Goodway Group's Privacy Policy

Website Visitors

Current or Prospective Business Partners

• Strictly Necessary Cookies. These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information.
• Performance  Cookies. These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site, and will not be able to monitor its performance.
• Targeting Cookies. These cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not store directly personal information, but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.
• Functional Cookies. These cookies enable the website to provide enhanced functionality and personalization. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies then some or all of these services may not function properly.
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Third-Party Cookies

The Sites allow third-parties to place cookies on your Internet-connected device in order to deliver advertisements based upon your web-browsing habits and history. Further, in order to provide interoperability and plug-ins from various social media websites (like Facebook), the Sites allow these third-parties to place and collect cookies on your Internet-connected device. However, you can restrict the third-party collection of cookies through the instructions provided in the section Transparency and Choice below.
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Analytics

We may use service providers to provide Site metrics and other analytics services. These service providers may use cookies (see above); web beacons (also called clear GIFs or pixels), which are small blocks of code that allow us to measure the actions of visitors using Goodway Group’s Sites; and other technologies to collect information, such as your IP address, identifiers associated with your device, other applications on your device, the browsers you use to access our Sites and Services, webpages viewed, time spent on webpages, links clicked and conversion information (e.g., transactions entered into).

This information may be used by Goodway Group and its service providers on behalf of Goodway Group to analyze and track usage of our Sites and Services to determine the popularity of certain content and to better understand how you use our Sites and Services. We use Google Analytics on the Site to analyze how individuals use the Site. We will package up information about how individuals interact with our Site and send it to Google Analytics to be processed into reports. This information includes basic pageviews and visit data such as device type, operating system, and browser type. When Google Analytics processes data, it aggregates and organizes the data based on particular criteria like whether a user’s device is mobile or desktop, or which browser they’re using. If, at any time, you choose not to participate in the use of analytics software, please use your web browser’s available opt-outs as described in the section Transparency and Choice.
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Advertising

We use remarketing with our service providers to advertise online. These vendors may show our ads on websites across the Internet. For example, we use Google Advertising cookies to identify what advertisements you see when you browse the Internet and how you have interacted with them. We may use this information for our own advertising or it could be pooled together by Google from your interactions with other websites to determine what kind of advertisements you may see on the Internet.
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Session Recorders

Session recordings are renderings of real actions taken by visitors as they browse a website. Recordings capture mouse movement, clicks, taps, and scrolling across multiple pages on desktop and mobile devices.

We use Hotjar in order to better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users’ experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices. This includes a device's IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our Sites. Hotjar stores this information on our behalf in a pseudonymized user profile. Hotjar is contractually forbidden to sell any of the data collected on our behalf.

For further details, please see the ‘about Hotjar’ section of Hotjar’s support site.
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Web Beacons, Tags, Pixels, and Scripts

In addition to cookies, we use other technologies to recognize and track visitors to Goodway Group’s Sites. A web beacon (also known as a “tracking pixel” or “clear GIF”) is a clear graphic image (typically a one-pixel tag) that is delivered through a web browser or HTML email, typically in conjunction with a cookie. Web beacons allows us certain functionality, for example, monitoring how users move from one page within a website to another, to track access to our communications, to understand whether users have come to a website from an online advertisement displayed on a third-party website, to measure how ads have been viewed and to improve site performance.

These technologies may be used on our Sites or in our emails to help us to deliver cookies, count visits, understand usage of our Sites, campaign effectiveness and determine whether an email has been opened and acted upon.
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Third Party/Embedded Content

These cookies may be set by third parties whose content is embedded in Goodway Group’s Sites (e.g., video). They may track your online activity in order to enhance your experience or assess the success of their application. We have no direct control over the information these cookies collect. Please review the third party’s privacy policy and privacy settings before clicking on embedded content in our site.
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Social Media Plugins

These plug-ins allow us to integrate social media functions into Goodway Group Sites and may also be used for advertising purposes by those social media companies. If you visit our Site while logged into your social media accounts, information about your visit to our Sites, your social media identifier and information about your browser may be provided to those third-party social media companies. You should review the privacy policy of any social media entity with whom you have an account to learn about how they may use your data.
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Do Not Track

Do Not Track (“DNT”) is an optional browser setting that allows you to express your preferences regarding tracking across websites. Most modern web browsers give you the option to send a Do Not Track signal to the websites you visit, indicating that you do not wish to be tracked. However, there is no accepted standard for how a website should respond to this signal, so we do not take any action in response to this signal. Goodway Group does not have a mechanism in place to respond to DNT signals. Instead, in addition to publicly available external tools, we offer you the choices described in this Cookies Policy to manage the collection and use of information about you.
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Transparency and Choice

People have different privacy concerns. Our goal is to be clear about what information we collect and how we use it, so that you can make meaningful choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your personal information:

• Privacy Preference Center.  You can visit our Privacy Preference Center at any time by clicking the cookie icon on the bottom left-hand corner of our Sites to set your cookie preferences. You can opt-out of non-essential cookie collection by disabling all non-“Strictly Necessary Cookies.”
• Google Ads.  View and edit your preferences about the Google ads shown to you on Google and across the web, such as which categories might interest you, using Ads Settings. You can also visit that page to opt out of certain Google advertising services.
• Profile Information.  Take out any of your personal information associated with any Goodway Group profile.
• Personalized Advertising.  If you do not want us to use personal information that we collect or that you provide to us to deliver advertisements according to our target-audience preferences, you can opt-out by selecting “Privacy Preferences” on our cookie notice banner and disable all non-“Strictly Necessary Cookies”. If you previously accepted cookies on our Sites and want to opt-out, please clear your cookies and follow the same steps.
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  If you no longer wish to receive advertising based on your interests or other web-browsing behavior, the online advertising industry provides websites from which you may opt out of interest-based advertising from Goodway Group and other companies that participate in industry self-regulatory programs.
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  - The U.S.-based opt-out pages are www.aboutads.info/choices and www.networkadvertising.org/choices.
  - The European based page is www.youronlinechoices.com.
  - In Canada, use www.youradchoices.ca/choices.
  
  We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website at optout.networkadvertising.org.
• You can set your browser to refuse all or some browser cookies (including cookies associated with our services), or to alert you when cookies are being sent.
  
  Most browsers are initially set up to accept cookies, but you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. If you choose to disable cookies, it may limit your use of certain features or functions on our Sites. If you wish to restrict or block the cookies which are set by any website, including our Sites, you should do this through each individual browser setting and on each device you use to access the Internet. You can allow cookies from specific websites by making them “trusted websites” in your Internet browser. The following links may be helpful to understand how you can change your browser settings to restrict the websites that can set cookies, or to stop your browser accepting cookies. The ‘Help’ option in your browser may also have further details.
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  Google Chrome
  Mozilla Firefox
  Safari
  Opera
  Microsoft Internet Explorer
  Microsoft Edge
  Safari for iOS (iPhone and iPad)
  Chrome for Android
  
  Or you can also use the following cookie management and disposal tool from Google Analytics by downloading and installing the browser plug-in from the following link: http://tools.google.com/dlpage/gaoptout.
  

Please be aware that restricting cookies may impact the functionality of our Sites. Additional general information about cookies, including how to be notified about the placement of new cookies and how to disable cookies, can be found at www.allaboutcookies.org.

• Process your personal data in a territory which the European Commission (or its equivalent in Switzerland or the UK) has determined provides an adequate level of protection for personal data;
• Implement appropriate safeguards to protect your personal data, including transferring it in accordance with applicable transfer mechanisms, such as the following:
  
  ○ European Commission’s Standard Contractual Clauses (available here);
  ○ The UK’s Information Commissioner’s Office International Data Transfer Agreement (available here); or
  ○ Switzerland’s Transborder Data Flow Agreement (available here); or
• Enter to data processing agreements with recipients that require them to provide an adequate level of protection, or relying on other legally-approved transfer mechanisms.

• Right to Confirmation and Access.  You may have the right to confirm whether or not Goodway Group is processing your personal information and to access such personal information. The general categories of personal information that we collect, process and disclose are listed above under the section: What Information We Collect And Disclose And For What Purposes. If you wish to access the specific pieces of personal information that we process about you, please submit a request as directed in the section titled How To Submit A Request.
• Right to Correct. You may have the right to request that Goodway Group correct inaccurate personal information that we maintain about you, taking into account the nature of the personal information and the purposes of the processing of the personal information.
• Right to Delete. You may have the right to request that Goodway Group delete the personal information that Goodway Group maintains about you.
• Right to Portability. You may have the right to request to receive your personal information in a portable and readily usable format, to the extent technically feasible.
• Right to Opt-Out of Sale/Targeted Advertising.  You may have the right to request to opt out of a “sale” of your personal information or processing of your personal information for purposes of targeted advertising (if any). “Targeted advertising” generally means displaying advertisements where the advertisement is selected based on personal information obtained from your activities over time and across websites or online applications to predict your preferences or interests.
  
  With regards to the “selling” or use of your online browsing information for targeted advertising, you can opt-out by clicking the “Privacy Preferences” icon on the lower left hand side of the particular Site that you are visiting. Please disable all cookies other than “Strictly Necessary” cookies, which are required for the operation of the Site. If no Shield icon is available for the Site you are visiting, please review our section titled Transparency and Choice for alternative options.
• Right to Opt-Out of Profiling.  You may have the right to request to opt out of automated profiling using your personal information that produces legal or similarly significant effects concerning you (if any). Applicable state laws allow you to opt out of the application of automated profiling when it relates to substantive decision making, such as denial of financial or lending services, housing, insurance, education enrollment or opportunity, criminal justice, employment opportunities, health-care services, or access to essential goods or services. However, we do not profile individuals in a manner that produces legal or similarly significant effects.
• Right to Information About Third Parties.  Oregon, Maryland, Delaware and Minnesota residents may have the right to request, at our option, a list of specific third parties, other than natural persons, to which Goodway Group has disclosed either your personal information or any personal information in general.
• Right to Question the Results of Profiling.  Minnesota residents may have the right to question the results of any automated processing of their personal data to evaluate, analyze, or predict personal aspects related to their economic situation, health, personal preferences, interests, reliability, behavior, location, or movements in furtherance of decisions that produce legal or similarly significant effects concerning them.
  
  If we engage in this profiling practice, you may have the right to (i) question the result of that profiling and (ii) be informed of the reason that the profiling resulted in the decision, and, if feasible, to be informed of what actions you might have taken to secure a different decision and the actions that you might take to secure a different decision in the future. You also may have the right to (iii) review your personal data used in the profiling and (iv) correct any incorrect personal data used to perform the profiling and have the profiling decision reevaluated based upon the corrected

• Right to Know: California residents have the right to know what personal information Goodway Group has collected about them. This includes the categories of personal information, the categories of sources from which the personal information is collected in the past 12 months, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom Goodway Group discloses personal information, and the specific pieces of personal information Goodway Group has collected about them.
  
  The general categories of personal information that we collect, process and disclose are listed above under the section: What Information We Collect And Disclose And For What Purposes. If you wish to access the specific pieces of personal information that we process about you, please submit a request as directed in the section titled How To Submit A Request.
• Right to Delete: California residents have the right to request the deletion of their personal information maintained by Goodway Group.
• Right to Correct:  California residents have the right to request that a business correct inaccurate personal information about them.
• Right to Non-Discrimination:  California residents have the right to not be discriminated against due to the exercise of their privacy rights under the CCPA.
• Right to Opt-Out: California residents have the right to opt-out of the “sale” or “sharing” of their personal information.
  
  A common understanding of “selling” information is that it involves a company taking information it has learned about you and exchanging that information with an unrelated third party for money, who will then use that data for a new purpose that you did not intend. We do not do this. However, California law has a much broader definition of “sell” which encompasses activities beyond the traditional common understanding of “selling” for money, such as disclosing, disseminating, making available, transferring or otherwise communicating by electronic or other means, a consumer’s personal information for money or other “valuable” consideration.
  
  There are certain activities we perform that do fall under the very broad definition of “sale.” You have the right to opt-out of the sale of your personal information. Please note that your right to opt-out does not apply to our sharing of data with service providers, who are parties who are engaged to perform a function on our behalf and are contractually obligated to use the data only for that function.
  
  Additionally, California law provides for a right to opt out of having your information “shared” for the purpose of delivering cross-context behavioral advertising. We also do this. We do not have actual knowledge that we have sold or shared the personal information of a California resident under 16 years of age.
  
  With regards to the “selling” or “sharing” of your online browsing information, you can opt-out by clicking the “Privacy Preferences” icon on the left hand side of the particular site that you are visiting. Please disable all cookies other than “Strictly Necessary” cookies, which are required for the operation of the Site. If no Shield icon is available for the Site you are visiting, please review our section titled Transparency and Choice for alternative options.
  
  Even if you opt-out of targeted advertising, you may still see Goodway Group  ads because we may advertise through other methods that are not based upon your behavior.If you would like to opt-out of the “sale” or “sharing” of your non-online browsing data, you may do so by filling out the interactive form below:
  https://www.goodwaygroup.com/do-not-sell-info
• Right to Limit Use and Disclosure of Sensitive Personal Information:  California residents have the right to direct a business to limit its use and disclosure of their “sensitive” personal information.
  
  California residents can request that a business limit its use or disclosure of their “sensitive” personal information to that use or disclosure which is necessary to perform the services or provide the goods reasonably expected by an average consumer, or to those uses or disclosures otherwise authorized by California law in CCPA regulation § 7027(m).
  
  While we may collect pieces of sensitive personal information as defined by the CCPA, such information is either exempt from the CCPA or is only used or disclosed to provide the Klarna Services or for other purposes permitted by the CCPA. Therefore, we have no obligation to provide you the right to limit the use or disclosure of sensitive personal information under the CCPA.
• Right to Make Requests Through an Authorized Agent: California residents can designate an authorized agent to make a request under the CCPA on their behalf.
  
  California residents can designate an authorized agent to make requests under the CCPA on their behalf relating to the residents’ personal information. Only you as a California resident, or a person you have designated in writing as your authorized agent, may make a consumer request related to your personal information.
  
  If you wish to have an authorized agent make a verifiable consumer request on your behalf, they will need to provide us with sufficient written proof that you have designated them as your authorized agent, such as a power of attorney pursuant to California Probate Code sections 4000 to 4465. We will still require you to provide sufficient information to allow us to reasonably verify that you are the person about whom we have collected personal information.
  
  We can deny any request made by a purported authorized agent who does not submit proof that they have been authorized by the California resident to act on the California resident’s behalf.

• The right to request confirmation that Goodway Group maintains or processes personal data about you.
• The right to know what categories of personal data Goodway Group maintains or processes about you.
• The right to access the personal data that Goodway Group maintains or processes about you.
• The right to request that a copy of your personal data that Goodway Group maintains or processes about you be provided to you or another data controller in a portable format.
• The right to know the purpose for Goodway Group maintaining and processing your personal data.
• The right to withdraw your consent for Goodway Group’s processing of your personal data, if our processing is based upon your consent.
• The right to request the correction of inaccurate personal data that Goodway Group maintains about you.
• The right to request that Goodway Group delete the personal data that it maintains about you (the “right to be forgotten”).
• The right to opt-out of any automated decision-making and profiling.
• The right to submit a complaint to Goodway Group’s privacy office as well as your local data protection authorities.

• We may require that you provide additional information to confirm your identity, including providing us with at least two or more pieces of personal information to match against personal information that we currently maintain about you. We reserve the right to reject your request if we are unable to verify your identity to a sufficiently high level of certainty. The information you provide to verify your identity will only be used for verification purposes, and a record of your request, including certain information contained within it, will be maintained by us for our files.
• To authenticate any request to correct personal information, you may be required to provide authentication information.
• Certain laws or other legal requirements might prevent some personal information from being deleted.

• you do not live in a state that grants you the specific right that you have requested;
• the information that you’ve requested is not subject to the regulation that grants you the right to make a request in relation to your personal information;
• we are prevented or exempted by law, regulation or rule from complying with your request;
• we do not maintain your personal information in a manner that is connected to your identity;
• we are not able to comply with your request without incurring disproportionate burden or expense; or
• if complying with your request conflicts with the integrity of our Services, the ability to administer our Sites, to administer our business and related relationships or to establish, defend or administer legal claims.

For non-U.S. residents, you have the right to raise a complaint with Goodway Group or the appropriate data protection authority of your country of residence if you feel that Goodway Group’s processing of your personal data violates your individual rights, is not in line with this Policy or violates the privacy principals, laws or regulations of your country of residence:

• You can contact Goodway by using the information provided under Contact Us.
• If you are a resident of the European Union, you can find your appropriate data protection authority by following this link.
• If you are a resident of Switzerland, you can contact your data protection authority through the information provided in this link.
• If you are a resident of the United Kingdom, you can contact your data protection authority through the information provided in this link.
• If you are a resident of Canada, you can contact your data protection authority through the information provided in this link.