SPINLGX PRIVACY POLICY

Public website, customer portal, and services

Spin Logistics Inc., doing business as SpinLGX (“SpinLGX,” “we,” “us,” or “our”), respects your privacy. This Privacy Policy explains how we collect, use, disclose, retain, and protect personal information when you visit www.spinlgx.com, submit an inquiry, request or receive services, access a SpinLGX portal or software product, or otherwise interact with us (collectively, the “Services”).

This Privacy Policy is a notice describing our information practices; it is not intended to create contractual rights beyond those provided by applicable law. Your use of the Services is also subject to the SpinLGX Terms of Service and any applicable order form, statement of work, confidentiality agreement, data processing agreement, or other written agreement.

1. Scope and Our Privacy Roles

This Policy applies to personal information SpinLGX handles through its public website, contact forms, customer portal, benchmarking and analytics services, consulting engagements, transportation-management technology, freight-audit and payment-administration services, and other non-regulated logistics-support services.

Depending on the context, SpinLGX may determine the purposes and means of processing personal information (sometimes called a “business” or “controller”), or may process personal information on behalf of a business customer (sometimes called a “service provider” or “processor”). When we process personal information solely on behalf of a customer, that customer is responsible for its own privacy notices, legal basis, and instructions, and its privacy policy may also apply.

This Policy does not apply to third parties we do not control, including carriers, licensed transportation brokers, freight forwarders, customs brokers, warehouses, insurers, payment processors, technology platforms, or other providers that process information under their own privacy notices. SpinLGX is not a carrier, transportation broker, freight forwarder, customs broker, warehouseman, or insurer.

2. Personal Information We Collect

The personal information we collect depends on how you interact with us and may include:

• Contact and identity information, such as name, business name, title, email address, telephone number, mailing address, and account identifiers.
• Account and authentication information, such as usernames, passwords or authentication tokens, permissions, and security logs.
• Business and professional information, such as employer, job title, business relationships, and information provided during sales, consulting, or support communications.
• Shipping, logistics, and commercial information, such as carrier invoices, contracts, rate guides, shipment history, tracking numbers, origin and destination information, package details, recipient information, service levels, costs, discounts, claims, audit data, and related documents.
• Billing and transaction information, such as invoices, payment status, tax information, and limited payment information. Full payment-card information, when used, is generally processed by third-party payment processors rather than stored by SpinLGX.
• Communications and submissions, including information in contact forms, emails, support requests, meeting notes, uploaded files, and feedback.
• Device, internet, and usage information, such as IP address, browser and device type, operating system, referring URL, pages viewed, timestamps, interactions, cookie identifiers, and security or diagnostic data.
• Information from third parties, such as customers, carriers, service providers, partners, public sources, fraud-prevention providers, and integration partners.

Documents submitted for benchmarking, carrier analysis, audit, payment administration, or transmission to a Customer-selected logistics or customs provider may contain sensitive personal information, such as financial account details, government identifiers, signatures, or precise shipment-location information. Please provide sensitive information only when reasonably necessary and authorized. SpinLGX does not use sensitive personal information to infer characteristics about individuals unless expressly disclosed and permitted by law.

3. How We Use Personal Information

We may use personal information to:

• Provide, administer, support, and improve the Services, including benchmarking, carrier analysis, contract optimization, consulting, invoice audit, payment administration, transportation-management technology, and related non-regulated logistics support.
• Respond to inquiries, prepare proposals or quotes, manage customer relationships, provide support, and communicate about accounts, projects, reports, shipments, and service updates.
• Authenticate users, maintain account security, monitor systems, detect and prevent fraud or misuse, troubleshoot, and protect SpinLGX, its customers, and others.
• Analyze shipping and operational data, develop benchmarks, prepare reports, and improve methodologies, products, and services, including through aggregated or de-identified information.
• Process invoices and payments, administer gainshare or other commercial arrangements, maintain business records, and collect amounts due.
• Comply with law, legal process, carrier requirements, contractual obligations, audits, tax requirements, sanctions, trade controls, and regulatory requests.
• Send newsletters or marketing communications where permitted. You may unsubscribe from marketing emails at any time; we may still send non-marketing service or legal communications.
• Evaluate or complete a merger, financing, acquisition, restructuring, sale, or other business transaction.

4. Cookies and Similar Technologies

SpinLGX and its service providers may use cookies, pixels, local storage, tags, software development kits, and similar technologies to operate and secure the Website, remember preferences, understand usage, measure performance, and, where enabled, support marketing. The Website is hosted on Our website hosting provider may place cookies and process device or usage information to provide hosting, security, forms, analytics, and related functionality.

Cookies may include:

• Strictly necessary cookies used for core functionality, security, authentication, load balancing, and fraud prevention.
• Functional cookies used to remember settings and improve the user experience.
• Analytics cookies used to understand traffic, usage, and performance.
• Advertising or marketing cookies, if enabled, used to measure campaigns or show more relevant content.

You may manage cookies through browser settings and any cookie preference tool presented on the Website. Where required by law, we will seek consent before placing non-essential cookies and will honor legally recognized universal opt-out preference signals, such as Global Privacy Control, when applicable. Blocking cookies may affect Website functionality.

5. How We Disclose Personal Information

We may disclose personal information to the following categories of recipients for the purposes described in this Policy:

• Service providers and processors that provide hosting, cloud storage, data processing, analytics, artificial-intelligence or automation tools, security, communications, customer support, billing, payment processing, and professional services.
• Customer-selected or Customer-authorized carriers, licensed transportation brokers, freight forwarders, customs brokers, warehouses, insurers, and other operational providers when requested by Customer or reasonably necessary to support the technology or administrative Services. Those providers process information under their own agreements and privacy notices.
• Business customers or authorized users, including when we process information on behalf of a customer or provide reports and services to that customer.
• Professional advisors, auditors, insurers, financing sources, and transaction counterparties subject to appropriate confidentiality obligations.
• Government authorities, courts, regulators, and other parties when required by law, legal process, or reasonably necessary to protect rights, safety, security, or prevent fraud.
• A successor or potential successor in connection with a merger, acquisition, financing, reorganization, bankruptcy, or sale of assets, subject to customary safeguards.

SpinLGX does not sell personal information for money. Certain analytics or advertising technologies, if enabled, may be considered a “sale,” “sharing,” or use for targeted advertising under some state privacy laws even when no money changes hands. Where applicable, we provide required notice and opt-out choices through cookie controls, a recognized preference signal, or by contacting us.

6. Aggregated and De-Identified Information

We may create and use aggregated, statistical, or de-identified information for benchmarking, research, analytics, security, and service improvement. We will not attempt to re-identify information that we maintain as de-identified except as permitted by law, such as to test whether de-identification processes are effective.

7. Data Retention

We retain personal information for as long as reasonably necessary for the purposes described in this Policy, including to provide the Services, maintain customer and business records, comply with tax, accounting, transportation, trade, and legal requirements, resolve disputes, enforce agreements, and protect security. Retention periods vary based on the type and sensitivity of information, the relationship involved, contractual requirements, legal limitation periods, and whether information is needed for ongoing services. When personal information is no longer reasonably needed, we take reasonable steps to delete, de-identify, or securely dispose of it, subject to backup cycles and legal holds.

8. Data Security

We use commercially reasonable administrative, technical, and physical safeguards designed to protect personal information. No security measure, transmission method, or storage system is completely secure, and we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of account credentials and promptly notifying us of suspected unauthorized access. Additional information about our security practices may be available in the SpinLGX Security & Compliance Statement.

9. Your Privacy Choices and Rights

You may update certain account information, unsubscribe from marketing emails, and manage cookies as described above. Depending on your location and subject to applicable exceptions, you may have rights to request:

• Access to or confirmation of personal information we process about you;
• Correction of inaccurate personal information;
• Deletion of personal information;
• A portable copy of certain personal information;
• Opt-out of the sale or sharing of personal information or use for targeted advertising;
• Restriction or limitation of certain uses of sensitive personal information; and
• An appeal of a decision concerning a privacy-rights request.

These rights apply only where provided by law and may be subject to identity verification, legal exceptions, and retention requirements. To submit a request, email privacy@spinlgx.com or use the Website contact form and clearly identify the request as a privacy request. We may request information reasonably necessary to verify your identity and authority. An authorized agent may submit a request where permitted, subject to verification of authorization. We will not discriminate against you for exercising applicable privacy rights.

10. U.S. State Privacy Notice

The following table summarizes categories of personal information SpinLGX may collect and disclose. The categories actually collected depend on the Services and relationship. “Disclosed” below means disclosed for a business purpose; it does not necessarily mean sold.

Category	Examples	Primary Purposes	Typical Recipients
Identifiers and contact data	Name, email, phone, IP address, account ID	Accounts, communications, security, services	Hosting, communications, security, customers
Commercial and logistics data	Invoices, shipment history, contracts, rates, package and recipient data	Benchmarking, analytics, audit, logistics services, billing	Customers, carriers, logistics and technology providers
Internet or network activity	Device data, pages viewed, cookie IDs, logs	Website operation, analytics, security	Website hosting provider, analytics, hosting, security providers
Professional information	Employer, title, business relationship	Sales, customer management, services	Service providers, advisors, customers
Sensitive information, when necessary	Financial details, government IDs, signatures, precise shipment data	Payments, compliance, requested logistics services	Payment providers, authorized operational providers, authorities

For residents of California and other states with comprehensive privacy laws, these disclosures are intended to supplement the remainder of this Policy. SpinLGX will honor applicable rights and legally recognized opt-out preference signals to the extent required. SpinLGX does not knowingly use or disclose sensitive personal information for purposes that require a right to limit unless separately disclosed.

11. International Users and Transfers

SpinLGX is based in the United States, and personal information may be processed in the United States and other countries where SpinLGX or its service providers operate. Those countries may have privacy laws that differ from the laws in your location. Where required, we use appropriate contractual or legal safeguards for international transfers. Business customers requiring a data processing agreement or specific transfer terms should contact us before submitting regulated personal information.

12. Children’s Privacy

The Services are intended for businesses and are not directed to children under 16. We do not knowingly collect personal information from children through the Services. If you believe a child has provided personal information to us, please contact us so we can take appropriate action.

13. Third-Party Links and Services

The Website and Services may link to or integrate with third-party websites, applications, carriers, and service providers. Their privacy practices are governed by their own notices, and SpinLGX is not responsible for their practices.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, Services, technologies, or legal requirements. We will post the updated Policy and revise the Last Updated date. When required, we will provide additional notice or obtain consent for material changes.

15. Contact Us

Spin Logistics Inc.

Privacy email: legal@spinlgx.com

Website: www.spinlgx.com

Business address: 733 59^th St., Brooklyn Ny 11220

Last Updated: Thursday, August 20, 2026