1.1 GT Nexus, an Infor company (“GT Nexus”), operates the world’s largest cloud-based business network and execution platform for global trade and supply chain management, as well as our marketing website(s) and various services, applications, products and content (the “GT Nexus Platform”). We post our Privacy and Confidentiality Policy to inform you and/or your organization (collectively “you” or “your”), as a visitor to our marketing website, a user of the GT Nexus Platform, what kinds of information we may gather about you, how we may use that information, whether we disclose it to anyone, the choices you have regarding our use of information, and your ability to correct that information. By accessing the GT Nexus Platform, you are consenting (i) to this Privacy and Confidentiality Policy and (ii) to having your personal data transferred to and/or processed in the United States in accordance with the terms of this Privacy and Confidentiality Policy. GT Nexus collects all data collected through www.gtnexus.com and is responsible for implementing and ensuring compliance with this Privacy and Confidentiality Policy. For information regarding GT Nexus’ Data Security Policy, please visit http://www.gtnexus.com/data-security-policy.
1.2 Please note that this Privacy and Confidentiality Policy applies only to the GT Nexus Platform, and not to other companies’ or organizations’ websites to which we link or to companies to which we refer a GT Nexus Platform member (a “Member”) (as an example to companies who may provide services for our Members). These sites may collect information about you. GT Nexus does not control sites that are operated by others and is not responsible for the information practices of these sites and this Privacy and Confidentiality Policy does not address the information practices of those websites or operators thereof.
2.1 When you visit our marketing website, www.gtnexus.com and/or any affiliated GT Nexus owned website (collectively, the “Website”), we do not collect personally identifiable information about you except when you specifically and knowingly provide it. For instance, if you request information from us, you will be asked to provide basic information about you and your organization, including your name, company, title, country, e-mail address, your company’s industry and other information that may assist us in providing services to your organization (the “Basic Information”). GT Nexus does not intentionally or knowingly collect sensitive personal information such religious beliefs, political opinions, health, sexual orientation, race or union membership. The GT Nexus Platform is not intended for and does not knowingly collect information from children under the age of 13.
2.2 We do not sell, trade, or rent to any third party any of the Basic Information that you provide to us prior to your organization becoming a Member of the GT Nexus Platform. We may provide Basic Information to third parties who provide services to us, and who agree to abide by the terms of this Privacy and Confidentiality Policy. We will use the Basic Information you provide to respond to your requests for additional information by email and also by telephone if you have consented to telephone contact. We also will use the Basic Information for future mailings informing you of products and services available to you. If you would like to opt-out of receiving future mailings, simply follow the unsubscribe directions at the bottom of the mailing, or send us an e-mail with your name referencing “Remove” in the subject line to firstname.lastname@example.org. Opt out requests will be handled by GT Nexus on an individual user basis and will not constitute an organization-wide opt out unless otherwise requested by your organization.
2.4 Our system logs some basic and generic information about your computer, including its:
We use this information about your computer to perform routine website maintenance, to generate aggregate website traffic reports, and enhance the performance of our website on different browsers and devices.
2.5 We are committed to providing reasonable and practical access to you to identify and to correct any inaccuracies in the information you may provide. Visitors who have provided Basic Information on our Website can contact us at email@example.com to correct any inaccuracies.
3.1 If your organization chooses to apply for membership to the GT Nexus Platform, you may be asked to provide Basic Information for individuals who will act as contacts on GT Nexus and detailed financial and business information about your organization. This information may be shared with financial service providers and payment providers to enable your organization to qualify for credit risk and payment services. During this registration process, we will allow you to choose whether or not you would like us to contact your organization’s trading partners for membership and other services related to transactions.
3.2 Once your organization becomes a Member, your Basic Information and your organization’s financial information, other confidential business data, and transaction details may be shared with other Members, GT Nexus service providers, and GT Nexus corporate alliances as necessary in order to conduct your transaction(s). GT Nexus service providers and corporate alliances include, but are not limited to payment providers, payment protection providers, country managers, freight forwarders, inspection agents, logistics providers, financing providers, sales support, marketing agents, and, subject to appropriate restrictions, to third parties who provide services to us regarding our business. In certain circumstances, we may modify the format of information you provide to us to make the format compatible with the GT Nexus Platform. We will not disclose your Basic Information and your organization’s financial information, confidential business data or transaction details without your consent, except as permitted by this Privacy and Confidentiality Policy or a GT Nexus Membership Agreement, our Master Subscription Agreement or any other agreement you or your organization have accepted with GT Nexus to govern your access to the GT Nexus Platform (the “GT Nexus Agreement”). Note that settlement services are provided through a GT Nexus, Inc. subsidiary, Platform Settlement Services LLC (“PSS”) and Members are required to enter into a separate Platform Settlement Services User Agreement with PSS, which shall be the entire agreement between such parties.
In addition, we aggregate your transaction data with that of other Members for benchmarking, statistical analysis and other similar purposes (the “GT Nexus Data”). GT Nexus reserves all rights in the GT Nexus Data, including but not limited to the right to commercialize GT Nexus Data as the sole and exclusive property of GT Nexus. GT Nexus Platform pricing is based in part on GT Nexus’ reservation of all rights in the GT Nexus Data, including the commercialization of GT Nexus Data.
3.3 Passwords and identity or security devices are private entry keys into the respective GT Nexus account. A user should never share his or her password or identity or security devices with anyone. If a user needs to walk away from his or her personal computing device (PC) for any reason, the user should log off from the GT Nexus session. Users should select passwords that are difficult to guess and change them frequently. Passwords should not be stored on the PC or on written notes near the PC. Identity or security devices should be stored in a secure place. GT Nexus is not responsible if the foregoing practices are not complied with.
3.4 When a user logs onto our transaction sites, the GT Nexus system uses session cookies, small text files placed temporarily on your system, to maintain user session records. These cookies are destroyed as soon as the user logs out and closes the browser and cannot be used to track other information about the user or his or her computer. They are required; a user cannot use the GT Nexus transaction system unless the user accepts these session cookies.
3.5 We will use the information you provide to contact you, if necessary, to service your organization’s account or for other administrative purposes. We may also access and use your organization’s information to resolve disputes, to troubleshoot problems, to enforce our GT Nexus Agreement, or for marketing purposes. In addition, the GT Nexus transaction system uses your transaction details to automate and to streamline your trade transaction by checking for electronic data compliance, providing reporting features, and transferring data from previous forms to those of the current transaction.
3.6 When this Privacy and Confidentiality Policy offers Members the opportunity to “opt in” or “opt out”, you may do so by contacting GT Nexus Member Services at firstname.lastname@example.org.
3.7 Members also have the opportunity to select certain types of emails they would like to receive from GT Nexus. This can be done easily by utilizing the Email Subscription Table located in the Admin section of the GT Nexus transaction site.
3.8 We are committed to providing reasonable and practical access to you to identify and to correct any inaccuracies in the information you may provide. Members can use the system’s administrative function on the transaction website or contact GT Nexus Member Services at email@example.com to maintain up to date account information.
3.9 Unless your organization opts out as described above, we may post your company name in the marketing section of our website to indicate that your organization is a Member.
4.1 We may disclose information about you and your organization to such third parties that you authorize.
4.2 We may provide GT Nexus Data to third parties, including Members, provided that in no event will GT Nexus use non-aggregated data that is captured by the GT Nexus Platform, which represents a specific relationship and/or transaction between Members of the GT Nexus Platform. Such data is not GT Nexus Data and GT Nexus will never use GT Nexus Data to expose the nature of Member relationships or identify specific transaction details between Members.
4.3 GT Nexus shall disclose information provided by you, about you and/or your organization, to the extent required by law through subpoena, search warrant or other legal process or requirement or as necessary to protect the rights, property, or safety of GT Nexus, our Members, or others.
5.1 GT Nexus reserves the right to change this Privacy and Confidentiality Policy, or any other GT Nexus policy or practice, at any time. You are responsible for checking this page periodically for changes. When we intend to make material changes to this Privacy and Confidentiality Policy, we will post those changes on this page and such changes are effective immediately upon posting. Your use of the GT Nexus service following any posted change(s) to the Privacy and Confidentiality Policy will be deemed an acceptance of such change(s). This Privacy and Confidentiality Policy is incorporated into, and part of, the GT Nexus Agreement between you and GT Nexus, if any.
5.2 We will endeavor to respond to your request to access, update or delete Member information as soon as practicable after you provide such updates to GT Nexus Member Services at firstname.lastname@example.org.
5.3 GT Nexus takes reasonable precautions to protect your Basic Information and your organization’s information from loss, misuse and unauthorized access, disclosure, alteration and destruction. Please visit http://www.gtnexus.com/data-security-policy/ for more information regarding GT Nexus’ Data Security Policy. Due to the inherent nature of the Internet as an open global communications vehicle, GT Nexus cannot guarantee that your information will be absolutely safe from intrusion by others, such as hackers. Any unauthorized access to or use of the GT Nexus sites or information collected and maintained by the GT Nexus sites should be immediately brought to the attention of GT Nexus Member Services at email@example.com. GT Nexus will investigate, and if necessary take action to prevent or halt, any violation of this Privacy and Confidentiality Policy of which it becomes aware. If you contact GT Nexus by e-mail, you should be aware that e-mail transmission might not be secure. A third party could view information you send by e-mail in transit. GT Nexus will have no liability for disclosure of your information due to errors or unauthorized acts of third parties during transmission. You may also contact GT Nexus by phone at +1-510-808-2222 or write to GT Nexus at 1111 Broadway, 5th Floor, Oakland CA 94607, Attention: Legal Affairs.
5.4 In the event that GT Nexus, or substantially all of its assets, are acquired by one or more third parties as a result of an acquisition, merger, sale, reorganization, consolidation or liquidation, such databases containing Member information may be one of the transferred assets. In using the GT Nexus services, you consent to such transfer of your information.
5.5 US-EU Privacy Shield. GT Nexus, which includes its respective successors, subsidiaries, divisions and groups, participates in and has certified its compliance with the EU-US Privacy Shield Framework. GT Nexus is committed to subjecting all personal data received from European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the US Department of Commerce’s Privacy Shield List at https://www.privacyshield.gov/list. GT Nexus is responsible for the processing of personal data it receives, and under Privacy Shield, we may subsequently transfer that data to a third party acting as an agent on our behalf. Infor complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions. With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Infor is subject to the regulatory enforcement powers of the US Federal Trade Commission. In certain situations, GT Nexus may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request. Under certain conditions, more fully described on the Privacy Shield website, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
5.6 US-Swiss Safe Harbor GT Nexus, which includes its respective successors, subsidiaries, divisions and groups, participates in and has certified its compliance with the the US–Swiss Safe Harbor Framework as set forth by the US Department of Commerce regarding the collection, use and retention of personal data from Switzerland. GT Nexus has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Infor’s certification, please visit https://safeharbor.export.gov/swisslist.aspx.