Privacy Policy

1 Introduction

Inco Group Co Inc. ("Inco," "we," "us," or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our cold storage and warehouse services, visit our website, or otherwise interact with us.

This Privacy Policy applies to:

• Our warehouse and cold storage services
• Our website and online contact forms
• Communications with our customers and business partners
• All information collected in connection with our services

By using our services or providing us with your information, you agree to the practices described in this Privacy Policy. If you do not agree with this Privacy Policy, please do not use our services or provide us with your information.

2 Information We Collect

We collect various types of information in connection with our warehouse and logistics services:

2.1 Business and Contact Information

• Names: Your name, business name, company name, and contact person names
• Email addresses: Business and personal email addresses for communication
• Phone numbers: Business phone, mobile phone, and emergency contact numbers
• Physical addresses: Business address, shipping addresses, billing addresses, and facility locations
• Business information: Company registration details, tax ID numbers, business type

2.2 Inventory and Shipment Data

• Inventory data: Product descriptions, quantities, lot numbers, serial numbers, expiration dates
• Shipment tracking information: Tracking numbers, delivery dates, carrier information, shipping manifests
• Storage requirements: Temperature specifications, special handling instructions, storage duration
• Product documentation: Bills of lading, packing lists, certificates of origin, safety data sheets
• Transaction records: Receiving records, shipping records, inventory movements

2.3 Payment and Billing Information

• Billing information: Invoices, payment terms, billing addresses
• Payment method information: Bank account details for ACH transfers, check information
• Financial records: Payment history, outstanding balances, credit terms

Note: We do not directly process credit card payments. If we add credit card processing in the future, we will use third-party payment processors and will update this policy accordingly.

2.4 Website Information

• Contact form submissions: Name, email, phone, message
• Technical information: IP address, browser type, device type, operating system
• Usage data: Pages visited, time spent on site, referring website
• Cookies: Small data files stored on your device (see Section 8 for details)

2.5 Communications

• Email correspondence
• Phone call records (date, time, purpose — not recordings)
• Text messages and other electronic communications
• Customer service inquiries and responses

2.6 Automatically Collected Information

• Log files and server data
• Device identifiers
• Geographic location (based on IP address)
• Date and time of access

3 How We Use Your Information

3.1 To Provide Our Services

• Receiving, storing, and managing your inventory
• Coordinating shipments and deliveries
• Maintaining accurate inventory records
• Processing cross-docking and warehouse services
• Providing temperature-controlled storage as specified
• Coordinating with carriers and transportation partners

3.2 Billing and Accounting

• Generating invoices and processing payments
• Maintaining financial records
• Managing accounts receivable
• Complying with tax and accounting requirements
• Recording transactions in QuickBooks (our accounting software)

3.3 Communication

• Responding to inquiries and requests
• Providing customer service and support
• Sending service updates and notifications
• Communicating about your inventory and shipments
• Sending invoices and payment reminders
• Providing operational updates (facility hours, service changes, etc.)

3.4 Compliance and Legal Obligations

• Complying with customs and import/export regulations
• Meeting food safety and quality requirements (FDA, USDA, etc.)
• Responding to government inquiries and inspections
• Maintaining required records and documentation
• Enforcing our Terms of Service
• Protecting our legal rights and interests

3.5 Business Operations

• Improving our services and operations
• Analyzing business trends and performance
• Training employees and contractors
• Managing our facility and equipment
• Planning capacity and resources

3.6 Safety and Security

• Maintaining facility security and access control
• Preventing theft, fraud, or unauthorized access
• Investigating incidents or claims
• Ensuring the safety of our employees and your goods

4 How We Share Your Information

We do not sell, rent, or trade your personal information. However, we may share your information with third parties in the following circumstances:

4.1 Service Providers and Business Partners

INDI (Our Affiliated Customs Brokerage Company):

• INDI is our affiliated Mexican customs brokerage company
• We share shipment and inventory information with INDI to facilitate import/export services
• INDI operates under separate terms and privacy practices
• Information shared includes: shipment details, product information, customer contact information, documentation

Transportation and Logistics Partners:

• Trucking companies and carriers (for deliveries and pickups)
• Freight forwarders and shipping companies
• We share: shipment details, delivery addresses, contact information, product information

Financial and Accounting Services:

• QuickBooks: We use QuickBooks for accounting and maintain customer billing information in this system
• Payment processors (if applicable)
• Banking institutions for payment processing

Other Service Providers:

• IT service providers and software vendors
• Insurance companies (for claims processing)
• Professional advisors (lawyers, accountants, consultants)
• Facility maintenance and equipment vendors

4.2 Government Agencies and Regulatory Authorities

• Customs and Border Protection (CBP): For international shipments and customs clearance
• FDA and USDA: For food safety compliance and inspections
• Tax authorities: For tax reporting and compliance
• Law enforcement: In response to subpoenas, court orders, or legal investigations
• Other regulatory agencies: As required by applicable laws and regulations

4.3 Business Transfers

If Inco is involved in a merger, acquisition, sale of assets, or bankruptcy, your information may be transferred to the acquiring or successor entity. We will notify you of any such transfer and any choices you may have.

4.4 Legal Requirements and Protection

• Comply with legal obligations, court orders, or government requests
• Enforce our Terms of Service or other agreements
• Protect our rights, property, or safety
• Protect the rights, property, or safety of our customers or others
• Investigate fraud, security issues, or illegal activities

4.5 With Your Consent

We may share your information with other parties when you have given us permission to do so.

5 Data Security

We take the security of your information seriously and implement reasonable measures to protect it from unauthorized access, disclosure, alteration, or destruction.

5.1 Security Measures

• Physical security: Restricted access to our facilities, security cameras, and alarm systems
• Administrative security: Employee training, confidentiality agreements, access controls
• Technical security: Firewalls, encryption (where applicable), secure data storage
• Vendor security: Requiring service providers to maintain appropriate security measures

5.2 Limitations

• No method of transmission over the internet is 100% secure
• No electronic storage system is completely secure
• We cannot guarantee absolute security of your information
• You are responsible for maintaining the confidentiality of any passwords or login credentials

5.3 Data Breach Notification

In the event of a data breach that affects your personal information, we will notify you as required by applicable law and take appropriate steps to address the breach.

6 Data Retention

We retain your information for as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law.

6.1 Retention Periods

• Active customer data: Maintained while you are an active customer and for a reasonable period afterward
• Inventory and shipment records: Retained for at least 3–7 years for business and legal purposes
• Financial records: Retained for at least 7 years as required by tax and accounting laws
• Communications: Retained for a reasonable period based on business needs
• Legal documents: Retained as required by law or for litigation purposes

6.2 Deletion

After the retention period expires, we will delete or anonymize your information, unless we are required to retain it by law or for legitimate business purposes (such as ongoing litigation or regulatory compliance).

7 Your Privacy Rights

Depending on your location and applicable laws, you may have certain rights regarding your personal information:

7.1 Access and Correction

• Right to access: You may request a copy of the personal information we hold about you
• Right to correct: You may request that we correct inaccurate or incomplete information

7.2 Deletion and Restriction

• Right to delete: You may request that we delete your personal information (subject to legal and contractual obligations)
• Right to restrict: You may request that we limit how we use your information

7.3 Objection and Portability

• Right to object: You may object to certain uses of your information
• Right to portability: You may request a copy of your information in a portable format

7.4 Marketing Communications

• You may opt out of receiving marketing emails by following the unsubscribe instructions in our emails
• Note: Even if you opt out of marketing, we will still send you service-related communications (invoices, shipment notifications, etc.)

7.5 How to Exercise Your Rights

To exercise any of these rights, please contact us:

We will respond to your request within a reasonable timeframe as required by applicable law. We may need to verify your identity before processing your request.

7.6 Limitations

• We are required to retain the information by law
• The information is necessary to fulfill our contractual obligations (such as maintaining your inventory records)
• The information is needed for legal claims or compliance
• The request is manifestly unfounded or excessive

8 Cookies & Tracking Technologies

8.1 What Are Cookies?

Cookies are small text files that are placed on your device when you visit a website. They help websites remember your preferences and improve your experience.

8.2 How We Use Cookies

• Essential cookies: Necessary for the website to function properly (e.g., security, session management)
• Functionality cookies: Remember your preferences and settings
• Analytics cookies: Help us understand how visitors use our website (if we implement analytics in the future)
• Performance cookies: Improve website speed and performance

8.3 Current Cookie Usage

• Session management
• Contact form functionality
• Basic security features

We may implement additional analytics or tracking in the future. If we do, we will update this Privacy Policy.

8.4 Managing Cookies

• View what cookies are stored on your device
• Delete cookies
• Block cookies from specific websites
• Block all cookies

Please note that blocking or deleting cookies may affect your ability to use certain features of our website.

8.5 Third-Party Cookies

Currently, we do not use third-party cookies (such as Google Analytics or advertising networks). If we implement third-party services in the future, we will update this policy and provide you with information about how to opt out.

9 International Data Transfers

9.1 Cross-Border Operations

Inco operates on the United States side of the border and serves both domestic and international customers. Our affiliated company, INDI, operates in Mexico.

• Stored on servers located in the United States
• Shared with INDI in Mexico for customs and import/export services
• Accessed by service providers in different countries
• Transmitted across borders for logistics and shipping purposes

9.2 Data Protection Standards

Different countries have different data protection laws. By using our services, you acknowledge and consent to the transfer of your information to the United States and other countries where we or our service providers operate.

9.3 Safeguards

• Using secure transmission methods
• Requiring service providers to protect data
• Complying with applicable data protection laws

10 Children's Privacy

Our services are designed for businesses and are not intended for individuals under the age of 18. We do not knowingly collect personal information from children under 18.

If we become aware that we have collected personal information from a child under 18, we will take steps to delete that information as soon as possible.

If you are a parent or guardian and believe your child has provided us with personal information, please contact us immediately.

11 Third-Party Websites & Services

Our website may contain links to third-party websites or services that are not operated by us. This Privacy Policy does not apply to those third-party sites.

We are not responsible for the privacy practices of third-party websites or services. We encourage you to review the privacy policies of any third-party sites you visit.

• Payment processors
• Shipping carriers and tracking services
• Government agency websites (FDA, CBP, etc.)
• INDI's website (our affiliated customs brokerage)

12 California Privacy Rights

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA):

12.1 Right to Know

• The categories of personal information we have collected about you
• The categories of sources from which we collected the information
• The business or commercial purpose for collecting the information
• The categories of third parties with whom we share the information
• The specific pieces of personal information we have collected about you

12.2 Right to Delete

You have the right to request that we delete personal information we have collected from you, subject to certain exceptions.

12.3 Right to Opt-Out of Sale

We do not sell your personal information. We have not sold personal information in the past 12 months and do not plan to do so in the future.

12.4 Right to Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights.

12.5 How to Exercise Your Rights

We will verify your identity before processing your request and respond within 45 days.

13 Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors.

13.1 Notice of Changes

• Update the "Last Updated" date at the top of this page
• Post the revised Privacy Policy on our website
• Notify you of material changes via email or prominent notice on our website (if appropriate)

13.2 Your Continued Use

Your continued use of our services after we post changes constitutes your acceptance of the updated Privacy Policy. If you do not agree with the changes, please stop using our services and contact us to close your account.

13.3 Review Regularly

We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information.

14 Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us:

We will respond to your inquiry as soon as reasonably possible, typically within 30 days.

15 Consent and Acceptance

By using our services, visiting our website, or providing us with your information, you acknowledge that:

• You have read and understood this Privacy Policy
• You consent to the collection, use, and disclosure of your information as described in this Privacy Policy
• You understand that your information may be transferred to and stored in the United States
• You understand that we may share your information with service providers, including INDI (our affiliated customs brokerage)
• You have the right to withdraw your consent at any time by discontinuing use of our services