Privacy Policy | Lynden

Lynden Incorporated

Privacy Policy

Last Modified: 6/1/26

Lynden Incorporated (“Lynden”, “we”, “us” or “our”) takes your privacy seriously. Please read this Privacy Policy to learn how we treat your Personal Data. By using or accessing our web or mobile application-based services including our websites available at  https://www.lynden.com, our online payment service at https://www.lynden.com/online-tools/online-payment and our EZ Commerce portal at https://ezc.lynden.com (including all webpages, subdomains and subparts therein contained, separately or collectively, our “Site”) and through all services available on or through the Site or otherwise provided by Lynden in connection with the Site and through social media, email, text, and other electronic communications between you and Lynden (collectively, the “Services”) in any manner, you acknowledge that you accept the practices and policies outlined below, and you hereby consent that we will collect, use and disclose your information as described in this Privacy Policy.

Your use of Lynden’s Services is at all times subject to our Terms of Use (https://www.lynden.com/legal/website-terms-of-use), which incorporates this Privacy Policy. Any terms we use in this Privacy Policy without defining them have the definitions given to them in the Terms of Use.

Changes to this Privacy Policy

As we work to improve our Services, we may need to change this Privacy Policy from time to time. We will seek to alert you of material changes by placing a notice on our Site, by sending you an email and/or by other means. Please note that if you have opted not to receive legal notice emails from us (or if you have not provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes. Use of information we collect is subject to the Privacy Policy in effect at the time such information is collected.

What this Privacy Policy Covers

This Privacy Policy covers how we treat Personal Data that we gather when you access or use our Services. “Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information”, “personal information” or “sensitive personal information” under applicable data privacy laws, rules or regulations. It also includes information we receive from third parties that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device.  It does not include deidentified or aggregated consumer information. This Privacy Policy does not cover the practices of companies we do not own or control or people we do not manage.

Personal Data

Categories of Personal Data We Collect

The following list details the categories of Personal Data that we may collect and have collected over the past 12 months:

1. Profile or Contact Data such as first and last name, email, phone number, mailing address and employer.

Business or Commercial Purpose(s) for Collection:

  • providing, customizing and improving the Services;
  • marketing the Services and
  • corresponding with you.

Categories of Third Parties With Whom We Disclose this Personal Data:

  • service providers and
  • advertising partners.

Identifiers such as social security number, driver’s license number, state identification card, and passport number.

Business or Commercial Purpose(s) for Collection:

  • providing, customizing and improving the Services and
  • corresponding with You.

Categories of Third Parties With Whom We Disclose this Personal Data:

  • service providers.

2. Payment Data such as financial account information, payment card type, full number of payment card, last 4 digits of payment card, card verification value (“CVV”), billing address, billing zip code and billing email.

Business or Commercial Purpose(s) for Collection:

  • providing, customizing and improving the Services.

Categories of Third Parties With Whom We Disclose this Personal Data:

  • service providers (specifically our payment processing partner).

3. Commercial Data such as purchase history and consumer profiles.

Business or Commercial Purpose(s) for Collection:

  • providing, customizing and improving the Services;
  • marketing the Services and
  • corresponding with you.

Categories of Third Parties With Whom We Disclose this Personal Data:

  • service providers and
  • advertising partners.

4. Device/IP Data such as IP address and type of device, operating system and browser used to access the Services.

Business or Commercial Purpose(s) for Collection:

  • providing, customizing and improving the Services;
  • marketing the Services and
  • corresponding with you.

Categories of Third Parties With Whom We Disclose this Personal Data:

  • service providers and
  • advertising partners.

5. Web Analytics such as browsing or search history, web page interactions (including with ads), referring webpage/source through which you accessed the Services and statistics associated with the interaction between device or browser and the Services.

Business or Commercial Purpose(s) for Collection:

  • providing, customizing and improving the Services;
  • marketing the Services and
  • corresponding with you.

Categories of Third Parties With Whom We Disclose this Personal Data:

  • service providers and
  • advertising partners.

6. Social Network Data such as email and user name.

Business or Commercial Purpose(s) for Collection:

  • providing, customizing and improving the Services;
  • marketing the Services and
  • corresponding with you.

Categories of Third Parties With Whom We Disclose this Personal Data:

  • service providers and
  • advertising partners.

7. Geolocation Data such as IP-address-based location information.

Business or Commercial Purpose(s) for Collection:

  • providing, customizing and improving the Services;
  • marketing the Services and
  • corresponding with you.

Categories of Third Parties With Whom We Disclose this Personal Data:

  • service providers and
  • advertising partners.

8. Inferences Drawn from Other Personal Data Collected such as attributes, user behavior, and predispositions.

Business or Commercial Purpose(s) for Collection:

  • providing, customizing and improving the Services;
  • marketing the Services and
  • corresponding with you.

Categories of Third Parties With Whom We Disclose this Personal Data:

  • service providers.

9. Other Identifying Information that You Voluntarily Choose to Provide such as emails, letters, texts, photos, and videos you send us.

Business or Commercial Purpose(s) for Collection:

  • providing, customizing and improving the Services;
  • marketing the Services and
  • corresponding with you.

Categories of Third Parties With Whom We Disclose this Personal Data:

  • service providers.

In addition to the above categories of Personal Data, we may collect other types of information which may or may not contain Personal Data. Information related to shipments and services may include shipment tracking number, shipment routing information, location data, status of a shipment, delivery location, packaging type, number of parcels, weight, picture of the parcels, and customs information. Depending on your interaction with Lynden, we may also get information about you from third parties and service providers that we engage to send promotional communications for us or provide marketing and advertising services.

Our Commercial or Business Purposes for Collecting Personal Data

  • Providing, Customizing and Improving the Services
    • creating and managing your account or other user profiles;
    • processing orders or other transactions and billing;
    • providing you with the products, services or information you request;
    • meeting or fulfilling the reason you provided the information to us;
    • providing support and assistance for the Services;
    • improving the Services, including testing, research, internal analytics and product or service development;
    • personalizing the Services, website content and communications based on your preferences;
    • providing fraud protection, security and debugging;
    • carrying out other business purposes stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws including the California Consumer Privacy Act of 2018 (Cal. Civ. Code §§ 1798.100 – 1798.199.100), and its implementing regulations and any related regulations or guidance provided by the California Attorney General or the California Privacy Protection Agency, as amended, extended, or superseded from time to time including by the California Privacy Rights Act of 2020 (the “CCPA”); and
    • certain areas of the Site require registration or a password for access.  Some of the information collected in registration, or when shipment or payment information is provided, is identifiable to an individual person. Examples of personal information include names, addresses, email addresses, and telephone numbers.
  • Marketing the Services
    • marketing and selling the Services and
    • showing you advertisements, including interest-based, online behavioral or targeted advertising.
  • Corresponding with You
    • responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about Lynden or the Services and
    • sending emails and other communications according to your preferences or that display content that we think will interest you.

Other Permitted Purposes for Processing Personal Data

In addition, each of the above referenced categories of Personal Data may be collected, used, and disclosed with the government, including law enforcement, or other parties to meet certain legal requirements and enforcing legal terms including: fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities; protecting the rights, property or safety of you, Lynden or another party; enforcing any agreements with you or another party; responding to claims that any posting or other content violates third-party rights; and resolving disputes.

We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated or incompatible purposes without providing you notice.

Categories of Sources of Personal Data

We collect Personal Data about you from the following categories of sources:

  • You
    • When you provide such information directly to us.
      • when you create an account or use our interactive tools and Services;
      • when you voluntarily provide information in free-form text boxes through the Services or through responses to surveys or questionnaires and
      • when you send us an email or otherwise contact us.
    • When you use the Services and such information is collected automatically.
      • through Cookies (defined in the “Tracking Tools, Advertising and Opt-Out” section below);
      • if you download our mobile applications or use a location-enabled browser, we may receive information about your location and mobile device, as applicable and
      • if you download and install certain applications and software we make available, we may receive and collect information transmitted from your computing device for the purpose of providing you the relevant Services, such as information regarding when you are logged on and available to receive updates or alert notices.
  • Third Parties
    • Vendors
      • We may use analytics providers to analyze how you interact and engage with the Services, or third parties may help us provide you with customer support and
      • We may use vendors to obtain information to generate leads and create user profiles.
    • Advertising Partners
      • We may receive information about you from some of our vendors who assist us with marketing or promotional services related to how you interact with our Site, applications, Services, advertisements or communications.
    • Third-Party Plug-Ins or Credentials
      • We may use social media plug-ins from social media networks like Facebook, X (formerly known as Twitter),  Instagram, LinkedIn and YouTube, which are labeled on the Site with the well-known symbols of the respective social network. If you interact with these plug-ins or provide your third-party account credentials, such as your social network account credentials, to us or otherwise sign in to the Services through a third-party site or service, some content and/or information in those accounts may be transmitted into your account with us and your activity on the Site may also be made available to those social networks. To understand how those social networks, use and disclose your Personal Data, please review the privacy policies available on the websites of those social networks.

How We Disclose Your Personal Data

We may disclose your Personal Data to the categories of service providers and other parties listed in this section. Depending on state laws that may be applicable to you, some of these disclosures may constitute a “sale” of your Personal Data. For more information, please refer to the state-specific sections below.

  • Service Providers. These parties help us provide the Services or perform business functions on our behalf. They include:
    • hosting, technology and communication providers;
    • analytics providers for web traffic or usage of the Services;
    • companies that track how users found or were referred to our Site;
    • companies that track how users interact with our Site;
    • security and fraud prevention consultants;
    • support and customer service vendors;
    • communication providers that facilitate, manage, and send or receive communications on our behalf via email, text/SMS, phone, or that record, transcribe, summarize, or process phone calls and meetings;
    • service fulfillment and delivery providers; and
    • payment processors:
      • our payment processing partner and their service provider collect your voluntarily-provided bank account information or payment card information necessary to process your payment.
      • Customers who register and use Lynden’s EZ Payment service or who make payment in person or by phone are passed through to servers operated by our payment processor and their service provider.  All information entered is processed and stored by our payment processor and their service provider other than the customer’s Login Id which is stored by Lynden.  The bank is solely responsible for maintaining the security of information on its servers.
    • ad networks and
    • marketing providers.
  • Analytics Partners. These parties provide analytics on web traffic or usage of the Services. They include:
    • companies that track how users found or were referred to the Services,
    • companies that track how users interact with the Services,
  • Third parties you authorize, access or authenticate.
    • third parties you access through the services and
    • social media services.

Legal Obligations

We may disclose any Personal Data that we collect with third parties in conjunction with any of the activities set forth under “Other Permitted Purposes for Processing Personal Data” section above.

Business Transfers

All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, sale of all or substantially all of our assets, reorganization, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part). You acknowledge that such transfers may occur and that any such third party may continue to use your Personal Data as set forth in this Privacy Policy. Should one of these events occur, we will make reasonable efforts to notify you before your Personal Data becomes subject to different privacy and security policies and practices.

Data that is Not Personal Data

We may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. For example, we collect statistical information about how visitors of our Site, collectively, use our Site. While some of this information may possibly be derived from Personal Data, this statistical information is not Personal Data and cannot be tied back to you or your web browser or device. We may use such aggregated, de-identified or anonymized data and disclose it with third parties for our lawful business purposes, including to analyze, build and improve the Services and promote our business, provided that we will not disclose such data in a manner that could identify you.

Tracking Tools, Advertising, and Opt-Out

The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser, tell us how and when you visit and use our Services, analyze trends, learn about our user base and operate and improve our Services. Cookies are small pieces of data– usually text files – placed on your computer, tablet, phone or similar device when you use that device to access our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s).

We use the following types of Cookies:

  • Strictly Necessary Cookies. Strictly Necessary Cookies are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Services. Disabling these Cookies may make certain features and services unavailable.
  • Functional Cookies. Functional Cookies are used to record your choices and settings regarding our Services, maintain your preferences over time and recognize you when you return to our Services. These Cookies help us to personalize our content for you, greet you by name and remember your preferences (e.g., your choice of language or region).
  • Analytics Cookies. Analytics Cookies allow us to understand how visitors use our Services. They do this by collecting information about the number of visitors to the Services, traffic sources, what pages visitors view on our Services and how long visitors are viewing pages on the Services. Analytics Cookies also help us measure the impact of our advertising campaigns in order to help us improve our campaigns and the Services’ content for those who engage with our advertising. For example, Google LLC (“Google”) uses cookies in connection with its Google Analytics services. Google’s ability to use and disclose information collected by Google Analytics about your visits to the Services is subject to the Google Analytics Terms of Use and the Google Privacy Policy. You have the option to opt-out of Google’s use of Cookies by visiting the Google advertising opt-out page at www.google.com/privacy_ads.html or the Google Analytics Opt-out Browser Add-on athttps://tools.google.com/dlpage/gaoptout/.
  • Performance Cookies.  Performance cookies are used to understand and analyze the key performance indexes of the website which helps in delivering a better user experience for the visitors.
  • Advertising/Targeting Cookies. Advertising/Targeting Cookies collect data about your online activity and identify your interests so that we can provide advertising that we believe is relevant to you. For more information about this, please see the section below titled “Information about Interest-Based Advertisements.”

Third Party Cookies. Our Site may contain helpful but non-essential features or plug-ins enabling third party services that use cookies, such as social network connectors. These cookies may enable visitor identification across websites and over time. We do not control the third party’s use of those cookies, their duration, or their ability to share Personal Data with other third parties. Please review each third party’s cookie policies available on the websites of those third party services.

You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our Site and some of the Services and functionalities may not work.

To explore what Cookie settings are available to you or to modify your preferences with respect to Cookies, you can access your Cookie management settings clicking the “Cookie Settings” link found in the Site footer. To find out more information about Cookies generally, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/.

Session Replay Technology

When you use our platform or Services, we may use session replay and similar technologies to identify and resolve customer issues, to monitor and analyze how you use and interact with our Services, including recording certain interactions with webpages such as your mouse clicks, website navigation, pages visited, page scrolling, form submissions and other related activity on our Site, to better understand your interactions with the Services, to review and improve the customer experience, to improve our marketing outreach, for troubleshooting purposes and to improve our Services. By continuing to use the Services, you consent to the use of session replay and similar technologies.

Information about Interest-Based Advertisements

We may serve advertisements, and also allow third-party ad networks, including third-party ad servers, ad agencies, ad technology vendors and research firms, to serve advertisements through the Services. These advertisements may be targeted to users who fit certain general profile categories or display certain preferences or behaviors (“Interest-Based Ads”). Information for Interest-Based Ads (including Personal Data) may be provided to us by you, or derived from the usage patterns of particular users on the Services and/or services of third parties. Such information may be gathered through tracking users’ activities across time and unaffiliated properties, including when you leave the Services. To accomplish this, we or our service providers may deliver Cookies, including a file (known as a “web beacon”) from an ad network to you through the Services. Web beacons allow ad networks to provide anonymized, aggregated auditing, research and reporting for us and for advertisers. Web beacons also enable ad networks to serve targeted advertisements to you when you visit other websites. Web beacons allow ad networks to view, edit or set their own Cookies on your browser, just as if you had requested a web page from their website.

Data Security

We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures, including by using industry-standard techniques. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure. We cannot guarantee the security of any such information and do not guarantee or warrant that such techniques will prevent unauthorized access to information about you that we store. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time. If you have reason to believe that your Personal Data has been compromised in any way, please notify us immediately by contacting Privacy@Lynden.com.

Data Retention

We will retain your Personal Data for the period necessary to fulfill the purposes outlined in this Privacy Policy, including providing you with our Services or to perform our business or commercial purposes including data analytics for collecting your Personal Data. When establishing a retention period for specific categories of data, we consider who we collected the data from, our need for the Personal Data, why we collected the Personal Data, and the sensitivity of the Personal Data. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.

Personal Data of Children

We do not knowingly collect or solicit Personal Data from children under 16 years of age; if you are a child under the age of 16, please do not attempt to register for, access or otherwise use the Services or send us any Personal Data. If we learn we have collected Personal Data from a child under 16 years of age, we will delete that information as quickly as possible. If you believe that a child under 16 years of age may have provided Personal Data to us, please contact us at Privacy@Lynden.com.

California Resident Rights

If you are a California resident, you have the rights set forth in this section. Please see the “Exercising Your Rights under State Privacy Laws” section below for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our customers’ end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data. Please note that your rights may be subject to certain conditions or exceptions under applicable law, which may permit or require us to deny your request.

If there are any conflicts between this section and any other provision of this Privacy Policy and you are a California resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at Privacy@Lynden.com.

Access

You have the right to request certain information about our collection and use of your Personal Data. In response, we will provide you with the following information in the past 12 months:

  • the categories of Personal Data that we have collected about you,
  • the categories of sources from which that Personal Data was collected,
  • the business or commercial purpose for collecting or selling your Personal Data,
  • the categories of third parties with whom we have shared your Personal Data and
  • the specific pieces of Personal Data that we have collected about you.

If we have disclosed your Personal Data to any third parties for a business purpose over the past 12 months, we will identify the categories of Personal Data shared with each category of third party recipient. If we have sold your Personal Data over the past 12 months, we will identify the categories of Personal Data sold to each category of third party recipient.

You may request the above information beyond the 12-month period, but no earlier than January 1, 2022. If you do make such a request, we are required to provide that information unless doing so proves impossible or would involve disproportionate effort.

Deletion

You have the right to request that we delete the Personal Data that we have collected about you. Under the CCPA, this right is subject to certain exceptions including that we may need to retain your Personal Data to provide you with the Services or complete a transaction or other action you have requested or if deletion of your Personal Data involves disproportionate effort. If your deletion request is subject to one of these exceptions, we may deny your deletion request.

Correction

You have the right to request that we correct any inaccurate Personal Data we have collected about you. Under the CCPA, this right is subject to certain exceptions including if we decide, based on the totality of circumstances related to your Personal Data, that such data is correct. If your correction request is subject to one of these exceptions, we may deny your request.

Personal Data Sales and Shares Opt-Out

Sale

We do not sell Personal Data as the term sell is commonly understood.  Under the CCPA, a sale is defined to include disclosures of Personal Data to a third party for monetary or valuable consideration. Select third parties, such as advertising technology partners, data analytics providers, and social networks (“Advertising Partners”), may collect or receive information so that Lynden can provide you with targeted marketing and advertising. These third parties may benefit from the use of this data for their own purposes, such as improving their own services, which may qualify as a sale (i.e., for valuable consideration but not for monetary value) under the CCPA. Within the last 12 months, we may have sold information within each of the following categories, with these third parties:

Personal Data:

  • Identifiers such as email address, IP address, cookies, and other user tracking information;
  • Internet or other network activity information relating to your interactions with our Site;.
  • General geolocation data, such as information about the approximate location of your device when you visit the Site or use a Lynden mobile application;.
  • Professional or employment-related information such as your job title and employer’s name; and
  • Inferences about your preferences.

Sensitive Personal Data:

  • None.

Share

Lynden may have shared certain Personal Data with third parties such as Advertising Partners for the purpose of targeted advertising (i.e., interest-based or online behavioral advertising), which may qualify as sharing under the CCPA. Within the last 12 months, we may have shared each of the following categories of information, with these third parties:

Personal Data:

  • Identifiers such as email address, IP address, cookies, and other user tracking information;
  • Internet or other network activity information relating to your interactions with the Site;
  • General geolocation data, such as information about the approximate location of your device when you visit the Site or use a Lynden mobile application;
  • Professional or employment-related information such as your job title and employer’s name; and
  • Inferences about your preferences.

Sensitive Personal Data:

  • None.

You have the right to opt-out of the sale or share of your Personal Data by following the instructions in the “Exercising Your Rights under State Privacy Laws” section. Once you have submitted an opt-out request, we will not ask you to reauthorize the sale of your Personal Data for at least 12 months.

We do not knowingly sell, share or process the Personal Data of any minors under the age of 16.

Limit the Use of Sensitive Personal Data

Consumers have certain rights over the processing of their sensitive personal information. However, we do not collect sensitive Personal Data.

We Will Not Discriminate Against You for Exercising Your Rights Under the CCPA

We will not discriminate against you for exercising your rights under the CCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CCPA. However, we may offer different tiers of our Services as allowed by applicable data privacy laws (including the CCPA) with varying prices, rates or levels of quality of the goods or services you receive related to the value of Personal Data that we receive from you.

California Shine The Light

California Civil Code Section 1798.83 (California’s “Shine The Light” law), permits California residents with an established business relationship with us to annually request information regarding the disclosure of your Personal Data (if any) to third parties for the third parties’ direct marketing purposes in the preceding calendar year. We do not share Personal Data with third parties for the third parties’ direct marketing purposes.

Exercising Your Rights under State Privacy Laws

To exercise the rights described in this Privacy Policy, you or, if you are a California resident, your Authorized Agent (defined below) must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data, and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request.

We will work to respond to your Valid Request within the time period required by applicable law. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.

Request to Opt-Out of Sale and/or Share

You may opt-out from any “sales” or “shares”, by using the following methods:

  • You can opt-out of the selling or sharing of Personal Data by emailing us at:  Privacy@Lynden.com; or
  • By implementing the Global Privacy Control or similar universal privacy control that is legally recognized by a government agency or industry standard and that complies with applicable State Privacy Laws. The signal issued by the control must be initiated by your browser and applies to the specific device and browser you use at the time you cast the signal. Please note this does not include Do Not Track signals.

Request to Access, Delete, or Correct

You may submit a Valid Request for any other rights afforded to you in this Privacy Policy by emailing us at:  Privacy@Lynden.com.

If you are a California resident, you may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.

Other State Law Privacy Rights

California Resident Rights

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at: Privacy@Lynden.com.

Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services that you do not wish such operators to track certain of your online activities over time and across different websites. Our Services do not support Do Not Track requests at this time. To find out more about “Do Not Track,” you can visit www.allaboutdnt.com.

Nevada Resident Rights

If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties. Please note that we do not currently sell your Personal Data as sales are defined in Nevada Revised Statutes Chapter 603A.

Other US State Privacy Rights

Residents of other states with applicable privacy laws (such as Colorado, Utah, Virginia, Connecticut and other states) may have similar rights. Please contact us at Privacy@Lynden.com to exercise any applicable rights.

Canadian Resident Privacy Rights

This section applies to residents of Canada and supplements the information in the main body of this Privacy Policy. In Canada, Lynden Incorporated controls and is accountable for the personal information that we collect, use, and disclose.

Our Role and Responsibilities

In most cases, Lynden acts as a service provider or data processor, handling personal information on behalf of our business clients (merchants and platforms) according to their instructions. However, Lynden acts as a data controller or business for certain activities, including when we collect information from business owners and principals during client onboarding and verification, collect information from website visitors, and manage employee and applicant information.

For data we control, we are responsible for protecting your privacy rights under Canadian law. For data we process on behalf of business clients, those businesses are responsible for honoring your rights, and you should direct privacy requests to them.

We collect information about you directly from you unless we have your consent or are legally permitted to collect your personal information indirectly. We will only collect, use and disclose your personal information with your consent, unless otherwise permitted or required by law. Your consent may be given expressly or implied, depending on the circumstances and the sensitivity of the information involved. You may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice.

Person Responsible for Protection of Personal Information. The person responsible for ensuring Lynden’s compliance with Canadian privacy laws is:

Chief Legal Officer

Email: Privacy@Lynden.com

Mail: Lynden Incorporated, 18000 International Blvd., Suite 600, Seattle, WA 98188

Cross-Border Data Transfers

All personal information collected in Canada is transferred to and processed in data centers located in the United States. This means your personal information will be subject to United States federal and state laws, including laws that may allow United States government authorities to access your information in certain circumstances.

We have implemented appropriate safeguards for this transfer, including contractual protections with our service providers, encryption and security controls, and access restrictions to ensure personal information is protected in accordance with Canadian privacy principles.

We conduct Privacy Impact Assessment for the transfer of personal information outside of Quebec, evaluating the risks associated with such transfers and we implement measures to mitigate those risks.

Your Privacy Rights Under Canadian Law

Depending on the jurisdiction in which you reside, you may have the following rights:

Right of Access. You have the right to request access to personal information we hold about you, including information about how we use and disclose that information. We will provide this information in a form that is generally understandable.

Right to Correction. If personal information we hold about you is inaccurate or incomplete, you have the right to request that we correct it.

Right to Withdraw Consent. Where we process personal information based on your consent, you have the right to withdraw that consent at any time. Withdrawing consent will not affect the lawfulness of processing based on consent before its withdrawal, but may impact our ability to continue providing services to you.

Right to File a Complaint. If you believe we have not complied with Canadian privacy laws, you have the right to file a complaint with a privacy regulator.

Right to Portability. You may have the right to receive personal information we hold about you in a structured, commonly used, technological format and, where technically feasible, to have it transmitted to another organization.

Right to De-Indexing. You may request in certain circumstances that we cease disseminating personal information through technological means that allow it to be located using a search function (such as search engines), subject to certain exceptions.

Right to Deletion. You may have the right to request deletion of your personal information, subject to our legal obligations to retain certain information as described in Section 7 of this Privacy Policy.

How to Exercise Your Rights

To exercise your rights under Canadian privacy law:

  • Email: Privacy@Lynden.com
  • Mail: Person Responsible for Privacy Protection, Chief Legal Officer, Lynden Incorporated, 18000 International Blvd., Suite 600, Seattle, WA 98188

We will respond to your request within 30 days (or such other period as specified by applicable law). If we need additional time, we will notify you of the extension and the reason for it.

Verification. We will verify your identity before processing your request by asking you to provide information that matches our records. For sensitive requests, we may require additional verification.

Fees. We do not charge a fee for responding to access requests, except in limited circumstances where permitted by law (such as when requests are manifestly unfounded, excessive, or repetitive).

European Union and United Kingdom Data Subject Rights

EU and UK Residents

If you are a resident of the European Union (“EU”), United Kingdom (“UK”), Liechtenstein, Norway or Iceland, you may have additional rights under the EU or UK General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, as outlined below.

For this section, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. Lynden will be the controller of your Personal Data processed in connection with the Services.

If there are any conflicts between this section and any other provision of this Privacy Policy, the policy or portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following applies to you, please contact us at Privacy@Lynden.com. Note that we may also process Personal Data of our customers’ end users or employees in connection with our provision of certain services to customers, in which case we are the processor of Personal Data. If we are the processor of your Personal Data (i.e., not the controller), please contact the controller party in the first instance to address your rights with respect to such data.

Personal Data We Collect

The “Categories of Personal Data We Collect” section above details the Personal Data that we collect from you.

Personal Data Use and Processing Grounds

The “Our Commercial or Business Purposes for Collecting Personal Data” section above explains how we use your Personal Data.

We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, as further described below.

  • Contractual Necessity: We process the following categories of Personal Data as a matter of “contractual necessity”, meaning that we need to process the data to perform under our Terms of Use with you, which enables us to provide you with the Services. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Services that require such data.
    • profile or contact fata (i.e., name, email address, login ID and address);
    • payment data;
    • commercial data and
    • device/IP data;
  • Legitimate Interest: We process certain categories of Personal Data when we believe it furthers the legitimate interest of us or third parties:
    • name;
    • email address;
    • login ID;
    • geolocation;
    • address;
    • web analytics;
    • social network data;
    • photos, videos, and recordings;
    • inferences drawn from other Personal Data collected and
    • other identifying information that you voluntarily choose to provide;
    • We may also de-identify or anonymize Personal Data to further our legitimate interests.

Examples of these legitimate interests include (as described in more detail above):

  • providing, customizing and improving the Services including
    • marketing the Services,
    • corresponding with you,
    • meeting legal requirements and enforcing legal terms and
    • completing corporate transactions;
  • Consent: we may process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection; and
  • Other Processing Grounds: we may need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.

Disclosing Personal Data

The “How We Disclose Your Personal Data” section above details how we disclose your Personal Data with third parties.

EU Data Subject Rights

You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email us at Privacy@Lynden.com. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.

  • Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data. You may also access certain of your Personal Data by logging on to your EZ Commerce portal account.
  • Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. You may also correct some of this information directly by logging on to your EZ Commerce portal account.
  • Erasure: You can request that we erase some or all of your Personal Data from our systems.
  • Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.
  • Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
  • Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes.
  • Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
  • Right to File Complaint: You have the right to lodge a complaint about Lynden’s practices with respect to your Personal Data with the supervisory authority of your country or EU Member State. A list of Supervisory Authorities is available here: https://www.edpb.europa.eu/about-edpb/our-members_en.

Transfers of Personal Data

The Services are hosted and operated in the United States (“U.S.”) through Lynden and its service providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. By using the Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to Lynden in the U.S. and will be hosted on U.S. servers, and you authorize Lynden to transfer, store and process your information to and in the U.S., and possibly other countries. In some circumstances, your Personal Data may be transferred to the U.S. pursuant to a data processing agreement incorporating standard data protection clauses.

Contact Information

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data or your choices and rights regarding such collection and use, please do not hesitate to contact us at: Privacy@Lynden.com.

Construction

For purposes of this Privacy Policy, (a) the words “include,” “includes” and “including” shall be deemed to be followed by the words “without limitation”; (b) the word “or” is not exclusive; and (c) the word “hereby” refers to this Privacy Policy as a whole.