Privacy Policy

APO Direct, LLC and its successors, parents, subsidiaries, affiliates, and related companies or other companies under a common control that we may have now or in the future operate (hereinafter referred to as either “APO Direct”, “we”, “us” or “our”) respect your concerns about privacy and personal data protection and value our relationship with you, and as such takes the private nature of your personal information very seriously. This privacy policy (the “Privacy Policy”) sets forth a description of practices related to personal data privacy and security of APO Direct for information collected via the APO Direct Website.

As used in this Privacy Policy, the term “Website” includes all websites and all devices or applications that collect personal information from you that we may have now or in the future operate that link to this Privacy Policy, web pages within each such website, device or application, any equivalent, mirror, replacement, substitute, or backup website, device, or application and web pages that are associated with each such website, device, or application. This Privacy Policy applies to this Website and all related products and services we offer on this Website and to personal information you may provide to us, or that we may collect on this Website. In this Privacy Policy, the words “you” and “your” refer to you, the user of this Website, as the party agreeing to this Privacy Policy.

In addition to this Privacy Policy, we have established Terms of Use that set forth the general rules and policies governing your use of this Website. A copy of the Terms of Use can be found at https://www.apo-direct.com/terms/.

This Privacy Policy describes:

How and why we collect your personal information
How your personal information is used and protected
When and with whom we share your personal information; and
The choices you can make about how we collect, use, and share your personal information.

As further described herein, your personal information may be collected, processed and stored by APO Direct or its service providers in the United States and other countries where such servers reside. You hereby agree with and consent to the transfer of your personal information to the United States and other countries where we and our service providers operate. Regardless of where we transfer your information, we still protect your personal information in the manner described in this Privacy Policy.

YOUR CONSENT

By affirmatively accepting this Privacy Policy, or otherwise using this Website or providing personal information to us, you hereby consent to our collection, use, and disclosure of your personal information as described in our current Privacy Policy as posted here, or as may otherwise be described at the time of collection. If you do not agree with any term in this Privacy Policy, please do not use this Website or provide personal information to us.

You may have a legal right to withdraw your consent to our collection, use, and disclosure of your personal information. To request to withdraw your consent, please contact us as set forth below. Note that if you withdraw your consent to certain uses of your personal information, we may no longer be able to provide certain of our products or services, including certain portions of this Website.

PERSONAL INFORMATION WE COLLECT

We collect personal information about you to deliver the products and services you request and to provide a customized user experience. You do not need to provide any personal information to visit public sections of this Website. There are times, however, that you may choose to give us personal information. For example, certain portions of this Website are available only to registered users.

We collect personal information from you directly in a variety of ways when you use this Website. Some examples are when you:

Request a quote

Complete a Customer Survey

Request to join our email list

Request customer service or contact us.

In order to request a quote, you must provide certain registration information, which may include your first and last name, email and physical addresses, phone numbers, and other details about your move request.

We may also collect personal information from you in other circumstances, both online and offline, such as when you open or respond to our e-mails, visit any page online that displays our ads or content, enter for giveaways, contests, and sweepstakes (which may be done in conjunction with Website registration), call us for customer support, or if you participate in promotions or special programs. We may also collect personal information in other circumstances with your consent, or where permitted or required by law.

We may combine the personal information you submit directly through this Website with other personal information we have collected from you, whether on- or offline. We may also combine it with information we receive about you from other sources, such as other companies and publicly available information sources.

OTHER INFORMATION WE MAY COLLECT ONLINE INCLUDING USING COOKIES OR OTHER TRACKING TECHNOLOGIES

When you access this Website, we may automatically gather information that your browser sends whenever you visit any website, such as your IP address, time and date of visit, browser type, referring/exit pages, internet service provider (ISP), and operating system, and our analytics platform may capture additional information about your use of this Website. We use this information to, for example, analyze trends, administer this Website, track users’ movements around this Website, and gather demographic information about our user base as a whole.

We may also use “cookies” and other user tracking devices (e.g., local shared objects), which are files or pieces of information that are stored by your browser on your computer’s hard drive, to collect information during your visit to this Website, such as the particular Website areas you visit and the products or services you utilize or buy through this Website. This is done so that we can provide a continuous and more personalized shopping experience for you (e.g., to recognize you by name when you return to this Website). We may use “persistent cookies,” which will remain on your computer even after you close your browser, to understand general Website usage and volume statistical information (which does not include personal information) and improve the content and offerings on this Website. We may also use persistent cookies to store user preferences. While most browsers are set to accept cookies and other tracking devices by default, you are always free to decline our cookies if your browser permits, but some parts of this Website may not work properly if you do. Your browser manufacturer has information on changing the default setting for your specific browser.

We may also use other standard Internet technologies, such as web beacons and similar technologies, to track your use of this Website or to track your response to email messages that we send you in connection with this Website. Web beacons (sometimes called transparent GIFs, clear GIFs, or web bugs) are small strings of code that provide a way for APO Direct to deliver a small graphic image (usually invisible) on a web page or in an email. Web beacons can recognize certain types of information on your computer such as cookies, the time and date a page is viewed, and a description of the page where the web beacon is placed. We may use web beacons to improve your experience on this Website, including to provide you with content customized to your interests and to understand whether users read email messages and click on links contained within those messages so that this Website can deliver relevant content. APO Direct’ web beacons may collect some contact information (for example, the email address associated with an email message that contains a web beacon).

Your selection of the “Do Not Track” option provided by your browser may not have any effect on our collection of cookie information for analytic and internal purposes. The only way to completely opt out of the collection of any information through cookies or other tracking technology is to actively manage the settings on your browser or device to delete and disable cookies and other tracking/recording tools. Please note, depending on your type of device or browser, it may not be possible to delete or disable all tracking mechanisms on your device.

APO Direct may allow third party ad servers (i.e., third parties that provide technology to place ads on web sites and track ad performance) to use cookies, web beacons and other technologies to automatically collect information about your visit to this Website or to place our ads on third-party sites and to analyze the effectiveness of those ads. This Privacy Policy covers the use of cookies and other tracking devices by APO Direct but does not cover the use of cookies or other tracking technologies by any of our advertising partners. We encourage you to review the privacy policies or statements of these third party advertising companies to learn more about their use of cookies and other technologies. If you would like to learn more about the third party advertisers that may be aware of the fact that you visit this Website, and to understand your choices about having such advertisers’ cookies turned off, please visit www.networkadvertising.org.

You can modify your preference for each cookie category (except strictly necessary cookies) by clicking on the “cookie settings” button below:

COOKIES SETTINGS

BLOGS AND OTHER FORUMS ON THIS WEBSITE

If you use a bulletin board, blog, or similar public forums on this Website, you should be aware that any information you submit there can be read, collected, or used by other users and could be used to send you unsolicited messages. The protections described in this Privacy Policy do not apply when you provide information (including personal information) in connection with your use of these public forums. We may use personal information about you to identify you with a posting you make in a public forum. APO Direct is not responsible for events arising from the distribution of any information you choose to publicly post or share through this Website.

HOW WE USE YOUR PERSONAL INFORMATION

APO Direct uses your email address and other personal information you provide to APO Direct or that we collect at registration or otherwise, as updated, as follows:

To offer and provide our products and services and to support our core business functions. These include order or service fulfillment, internal business processes, marketing, authentication, loss and fraud prevention, public safety and legal functions. Some examples include:

To process and fulfill your order and communicate with you about your order
To send an order confirmation
To register and service your account
To send you information about product or service information
To send product updates
To respond to customer service requests
To maintain our customer relationships
For direct marketing purposes, namely, to invite you to participate in contests, giveaways and promotions and to tell you about our products or services, new items, or news or information that you have otherwise requested
To provide you with notifications about or changes to this Website, our Terms of Use, or this Privacy Policy
To display content based upon your interests
To conduct research, analysis and advertising
To invite you to participate in promotions, special offers, or user surveys or to ask for your feedback on this Website or our products
For internal statistical, marketing, or operational purposes, such as to measure and understand demographic, user, user interest, purchasing, and other trends among our users
To protect the security or integrity of this Website and our business
To investigate, prevent, defend against or take other action regarding violations of this Privacy Policy or the Terms of Use, illegal activities, suspected fraud, or situations involving potential threats to the legal rights of others or us
To comply with applicable laws and regulations
We may also use your personal information for any other purposes for which we notify you specifically at the time of collection or as otherwise described in this Privacy Policy or as permitted or required by law, rule, regulation, subpoena, or other legal process.

To accomplish these purposes, we may combine personal information and other information we collect with offline information, including information from third parties. We may also transfer or disclose your information within our corporate family of companies for these purposes.

CONTESTS, GIVEAWAYS, PROMOTIONS, AND SURVEYS

From time to time, we may offer you the opportunity to participate in contests, giveaways, and other promotions. You may decline to participate in any or all of the contests, giveaways, and other promotions. Any information submitted in connection with such activities will be treated in accordance with this Privacy Policy, except as specifically set forth in the rules for the applicable contest, giveaway, or promotion. We may use the information you provide when registering for a contest, giveaway, or promotion to manage your entry, fulfill prizes (which may include disclosure to third party entities that assist with such fulfillment), and for other marketing and promotional purposes related to the contest, giveaway, or promotion as disclosed on the rules applicable to a particular contest, giveaway, or promotion.

From time to time, we may also ask you to participate in surveys designed to help improve this Website. Any personal information provided in connection with any survey will be used only in relation to that survey and as elsewhere set forth in this Privacy Policy.

HOW WE DISCLOSE YOUR PERSONAL INFORMATION

APO Direct does not sell or rent your personal information to third parties. We only disclose your personal information to third parties when we have your prior consent or under the following limited circumstances:

If APO Direct engages in a joint promotion with an affiliate and/or partner, we may share your contact information with our affiliate and/or partner, to be used solely in relation to the promotion. We will require such affiliate or partner to keep your information secure and to only use your information based on our instructions and in compliance with this Privacy Policy.

We may disclose or otherwise make available your personal information:

to our service providers that help with our business operations for the purpose of processing your personal information on our behalf or to assist us with this Website, marketing, IT services, website hosting, advertising, and fulfillment of orders. For example, we may provide personal information to our service providers for direct emailing of our newsletters, online surveys, or notifications of our product/service offerings, and also may provide personal information to shipping vendors, billing and refund vendors, payment card processors, and companies that help us improve our product and service offerings and this Website. Your personal information may be stored and processed by our service providers in the United States or other locations where the service providers or APO Direct maintain facilities. We require our service providers to keep your information secure and also require that these parties agree to process such information based on our instructions and in compliance with this Privacy Policy. In addition, our service providers are prohibited from using or disclosing personal information for any purpose other than providing the services on our behalf;

when we have a good faith belief that access, use, preservation, or disclosure of such information is reasonably necessary to: (a) satisfy any applicable law, regulation, legal process, or enforceable governmental request, (b) enforce applicable Terms of Use, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address fraud or other criminal activity or errors, security, or technical issues, (d) protect against imminent harm to the safety, property, or other rights of APO Direct, our users, or any other person, (e) protect our operations or those of any of our affiliates, (f) protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others, or (g) allow us to pursue available remedies or limit the damages that we may sustain; where otherwise required or permitted by law; and for market research, project planning, and to troubleshoot problems.

We may share aggregate, non-personal information that does not identify you individually with third parties. For example, we may share non-personal information (such as the number of daily visitors to a particular web page, or the size of an order placed on a certain date) with third parties such as advertising partners. Such disclosure may result from cookies, widgets, and beacons on this Website. This information does not directly personally identify you or any user.

If we become involved in a merger, acquisition, corporate reorganization, change in control, reorganization, liquidation, or any form of sale or transfer of some or all of our assets, to the extent permitted by (or not prohibited) by law, we may transfer, sell, or assign to third parties information concerning your relationship with us, including, without limitation, personal information we have about you and other information concerning your relationship with us. Such third parties will assume responsibility for the personal information collected by APO Direct in connection with APO Direct’ business operations or through this Website and such third parties will assume the rights and obligations regarding such information as described in this Privacy Policy.

CHOICE / OPT-OUT

You may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in the newsletter or marketing email or by updating your communications preferences in your membership account on this Website. However, please note that certain Website-related email messages that we send users are necessary for the proper functioning and use of the services available through this Website, and registered users of this Website do not have the ability to opt out of such email messages, except by cancelling their account with us.

HOW TO ACCESS AND UPDATE YOUR PERSONAL INFORMATION

APO Direct takes reasonable steps to keep your personal information accurate and complete. If you have created an account this Website, you may be able to access and update your information, including contact or account information, by logging into your account.

You can also contact us with a request to access, update, or delete your personal information by submitting a request by clicking here or by calling 1-866-262-7870. We will make a reasonable effort to respond in a timely manner to your request and, if applicable and appropriate, provide you access to the personal information you have provided us and/or make the requested change in our active databases as soon as reasonably practicable. Your right to access or correct your personal information is subject to applicable legal restrictions. We may take reasonable steps to verify your identity before granting access or making corrections. Please note that we may not be able to fulfill certain requests while allowing you access to certain benefits and features of this Website.

We will retain your personal information for as long as your account is active or as needed to provide you services and to maintain a record of your transactions for financial reporting purposes. We may also retain and use your personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

PRIVACY OF CHILDREN ONLINE

We are committed to protecting children’s online privacy. This Website is for a general audience and is not geared towards children. In order to protect the privacy of children, we do not knowingly collect personal information from children under the age of 13 without prior parental consent. If you are a parent or guardian of a child under the age of 13 and believe he or she has disclosed personal information to us please contact us at privacy@apo-direct.com A parent or guardian of a child under the age of 13 may review and request deletion of such child’s personal information as well as prohibits the use thereof.

INTEGRATION WITH AND LINKS TO THIRD PARTY SITES

This Website may include functionality that allows integration with third party sites, such as Twitter, Facebook, or other social networks. Some of those third party services may provide us with your information to enhance and personalize your use of this Website. If you submit your credentials (e.g., username and password) for a third party website or service during your registration for this Website or in connection with updating your user profile, we may receive your information from such third party website or service.

From time to time, this Website may contain links to other websites, including other websites that are operated by our affiliates or us but are subject to separate privacy policies. If you use these links, you will leave this Website. The privacy policies of such other websites govern the information collection, use and dissemination practices occurring on such websites.

We encourage you to read the privacy statements and terms and conditions of linked or referenced sites you enter. These third party websites may send their own cookies and other tracking devices to you, log your IP address, and otherwise collect data or solicit personal information. APO Direct DOES NOT CONTROL AND IS NOT RESPONSIBLE FOR WHAT THIRD PARTIES DO IN CONNECTION WITH THEIR WEBSITES, OR HOW THEY HANDLE YOUR PERSONAL INFORMATION. PLEASE EXERCISE CAUTION AND CONSULT THE PRIVACY POLICIES POSTED ON EACH THIRD PARTY WEBSITE FOR FURTHER INFORMATION.

SECURITY

We maintain physical, organizational, and electronic safeguards that are designed to prevent unauthorized access to, or use or disclosure of, personal information in our custody and control.

We may establish and maintain a file of your personal information for the purposes described in this Privacy Policy, which will be accessible at our offices. Authorized employees and agents who require access to your personal information in order to fulfill their job requirements will have access to your personal information.

When you enter sensitive information (such as a credit card number or your password), we, or, where applicable, our third party payment processor, encrypt that information using secure socket layer technology (“SSL”). No method of transmission over the Internet, or method of electronic storage, is completely secure. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

Due to the open communication nature of the Internet, we cannot represent, warrant, or guarantee that communications between you and us, or personal information stored on our servers, will be free from unauthorized access by third parties, loss, misuse, or alterations.

CHANGES TO THIS PRIVACY POLICY

We reserve the right to change this Privacy Policy at any time. Please check this Privacy Policy periodically for changes. We will also notify you here, by email, or through notice on our home page if we make material updates and will post the date it was last updated at the top of this Privacy Policy. We encourage you to refer to this Privacy Policy on an ongoing basis so that you understand our then-current privacy policy.

YOUR CALIFORNIA PRIVACY RIGHTS

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. Click here to learn more about your California privacy rights.

INTERNATIONAL USERS

APO Direct is based in the United States and Guam. By accessing or using the Website or otherwise providing information to us, you consent to the processing and transfer of information in and to the U.S. and other countries. While this Privacy Policy applies to personal information generally, the local laws, rules and regulations of jurisdictions that are applicable to APO Direct (“Local Laws”) may require standards which are stricter than this Privacy Policy and, in such event, APO Direct will comply with applicable Local Laws. Specific privacy policies may be adopted to address the specific privacy requirements of particular jurisdictions. Your personal information may be stored and processed in any country where we have facilities or service providers. Irrespective of which country your personal information is transferred, we would only share your personal information under a ‘need to know’ basis. In these circumstances we will, as required by applicable law, ensure that your privacy rights are protected by organizational, technical, contractual and/or other lawful means.

EU Data Subjects In the European Economic Area and Switzerland (“EU”), “Personal Data” is defined very broadly and includes any information about a natural person, who can be identified, directly or indirectly, from data that we hold about them or from data that is combined with other information. EU data protection law requires us to have a legal basis before processing any Personal Data about you. The legal basis’ for us processing your Personal Data for the above purposes may be because: (i) you have provided your consent; (ii) it is necessary to for the performance of a contract with you; (iii) the processing is necessary for our compliance with a legal obligation; or (iv) the processing is in our legitimate interests. To the extent provided by applicable law, you may withdraw any consent you previously provided to us, or object at any time on legitimate grounds, to the processing of your Personal Data. In some circumstances, withdrawing your consent to APO Direct’ use or disclosure of your Personal Data will mean that you cannot take advantage of certain APO Direct products or services. We may transfer your Personal Data outside EU to the United States or any country that APO Direct or its service providers may have operations. Such countries do not have the same data protection laws as EU. Any transfer of your Personal Data will be subject to a European Commission approved contract (as permitted under the General Data Protection Regulation) that is designed to help safeguard your privacy rights and give you remedies in the unlikely event of a misuse of your Personal Data. To obtain a copy of the such safeguards please contact us. Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:

Fair processing of information and transparency over how we use your use Personal Data

Access to your Personal Data and to certain other supplementary information that this privacy policy is already designed to address

Require us to correct any mistakes in your information which we hold

Require the erasure of Personal Data concerning you in certain situations

Receive the Personal Data concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations

Object at any time to processing of Personal Data concerning you for direct marketing

Object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you

Object in certain other situations to our continued processing of your Personal Data

Otherwise restrict our processing of your Personal Data in certain circumstances

For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation (or other relevant guidance). If you would like to exercise any of those rights, please email, call, or write to us with the following:

Enough information to identify you

Proof of your identity and address

The information to which your request relates

How to Complain The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in EU state where you work, normally live, or where any alleged infringement of data protection laws occurred. Otherwise, a complaint may be submitted directly to us:

By email at privacy@apo-direct.com; or

By mail at APO Direct, 220 Valley Rd. Wilmington, DE 19804-1312

COMPLIANCE

APO Direct will use a self-assessment approach to verify compliance with this Privacy Policy and periodically verify that the Privacy Policy is accurate, comprehensive for the information intended to be covered, prominently displayed, implemented and accessible.

If you believe that your personal information has been processed or disclosed in violation of this Privacy Policy, APO Direct encourages you to raise any concerns using the contact information provided in this Privacy Policy. APO Direct will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of personal information.

CONTACT US

Feel free to contact us with any questions or comments about this Privacy Policy or about how your information is handled. You can also contact us via email privacy@apo-direct.com, by phone at , or by mail at the following address:

APO Direct

ATTN: IT Director

220 Valley Rd.

Wilmington, DE 19804-1312