Privacy Policy

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This Privacy Policy and Consent for Data Use (the "Policy") explains the use of the information that Customers provide to EASYSHOP, Inc. ("EASYSHOP"), the owners of the information (whether a natural person, supplier, contractor, employee, or any other person under any relationship with EASYSHOP), regardless of whether it was provided in connection with purchases, when visiting our website, or by any other means. This Policy allows you to make informed decisions about whether to provide us with your personal information and also informs you of the opportunity to indicate that we limit the way we use your personal information.

Our Purpose

EASYSHOP believes it is important to protect the privacy of customers and other owners of personal information. We collect and use your information, including your name, contact information, postal address, other identifying information, purchase history, etc., solely to provide you with better service and fulfill our corporate mission.

Your Consent

By using our website in any way, you are making an unequivocal act that allows us to reasonably conclude that you agree with our use of your data and that you have accepted the terms and conditions described in this Policy.

Collection of Personal Data and Security

You provide, obtain, and may store your personal information within the scope of the use described in this document when you:

  • Create an account to receive news or notifications from EASYSHOP;
  • Maintain a business relationship with EASYSHOP or communicate with us for any other reason, whether by email, phone, fax, in writing, or in person at one of our offices.

We make all commercially reasonable efforts to protect such information from unauthorized access, loss, misuse, or alteration through technical, contractual, physical, and administrative measures.

Additional Online Data Collection and Related Security

When you visit our website, we may automatically collect information that helps us recognize you and assists us in providing you with better service, which includes, among other things, your computer's network address and system operation; the site from which you linked to us, your activity on the site, and the time and date of your visit and purchases.

Confidentially and responsibly, we collect, process, and maintain certain payment information in accordance with the data security standards adopted by credit card companies such as Visa, MasterCard, and American Express. This means we do not retain credit card numbers, debit card PIN numbers, or credit card security codes, and whenever we store any information, we use appropriate encryption and access controls to protect it. If you use our website, any transmission of your data will be protected by Secure Socket Layer (SSL) or Transport Layer Security (TLS) encrypted technologies.

Types of Data We Collect and Use

Personal Data

Refers to data that allows someone to identify or contact you, including, for example, your name, address, phone number, email address, as well as any other non-public information about you that is associated or linked to any of the above data.

Anonymous Data

Means data that is not associated or linked to your Personal Data; Anonymous data does not, by itself, allow for the identification of individual persons. We collect Personal Data and Anonymous Data, as described below.

Information from Social Media Sites

The Services allow users to register for an account and log in through social media sites such as Facebook, Google, and TikTok (each a "SNS"). By registering or logging in through an SNS, you are allowing the Services to access your information and agree to the Terms of Use and Privacy Policy of the SNS regarding such services. You may receive information from the SNS to facilitate the creation of an account with us. Any information we collect from your SNS account may depend on the privacy settings you have with that SNS, so please consult the privacy and data practices of the SNS.

SMS and WhatsApp Services

We may provide you with services through which you can receive messages on your phone or wireless device. We may also offer content through WAP and mobile services. If you subscribe to one of our SMS or WhatsApp services or an SMS service from one of our partners, you agree to receive services and messages at the address you provide for such purposes. We will use the information we obtain in relation to these services in accordance with this Privacy Policy. Your wireless service provider and other service providers not affiliated with EASYSHOP may also collect data regarding the use of your wireless device, and their practices are governed by their own policies.

Creation of Anonymous Data

We may create records of Anonymous Data from Personal Data by excluding information (such as your name) that personally identifies you. We use this Anonymous Data to analyze request and usage patterns so that we can improve our Services and enhance the navigation of the Site. We reserve the right to use Anonymous Data for any purpose and disclose Anonymous Data to third parties at our sole discretion.

Use, Storage, and Disclosure of Your Personal Data

EASYSHOP uses the personal information it collects to process your orders or transactions, to follow up on any requests or comments you may have, to provide quality customer service, and to understand your purchasing needs in order to serve you better. We may use your personal information to offer you promotional information, products and services, and special notifications. In the case of employees and suppliers, EASYSHOP uses your personal information to process payments, support internal and external audit processes, and for additional purposes to enhance the relationship between you and EASYSHOP.

If you apply for or request certain products, offers, or services, the personal information provided may be shared directly with third parties that provide the requested products, offers, or services. The third parties we may share information with are not allowed to use the personal information we share with them for any purposes other than providing the services we requested. Since we are not responsible for any additional information you provide directly to these third parties, you should familiarize yourself with their privacy and security policies and practices before disclosing any information to them.

Additionally, we may disclose personal information when it is reasonably necessary to comply with a legal process or authorities, respond to any demands, or protect the rights, property, or personal safety of EASYSHOP, our customers, employees, or the public. Information about our customers, including personal information, may be disclosed or transferred as part of or during negotiations for any merger, sale of company assets, or acquisition.

Similarly, we may transfer or transmit (as applicable) your personal data to other companies abroad for security, management, efficiency reasons, and to provide you with better service, unless you indicate otherwise. EASYSHOP has adopted measures for these companies to implement, in their jurisdiction and in accordance with applicable laws, security standards and personal data protection similar to those stipulated in this document and EASYSHOP's policies in general. Additionally, we inform you that if we no longer need to process your data, we may delete it from our databases.

Corporate Restructuring

We may share some or all of your Personal Data in connection with or during the negotiation of any transaction or proceeding involving merger, financing, acquisition, or dissolution that involves the sale, transfer, divestiture, or disclosure of all or part of our business or assets. In the event of insolvency, bankruptcy, or judicial administration, Personal Data may also be transferred as a business asset. If another company acquires our company, business, or assets, that company will own the Personal Data collected by us and will assume the rights and obligations regarding your Personal Data as described in this Privacy Policy.

Third-Party Data and Aggregate Data

In accordance with agreements between EASYSHOP and third parties, EASYSHOP may match user information with third-party data. EASYSHOP may also disclose aggregated member statistics (i.e., percentage of female buyers, percentage of online users) in order to describe our business or services to potential partners, advertisers, and other third parties, as well as for other legal purposes.

Use of Cookies

Cookies are alphanumeric identifiers that we transfer to your computer's hard drive through your web browser, which help us identify you when you visit our website. You can choose options regarding cookies. By modifying your browsing preferences, you have the option to accept all cookies, be notified when a cookie is set, or reject all cookies. If you choose to reject all cookies, you may not be able to use EASYSHOP services that require registration.

As a provider of personal data in relation to EASYSHOP, you may:

  • Review and request that we update, modify, or delete your personal information;
  • Receive additional information, upon request, about the use of personal data;
  • Revoke (eventually) an express authorization to process the information;
  • Access your personal data processed during the last year.

Google Analytics

EASYSHOP uses Google Analytics analysis tools to analyze the traffic on this website. Google Analytics does not create individual visitor profiles and only collects data in aggregate. For more information about Google Analytics, click on the following link: http://www.google.com/analytics

How Can You Access or Correct Your Information?

You have the right to access your personally identifiable information held by EASYSHOP. You can correct factual errors in that information by sending us a request that accurately demonstrates the error. To protect your privacy and security, we will take reasonable steps to verify your identity before granting access or making corrections.

Data Deletion Request

To request the deletion of your EASYSHOP account, email [email protected] indicating your desire to delete your active EASYSHOP account. The email should include the name, email address associated with the account, and the account number. Once the customer service team receives the request, the customer will be notified within 72 hours that their account and data have been deleted.

Children's Privacy

We do not intentionally collect personal data from visitors under the age of 16. If a child under 16 years old submits personal data to EASYSHOP, and we become aware that the personal data is information from a child under 16 years old, we will attempt to delete the information as soon as possible. If you believe we may have personal data from a child under 16 years old, please contact us at [email protected].

International Data Transfer

If you are not a U.S. user of the Site, by visiting the Site and providing us with data, you acknowledge and agree that your Personal Data may be processed for the purposes identified in the Privacy Policy. Additionally, your Personal Data may be processed in the country where it was collected and in other countries, including the United States, where laws regarding the processing of Personal Data may be less stringent than the laws of your country. By providing your data, you consent to such processing and transfer.

Suspension of Service

EASYSHOP reserves the right to refuse any service, cancel any account, remove or edit content, refuse to accept packages, or cancel orders at its sole discretion. If there is any suspicion that an account is fraudulent, unethical, or illegal, whether due to the handling of stolen property, stolen identities or credit cards, or involvement in other illegal activities, including but not limited to document forgery, EASYSHOP will report it to the appropriate authorities. EASYSHOP reserves the right to provide information about accounts, users, and packages to the Authorities, the original merchant, or any other involved party, at EASYSHOP's discretion.

You can cancel your Account with EASYSHOP at any time by stopping the use of EASYSHOP's Services. The Customer will be responsible for any outstanding payments, including abandoned packages, which must be paid immediately upon termination of the service.

Copyright & Trademarks

Copyright

All content hosted or made available through any of EASYSHOP's Services, such as text, graphics, logos, button icons, images, audio clips, digital downloads, and data compilations, is the property of EASYSHOP or its content providers and is protected by domestic and intellectual property laws of the United States of America. All content hosted or made available through any EASYSHOP Service as a whole is the exclusive property of EASYSHOP and is protected by national and United States intellectual property laws.

Trademarks

The graphics, logos, page headers, button icons, scripts, and service names that appear or are available through EASYSHOP's Services are trademarks or represent the commercial image of EASYSHOP in the United States of America and other countries. EASYSHOP's trademarks and commercial image may not be used in any way that could cause confusion among users or that could disparage or discredit EASYSHOP. All other trademarks not owned by EASYSHOP and available through EASYSHOP's Services are the property of their respective owners, who may or may not be affiliated with, related to, or sponsored by EASYSHOP.

Licenses and Access

Subject to compliance with these Terms and Conditions, as well as payment of the applicable price, EASYSHOP or its content providers grant you a limited, non-exclusive, non-transferable, and non-sublicensable license to access and use EASYSHOP's Services for personal, non-commercial purposes. This license does not include any right of resale or commercial use of any EASYSHOP Services or their contents; any right to compile or use any product lists, descriptions, or prices; any right to make any derivative use of EASYSHOP Services or their contents; to download or copy any account information for the benefit of another company; or the use of data mining tools, robots, or similar processes, nor the application of reverse engineering systems or processes.

Exclusions of Warranties and Limits on Our Liability

EASYSHOP Services and all other information, content, materials, products (including the Website and software), and other services included and/or made available through EASYSHOP Services are offered "as is" and "as available" unless otherwise stated in writing. EASYSHOP makes no representations or warranties, express or implied, regarding the operation of EASYSHOP Services or the information, content materials, products (including the website and software), or any other materials made available through EASYSHOP Services, unless otherwise stated in writing. You expressly agree that your use of EASYSHOP Services is at your own risk.

To the extent permitted by applicable law, EASYSHOP disclaims any warranties, express or implied, including but not limited to the implied warranties of merchantability and fitness for a particular purpose. EASYSHOP does not warrant that EASYSHOP Services, the information content, materials, products (including software), or other services included or made available through EASYSHOP services, EASYSHOP administrators, or electronic communications sent from EASYSHOP are free of viruses or other harmful components.

The laws of some countries do not allow limitations on implied warranties or the exclusion or limitation of certain damages. If these laws apply to you, some or all of the above disclaimers, exclusions, or limitations may not apply to you, and you may have additional rights.

Dispute Resolution

EASYSHOP strives to provide a highly satisfying shopping experience. If you are unable to resolve an issue satisfactorily, please send us a message at [email protected].

Our headquarters is located in Miami, Florida, and our legal jurisdiction is that of Miami-Dade County in Florida. Our address is:

EASYSHOP

PO 25331

1 EASYSHOP Way #MIA 4567

Miami, FL 33102-5331

Miami, FL 33206-3206

Online Payment Policy

Policy & Procedures

Effective date: 04/01/2026Document owner: Risk & Claims ManagerVersion: 1.0

Purpose

This policy defines the rules, roles, and procedures for online payments at EasyShop to ensure secure, prepaid package release, clear country partner responsibilities, and standardized fraud-prevention and chargeback handling.

Scope

Applies to all countries' customers, country participants, network, and third-party payment processors involved in processing or authorizing payments for EasyShop package/cargo shipping services.

1. Payment Model and Release Conditions

  • Prepaid model: All package services are prepaid. A package will not be released or executed until payment is confirmed and cleared according to this policy.
  • Accepted payment flows:
    1. Direct online payment by the customer via EasyShop's payment gateway.
    2. Local payment: Customer pays the country participant locally.
    3. The country participant submits payment for that specific transaction through EasyShop's systems before release.
  • Country participant option: A country participant may elect to require all customers in their territory to pay locally. In that case the partner is responsible for authorizing and forwarding payments to EasyShop before any package release.

2. Transaction Authorization & Approval

  • Gateway approval: All transactions are processed and initially approved or declined by the payment gateway based on card validity and fraud filters.
  • $200 USD threshold:
    • Transactions ≤ $200 USD: Payment gateway will process and approve pending required customer authorization and documentation (see Section 4).
    • Transactions > $200 USD: Payment gateway will automatically deny the transaction for additional validation. The transaction cannot be released until the customer signs the authorization form specifying the exact amount and package/transaction number and all supporting documents are received and verified by EasyShop or the country participant.
  • Documentation must be verified and on file prior to package payment and release for every approved transaction.

3. Country Partner Roles & Responsibilities

  • Authorized payer: When a country participant pays on behalf of a customer, the partner must ensure payment is submitted promptly and documentation for the customer is collected and maintained.
  • Operational choice: If a partner mandates local payment for all customers, the participant must:
    • Ensure timely payment transactions to EasyShop before package/cargo release.
    • Maintain required customer authorization documentation in accordance with Section 4 and retention rules.
    • Monitor and reconcile transactions and report any anomalies to EasyShop immediately.
  • Financial liability: The country partner accepts financial responsibility for funds recovered by issuing banks for transactions found in fraudulent activity or chargebacks (see Section 5).

4. Fraud Prevention & Required Customer Documentation

For every transaction (customers or partner-submitted), EasyShop requires the following before package release:

  • Signed Authorization Form: A completed and signed payment authorization form (physical or electronic) that includes customer name, telephone number, email, transaction/package number, amount, and explicit consent to charge the payment method with credit card.
  • Photo ID copy: Government-issued photo ID (passport, national ID, or driver's license) copy for identity verification.
  • Card image: Photograph of the credit card showing the cardholder's name and last six digits only; all other card numbers and CVV must be obscured. (Full card numbers and CVV must never be stored in EasyShop systems or Country participants.)
  • Verification checklist: Country participants must confirm name matching across authorization form, ID, and card image before approving release.
  • Recordkeeping: All documentation must be stored securely and retained for a minimum of 24 months or longer where required by local law.
  • Signed Authorization Form (over $200 USD): For transactions > $200 USD, an individual signed authorization form must be completed with the specific amount of the transaction.

5. Chargebacks, Fraud, and Financial Responsibility

Chargeback handling

  • If a chargeback or reversal occurs and funds are recovered by the issuing financial institution, the financial responsibility falls on the country participant that authorized/submitted the transaction.
  • EasyShop will deduct the chargeback amount, plus any associated fees, from that country participant's next monthly compensation. If monthly compensation is insufficient, EasyShop may recover outstanding amounts via invoicing, escrowed funds, or other agreed mechanisms.

Notification and dispute

  • EasyShop will notify the country participant within 5 business days of becoming aware of a chargeback and provide supporting documentation for dispute attempts where available.
  • The country participant has the right to provide additional documentation or dispute the chargeback; EasyShop will cooperate in dispute resolution, but final financial responsibility remains with the partner for transactions they authorized.

Fraud detection: EasyShop reserves the right to block or flag accounts/transactions that trigger fraud indicators. Repeated high-risk behavior by a customer may result in suspension or termination of the account.

6. Transaction Denials, Refunds, and Exceptions

  • Denials: Transactions denied by the gateway require follow-up per gateway guidance and must not be overridden. For amounts >$200 USD, denial triggers the enhanced authorization process (Section 2).
  • Refunds: Refunds follow EasyShop's refund policy; however, if a refund leads to recovery by the issuing bank (chargeback), the country partner remains liable if they submitted or authorized the original payment.
  • Exceptions: Any exception to this policy must be approved in writing by EasyShop Finance and Compliance teams.

7. Security & Data Handling

  • Sensitive data: Full card numbers and CVV must never be stored in EasyShop systems. Card images must be redacted per requirements above.
  • Secure storage: Authorization forms, ID copies, and allowed card images must be stored securely with access limited to authorized personnel.
  • Data breach: Any suspected data breach involving payment data must be reported immediately to EasyShop Compliance and handled per applicable breach notification laws.

Amendments & Effective Date

EasyShop may amend this policy; participants and customers will be notified of material changes. This version is effective immediately upon distribution.

Contact

For questions, dispute support, or to report suspected fraud, contact EasyShop Finance & Compliance at [email protected] (or local participant support channel).

Acknowledgment: By using EasyShop services or submitting payments, customers and country partners acknowledge and agree to comply with this Online Payment Policy.

Package Protection Program (PPP)

Policy & Procedures

Effective date: 04/01/2026Document owner: Risk & Claims ManagerVersion: 1.0

Purpose

  • Protect customer packages and cargo under EasyShop direct custody from the moment of arrival scan-in at the Miami processing center (8578 NW 61st St., Doral, FL 33166) until delivery or authorized customer pickup.
  • Protection covers loss, theft, missing contents, and physical damage discovered while the package/cargo is under EasyShop supervision, subject to terms, exclusions, and limits below.

Scope & Eligibility

  • Covered: Packages received, scanned and held/handled at EasyShop Miami and moved through EasyHUBS, then manifested and delivered/picked up under EasyShop-managed last-mile or customer pickup processes.
  • Not covered:
    • Packages and items not physically received and scanned into EasyHUBS at the Miami processing center.
    • Content visible damaged at time of arrival and upon inspection by qualified personnel and picture taken.
  • Returns: Coverage for return shipments applies only when the seller (merchant) has expressly authorized returns to EasyShop Miami and provided a valid return shipping label originating from Miami. Returns are covered from country-origin pickup back to Miami only after acceptance under these conditions.

1. Covered Loss Types

  • Total loss (package not delivered and not recoverable).
  • Missing contents (documented shortage vs. manifest/packing list).
  • Physical damage rendering item unusable or materially reduced in value.
  • Theft while under EasyShop custody.

2. Valuation & Payout Limits

  • Primary limit: Payout limited to the product price as stated on the commercial invoice or MyEasyShop transaction record (the “Declared Value”), up to the Declared Value per item/package as it entered EasyHUBS. Invoices entered after the package is paid and the incident occurred are not accepted and only the minimum value will be compensated.
  • Shipping & handling: Refunds may include paid shipping/handling charges paid to EasyShop only when those charges were paid through MyEasyShop and are documented on the invoice.
  • Excluded from payout: The value of the PPP coverage, the Duties, local taxes, and third-party local charges are not refundable under PPP.
  • Company discretion: EasyShop reserves the right to compensate the value of a return approved item, when reimbursement makes it economically practical (e.g., shipping cost to return/return item exceeds product value) or where repair/replacement is a viable and lower-cost remedy. Such decisions will be documented and communicated to the customer.
  • Salvage & recovery: If damaged goods are recovered and retain value, EasyShop may require return of salvaged items and deduct salvage value from the payout.

3. Deductibles & Aggregation

  • Standard deductible: None, unless otherwise specified in customer plan or country partner agreement.
  • Aggregate limits: Company-wide limits may apply for bulk losses (e.g., disaster), and settlement may be prorated across affected claims.

4. Exclusions (non-exhaustive)

  • Prohibited, undeclared or misdeclared high-value items not declared per MyEasyShop terms (e.g., jewelry, precious metals) unless pre-approved.
  • Items excluded by law or carrier rules (perishable goods beyond allowable shelf-life, live animals, illicit goods).
  • Damage due to improper packaging by sender when packaging does not meet EasyShop’s published packaging guidelines.
  • Losses arising during international transit when EasyShop custody ends (airline/sea carrier liability period).
  • Unapproved returns (no seller-provided Miami return label).
  • Consequential losses (lost profits, business interruption).
  • Fraudulent claims or misrepresentations.
  • Fragile items on Sea-shipping (example but not limited to: mirrors, tv’s, screens, all glasses and porcelain, computers)

5. Documentation Required for Claims

Customer must file a claim within the timelines below and provide:

  • Tracking number, Tracking history.
  • Photos of damage (external and internal) including packaging (if available).
  • Commercial invoice submitted showing product price and shipping paid to EasyShop.
  • Seller return authorization and return shipping label (for return-related claims).

6. Claim Timelines & Submission

  • Time to report: Customer or country participant must open a claim in MyEasyShop/CRM within:
    • Damage or missing contents discovered at delivery/pickup: 24 hours of delivery/POD.
    • Total loss (no delivery): 14 days after expected delivery date.
    • Returns-in-transit issues: 30 days from package delivery.
  • Internal processing SLA: Acknowledgement within 24 hours of receipt; initial decision or request for more info within 2 business days; final resolution within 5 calendar days of complete documentation receipt (may extend if carrier/third-party investigation required).

7. Investigation & Inspection

  • EasyShop will inspect damaged items and packaging. Customer must return the item within 2 days or until instructed otherwise.
  • EasyShop may escalate to carrier and/or insurer for joint inspection.
  • Failure to preserve evidence may result in claim denial or reduced payout.

8. Payment Methods & Settlement

  • Refunds issued to the original payment method where possible, or as account credit to MyEasyShop at EasyShop’s discretion.
  • Cash or third-party reimbursements only by approved exception with documented justification.
  • Where repair or replacement occurs instead of cash payout, EasyShop will coordinate replacement or repair provider; customer must accept alternative in writing.

9. Returns & Recoveries

  • For covered returns (seller-authorized within 30-days of item delivered), EasyShop will process return shipments per seller instructions under the Return Shipping Label from Miami to Store and adjust claims/payouts accordingly.
  • If seller accepts returned item and issues refund to EasyShop or customer, EasyShop will offset PPP payout accordingly.

10. Fraud Prevention & Audit

  • Claims are subject to fraud detection and verification. Submitting false documentation is grounds for denial and may be referred for prosecution.
  • EasyShop reserves the right to audit claim history, customer account activity, and seller documentation.

11. Appeals & Dispute Resolution

  • Customers may appeal claim denials within 5 days of decision via MyEasyShop. Appeals reviewed by Risk & Claims Manager; final determination issued within 15 business days.
  • Unresolved disputes escalated per contractual dispute resolution terms, jurisdiction per company terms of service.

12. Recordkeeping & Retention

  • Maintain claim files, supporting documents, inspection notes, and correspondence for a minimum of five (5) years.
  • Claims data used for trend analysis, carrier performance, and process improvement.

13. Country Participant & Seller Obligations

  • Country Participant and sellers must cooperate in claims investigation, provide requested documents, and honor valid seller return authorizations.
  • Sellers must provide accurate invoices, truthful descriptions, and return labels originating from Miami for return coverage.

14. Communication & Customer Guidance

  • PPP coverage summary presented at purchase and in MyEasyShop.
  • Claim submission instructions available in MyEasyShop Help Center and EasyTEAMS for participants.
  • Standardized templates for damage report, missing-content report, and claim acknowledgment used for transparency.

15. Exceptions & Management Discretion

  • Management may authorize exceptions (e.g., goodwill payments, expedited settlements) recorded with rationale and approved by Risk & Claims Manager.
  • EasyShop may settle claims for less than full invoice value where evidence or economics justify partial payment.

16. Review & Updates

  • PPP policy reviewed annually or after major incidents/claims trends.
  • Revisions approved by Risk & Claims Manager and communicated to customers, country participants, and internal teams.

Appendix A — Quick Claims Procedure (summary)

  1. Customer discovers loss/damage → report via MyEasyShop/CRM within timelines.
  2. Submit required documentation (invoice, photos, tracking, POD).
  3. EasyShop acknowledges within 48 hours; requests additional info if needed.
  4. Inspection by EasyShop PPP as required.
  5. Decision and payout or denial communicated within 5 days; appeals process available.

Appendix B — Sample Required Documents Checklist

  • MyEasyShop order number / EasyHUBS ID
  • Commercial invoice/receipt
  • Photos of package and contents
  • Seller returns label/authorization (for returns)
  • Any third-party repair estimates (if applicable)

Contact Claims & Risk Team

[email protected] (or via MyEasyShop Claims portal)

Dangerous Goods (DG) Acceptance

Standard Operating Procedures (SOP)

Effective date: 04/01/2026Document No.: MIA10001Revision: 1

SOP 1: Dangerous Goods (DG) Acceptance

Purpose

Define procedures to screen, accept, reject and document dangerous goods for air and ocean shipments to ensure regulatory compliance (49 CFR, IATA DGR, IMDG).

Scope

Applies to all staff involved in booking, customer service, acceptance, packing, inspection and dispatch of cargo at EasyShop locations.

Responsibilities

  • DG Compliance Officer: Luis Defreitas — oversight, final decision on non-routine shipments, training sign-off.
  • Customer Service/Bookings: initial screening, obtain necessary docs from shipper.
  • Acceptance/Check-in Staff: physical inspection, documentation verification, final acceptance/ rejection.
  • Warehouse/Pack Staff: packing/segregation per SOPs.
  • Operations Manager: notify carriers, update systems, incident escalation.

Procedure

  1. Pre-acceptance booking: Collect product description, UN number, NET quantity, SDS, etc. Run DG screening in TMS.
  2. Documentation check: Verify SDS, manufacturer declarations, UN number, Proper Shipping Name, Class, etc.
  3. Physical inspection: Inspect packaging integrity, markings, labels. Segregate incompatible goods.
  4. Acceptance decision: Stamp/sign "ACCEPTED" if compliant. Attach docs and photos to record.
  5. Special cases: Lithium batteries require manufacturer test reports. Radioactive/infectious require DGCO review.

SOP 2: Shipper’s Declaration for Dangerous Goods (Air)

Purpose

Ensure accurate preparation, verification and retention of the Shipper’s Declaration for Dangerous Goods required by IATA DGR for air shipments.

Declaration preparation checklist

  • • Shipper’s name & address
  • • Consignee name & address
  • • Airport of departure / destination
  • • Proper Shipping Name
  • • UN Number & Class
  • • Packing Instruction number
  • • Emergency contact: Dino Nassi, 1 954 260-9620

SOP 3: IMDG Container & Cargo Packing

Purpose

Ensure safe, compliant packing, marking, labeling and securing of dangerous goods for sea transport in accordance with the IMDG Code and SOLAS requirements.

Procedure

  • Pre-packing checks: Confirm shipment acceptance; verify SDS, UN number, container suitability.
  • Packaging: Use UN-approved packaging; ensure inner packaging is secured and leak-proof.
  • Container stuffing: Follow packing plan; maintain segregation distances; secure cargo with dunnage/lashing.
  • Labeling & Placarding: Apply required labels and exterior placards per IMDG.
  • Certification: Complete and sign Multimodal Container Packing Certificate.

SOP 4: Emergency Response & Incident Reporting

Emergency Contacts (24/7)

Local Emergency: 911

EasyShop Emergency: Dino Nassi, 1 954 260-9620

CHEMTREC (U.S.): 1-800-424-9300

DG Compliance: Luis Defreitas

Immediate Actions

  1. Assess safety: Do not put yourself at risk.
  2. Isolate area: Establish exclusion zone.
  3. Alert: Notify DG Compliance Officer immediately.
  4. Identify substance: Use SDS, labels, or UN number.
  5. Contain if safe: Use absorbents only if trained.

U.S. Foreign Corrupt Practices Act and Anti-Bribery

Policy & Procedures

Effective date: 04/01/2025Document owner: Dino Nassi

Purpose

  • Affirm EasyShop's commitment to comply with the U.S. Foreign Corrupt Practices Act (FCPA) and all applicable anti-bribery laws in countries where we operate by prohibiting any offer, promise, payment or authorization of anything of value to obtain or retain business or secure any improper advantage.
  • Require appropriate due diligence, accurate books and records, internal controls, training and prompt reporting of suspected violations to prevent, detect and respond to bribery risk across EasyShop's operations and third-party relationships.

Introduction

EasyShop is committed to conducting its business ethically and in compliance with applicable laws and regulations, including the U.S. Foreign Corrupt Practices Act (FCPA) and other laws that prohibit improper payments to obtain a business advantage.

This document sets out EasyShop's policy prohibiting bribery and other improper payments in EasyShop's business operations and the responsibility of its employees to implement this policy. Any questions about this policy or its application in particular circumstances should be directed to Executive Management.

Policy Overview

EasyShop strictly prohibits bribery or any other form of improper payment in any part of its business operations. This prohibition applies to all business activities worldwide, whether they involve government officials or are purely commercial. A bribe or other improper payment to secure a business advantage will never be acceptable and may expose the individuals involved and EasyShop to criminal prosecution, reputational harm, and other serious consequences.

This policy applies to all persons within EasyShop, including officers, employees and intermediaries acting on EasyShop's behalf. Every EasyShop officer and employee has a personal responsibility and duty to conduct EasyShop's business activities ethically and lawfully. Failure to meet that responsibility and duty may result in disciplinary action up to and including termination.

Prohibited improper payments under this policy include any form of bribery, secret commissions, excessive gifts or entertainment, or any other payment made or offered to obtain an improper business advantage. These payments should not be confused with legitimate, reasonable, and modest corporate gifts, business entertainment, or other activities that are directly related to EasyShop's business conduct.

EasyShop has developed a comprehensive program to implement this policy through guidance, training, investigation and oversight. Executive Management is responsible for the program overall and will be supported by regional implementation directors (the O-Team) and the general managers in each country. Executive Management is responsible for interpreting and applying this policy, providing supporting training and education, and responding to raised concerns.

U.S. Foreign Corrupt Practices Act Compliance

The prohibition on bribery and other improper payments applies to all business activities but is especially important when government officials are involved. The U.S. Foreign Corrupt Practices Act and similar laws in other countries strictly prohibit improper payments to obtain business advantage and impose severe penalties for violations. The following summary is intended to provide basic familiarity to personnel involved in international activities so they can avoid inadvertent violations and recognize potential issues in time to address them properly.

Summary of the Foreign Corrupt Practices Act

The Foreign Corrupt Practices Act (FCPA) is a criminal statute that prohibits improper payments to government officials to influence the performance of their official duties. It is illegal for any U.S. company and its employees or agents to offer, promise, pay or authorize payment of anything of value to a foreign official—a term defined broadly—to help the company obtain business or any other improper business advantage. This prohibition applies to direct payments as well as payments made through a third party.

In addition to prohibiting improper payments to foreign officials, the FCPA requires U.S. companies and their controlled affiliates to keep accurate books and records of transactions they have engaged in and to maintain a system of internal accounting controls that, among other things, prevent "slush funds" and unrecorded accounts that could be used to facilitate or conceal questionable foreign payments. The FCPA accounting requirements apply to all business activities, not only those involving foreign officials.

Penalties for violating the FCPA are severe. For a company, sanctions can include multi-million dollar fines, disgorgement of profits derived from an improper payment, suspension of export privileges, or ineligibility to bid for U.S. government contracts. These penalties come in addition to potential reputational damage and the costs of investigation and legal defense, which can arise even without a government prosecution. Penalties for individuals can be even more severe, including substantial fines and imprisonment.

Frequently asked questions about the FCPA

When does the FCPA bribery prohibition apply?

The FCPA's bribery prohibition applies to improper payments made by a "U.S. person" anywhere in the world, regardless of any other connection to the United States. The term "U.S. person" includes U.S. companies as well as individuals who are U.S. citizens or lawful permanent residents. Foreign nationals can also be prosecuted for causing, directly or through a third party, any act in the United States that furthers a corrupt payment. This applies to all EasyShop employees and affiliates.

What does the FCPA prohibit?

The FCPA makes it illegal to bribe a foreign official to obtain an "improper business advantage." An improper business advantage can involve efforts to obtain or retain business, such as winning a government contract, but can also involve regulatory measures like obtaining licenses or approvals. Examples of prohibited regulatory bribery include paying a foreign official to ignore an applicable customs requirement or to expedite a tax refund.

The FCPA's bribery prohibition has been interpreted broadly. A violation can occur even if only an offer or promise of an improper payment is made (even if no payment is ever made), if a payment is made but does not achieve the expected result, or if the payment benefits a third party rather than the person who made the bribe (for example, generating business for another party). It makes no difference whether the foreign official solicited or demanded a bribe, or whether the company believes it is entitled to the governmental action. Although limited exceptions may apply, one should never rely on them without seeking expert guidance.

Who is considered a "foreign official"?

For FCPA purposes, a "foreign official" is anyone who exercises government authority. This includes any official or employee of a government department or agency—executive, legislative or judicial—at the national, state or local level. It also includes officials and employees of government-owned or government-controlled entities, private individuals acting in an official capacity for a government, political parties and their candidates, and officials of public international organizations such as the United Nations.

A person's status as a foreign official will often be apparent, but not always. Personnel involved in international activities are responsible under this Policy to investigate whether a particular activity could involve a foreign official or a government-owned or -controlled entity, and should consult with Executive Management when questions arise about any individual's status.

What types of payments are prohibited?

The FCPA prohibits offering, promising, or delivering "anything of value" to foreign officials for the purpose of obtaining an improper business advantage. Beyond cash payments, "anything of value" may include:

  • Gifts, entertainment or other business promotional activities.
  • Paying or reimbursing an official's expenses.
  • Offering jobs or other benefits to a foreign official's family or friends.
  • Making contributions to political parties or candidates.
  • Making charitable donations and sponsorships.

Less obvious forms of bribery also qualify as FCPA violations. Examples include in-kind contributions, investment opportunities, stock or joint business positions, and preferential or controlled subcontracting.

Is there any permissible activity?

The FCPA does not prohibit reasonable promotional activities or other legitimate business activities, including bona fide charitable donations or sponsorships. However, special care must be taken when foreign officials are involved in such activities to avoid any appearance that benefits are being offered to improperly influence their official duties.

Please contact Executive Management for guidance regarding foreign officials and (a) customary gifts, meals and entertainment; (b) promotional expenses such as travel and entertainment reimbursement; (c) contributions to political parties and candidates; and (d) charitable donations and sponsorships.

Third-Party Responsibility

EasyShop can be held responsible for improper payments made by third parties. The FCPA applies whether a bribe is made directly or through an agent, consultant or other intermediary. Under the law, EasyShop and the individuals involved can be held liable for improper payments made by an agent or other intermediary if there is knowledge that a bribe would be paid.

Willful blindness—including failing to conduct appropriate inquiry when circumstances are suspicious—does not constitute a valid defense. Therefore, all employees must remain alert to potential "red flags" in dealings with third parties.

Working with Agents and Other Third Parties

Occasionally EasyShop may require the services of an agent, consultant or other intermediary to support its business activities. These relationships are important but can also present compliance challenges and require appropriate measures to prevent bribery.

Guidance for selecting and managing agents may include (a) risk assessment, (b) third-party due diligence procedures, (c) bribery "red flag" checks, (d) necessary contractual provisions, (e) monitoring and audit, and (f) documentation. Hiring requires prior approval from an appropriate senior director and a written contract.

Employee Responsibilities

All officers, employees and agents are responsible for understanding and complying with the policy. Each employee must:

  • Familiarize themselves with the policy provisions relevant to their duties.
  • Seek guidance where the policy or required actions are unclear.
  • Properly manage and monitor third-party business activities.
  • Be alert to indicators or evidence of potential violations.
  • Promptly report any violations or potential violations through the appropriate channels.

Reporting Suspected Violations

Any employee who has reason to believe a violation of this policy has occurred or may occur must report that information to their supervisor, the next level manager, or Executive Management.

As an alternative resource, employees may report confidentially by calling the U.S. hotline at (305) 592-5534 (Ext. 102).

Retaliation of any kind against an employee who, in good faith, reports a violation or possible violation of this policy is strictly prohibited.

Last updated: March 24, 2026

This Policy may be modified at any time. We recommend reviewing periodically.