service providers or other third parties, should be directed to privacy@wsl.com or by contacting us using the information below:

• By Phone to our Corporate Office: 253-200-3800
• By Mail to:
• Westwood Shipping Lines
  1019 39th Avenue SE Suite 210
  Puyallup, WA 98374