Privacy Notice for Position Imaging Smart Package Room (SPR) and iPickup
As of April 2026
Position Imaging, Inc. (“Company”, “we”, “us”, or “our”) acts as a “processor” for shipping carriers, property owners and managers, airlines, and other businesses that engage us to process, track, and deliver packages. We facilitate those businesses by providing secure facilities to store your package and enable you to safely retrieve it. This Privacy Notice describes how we treat personal information that we obtain from the third-party companies that contracted with us in order to provide those services.
If you have directly signed up for one of our products or services, please click here for our Privacy Policy.
If there are any terms in this privacy notice that you do not agree with, please discontinue use of our services, including SPR and iPickup. If you have any questions or concerns about our privacy notice, or our practices with regards to your personal information, please contact us at dpo@position-imaging.com. All other questions and concerns should be directed to your shipping carrier, property owner/manager, or other business that engaged our services.
This privacy notice applies to all information we collect and process about you. We may receive information directly from the business that engaged our services and through your use of our pick-up kiosk portals. This privacy notice does not apply to data we, or our authorized third-party vendors or partners, collect that cannot be used to identify an individual or to pseudonymous data.
Please read this privacy notice carefully.
1. WHAT INFORMATION DO WE COLLECT?
It is necessary for us to obtain information about you from the third-party company that engaged us to provide services. Specifically, they have provided us with your email, physical address, and phone number.
2. HOW DO WE USE YOUR INFORMATION?
We process your personal information to perform a contract and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below:
We use the information we collect or receive:
To send administrative information to you – We may use your personal information to communicate with you about package deliveries.
To protect our Sites, respond to legal requests and prevent harm – We may use your information for fraud monitoring and prevention or to respond to a subpoena or other legal request.
We may anonymize and aggregate personal information from our users and use it for the limited internal purposes of data analytics, identifying usage trends, and to evaluate and improve our products and services. Under no circumstances can we ever re-identify such information, once anonymized and aggregated, and under no circumstances do we share such anonymized and aggregated information with third-parties.
3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
We may share data based on the following legal bases:
Performance of a Contract: We will process your personal information on behalf of your shipping carrier, property owner/manager, or other business to fulfill the terms of the contract you entered into with that business.
Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, government requests, a judicial proceeding, court order, or legal process,such as in response to a court order or subpoena (including in response to public authorities to meet national security or law enforcement requirements).
Vital Interests: We may disclose your information where we believe it is necessary to investigate,prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
4. WHO WILL YOUR INFORMATION BE SHARED WITH?
We may share your personal information or data with our authorized subprocessors/service providers who perform services for us or on our behalf and require access to such information to do that work. Examples include: email delivery, text message delivery and customer service.
We only disclose your personal information to such subprocessors/service providers pursuant to written contracts that describe the purpose, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract. We do not share, sell, rent or trade any of your information with other third-parties.
5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
We may use essential cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies is set out in Section 11, below.
6. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
We are a global organization, so we sometimes need to share your personal data with our other offices or with third-party service providers and suppliers who are located in countries other than your own. Note in particular that if you are accessing SPR or iPickup from outside of the United States, your information may be transferred to, stored, and processed by us in our facilities and by those third-parties with whom we may share your personal information (see “WILL YOUR INFORMATION BE SHARED WITH ANYONE?”), in the United States, and other countries.
If you are a resident in the European Economic Area or the United Kingdom, then these countries may not have data protection or other laws as comprehensive as those in your country. We will, however, take all necessary measures to protect your personal information in accordance with this privacy notice and applicable law, including, where applicable, ensuring that the transfer is governed by appropriate transfer mechanisms such as the Standard Contractual Clauses for data transfers between EU and non-EU countries.
7. HOW LONG DO WE KEEP YOUR INFORMATION?
We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
No purpose in this notice will require us keeping your personal information for longer than the period of time in which we provide services to the business that engaged us. Unless contractually required to retain information for a different period of time, under our standard retention practices, we delete any information provided by a third-party business to us shortly after you pick up your package.
8. HOW DO WE KEEP YOUR INFORMATION SAFE?
We have implemented appropriate technical and organizational and technical security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that connected technologies are 100% secure.
9. DO WE COLLECT INFORMATION FROM MINORS?
We do not knowingly collect, solicit data from, or market to children under 18 years of age. By using SPR or iPickup, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of SPR or iPickup. If we learn that personal information from users less than 18 years of age has been collected, we will take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 18, please contact us at contact@position-imaging.com.
10. WHAT ARE YOUR PRIVACY RIGHTS?
Under state or international law, you may have certain rights, such as the right to know, data portability, right to rectify, right to delete, right to opt-out and right to withdraw consent. Please contact the business that engaged our services to exercise your rights.
11. WHAT ABOUT COOKIES AND TRACKING TECHNOLOGIES?
Cookies and similar technologies: Like most web browsers, ours is set to accept essential cookies by default. We do not collect or place non-essential cookies or other non-essential tracking technologies.
12. DO WE MAKE UPDATES TO THIS NOTICE?
We may update this privacy notice from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.
13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you reside in the European Economic Area, we have appointed a data protection officer for you to contact if you have any questions or concerns about your personal data. Our data protection officer can be contacted to answer questions or concerns from around the globe at: dpo@position-imaging.com or by writing us at the address below. If you have any questions or comments about this policy, you may email us at dpo@position-imaging.com or by post to:
Position Imaging
22 Marin Way Unit 1
Stratham, NH 03885
United States
Phone: 1-888-909-2468
If you have questions or concerns about your shipping carrier, property owner/property manager, airline, or other business’ engagement with us for the processing, tracking, and delivery of packages, you will need to contact that business directly to ask your question(s) or convey your concerns.