CWILL Privacy Policy

Effective Date: January 9 , 2026

CWILL. also known as "CWILL" ("We", "Us", "Our") recognizes the importance of privacy. CWILL will process Your Personal Data, in a number of ways: collected through our Site located at cwill.com, the website applications, the application programming interface (API) related services, and affiliated sites owned by CWILL (collectively "Sites") based on CWILL belief of respect for the individual and in accordance with this CWILL Privacy Policy ("Privacy Policy").

This Privacy Policy applies to CWILL's handling of Personal Data collected from Users of the Sites. By using the site in any way, including browsing, purchasing, and using any of the services provided through the site, you acknowledge our privacy practices and the processing of Your personal data in accordance with data protection laws. If you do not agree with this Privacy Policy, please do not provide your Personal Data and immediately cease using the Sites and all related services.

For Users engaging with CWILL in a professional capacity, such as merchants in a business-to-business (B2B) context, this Privacy Policy governs CWILL's processing of Personal Data related to customer relationship management and associated activities.

CWILL is committed to protecting User privacy and ensuring that Personal Data is processed in accordance with applicable laws and regulations.

We process your Personal Data to provide the services You request, to improve Your interaction with CWILL, and to communicate with You about shipping information, services, promotions and contests. We limit the personal data we collect to information required to support the intended purpose of collection.

We collect Personal Data when You:

Create an account on the Sites;

Make an online purchase from CWILL;

Request customer service or contact Us;

Link an email account or other third-party account to Your Account;

Submit a review or post any User Content on the Sites; or

Otherwise provide Personal Data to CWILL for the provision of Services.

The Personal Data we collect may include authentication information (including but not limited to Username and encrypted access credentials) of Your email accounts, social networking accounts or any other accounts from any third-party application or Site that You link to Your Account, transaction information such as product name and price, contact and payment information, Your name and/or company name, address, phone number, email address, and shipping information.

When You ask Us to provide services on the behalf of a third party, You confirm that you are legally authorized by said third party to disclose his/her Personal Data to Us. This authorization shall cover Personal Data including but not limited to the name, address, phone number, email address, credit card, and shipping information of the third party. You will ensure that the third party is aware of and has the authority to consent to the processing of his/her Personal Data set forth in this Privacy Policy, and You will be responsible with respect to the provision of this personal data to CWILL.

Our data collection practices are in line with all applicable data protection laws. The data collection practices adhere to specific principles based on sensitivity of the Personal Data involved. We obtain the categories of personal information listed above from the following categories of sources:

• Directly from you. For example, from forms you complete or products and services you purchase.
• Indirectly from you. For example, from affiliates and third parties to whom you provide your information.

All data collection practices adhere to privacy principles required under the data protection laws, to ensure the safety and privacy of User information.

CWILL processes Personal Data for the following purposes and based on the following legal grounds:

Where necessary, We may combine limited usage information We collect to provide you a Service.

The Personal Data requested with regard to the creation and use of a User account is necessary for the performance of CWILL Services and to fulfill Your requests. Additional Personal Data You provide through linking different User accounts, is done so on a voluntary basis or to meet a request You have formulated.

The Personal Data will be stored for as long as You have an active account and continue to use CWILL Services, or as is required for the Purpose for which the Personal Data was collected..

CWILL will usually remove Your Personal Data generated and/or provided by You within 180 days after the data has been generated or provided. However, if the storage period needs to be extended for the purpose of fulfilling contractual obligations, resolving disputes, or complying with legal requirements, Users will be notified in writing of the reasons and the extended period, with the maximum extended period not exceeding the legal limit.

Additionally, Personal Data You provide in connection with the CWILL Services may be anonymizedin some cases and used by CWILL for data analysis, for example, to evaluate the performance of shipping carriers.

We use cookies to enhance and simplify Your visit; namely, in order to offer easier surfing on the Site, to make login easier, for internal security purposes, system administration to tailor advertisements to Your preferences, and business operations that we require. Cookies are small data files stored on the hard disk of a User's computer. In addition to cookies that send information to us, We also use cookies that collect information and send it to third parties. An example of this is Google Analytics. Some of Our cookies may collect and store Your Personal Data, such as Your name or email address.

CWILL uses cookies and similar technologies in accordance with applicable privacy regulations. Upon Your first visit, We provide a cookie banner allowing you to accept or reject cookies. You may modify Your preferences at any time through Our "Cookie Settings" button at the bottom of each webpage. We categorize cookies as follows: Strictly necessary, performance, functional, and marketing cookies.

We may also use web beacons. Web beacons allow Us to understand if a certain page of the Site was visited or if an email was opened or if advertising banners on other Sites were effective.

Most web browsers are set to accept cookies by default. If You prefer, You can usually set Your browser to remove or reject cookies, but note that doing so does not necessarily affect third-party flash cookies used in conjunction with Our Site. For more information about disabling flash cookies, see www.adobe.com/products/flashplayer/security. Please note that if You choose to remove or reject cookies, this could affect the availability and functionality of the Site and You may not be able to access or use some or all areas and functionalities of the Site.

CWILL uses Your Personal Data and usage information to offer and provide Our products and services and to support Our core business functions. These include order or service fulfillment, customer service, internal business processes, marketing, including contests and sweepstakes, authentication, loss and fraud prevention, public safety and legal functions. Some examples include:

To fulfill Your requests for products and services and communicate with You about said requests;

To send You notifications concerning information We need to convey;

To register Your account on the Sites;

To administer surveys, contests, sweepstakes, and promotions;

To provide customer service;

To help Us improve and customize the Sites;

To send You information about Our products, services, promotions, contests, and sweepstakes; and

To protect the security or integrity of the Site and Our business.

Depending on the Services you use, CWILL may process Personal Data on behalf of the Merchant as described below:

If you use ParcelWILL's shipment tracking functionality, CWILL may process order-related and shipment tracking information on behalf of the Merchant for the purpose of providing shipment tracking, delivery status updates, and related customer service features. Such information may include shipment identifiers, carrier-provided tracking events, delivery status, and related metadata. CWILL processes this information solely in accordance with the Merchant's instructions and does not independently determine the purposes for which such data is used.

If you use TrustWILL's reviews or loyalty functionality and choose to submit a review or participate in a loyalty program, Personal Data may be processed in connection with reviews, ratings, or loyalty-related interactions, as configured by the Merchant. Any reviews or ratings submitted may be publicly displayed depending on the Merchant's settings. CWILL processes such information on behalf of the Merchant and does not independently determine the purposes for which such data is used.

If you use SendWILL's email marketing functionality provided through the Services, CWILL may process email-related information on behalf of the Merchant for the purpose of sending communications as instructed by the Merchant. CWILL does not independently determine the recipients, content, or purposes of such communications. The Merchant is responsible for ensuring that all email communications sent using the Services comply with applicable marketing, anti-spam, and data protection laws.

If you use ChatWILL's chat or AI-assisted customer support functionality, CWILL may process chat messages and related conversation content submitted by End-Users on behalf of the Merchant for the purpose of assisting the Merchant in providing customer support services. CWILL processes such information solely in accordance with the Merchant's instructions and does not independently determine the purposes for which such data is used.

If You are engaging with Our services in a professional role, such as a merchant operating in a business-to-business (B2B) environment, We process Your Personal Data for various purposes, including contract administration and renewals, customer relationship management, order management, and shipping invoicing, and solvency monitoring. We also use Your Personal Data for customer support, personalized marketing and advertising, and to register and manage Your business's clientele and relevant profile based on purchases. In providing the Personal Data of your Business Associates (including employees and customers) You as a professional User confirm you have obtained consent allowing Us to process their Personal Data.

We will only use this data as necessary to fulfill contractual obligations or legal requirements, adhering to the principle of data minimization.

In the course of our operations, we process personal data and subsequently anonymize it for specific analytical purposes consistent with this Policy. Anonymized data is used to create reports based on data analysis with regards to the CWILL Services, for example, to determine the fastest carriers or average delivery times.

CWILL utilizes artificial intelligence ("AI") technologies to enhance and provide certain features of the Services ("AI Features").

If you use ParcelWILL's AI functionality, CWILL may use AI technologies, including predictive analytics, to perform automated tasks, analyze data, and support feature improvements. These AI Features are intended to improve user experience, operational efficiency, and service accuracy.

If you use ChatWILL's AI functionality, CWILL may use AI technologies to process chat messages and conversation content submitted by End-Users for the purpose of assisting Merchants in providing customer support services. This may include analyzing chat inputs, generating automated or suggested responses, and routing or categorizing inquiries to improve response efficiency and service quality.ChatWILL's AI functionality is designed to support and augment customer service operations on behalf of the Merchant and does not independently determine business decisions. Any responses generated through AI are based on the content submitted and the configurations set by the Merchant.CWILL processes chat content and any Personal Data contained therein solely on behalf of the Merchant and in accordance with the Merchant's instructions. CWILL does not use Personal Data processed through ChatWILL's AI functionality for independent profiling of End-Users or for CWILL's own marketing purposes.

If you use TrustWILL Reviews 's AI functionality, CWILL may use artificial intelligence technologies to analyze review-related data for the purpose of generating aggregated insights, summaries, or trends for Merchants. Such AI analysis is intended to help Merchants better understand overall feedback patterns and high-level observations derived from reviews.CWILL processes review-related data used for such AI analysis on behalf of the Merchant and in accordance with the Merchant's instructions. CWILL does not use such data for its own independent marketing purposes or for individualized profiling of End-Users.

All AI Features are developed and deployed in accordance with established ethical guidelines. Specific AI Features, including their purposes and scope of use, will be described in the applicable service-specific terms and related Documentation.

CWILL does not sell or share Your personal data to with third parties for cross-context behavioral advertising, as those terms are defined under the CCPA, as amended by the CPRA.

We may disclose Personal Data to third parties for legitimate business purposes, including to service providers that support our operational, technical, and administrative functions; to professional advisers who assist with compliance and governance; and to partners or vendors engaged to perform services on our behalf. Such disclosures are made pursuant to appropriate contractual and organizational safeguards and are limited to the purposes for which the information was originally collected or otherwise authorized by You.

We may disclose or otherwise make available Your Personal Data, including transaction information, to other service providers and vendors for the purpose of managing, providing, and improving CWILL services. Examples are shipping companies, vendors, payment companies, credit card processors, and other payment service providers such as PayPal, financial institution partners, hosting and maintenance providers, data storage and management providers. Generally, companies that help Us to furnish the CWILL services and improve Our product and service offerings and Our Sites.

In doing so, Your Personal Data will be transferred to such recipients outside the European Economic Area. In the case of any such transfers, We will ensure that Your Personal Data is adequately safeguarded through the implementation of standard data protection clauses according to applicable laws and regulations. For more information on such measures contact [email protected].

We may access, preserve and disclose Your information in other special circumstances, namely (a) to enforce the Terms; (b) to respond to claims that any content violates the rights of third parties; (c) to protect the safety, property, or other rights of CWILL, CWILL customers, associates, or any other person; or (d) where otherwise required by law. Examples include protecting the health or safety of customers, or addressing crimes committed on the Site. CWILL may provide Your Personal Data in response to a search warrant, subpoena or other legally valid inquiry or order, or as otherwise required by applicable law.

We may transfer any information We have about You in connection with a merger or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of CWILL or as part of a corporate reorganization or other change in corporate control. Such transfer shall be deemed Your consent to the new recipient's continued processing of Your Personal Data, and the new recipient shall be bound by this Privacy Policy; if You object to such transfer, You can terminate the use of Our services and request the deletion of Your Personal Data before the completion of the transfer, otherwise, it shall be deemed as acceptance.

We may occasionally share Your Personal Data with Our trusted partners for promotional and marketing purposes subject to Your consent. You may provide or withdraw consent at any time. All handling and transferring of Personal Data is done in a secure manner in compliance with Applicable Data Protection Laws.

Depending on your country or jurisdiction, You may have the following rights:

To be informed on how Your Personal Data is being Processed;

To request access to Your Personal Data;

To rectify any inaccurate Personal Data;

To request the erasure of Personal Data, under certain conditions;

To object to the Processing of Your Personal Data;

To limit the processing activities to which the Personal Data is subject, under certain conditions;

To receive Your Personal Data in a structured, commonly used and machine-readable format, and have the Personal Data transmitted to another controller, under specific conditions;

If processing is based on consent, to withdraw consent at any time (although this does not impact the lawfulness of past processing activities);

To lodge a complaint with the national supervisory authority;

To obtain the names of third parties with whom CWILL is sharing personal data;

To the extent any automated decision making would be involved, You have the right not to be subject to a decision (which engenders legal effects) based solely on automated decision making.

You can exercise Your rights related to Your Personal Data, including contact or account information, by sending Us an email at [email protected] or by submitting a request through our

We may require identity verification before responding. Requests will be processed within 30 days, or otherwise in accordance with data protection requirements.

We want to communicate with You in the ways that You want to hear from us. If You no longer want to receive marketing messages from us, You can click on the "Unsubscribe" link at the bottom of Our marketing emails. Please note that Your preferences will be processed in accordance with applicable data protection laws.

If You no longer want to receive delivery notifications from us, You can change Your delivery notification triggers by updating Your Account Delivery Notifications. Your preferences will be processed according to our internal processes.

Securing Your information is important to CWILL. We maintain technical and organizational safeguards to protect the confidentiality and security of information transmitted to us. For example, confidential data is secured through end-to-end encryption, while sensitive and internal data are transmitted securely via HTTPS, ensuring adequate protection for every type of Personal Data collected.

Notwithstanding, no data transmission over the Internet or other network can be guaranteed to be 100% secure. As a result, while We strive to protect information transmitted on or through the Sites, We cannot and do not guarantee the security of any information You transmit on or through the Site...

We are committed to protecting children's online privacy. In order to protect the privacy of children, CWILL does not knowingly collect Personal Data from children under the age of 16 without prior parental consent. If We become aware that We have inadvertently received Personal Data from a child under the age of 16, We will delete such information from Our records.

Our Site may contain links to other Sites. A link to a third party's Site does not mean that We endorse it or that We are affiliated with it. We do not exercise control over third-party Sites. You access such third-party Sites or content at Your own risk. You should always read the privacy policy of a third-party Site before providing any information to the Site. You confirm that any disputes between You and third parties arising from accessing third-party Sites via links on Our Site are unrelated to CWILL, and We shall not be liable for any coordination or compensation.

As a global company, CWILL may process, store, and transfer Personal Data in the United States or in any other country in which a company of the CWILL Group is incorporated. CWILL requires that all companies of the CWILL Group adequately safeguard Your Personal Data, regardless of where it is processed. When We transfer Personal Data from the European Union (EU), European Economic Area (EEA), the United Kingdom (UK), and Switzerland to countries that the European Commission has not recognized as having an adequate level of data protection, We will rely on the standard contractual clauses published by the European Commission, or other equivalent mechanisms.

CWILL may change the Privacy Policy from time to time. We will inform You by posting the revised Privacy Policy on the Sites. Please check Our Privacy Policy periodically for changes. We will post the date the Privacy Policy was last updated at the top of the Privacy Policy. The changes will go into effect on the "Last Updated" date shown in the revised Privacy Policy.

If You have any questions about Our Privacy Policy, please contact Us directly at [email protected] We are dedicated to addressing any inquiries or concerns You may have regarding the handling of Your personal data.

For Users in the European Union, We comply with the General Data Protection Regulation (GDPR) and have appointed the European Data Protection Office (EDPO) as Our GDPR Representative. You may contact the EDPO regarding matters pertaining to the GDPR: by using EDPO's online request form: https://edpo.com/gdpr-data-request/ by writing to EDPO at Avenue Huart Hamoir 71, 1030 Brussels, Belgium.

If You have questions related to data protection laws or Your rights under these regulations, please reach out to Our Data Protection Officer at [email protected] or by submitting a request through our online form. Our team is here to assist You and will respond promptly.