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Privacy Policy

Shipwize and Circles Privacy Policy

Last Updated: October 23, 2025

1. Introduction

Welcome to Shipwize Services Ltd and Circles Logistics Ltd (“we,” “us,” “our,” or collectively “the Companies”).

This Privacy Policy explains how we collect, use, disclose, and protect your personal information when you interact with our services — including the websites shipwize.com and circlesja.com, our mobile applications, and related digital platforms (collectively, the “Services”).

It also outlines your rights under the Data Protection Act 2020 (Jamaica), the General Data Protection Regulation (GDPR – EU 2016/679), the UK Data Protection Act 2018, and the California Consumer Privacy Rights Act (CPRA 2023).

By using our Services, you acknowledge that you have read and understood this Privacy Policy.

2. Scope

This Privacy Policy applies to all digital and offline interactions between you and the Companies, including:

  • Shipwize's and Circles’ websites and mobile apps
  • Customer portals, logistics tracking systems, and payment interfaces
  • Customer-service communications, social-media interactions, and offline registrations that reference this Policy

This Policy does not apply to third-party websites, services, or applications that we do not control.

3. Definitions

  • Account – a unique profile you create to access our Services.
  • Affiliate – an entity that controls, is controlled by, or is under common control with either Company.
  • Application – the Shipwize or Circles software application you install or use.
  • Companies / we / us / our – Shipwize Services Ltd and Circles Logistics Ltd, both headquartered in Kingston, Jamaica.
  • Cookies – small text files stored on your device to remember preferences or session information.
  • Device – any hardware that can access our Services (computer, smartphone, tablet, etc.).
  • Personal Data – information relating to an identified or identifiable individual (as defined in Section 2 of the Jamaica Data Protection Act 2020).
  • Service Provider – any third party that processes data on our behalf under a written contract.
  • Usage Data – technical data automatically collected when you use the Services (e.g., IP address, browser type, session duration).

4. What We Collect

A. Personal Data You Provide

When you interact with our Services, we may collect:

  • Name, email address, and phone number
  • Tax Identification Number (TRN)
  • Shipping, billing, or delivery addresses
  • Account credentials (username, password)
  • Payment or transaction information
  • Identity documents (for customs, verification, or compliance)
  • Communications or support messages you send us

B. Automatically Collected Data

We automatically gather Usage Data such as:

  • IP address, browser, and operating system
  • Device ID and mobile network data
  • Pages visited, duration, and actions taken
  • Location data (if you enable location services)
  • Diagnostic and performance logs

C. Third-Party Sources

We may receive limited data from logistics partners, payment processors, marketing affiliates, or social media integrations, in accordance with their privacy policies.

5. How We Use Your Information

We use Personal Data only for lawful purposes, including:

Purpose Legal Basis / Justification
Provide, maintain, and improve our Services Contractual necessity (DPA § 22 (1)(b))
Manage your Account and bookings Legitimate interest / Contract performance
Process payments, shipments, and deliveries Contract performance / Legal obligation
Communicate with you (customer support, updates) Legitimate interest
Send marketing messages (opt-in only) Consent (DPA § 24 (1))
Comply with tax, customs, and anti-fraud laws Legal obligation
Analyze usage and improve functionality Legitimate interest
Manage business transfers or restructuring Legitimate interest
Enforce terms and protect against fraud or misuse Legitimate interest / Legal obligation

We do not sell or rent your Personal Data.

6. Cookies & Tracking Technologies

We use cookies, pixels, and similar tools to operate our websites efficiently and understand visitor behavior.

You may disable non-essential cookies at any time through our cookie banner or your browser settings.

Types of cookies used:
  • Strictly Necessary – site operation, authentication, and security.
  • Preferences – language or regional settings.
  • Analytics – aggregated statistics to improve performance.
  • Marketing – only if you have opted in.

For full details, see our Cookie Policy or the cookie notice on circlesja.com.

7. Sharing & Disclosure of Data

Your information may be shared in the following limited circumstances:

  • With Affiliates: between Shipwize and Circles for unified logistics, billing, and support.
  • With Service Providers: to process payments, host systems, send communications, or perform analytics — under written data-processing agreements compliant with the Jamaica DPA and GDPR Article 28.
  • Legal Requirements: if disclosure is required by a court order, regulator, or law-enforcement authority.
  • Business Transfers: during mergers, acquisitions, or similar restructuring, subject to confidentiality.
  • With Your Consent: when you explicitly authorize sharing.

We will never sell your data to advertisers or data brokers.

8. International Data Transfers

Your Personal Data may be transferred to and processed outside Jamaica — for example, on secure servers in the United States or the European Union.

Whenever data is transferred internationally, we ensure:

  • Adequate protection consistent with the Jamaica Data Protection Act 2020 (Part III, Sections 27-29); and
  • Standard Contractual Clauses (SCCs) or other recognised safeguards under GDPR Chapter V.

By using our Services, you consent to such lawful transfers.

9. Data Retention & Deletion

We retain Personal Data only as long as necessary for the purposes stated in this Policy or as required by law (e.g., financial or customs records).

When data is no longer needed, we securely delete or anonymize it in accordance with Schedule 1, Part II of the Jamaica DPA and GDPR Article 5(1)(e).

You may request deletion of your account and data by contacting us (see Section 14).

10. Your Rights

Under the Jamaica Data Protection Act, GDPR, and CPRA, you may exercise the following rights:

  • Access: Request a copy of your data.
  • Rectification: Correct inaccurate or incomplete information.
  • Erasur: Request deletion where no lawful basis exists to retain it.
  • Restrictio: Limit processing in certain cases.
  • Data Portability: Receive your data in machine-readable format.
  • Objection: Object to marketing or profiling.
  • Withdraw Consent: Revoke previously given permissions.

To exercise these rights, email privacy@shipwize.com or privacy@circlesja.com.

We will verify your identity and respond within the statutory timeframe:

  • 30 days (Jamaica DPA § 21(1)) or
  • One month (GDPR Art. 12(3)), whichever applies.

If unsatisfied, you may lodge a complaint with the Information Commissioner (Jamaica) or your local supervisory authority.

11. Security of Your Information

We implement technical and organizational measures consistent with ISO/IEC 27001 and GDPR Article 32, including:

  • Encryption at rest and in transit;
  • Role-based access controls;
  • Firewalls and network segmentation;
  • Routine audits and penetration testing;
  • Employee confidentiality and data-protection training.

While we strive for industry-standard security, no method of transmission over the Internet is completely secure; we therefore cannot guarantee absolute security.

If a data breach occurs, we will notify affected individuals and the Information Commissioner (Jamaica) within the statutory period under Section 31 of the DPA and GDPR Articles 33-34.

12. Children’s Privacy

Our Services are not directed to persons under 16 years.

We do not knowingly collect Personal Data from minors.

If we learn that a minor’s information was collected without verifiable parental consent, we will delete it promptly and notify the guardian and relevant authorities as required by law.

13. Links to Other Websites

Our Services may contain links to third-party websites not operated by us.

We are not responsible for their content or privacy practices.

Please review the privacy policies of any external sites you visit.

14. Contact Us

For questions, requests, or to exercise your data-protection rights, please contact:

15. Changes to This Policy

We may revise this Privacy Policy periodically to reflect operational, legal, or regulatory updates.

The latest version will always appear on our websites.

If we make material changes, we will notify users by email or in-app notice before the new terms take effect.