Privacy Policy

1. Introduction

JDL Cargo Control, also known as the Verification & Safety Officer (VSO) Platform, is a cargo gate-release verification system used by authorized personnel to record, verify, manage, and document cargo releases.

This Privacy Policy explains how personal information is collected, used, stored, disclosed, and protected in connection with the platform.

The platform is intended for authorized personnel involved in cargo-release operations, including officers, supervisors, administrators, and other approved users. Customers and cargo recipients do not need a platform account to be affected by this policy. Their information may be recorded as part of cargo-release verification.

JDL Cargo Control supports operational verification, evidence preservation, accountability, and the submission of relevant cargo-release information to JDL's Magaya environment.

2. Who Is Responsible for Your Information?

Responsible organization: JDL CARGO MANAGEMENT COMPANY
Platform: JDL Cargo Control / VSO Platform
Privacy contact: [email protected]
Business address: LPIA Cargo Wing, Windsor Field Road, Nassau, The Bahamas

JDL CARGO MANAGEMENT COMPANY determines the purposes for which personal information is collected and used in connection with cargo-release operations.

Dragonshield Systems LLC provides technology and platform services and may process information on JDL's behalf for authorized hosting, storage, maintenance, security, and technical support, subject to applicable service arrangements.

Questions and requests about personal information may be sent to the privacy contact above.

3. Personal Information We Collect

The information collected depends on the cargo-release activity and the features used.

A. User and Account Information

We may collect and maintain:

• Names and email addresses of authorized users.
• Account roles and access permissions.
• Authentication and session-related information.
• Account activity and relevant security events.

B. Cargo-Release and Operational Information

The platform may record:

• Cargo-release numbers and related reference numbers.
• Customer, company, consignee, receiving-party, and collector names.
• Relevant contact details and collection information.
• Cargo descriptions, quantities, weights, and other release details.
• Full releases, partial releases, outstanding pickups, and related operational changes.
• Notes and information entered by authorized personnel.

C. Photographs, Documents, and Signatures

Depending on the workflow, the platform may collect or generate:

• Photographs of cargo, packages, and supporting documents.
• Images of paper cargo-release forms.
• Customer signatures captured at the front desk or at the point of collection, where that feature is used.
• Officer-attributed attestations documenting who completed a release and when.
• Other evidence necessary to support a cargo-release record.

These records may contain personal information about employees, customers, authorized representatives, and cargo recipients.

D. Technical and Security Information

The platform may process technical information needed to provide and protect the service, including device registrations, device or application information, IP addresses, browser information, session information, and security or audit logs where recorded. Device tokens and related information may be used to deliver operational notifications to registered devices.

E. Cookies and Session Information

The website may use essential cookies or similar technologies to maintain authenticated sessions, renew sessions securely, and support access-control features. Details about the cookies actually used by the website are described in the Cookie Policy.

4. How We Obtain Information

Information may be obtained:

• Directly from authorized personnel using the platform.
• From cargo-release records and information retrieved through JDL's existing systems, including Magaya.
• Through photographs, documents, and signatures collected during the release process.
• Automatically through authentication, application operation, and security logging.
• From authorized administrators who create accounts, assign access, or correct records.

Users are expected to enter accurate information and capture evidence that relates to the correct cargo release.

5. Why We Use Personal Information

Personal information is used for cargo-management, verification, security, and administrative purposes, including:

Cargo-release operations. To identify cargo releases, support verification at the gate, record full or partial releases, and document outstanding pickups.

Evidence and accountability. To preserve relevant photographs, documents, signatures, officer attribution, and timestamps so the organization can establish what was recorded and who performed an action.

Magaya integration. To submit relevant cargo-release information and supporting evidence to JDL's Magaya environment through the configured integration.

System reliability. To synchronize information between authorized devices, maintain records, retry interrupted uploads or submissions, and support continuity when a downstream system is unavailable.

Security and administration. To authenticate users, control access, investigate suspected misuse, maintain audit records, troubleshoot errors, and administer accounts.

Legal and operational requirements. To address applicable legal obligations, properly raised disputes, audits, investigations, and legitimate business requirements.

Personal information should not be used for unrelated purposes that are incompatible with the purposes described in this policy.

6. Fair and Lawful Processing

Personal information must be collected and used fairly, for specified and lawful purposes, and only to the extent reasonably relevant to those purposes.

JDL will assess the applicable legal grounds for its processing activities under relevant data-protection and other applicable laws. Where a separate activity legally requires consent, that consent will be addressed separately and specifically.

An employee's acknowledgment that they have received or read this Privacy Policy is not blanket consent to unrelated processing, a waiver of privacy rights, or authorization to disclose information outside the purposes described here.

7. Who May Receive Personal Information?

Personal information may be accessed or disclosed when necessary and authorized to:

• JDL personnel whose responsibilities require access to relevant cargo-release records.
• Authorized supervisors and administrators performing operational, compliance, or review functions.
• Dragonshield Systems LLC, as the technology provider, for authorized technical and operational support.
• JDL's Magaya environment and systems involved in the authorized cargo-release submission workflow.
• Hosting, cloud storage, communications, notification, backup, and other service providers supporting the platform.
• Legal authorities, regulators, or other parties where disclosure is required or permitted by applicable law.

Access should be limited to the information and functions required for the recipient's role.

JDL does not sell or rent personal information for third-party marketing. Information is not made available to the public merely because it is recorded in the platform.

8. Storage and International Processing

JDL Cargo Control uses cloud-hosted infrastructure and storage services to support the platform, its records, and supporting evidence. Depending on service configuration, personal information may be stored or processed in jurisdictions outside The Bahamas.

International processing and transfers must be assessed and managed in accordance with applicable law and relevant service arrangements. Service providers handling information on JDL's behalf should be subject to appropriate contractual and security requirements.

9. Data Retention

Personal information is retained only for as long as reasonably necessary for the purposes for which it was collected, subject to applicable legal requirements and legitimate operational needs.

Cargo-release records and supporting evidence may need to be retained to establish that a release occurred, support internal reviews, address disputes, investigate incidents, and meet applicable recordkeeping obligations.

Different retention periods may apply to cargo-release records and evidence, user accounts and access records, security and audit logs, temporary files, operational queues, and backups. Those periods are governed by JDL's applicable records-retention requirements and any lawful preservation hold.

When information is no longer required, it should be securely deleted or anonymized where appropriate, unless it must be retained for a legal obligation, dispute, investigation, audit, or other permitted purpose. Retention must not be indefinite merely because storage remains available.

10. Information Security

JDL Cargo Control is designed to protect information through controls such as authenticated access, role-based permissions, security logging, and safeguards for storing and transmitting operational records.

Authorized personnel must safeguard their credentials, avoid sharing accounts, use the platform only for approved duties, and report suspected unauthorized access or disclosure.

No electronic system or storage environment can be guaranteed completely secure. JDL and its service providers must maintain and review appropriate safeguards in light of the information processed and the risks involved.

11. Privacy Rights and Requests

Subject to applicable law and lawful restrictions, individuals may request information about personal data held about them and may ask for inaccurate information to be corrected or personal information to be erased where appropriate.

Requests may be subject to identity verification and review, particularly where records contain information about other individuals, relate to an active cargo operation, or must be retained for legitimate legal, security, or recordkeeping purposes.

Requests should be submitted to [email protected]. Please describe the information concerned and the nature of your request. Do not send identity documents or other sensitive information unless the privacy contact explains that they are necessary and provides an appropriate submission method.

JDL will assess requests in accordance with applicable law.

12. Cookies

The website may use essential session technologies to support authentication and secure access to the platform. The Cookie Policy explains the purposes of these technologies and provides further information about the cookies in use.

Non-essential cookies or tracking technologies, if introduced in the future, must be assessed under applicable law before use.

13. Privacy Concerns and Security Incidents

Anyone who believes their personal information has been accessed, used, or disclosed improperly may report the concern to [email protected].

Users should promptly report suspected account compromise, lost devices containing platform information, misdirected evidence, or other potential security incidents. JDL will assess reports and take appropriate action, including notifications or other steps required by applicable law.

14. Changes to This Policy

This Privacy Policy may be updated when the platform, its operations, its service providers, or applicable legal requirements change.

The current version will be made available through the platform's public Privacy Policy page. Material changes should be communicated to authorized users and, where appropriate, other affected individuals.

The effective date and last-updated date appear at the beginning of this policy.

15. Contact

For questions about this Privacy Policy or the handling of personal information connected with JDL Cargo Control, contact:

JDL CARGO MANAGEMENT COMPANY
LPIA Cargo Wing, Windsor Field Road
Nassau, The Bahamas
Email: [email protected]

This policy explains JDL Cargo Control's privacy practices. It does not remove or restrict any rights or obligations arising under applicable law.