Palleter’s Privacy Policy

Welcome, and thank you for your interest in Palleter application (the App) and our website www.palleter.com (the Website), provided to you by an Estonian private limited company OÜ Palleters, registry code 12945071, (Palleter, us or we). The Website and the App, as well as all related platforms, networks, downloadable software, and other services provided by us, are collectively referred to as our Service.
This privacy policy (the Policy) describes the information that we gather from you in relation to the Service, how we use and disclose such information, and the steps we take to protect such information. By using the Service, you consent to the privacy practices described in this Policy.
This Policy is incorporated into our Terms of Service and into your Agreement with us. Capitalized terms used but not defined in this Policy have the meaning given to them in the Terms of Service, available at palleter.com/terms.

This is the information we collect in relation to the Service:

  1. User-provided Information. When you use the Service, you may provide and we may collect information from you, also including information what is generally called “personally identifiable” information, or “personal information,” which is any information relating to an identified or identifiable natural person (the Personal Data). Examples of Personal Data include name, email address, mailing address, mobile phone number, and credit card or other billing information. Personal Data also includes other information, such as date of birth, geographic area, or preferences, when any such information is linked to information that identifies or is able to identify a specific individual. You may provide us with Personal Data in various ways on the Service. For example, you provide us with Personal Data when you register for an account, use the Service, post Client Data, sign documents, interact with other users of the Service through communication or messaging features, or send us customer service related requests.
  2. As part of the Service, you may provide us with Client Data, including Personal Data about your customer or a third person, to store in the System on your behalf in connection with your use of the Service. Please note that we have no direct relationship with the individuals or companies whose Personal Data you have inserted in the System as part of Client Data. We may work with you to help you provide notice to your customers and third persons concerning the purpose for which their Personal Data is collected and how it is processed in the Service as part of Client Data, but as we are not acting as a data controller in that respect, we have no such notification obligation.
  3. Cookies Information. When you use the Service, we may send one or more cookies – small text files containing a string of alphanumeric characters – to your device. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to the Service. Please review your web browser “Help"-file to learn the proper way to modify your cookie settings. Please note that if you delete or choose not to accept cookies from the Service, you may not be able to utilize the features of the Service to their fullest potential.
  4. Automatically Collected Information. When you use the Service, we may automatically record certain information from your device by using various types of technology, including “clear gifs" or “web beacons.” This “automatically collected” information may include your IP address or other device address or ID, web browser and/or device type, the web pages or sites that you visit just before or just after you use the Service, the pages or other content you view or otherwise interact with on the Service, and the dates and times that you visit, access, or use the Service. “Automatically collected” information may also include device tokens or other forms of device identification. Device tokens or similar device identifiers are unique to each mobile device and we use them to send push notifications to your device. We also may use these technologies to collect information regarding your interaction with email messages, such as whether you opened, clicked on, or forwarded a message. This information is gathered from all users.
  5. Third Party Web Beacons and Third Party Buttons. We may also implement third-party content or advertising on the Service that may use clear gifs or other forms of web beacons, which allow the third-party content provider to read and write cookies to your browser in connection with your viewing of the third party content on the Service. Additionally, we may implement third party buttons (such as Facebook “like” or “share” buttons) that may allow third parties to collect information about you through such third parties’ browser cookies, even when you do not interact with the button. Information collected through web beacons and buttons is collected directly by these third parties, and Palleter does not participate in that data transmission. Information collected by a third party in this manner is subject to that third party’s own data collection, use, and disclosure policies.
  6. Integrated Services. You may be given the option to access or register for the Service through the use of your user name and password for certain services provided by third parties (each, an Integrated Service), such as through the use of your Facebook or Google account, or otherwise have the option to authorize an Integrated Service to provide Personal Data or other information to us. By authorizing us to connect with an Integrated Service, you authorize us to access and store your name, email address(es), date of birth, gender, current city, profile picture URL, and other information that the Integrated Service makes available to us, and to use and disclose it in accordance with this Policy. You should check your privacy settings on each Integrated Service to understand and change the information sent to us through each Integrated Service. Please review each Integrated Service’s terms of use and privacy policies carefully before using their services and connecting to our Service.
  7. Information from Other Sources. We may obtain information, including Personal Data, from third parties and sources other than the Service, such as our partners, advertisers, and Integrated Services. If we combine or associate information from other sources with Personal Data that we collect through the Service, we will treat the combined information as Personal Data in accordance with this Policy.
  8. Location Information. We may track and save your location and the location of the cargo you are transporting. We may disclose your location or the current or estimated future location of the cargo you are transporting to other Marketplace Feature users, in order to help you to fill you spare cargo space with nearby freight.
You agree that any information we collect and process is relevant and not excessive in relation to the purposes for which the information is collected and/or further processed.

Data Controller and Data Processor

We do not own, control, direct or determine the use of any of the information stored or processed by you via Service. Only the Client or the Users are entitled to access, retrieve, determine and direct the use of such information. Please note that we are largely unaware of what information is actually being stored or made available by you to the Service and we do not directly access such information or data except as authorized by you or as necessary to provide the Service to you.

Because we do not collect or determine the use of any Personal Data contained in the Client Data and because we do not determine the purposes for which such Personal Data is collected, the means of collecting such Personal Data, or the uses of such data, we are not acting in the capacity of data controller in terms of the European Union’s Directive 95/46/EC on data privacy (the Directive) and we do not have the associated responsibilities under the Directive. Palleter should be considered only as a processor on behalf of its Clients and Users as to any Client Data containing Personal Data that is subject to the requirements of the Directive. Except as provided in this Privacy Policy, Palleter does not independently cause Client Data containing Personal Data stored in connection with the Service to be transferred or otherwise made available to third parties, except to third party subcontractors who may process such data on behalf of Palleter in connection with Palleter’s provision of Service to Clients. Such actions are performed or authorized only by the respective Client or User.

You acknowledge and agree that you are the data controller under the Directive for any Client Data containing Personal Data, meaning that you control the manner such Personal Data is collected, and you determine the purposes and means of processing of such Personal Data. Palleter is not responsible for the content of the Personal Data contained in the Client Data or other information stored on its servers (or its subcontractors’ servers) at the discretion of the Client or User, nor is Palleter responsible for the manner in which the Client or User collects, handles disclosure, distributes or otherwise processes such information. You represent and warrant that you are aware of your responsibilities as a data controller arising from applicable legal acts (incl. the Directive).

How we use the information we collect

We use information we collect on the Service in a variety of ways in providing the Service and operating our business, including the following:


When we disclose information

Except as described in this Policy, we will not disclose your information that we collect on the Service to third parties without your consent. We may disclose information to third parties if you consent to us doing so, as well in the following circumstances:

  1. Information about our users, including Personal Data, may be disclosed and otherwise transferred to an acquirer, or successor or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets.
  2. If you accept a transport request via our marketplace feature, we may provide location information of the cargo you carry to the requesting consignor/consignee.
  3. We also may disclose your information as may be described in a notice to you at the time the information is collected, or in any other manner to which you consent.

Your Choices

We respect your privacy rights and provide you with reasonable access to the Personal Data that you may provide through the Service. Further, we provide you with the ability to correct inconsistencies of or to update your information.
You may, of course, decline to share certain Personal Data with us, in which case we may not be able to provide to you some of the features and functionality of the Service. You may update, correct, or delete your profile information and preferences at any time by accessing your Account preferences page on the Service. If you wish to access or amend any other Personal Data we hold about you, or to request that we delete any information about you that we have obtained from an Integrated Service, you may contact us at privacy@palleter.com. Please note that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain all information you submit for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.
You may opt out from sending navigation information about your visit to the Website to Google Analytics by using the Google Analytics Opt-out page.
If you receive commercial or promotional email from us, you may unsubscribe from it at any time by clicking respective link at the bottom of the email. We may allow you to view and modify settings relating to the nature and frequency of promotional communications that you receive from us also in Account functionality on the Service.
Please be aware that if you opt-out of receiving commercial email from us or otherwise modify the nature or frequency of promotional communications you receive from us, it may take up to ten business days for us to process your request, and during that period you may receive promotional communications from us that you have opted-out from. Additionally, even after you opt-out from receiving commercial messages from us, you will continue to receive administrative messages from us regarding the Service.
Palleter has no direct relationship with a Client’s customer or third party whose Personal Data Palleter may process on behalf of a Client. An individual who seeks access, or who seeks to correct, amend, delete inaccurate data or withdraw consent for further contact should direct her query to the Client or User they deal with directly. If the Client thereafter requests Palleter to remove the data, we will respond to the request within 30 days. In any event, we will delete or amend any Personal Data that we are storing if we receive a written request to do so, unless we have a legal right to retain such Personal Data. Any such request should be addressed to privacy@palleter.com and include sufficient information for Palleter to identify the Client or its customer or third party and the information to be deleted or amended.

Do Not Track Settings

Your device operating system or browser may include settings, options, or add-on components to control the placement and presence of cookies and access to location information. We do not track our users over time and across third party websites to provide targeted advertising and do not specifically respond to Do Not Track (DNT) signals. However, some third party websites do keep track of your browsing activities, including across other websites on the Internet, which enables these websites to tailor what they present to you. If you are visiting such websites, your browser may allow you to set a DNT signal on your browser so that third parties know you do not want to be tracked.

Third-Party Services

The Service may contain features or links to websites and services provided by third parties. Any information you provide on third-party sites or services is provided directly to the operators of such services and is subject to those operators’ policies, if any, governing privacy and security, even if accessed through the Service. We are not responsible for the content or privacy and security practices and policies of third-party sites or services to which links or access are provided through the Service. We encourage you to learn about third parties’ privacy and security policies before providing them with information.

Children’s Privacy

Protecting the privacy of young children is especially important. Our Service is not directed to children under the age of 18, and we do not knowingly collect Personal Data from children under the age of 18 without obtaining parental consent. If you are under 18 years of age, then please do not use or access the Service at any time or in any manner. If you are a parent or guardian and discover that your child under 18 years of age has obtained an account on the Service, then you may alert us at privacy@palleter.com and request that we delete that child’s personally identifiable information from our systems.

Data Security

We follow generally accepted industry standards to protect the information submitted to us, both during transmission and once we receive it. We use certain physical, managerial, and technical safeguards that are designed to improve the integrity and security of your Personal Data.

However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. We cannot therefore ensure or warrant the security of any information you transmit to us or store on the Service, and you do so at your own risk. We also cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. If you believe your Personal Data has been compromised, please contact us at privacy@palleter.com.

If we learn of a security systems breach, then we may attempt to notify you electronically so that you can take appropriate protective steps. We may post a notice through the Service if a security breach occurs.

Data Retention

We only retain the information collected from you for as long as your account is active or otherwise for a limited period of time as long as we need it to fulfill the purposes for which we have initially collected it, unless otherwise required by law. We will retain and use information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements as follows:
  1. billing information is retained for a period of seven years as of their provision to Palleter in accordance with the Estonian accounting and taxation laws;
  2. information on legal transactions between you and us is retained for a period of ten years as of provision of such information to Palleter in accordance with the general limitation period set for civil claims in the Estonian General Part of the Civil Code Act.

Privacy Settings

Although we may allow you to adjust your privacy settings to limit access to certain Personal Data, please be aware that no security measures are perfect or impenetrable. We are not responsible for circumvention of any privacy settings or security measures on the Service. Additionally, we cannot control the actions of other users with whom you may choose to share your information. Further, even after information posted on the Service is removed, caching and archiving services may have saved that information, and other users or third parties may have copied or stored the information available on the Service. We cannot and do not guarantee that information you post on or transmit to the Service will not be viewed by unauthorized persons.

Data Transfer

We may transfer, process and store Personal Data we collect through the Services in centralized databases located in Estonia, or in other areas of Europe, or outside Europe, e.g. in United States. The country we are processing the information may not have the same data protection framework as the country from which you may be using the Service. We will comply with applicable legal requirements providing adequate protection for the transfer of Personal Data.

International Visitors

The Service is hosted in Europe and is intended for visitors located in Europe. If you choose to use the Service from other regions of the world with laws governing data collection and use that may differ from the laws in European Union (the EU), then please note that we may be transferring your Personal Data outside of those regions to EU for storage and processing. Also, we may transfer your data from EU to other countries or regions. By providing any information, including Personal Data, on or to the Service, you consent to such transfer, storage, and processing.

Changes and Updates to this Policy

Please revisit this page periodically to stay aware of any changes to this Policy, which we may update from time to time. If we modify the Policy, we will make it available through the Service, and indicate the date of the latest revision. Any material changes will be posted on the Website and will come into effect 30 days after their posting. In the event that the modifications materially alter your rights or obligations, we will make reasonable efforts to notify you of the change. For example, we may send a message to your email address, if we have one on file, or generate a pop-up or similar notification when you access the Service for the first time after such material changes are made. If you do not refuse the changes in writing before they become effective, this means you have consented to the Privacy Policy as changed. Your continued use of the Service after the revised Policy has become effective indicates that you have read, understood and agreed to the current version of the Policy.

Our Contact Information

Please contact us with any questions or comments about this Policy, your Personal Data, our use and disclosure practices, or your consent choices by email at privacy@palleter.com.

Palleters OÜ
Aadress: Raekoja plats 1, Tartu, Estonia

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