Privacy Policy

This Privacy Policy applies to GAMA services operated by Gama Climax Technologies Inc. For privacy inquiries or rights requests, contact privacy@gamasuite.com.

1. Introduction and Scope

This Privacy Policy explains how GAMA (“GAMA,” “we,” “our,” or “us”) collects, uses, shares, retains, and protects personal information in connection with our websites, software platforms, applications, customer and agent portals, APIs, integrations, and related business activities. GAMA provides logistics technology for freight forwarders, shippers, beneficial cargo owners, importers, exporters, agents, and supply-chain partners. Features may include rate management, quotations, bookings, purchase orders, shipment and multimodal visibility, tracking, documentation, customer relationship management, billing, analytics, and AI-enabled automation.

This Policy applies to website visitors, prospects, business contacts, account administrators, authorized platform users, and individuals whose information we process for our own purposes. For personal information entered into GAMA by business customers, those customers may be responsible for providing their own notices and handling requests. Separate customer contracts and data processing agreements may govern that information. This Policy does not override those agreements or applicable law.

2. Who Is Responsible for Your Data

Gama Climax Technologies Inc, located at 2425 N. Central Expy. Suite 700, Richardson, TX 75080, operates GAMA and is responsible for the processing described here where it determines the purposes and means of processing. You can contact our Privacy Team at privacy@gamasuite.com.

GAMA generally acts as an independent controller for its website, sales inquiries, marketing, vendor management, billing administration, security, and direct business relationships. GAMA generally acts as a processor or service provider when a business customer determines the purposes of processing data in its GAMA workspace, such as shipment contacts, purchase orders, tracking records, uploaded documents, and customer communications. Roles can differ by feature and jurisdiction. Where GAMA is a processor, we process data under the customer's documented instructions, subject to applicable law and contractual terms.

3. Categories and Sources of Information

We may collect: (a) business identity and contact details, including names, job titles, employer, email, phone number, and address; (b) account and authentication information, including user identifiers, access rights, sign-in history, and security events; (c) commercial and operational records, including quotes, freight rates, contracts, purchase orders, bookings, shipping instructions, invoices, delivery records, and documents; (d) shipment and visibility information, including container, vessel, flight, vehicle, route, milestone, exception, and delivery data, which may be associated with identifiable individuals; (e) device and usage data, such as IP address, browser, device identifiers, pages visited, session activity, and diagnostic logs; (f) communications, including sales correspondence, support requests, emails or messages connected to services, and AI assistant inputs and outputs when enabled; and (g) payment and subscription details, such as billing contacts, transaction status, and payment references.

We obtain information directly from you, from your employer or the customer administering your account, through your use of services, and from connected providers such as carriers, tracking vendors, logistics partners, authentication services, and payment providers. Some integrations may transmit information about third parties. Business customers are responsible for having an appropriate basis to provide that information.

4. Purposes and Legal Bases for Processing

We process personal information to provide and maintain services; register and authenticate users; execute customer instructions; support logistics and shipment visibility workflows; deliver support and service notifications; administer contracts, subscriptions, and payments; secure systems and detect abuse; troubleshoot, measure performance, and improve functionality; comply with law; and communicate about relevant products and events where permitted.

Where the EU/UK GDPR applies and GAMA acts as controller, our legal bases may include performance of a contract, legitimate interests (such as service security, customer support, and appropriate business communications), compliance with legal obligations, and consent where required (such as certain cookies or marketing). We assess the appropriate basis for each processing activity. Where we rely on consent, it may be withdrawn without affecting processing already lawfully carried out. Where we rely on legitimate interests, individuals may have a right to object. When acting as processor, our customer determines the applicable legal basis for its processing.

5. Customer Data, Confidentiality, and Tenant Separation

Customer-uploaded operational and commercial records remain subject to the customer's control and applicable agreements. We do not treat customer freight rates, contracts, supplier lists, purchase orders, shipment details, or financial records as public merely because they are processed in GAMA. Access is limited to authorized users, service personnel with a legitimate need, and approved service providers, subject to access controls and contractual restrictions.

GAMA may use aggregated or de-identified information for analytics and service improvement only where lawful, appropriately protected against re-identification, and permitted by customer agreements. We do not publicly disclose identifiable customer booking volumes, carrier spend, commercial rates, or other confidential business intelligence without authorization or another lawful basis.

6. AI Features and Automated Processing

Certain optional features may use AI to classify inquiries, extract information from emails and documents, summarize communications, assist with quotes or operations, support conversational workflows, or analyze logistics events. Depending on configuration, AI processing may involve prompts, documents, email content, customer records, shipment information, and generated responses. AI outputs may contain errors and should be reviewed before operational or commercial reliance.

We use AI-related data to deliver the requested functionality and for security, troubleshooting, and other disclosed purposes. Whether any third-party AI provider retains inputs or uses them for model training depends on the actual provider, service terms, and GAMA configuration. Contact our Privacy Team for information about the AI processing arrangements applicable to your service. If automated decisions produce legal or similarly significant effects on individuals, we will provide any notices, safeguards, and rights required by applicable law.

7. Shipment, GPS, and Location Information

Shipment visibility features may display tracking events and location information sourced from carriers, logistics partners, telematics devices, GPS providers, user submissions, and other integrations. Such information can include vehicle or driver location where a service is configured to collect it. We use this information to provide authorized tracking, estimated arrivals, exceptions, route history, and delivery confirmation.

Customers are responsible for providing notices and obtaining any required permissions from drivers, employees, and other individuals whose location is collected through their operations. Access to location information is governed by applicable permissions, and retention follows contractual schedules and legal requirements. Location information is not necessarily precise, real-time, or independently verified.

For the driver application's delivery-tracking feature, GAMA collects precise device location while the application is in use and, with the driver's explicit permission, in the background. Background access supports live tracking and estimated arrival updates during an active delivery, including when the app is minimized or the screen is off.

For this driver-tracking feature, location data is used for delivery tracking and estimated arrival calculations, not advertising, marketing, or third-party commercial purposes. Background tracking is active only during an ongoing delivery or trip and stops when the delivery is completed or the driver logs out. Drivers can revoke location permission through device settings, which disables this feature. Location data is transmitted securely and retained only as long as necessary for delivery verification and operational records, according to applicable retention requirements.

8. Cookies, Analytics, and Similar Technologies

Our websites and services may use strictly necessary cookies and similar technologies for authentication, security, session continuity, and user preferences. We may also use analytics, performance, advertising, or personalization technologies, where implemented and permitted. Our Cookie Policy describes the website cookie categories, configured providers, durations, and available consent choices.

Where required by law, non-essential cookies will not be set until valid consent is obtained. You may manage available preferences through our cookie controls and browser settings. Disabling necessary cookies may affect service functionality.

9. Disclosures and Subprocessors

We may share personal information with authorized hosting and infrastructure providers, cloud security and monitoring services, payment processors, support and communications tools, analytics providers, AI service providers, and logistics data integrations as needed to operate services. We may also disclose information to customer-authorized users and partners, professional advisers, regulators, law enforcement, or parties to a corporate transaction when lawful and appropriate.

Service providers must be subject to appropriate confidentiality, security, and data-protection commitments. For customer-controlled data, we will use subprocessors as permitted under applicable customer agreements and provide required notifications of changes. Contact our Privacy Team for information about relevant service providers, their purposes, and processing locations. We do not sell personal information in the ordinary meaning of that term; however, legal definitions of “sale” and “sharing” may cover certain advertising technologies, depending on actual website practices and applicable law.

10. International Data Transfers

GAMA operates in an international logistics environment. Personal information may be accessed or processed in countries other than the country where an individual is located, including locations used by hosting providers, authorized support teams, customers, and integrations. Processing locations and any data residency commitments depend on the relevant service and contractual arrangements.

When applicable law restricts international transfers, we use appropriate transfer mechanisms and safeguards, which may include adequacy decisions, approved standard contractual clauses, UK addenda or agreements, and supplementary safeguards where required. Individuals may request information about applicable safeguards through the privacy contact. We do not guarantee that all information remains within a particular country unless the applicable service agreement provides for this.

11. Security Measures and Incident Response

We maintain a risk-based information security program intended to protect information against unauthorized access, alteration, disclosure, and loss. Measures may include role-based access controls, authentication protections, encryption in transit, appropriate encryption at rest, logging, backup and recovery processes, vulnerability management, personnel access restrictions, and supplier assessments, according to the systems and configurations actually deployed. No internet-based system is completely secure.

We investigate suspected security incidents and notify affected customers, individuals, or authorities when required by law or contract. Enterprise customers should consult applicable service agreements and security documentation for incident notification procedures and service-specific commitments.

12. Retention and Deletion

We retain personal information for as long as necessary for the purposes described in this Policy, including service delivery, customer instructions, legitimate business needs, dispute resolution, security, and legal or tax obligations. Retention periods vary by category: account records may be kept during the relationship and for an appropriate post-termination period; financial records may be retained as legally required; technical logs may have shorter schedules; and customer-controlled operational data follows the applicable contract and customer instructions.

Upon contract termination or a valid request, we delete, return, or de-identify eligible data as required by agreement and law. Deletion from backups may occur through established backup rotation, with access restrictions in the interim.

13. Your Privacy Rights

Depending on applicable law, you may request access to personal information, correction, deletion, portability, restriction of processing, or information about processing. You may object to certain processing, withdraw consent where consent is the basis, opt out of direct marketing, and appeal a request decision where provided by law. You may also lodge a complaint with an applicable supervisory authority. We do not discriminate against individuals for exercising rights protected by law. Rights are not absolute and may be subject to identity verification, exemptions, and legal retention obligations.

If your information is processed by GAMA on behalf of your employer or another business customer, that customer is generally the appropriate first contact for rights requests concerning its workspace. We will assist customers as required by law and our agreements.

14. How to Submit and Track a Privacy Request

To submit a request, email the GAMA Privacy Team at privacy@gamasuite.com with the subject “Privacy Rights Request”. Include your name, preferred reply email, relevant organization and GAMA service, type of request, and a concise description of the data concerned. Do not send passwords, full payment card details, or identity documents in the initial message.

We aim to acknowledge requests within five business days. We may request proportionate information to verify identity or authorized agency, using secure methods where appropriate. We will record the date received, request category, verification status, applicable deadline, responsible owner, actions, decision, and closure.

We respond within applicable legal deadlines. Under the EU/UK GDPR, the general deadline is one month, subject to permitted extensions. Under applicable California consumer privacy law, the general deadline for certain verified requests is 45 days, subject to permitted extensions and exceptions. Other jurisdictions may prescribe different deadlines. We will explain any denial or limitation when legally permitted and provide appeal instructions where required.

For customer-controlled data, we may refer the requester to the relevant customer or assist the customer in handling the request. If you disagree with a decision, reply to our response with the subject “Privacy Request Appeal” or “Privacy Request Escalation”. Where applicable, we will provide information about contacting the relevant regulator. We retain request records only as necessary for compliance, security, and dispute resolution.

15. Marketing Communications and Preferences

Where permitted, we may send product news, event invitations, updates, and other business communications. Marketing messages will include a reasonable opt-out method when required, and you may contact the privacy team to change preferences. We may continue to send essential service, security, billing, or contractual notices even after you opt out of marketing. Where consent is legally required for marketing, we will obtain it before sending the relevant messages.

16. Children, External Links, and Third-Party Services

GAMA's business services are not directed to children, and we do not knowingly solicit personal information from children through our marketing website. If we learn that we have collected children's personal information in violation of applicable law, we will take appropriate steps to address it.

Our services may link to third-party sites or connect with carriers, payment services, mapping tools, and other providers. Their independent processing is governed by their own notices and contractual terms. We encourage users to review those notices.

When you choose to load an embedded Instagram or YouTube video, your browser connects to that provider. The provider may receive technical information such as your IP address, browser information, and referring page, and may use cookies or similar technologies under its own privacy practices. You can also open the original video on the provider's website.

17. Jurisdiction-Specific Information

Residents of the EEA, UK, Switzerland, California, and other jurisdictions may have additional rights or receive supplemental disclosures under local laws. Where applicable, GAMA will provide required information about legal bases, international transfers, data categories, sources, purposes, recipients, retention, sensitive information, targeted advertising, sale or sharing, and authorized agents. Additional jurisdiction-specific disclosures depend on the relevant legal entity, applicable legal thresholds, and processing activities.

For the EEA/UK, if GAMA is required to appoint a representative or data protection officer, the applicable contact details will be published. Our Privacy Team can assist with questions about the regional contacts applicable to your service.

18. Updates to This Policy

We may update this Policy to reflect changes in products, data practices, legal requirements, or service providers. We will post the revised version with an updated effective date and provide additional notice or obtain consent where required. Material changes will not retroactively authorize processing that requires a separate lawful basis.

19. Contact Information

Privacy inquiries and rights requests: GAMA Privacy Team — privacy@gamasuite.com.

Legal entity: Gama Climax Technologies Inc.

Registered address: 2425 N. Central Expy. Suite 700, Richardson, TX 75080.

Website: https://gamasuite.com/