Privacy Policy

1. Your Consent to This Privacy Policy

You indicate your consent to this Privacy Policy by using our Website or otherwise participating in our Services. We may also request your express consent when we collect certain categories of Personal Information from you, including when you opt into SMS communications. In any case, by using the Platform you acknowledge that you have read and understood this Privacy Policy and agree to be legally bound by it. If you do not agree with the terms of this Privacy Policy, then please do not use our Platform.

2. Scope of This Privacy Policy

This Privacy Policy applies to information collected through the Platform and through direct communications with WideScale, including by email, phone, and SMS. It does not apply to information collected by third-party service providers operating under their own privacy policies, except as described in Section 7.1 (Our Service Providers). Where WideScale engages third-party providers to perform functions on our behalf, we require those providers to safeguard Personal Information in a manner consistent with this Privacy Policy.

3. The Information We Collect

To provide our Services and conduct our business, we rely on information provided by and collected from our users. This information consists of the following:

3.1 Personal Information

We collect certain information that identifies you as an individual, and any other information that we associate with it (collectively, "Personal Information"). The Personal Information we collect may include the following:

• Your name, phone number, email address, and other contact information;
• Your account username and password;
• The company, organization, or other entity that you represent, and your title or role;
• Your geolocation information, including zip code and physical mailing address and/or business address;
• Information you provide to us directly (including through the Portal) in connection with your freight forwarding, customs brokerage, or trade compliance services;
• Any information or feedback you provide to us through the Platform or via social media, email, phone, or SMS; and
• Your transaction and account history with us.

If you provide us with any Personal Information relating to another individual, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

3.2 Shipment and Trade Data

In connection with your use of our Services and the Portal, we collect information related to your shipments and trade activity, including but not limited to:

• Import and export shipment details, including commodity descriptions, quantities, weights, and values;
• HTS classification history and associated CBP ruling citations;
• Commercial invoices, packing lists, bills of lading, and other shipping documents;
• Carrier selections, routing preferences, and freight profile information;
• Entry filing records, duty and fee calculations, and clearance status;
• Country of origin information and trade compliance documentation.

This shipment and trade data is used to provide our Services, build and maintain your freight profile, and improve the accuracy and efficiency of your future shipments. It is also maintained as part of your audit-ready compliance record. Where this data is associated with Personal Information, we treat it as Personal Information subject to this Privacy Policy.

3.3 Online Activity Information

We collect technical and device-related information through our Platform and third-party analytics tools (collectively, "Online Activity Information"). For example, we use your IP address, time and date of your visit, and your interactions within the Platform to monitor traffic patterns and site usage, and to improve your user experience. We will treat Online Activity Information as Anonymous Information unless applicable law establishes otherwise.

3.4 Anonymous Information

We may also have (i) information that does not identify you or your devices, and (ii) de-identified Personal Information that no longer identifies you (collectively, "Anonymous Information"). Anonymous Information may include certain aggregate or statistical information. Because Anonymous Information does not include Personal Information, it is not subject to this Privacy Policy.

3.5 Treatment of Combined Information

If we combine Online Activity Information, Shipment and Trade Data, or Anonymous Information with Personal Information, we will treat the resulting combination as Personal Information subject to this Privacy Policy.

4. How We Collect Information

4.1 Site Visitors

We allow you to visit our Site and review information about our Services without revealing your identity or providing Personal Information. In that case, the only information we collect from your visit will be Online Activity Information or Anonymous Information. As a site visitor, you decide whether to provide us with your Personal Information.

4.2 Account Registration

To access certain Services on our Platform that are limited to Registered Users, we may require you to complete a registration process and obtain a username and password associated with your account. This process may ask for certain Personal Information.

4.3 Contacting WideScale

You may contact us with questions, comments, requests, or other communications by email, phone, SMS, or through the Platform. In order to communicate with us, you will need to provide certain Personal Information. We may use that information to respond to your inquiry and provide the requested Services.

4.4 Information Received from Third Parties

We may engage third parties to perform certain services on our behalf. We may obtain from those third parties information you have provided to them, including Personal Information, to the extent necessary to provide our Services. We may also receive information from public databases, logistics partners, and government sources (such as CBP) in connection with your shipments and entries. This Privacy Policy governs how we use information we collect in this manner.

4.5 Collection of Personal Information Offline

We may request Personal Information via phone or in-person interactions. We will provide notice of this Privacy Policy upon request.

4.6 SMS Communications

If you opt into SMS communications from WideScale, we will collect your mobile phone number and your SMS opt-in consent record. We use your mobile number to send you operational communications related to your shipments and account as described in Section 6.1 (SMS Communications) below. You may opt out of SMS communications at any time by replying STOP to any message. See Section 12 (Opting Out of Communications) for more information.

4.7 Email Communications

We may collect your email address to send you operational communications and, where applicable, marketing or newsletter content. You may opt out of marketing emails at any time as described in Section 12.

4.8 Employment Applications

In the careers section of our Website, we may invite you to apply for employment opportunities by submitting your Personal Information, resume, and related information. We will use this information to assess and process your employment application and will treat it in compliance with this Privacy Policy. We do not guarantee that we will contact you after you submit an application.

5. How We Collect Online Activity Information and Anonymous Information

5.1 Logs and IP Addresses

Either directly or through our service providers, we may automatically receive and record information from your browser, including your IP address, the type and version of your web browser, referrer addresses, and other generally accepted log information. We may record page views and other general statistical information to understand how our Platform is used and for security monitoring purposes.

5.2 Cookies

A cookie is a small amount of data sent to your browser from a website and stored on your device. We may use cookies to provide you with a tailored user experience and to recognize you when you return to the Platform. You may choose not to accept cookies; however, certain personalized features of our Services may require cookies to function.

5.3 Tags and Pixel Tracking

We may use pixel tags or web beacons to identify which parts of the Platform have been visited or to measure the effectiveness of communications. Any Personal Information collected using such tools will be subject to this Privacy Policy.

5.4 Click-Through Tracking

We may send emails that use click-through URLs linked to content on our Platform. We track this data to measure the effectiveness of our communications. If you prefer not to be tracked, do not click links in the email or contact us as provided in Section 12.

5.5 Do Not Track

Our Website does not currently change its behavior in response to "Do Not Track" signals from browser software.

6. How We Use This Information

We use the information we collect, including Personal Information, Shipment and Trade Data, Online Activity Information, and Anonymous Information, as permitted under applicable law and consistent with this Privacy Policy. Specifically, we use this information for the following purposes:

• To provide you with the freight forwarding, customs brokerage, and trade compliance Services you request;
• To build and maintain your freight profile, including classification history, carrier preferences, and client-specific requirements, in order to improve the precision and efficiency of your shipments over time;
• To prepare, file, and document customs entries and related trade compliance records;
• To communicate with you about your account, shipments, and our Services, including by email and SMS;
• To allow you to access the WideScale Portal and submit documents and instructions;
• To process and maintain audit-ready entry records and classification documentation;
• To create aggregated or de-identified statistical information about our users and their activity;
• To customize, enhance, and improve your use of the Platform;
• To evaluate and improve our Services, and to develop and test new capabilities;
• To consider your submissions in connection with employment opportunities; and
• To engage in the activities specified in Section 7 (How We May Disclose This Information).

We may also use information as we believe necessary or appropriate to: (i) comply with applicable law and legal process; (ii) respond to requests from government authorities, including CBP and other customs or trade regulatory agencies; (iii) detect, prevent, or investigate potential security incidents or fraud; (iv) enforce our Terms of Use and service agreements; (v) protect our rights, property, and operations; and (vi) pursue available remedies or limit damages.

6.1 SMS Communications

If you have opted in to SMS communications, WideScale will use your mobile phone number to send you text messages related to your shipments and account. These communications may include shipment status updates, clearance notifications, document requests, entry filing notices, and two-way operational communications with WideScale staff regarding your active shipments. Message frequency varies based on your account activity. Message and data rates may apply. Reply HELP for help or STOP to opt out at any time.

WideScale will not sell, rent, or share your mobile phone number with third parties or affiliates for marketing or promotional purposes. WideScale will not disclose your SMS opt-in consent status to any third party, except as required by applicable law or as necessary to operate the SMS program through our SMS service provider.

6.2 Email Communications

WideScale uses your email address to send operational communications related to your Services, and, where you have consented or where otherwise permitted by applicable law, to send marketing or newsletter content. Each marketing email will clearly identify WideScale as the sender, include our physical address, and provide a mechanism to opt out. See Section 12 for opt-out instructions.

7. How We May Disclose This Information

We share the information we collect only in the manner set out below.

7.1 Our Service Providers

We engage third parties to perform functions on our behalf, including maintaining the Platform, processing communications, operating our SMS program, providing analytics, and supporting our customs and logistics operations (collectively, "Service Providers"). We may provide Service Providers with Personal Information, Shipment and Trade Data, Online Activity Information, and Anonymous Information as necessary for them to perform these services. We require our Service Providers to contractually commit to protect the privacy and security of the information they process on our behalf.

Examples of Service Provider functions include:

• SMS delivery and communications platforms (including Twilio or similar providers);
• Email delivery and marketing automation platforms;
• Cloud storage and infrastructure providers;
• Analytics tools, including Google Analytics (information on Google's practices is available at https://policies.google.com/privacy/partners; opt-out options are available at https://tools.google.com/dlpage/gaoptout);
• Customs and logistics software providers used in connection with entry preparation and carrier coordination.

7.2 Government Authorities; Legal Process

We may disclose your Personal Information and Shipment and Trade Data to government authorities, including U.S. Customs and Border Protection (CBP), other federal or state regulatory agencies, law enforcement, and courts, where it is necessary or where we have a good faith belief that it is necessary to: (i) comply with legal process or regulatory requirements; (ii) protect and defend our rights and property; (iii) protect against misuse or unauthorized use of our Platform; (iv) protect the personal safety or property of users or the public; or (v) cooperate with public and government authorities. We will take reasonable steps to limit such disclosure to information reasonably necessary for the above purposes.

7.3 Corporate Transactions

We may transfer information we collect (including Personal Information) to a third party in connection with a reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or substantially all assets or stock of the business unit responsible for the information under this Privacy Policy, provided the acquiring party agrees to safeguard your Personal Information consistent with this Privacy Policy.

7.4 Our Affiliates

We may share information we collect with our affiliates. Our affiliates will be bound by the terms of this Privacy Policy.

8. Disclosing Personal Information Where Not Specifically Requested

If we have not specifically asked for your Personal Information in a particular portion of a form or interaction, you should not provide Personal Information in that portion.

9. Our Retention of Personal Information

We retain Personal Information for the period necessary to fulfill the purposes for which it was collected, consistent with applicable law. Factors we consider include: (i) the duration of our relationship with you; (ii) the existence of a legal obligation regarding the retention period; and (iii) the advisability of retaining information in light of our legal position, including applicable statutes of limitations and regulatory requirements. Entry and classification records may be subject to extended retention requirements under CBP regulations.

10. Accuracy and Minimization of Personal Information

We take reasonable steps to maintain the accuracy of the Personal Information we process and to limit the Personal Information we process to what is reasonably necessary for the purposes for which it was collected.

11. Your Choices Regarding Your Personal Information

If you would like to review, correct, or request deletion of the Personal Information we hold about you, please contact us as provided in Section 18 (Contact Us). Deletion requests are subject to limitations — for example, we may retain Personal Information as permitted by law, such as for tax, regulatory, or customs recordkeeping purposes, to maintain an active account, or for other internal business purposes consistent with how it was collected.

12. Opting Out of Communications

12.1 SMS Opt-Out

To opt out of SMS communications from WideScale, reply STOP to any text message from WideScale. You will receive a single confirmation message and no further SMS messages will be sent except as required by law. To re-enroll, reply START or contact us at legal@widescale.com.

12.2 Email Opt-Out

To opt out of marketing or newsletter emails from WideScale, follow the unsubscribe instructions in any such email or contact us at legal@widescale.com. We will honor opt-out requests within ten (10) business days. Opting out of marketing emails does not affect your receipt of operational emails necessary for your Services.

13. Security

We recognize the sensitivity of your Personal Information and have implemented security systems designed to prevent unauthorized access to or disclosure of Personal Information. Our security measures include physical, technical, and administrative information security controls, and we take commercially reasonable steps to safeguard Personal Information in accordance with applicable law. However, due to the nature of internet communications and information technology, we cannot guarantee that the information you provide to us will remain free from loss, misuse, or alteration by third parties who, despite our efforts, obtain unauthorized access.

14. California Privacy Rights

14.1 CCPA / CPRA

If you are a California resident, you have specific rights under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA), including the right to:

• Know what Personal Information we collect, use, disclose, and sell (or share);
• Access the specific Personal Information we have collected about you;
• Delete your Personal Information, subject to certain exceptions;
• Correct inaccurate Personal Information;
• Opt Out of the sale or sharing of your Personal Information (WideScale does not sell Personal Information as defined under the CCPA);
• Limit Use of sensitive Personal Information to purposes specified by the CCPA; and
• Non-Discrimination — we will not discriminate against you for exercising your CCPA rights.

To exercise these rights, contact us at privacy@widescale.com or as provided in Section 18. We will respond to verifiable consumer requests within 45 days, with a possible extension of an additional 45 days where necessary, as permitted by law.

14.2 Shine the Light

California's "Shine the Light" law permits California residents to request information about our disclosure of Personal Information to third parties for their direct marketing purposes. WideScale does not disclose Personal Information to third parties for their own direct marketing purposes without your consent.

14.3 California Complaints

If you are a California resident and have complaints about our privacy practices, you may contact the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs at 1625 North Market Blvd., Suite N 112, Sacramento, CA 95834, or by telephone at (800) 952-5210.

15. Advisory Regarding Participation by Minors

WideScale's Platform and Services are intended for use by businesses and business professionals. Children under the age of 13 may not create an account with us or use our Platform. We do not knowingly collect Personal Information from individuals under 13 years old. If we learn we have collected Personal Information from a child under 13, we will delete that information as promptly as possible. If you are between 13 and the applicable age of majority in your jurisdiction, please review this Privacy Policy with your parent or guardian.

16. Changes to This Privacy Policy

From time to time, we may update this Privacy Policy for our business purposes and to comply with changes in applicable law. In the event of substantive or material changes, we will communicate these changes to you by posting the updated Privacy Policy on the Platform and/or notifying you via the Platform, email, or other methods. Your subsequent use of the Platform following any update constitutes your agreement to be bound by the Privacy Policy, as updated.

17. Feedback

We welcome your feedback. If you have suggestions on how we can improve our Services or concerns you would like us to address, please contact us at the address set out in Section 18 (Contact Us). If you are a California resident, you may report complaints to the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs. Other states may provide similar avenues for lodging complaints.

18. Contact Us

If you have any questions or concerns about this Privacy Policy or our information practices, please contact us at:

For questions about technical support or your account, please contact us at legal@widescale.com.

19. International Considerations

Our Services are intended for use within the United States. Our primary data centers are located in the United States. If we transfer information outside of the United States in connection with a Service Provider relationship, we will seek assurances that Personal Information is safeguarded adequately and in accordance with this Privacy Policy and applicable law. By providing your Personal Information, you consent to any transfer and processing in accordance with this Privacy Policy.

20. Relationship to Other Contracts and the Terms of Use

This Privacy Policy must be read in conjunction with our Terms of Use and any other agreement entered into by you and us that references this Privacy Policy or that otherwise relates to Personal Information. To the extent the Terms of Use conflict with this Privacy Policy, this Privacy Policy shall control with respect to our treatment of Personal Information. To the extent any service agreement between you and WideScale conflicts with this Privacy Policy, the Privacy Policy shall control with respect to Personal Information unless expressly stated otherwise in that agreement.

21. Effective Date

The effective date of this Privacy Policy is May 7, 2026.