Privacy Policy

This Policy applies to our websites, products, services, software, or applications (“apps”) on which we post a direct link to this Policy or refer to within this Policy (collectively the “Services”). It does not apply to our job application and candidate websites and applications, for which a separate privacy policy applies.

We collect a variety of personal data through the means described below. You have choices about the personal data we collect. When you are asked to provide personal data to us, you may choose not to. But if you decline to provide personal data, your ability to use the applicable Services may be diminished or restricted.

We collect your name, email address(es), account name, password, mailing address(es), telephone number(s), company for which you work, and personal data which you otherwise intentionally send to us. We may also ask you to provide information about the product you are registering (e.g. a device identifier) or the person/company that installed or maintains it.

Personal data we automatically collect from our websites

When you visit one of our websites, we collect general data including some personal data from your computer or mobile device such as your browser type, operating system, IP address, the domain name from which you accessed the site, and your device type. We also collect data about how you use our websites, such as the date and time you visit the site, the areas or pages of the site that you visit, the amount of time you spend viewing the site, the number of times you return to the site, and other click-stream data. Please see our Cookies section for further information.

Personal data we collect from our Services

Our Services, including our software and apps, may collect personal data and other information from you, some of this information may be collected automatically. For example, we may collect the unique ID associated to your account, account name, location information, information about the Services you subscribe to and the software and applications you engage with, use, and how long you use them.

Third Party Sources and Links

Our website may contain links to third-party websites. Each of these third parties may have its own privacy policy. Clicking on those links or enabling those connections may allow third parties to collect or share personal data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

Children’s Privacy

Our Services are not directed at children under the age of 16. We do not intentionally or knowingly collect personally-identifiable information from children under 16. If you are under 16, please do not provide any personal data to us.

Cookies

We use cookies, web beacons, or similar technologies to collect data about your use of our Services. Cookies are small text files sent to and stored on users’ computers. We use cookies to help operate our sites and Services, including to: (a) remember you so you don’t have to enter the same information when you return to the site, (b) provide you with customized content or offers on the site; (c) develop aggregate statistics to help monitor site performance, conduct research, improve our content and Services, and (d) help protect the security of our sites and Services. If you do not want cookies to be accessible by this or any other Service, you should adjust the settings on your browser program to deny or disable the use of cookies. However, denying or disabling cookies or similar technology may prevent you from accessing some of our content or using some of the features on the Services.

Web Beacons

The Service may also use web beacons. A web beacon is usually a pixel on a website that can be used to track whether a user has visited a particular website to deliver targeted advertising. Web beacons are used in combination with cookies, which means that, if you turn off your browser’s cookies, the web beacons will not be able to track your activity. The web beacon will still count as a website visit, but your unique information will not be recorded. Information collected by web beacons may include IP address information.

IP Addresses

An Internet Protocol (IP) address is a number that is used by computers on the network to identify your computer every time you log on to the Internet. Trackonomy may collect and keep track of IP addresses to, among other things: (a) maintain Website safety and security, (b) restrict access to our Websites to certain users, (c) troubleshoot technical issues, and (d) better understand how the Service is used.

Log Files

Trackonomy (or third parties on behalf of Trackonomy) may collect information in the form of log files that are recording user activities and statistics about habits. Log files are used for internal purposes only. By using log files, Trackonomy can constantly improve and customize its Service.

We collect and process personal data about you with your consent (where required), and/or as necessary to provide the Services you use, authenticate you as a user and allow you access to certain parts of our Service, operate our business, meet our contractual and legal obligations, protect the security of our systems and our customers, to take steps to develop and grow our business.

The purposes for which we collect and use personal data include:

• To respond to the request that you sent us such as your request for information;
• To provide, manage, maintain, and secure the Services you request;
• To operate and improve our business, including to administer, protect, and improve our Services and our security of our systems, to develop new products and services, and for other internal business purposes;
• To help us to understand how you use and interact with our Services, compile aggregated statistics about usage of our Services, and help personalize your experience of our website and Services;
• Obtain your location data in order to provide requested information or services and to provide localized content;
• Respond to a legitimate legal request from law enforcement authorities or other government regulators;
• Protect against fraud or investigate suspected or actual illegal activity;
• Advertise and provide you with information about products, services, promotions and events relating to Trackonomy; and
• Any other use we describe in this Policy or at the point where we collect the personal data.
• To achieve these purposes, and to the extent permitted by applicable law, we may combine the various types of personal data that we collect from different sources.

We access your personal data with our affiliated companies, including our direct and indirect subsidiaries. We and our group companies share personal data with third party vendor or service providers, including data hosting providers and analytics providers, that process the data on our behalf for the purposes set forth in this Policy. We may also offer training or other services to the employees and workers of our business customers. In such cases, we may share personal data relating to the use of our training and other services with the identified business customers for their business use. We may also share your personal data with third parties such as professional advisors or banks and accountants, as permitted or required by law or in the interest of protecting or exercising our or others’ legal rights, e.g., without limitation, in connection with requests from law enforcement officials and in connection with court proceedings and with investigating suspected or actual activity in violation of our rights or the rights of others. We may share or transfer your personal data in connection with a prospective or actual sale, merger, transfer or other reorganization of all or parts of our business. Finally, we may also share your personal data where you have granted us permission.

Do Not Track

Do Not Track. We do not currently respond to “Do Not Track” (“DNT”) signals sent by web browsers. A uniform standard has not yet been adopted to determine how DNT signals should be interpreted and what actions should be taken by websites and third parties that receive them. However, you may use a variety of other means of controlling data collection and use, including cookie controls in your browser settings and the personalized advertising controls described in the Cookies section above.

Retention

We retain personal data while your account is active, as needed to provide you Services. We will, also, retain personal data as necessary to comply with our legal obligations, as legally permitted, resolve disputes, and enforce our agreements. We may retain your personal data for a reasonable period after you stopped using the Services, and after this period it may be deleted without notice to you.

Security

Trackonomy is committed to ensuring the security and integrity of personal data. Trackonomy has adopted reasonable physical, technical and administrative procedures to safeguard your personal data. However, due to the nature of Internet communications, we cannot guarantee or warrant that your transmission to us is secure. It is your responsibility to safeguard your passwords and User IDs and to notify us using one of the Contact methods listed below if you ever suspect that your password or User ID for one of our Services has been compromised. You are solely responsible for any unauthorized use of our Services conducted via your password and User ID.

Trackonomy may use the personal data you provide to contact you about products, services, promotions, special offers, surveys, and other information that may be of interest to you. If you prefer not to receive such communications, please use the “unsubscribe” function within the Services, or let us know by sending an email to privacy@trackonomysystems.com. Trackonomy will ensure that any marketing communications sent by electronic means will provide a simple method for you to opt-out or unsubscribe. Please note that if you unsubscribe from marketing communications, you may continue to receive communications about our account or transactions with us.

Trackonomy may use the personal data you provide to contact you about products, services, promotions, special offers, surveys, and other information that may be of interest to you. If you prefer not to receive such communications, please use the “unsubscribe” function within the Services, or let us know by sending an email to privacy@trackonomysystems.com. Trackonomy will ensure that any marketing communications sent by electronic means will provide a simple method for you to opt-out or unsubscribe. Please note that if you unsubscribe from marketing communications, you may continue to receive communications about our account or transactions with us.

Our Service is intended for visitors who are at least 18 years of age, or the age of majority in their jurisdiction of residence. Trackonomy does not knowingly solicit information from, or market products or services to, children. If you do not meet the age requirements set out above, please do not enter your personal data on this or any other Service.

This Privacy Policy is required by the California Consumer Privacy Act (“CCPA”). For purposes of this Privacy Policy, “consumer” or “you” means individuals who are in California for other than a temporary or transitory purpose, and individuals who are domiciled in California who are outside California for a temporary or transitory purpose (“California Residents”) and “we” or “us” means Trackonomy Systems, Inc. and our subsidiaries.

The purpose of this Privacy Policy is to provide consumers with a comprehensive description of our online and offline practices regarding the collection, use, disclosure, and sale of personal information and of the rights of consumers regarding their personal information.

You have the right to request that we disclose what personal information we collect, use, disclose, and sell.

Access

If you want to submit a verifiable consumer request under the CCPA, please email privacy@trackonomysystems.com.

Verification

We may need to verify your identification prior to providing any requested information or making any requested changes.

Right to Request Correction or Deletion of Personal Information

You may request to access, update, correct, change, or delete your personal data at any time. Trackonomy will use reasonable efforts to timely update and/or remove your personal data. To protect the user’s privacy and security, Trackonomy will take steps to verify the user’s identity before making any requested access or change. To access, update, correct, change, or delete your personal data, to ask questions or to raise concerns regarding data protection and privacy, send an email to privacy@trackonomysystems.com. When contacting us to exercise your rights, please put “California Privacy Rights” in the subject and body of your request and describe the nature of your request. Some of our Services may allow you to make corrections directly at the site without need to further contact Trackonomy.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

Requests to exercise rights under the CCPA are subject to verification by Trackonomy and are also subject to certain restrictions provided by the CCPA. We will not discriminate against California residents for exercising any of their applicable CCPA rights.

An authorized agent can make a request under the CCPA on your behalf. To designate an authorized agent, you must:

• Provide your authorized agent signed permission to make a request to know or request to delete;
• Verify your own identity directly with us; and
• Directly confirm with us that you provided the authorized agent permission to submit the request.

This process does not apply when you have provided your authorized agent with power of attorney pursuant to California Probate Code sections 4000 to 4465.

For our users based in the UK and the European Economic Area (“EEA“), the General Data Protection Regulation and UK General Data Protection Regulation (“GDPR“) will apply to our processing of your personal data.

Under GDPR we are required to have a “lawful basis” for processing your personal data. “Lawful basis” means we have a legitimate reason recognised by GDPR for processing your information and using it as we set out in this policy. Unless we are required to obtain your consent before processing your personal data (e.g., for the purpose of processing location data), we may rely on a legitimate business interest. Some legitimate reasons for this use of your personal data are:

• for the purpose of our contract with you and so that we can provide, manage, maintain and secure the Services you request;
  to fulfill our legitimate interest to operate and improve our business, including to administer, protect, and improve our Services and our systems, to develop new products and services, and for other internal business purposes;
• to fulfill our legitimate interest to better understand the preferences of the users of our Services, help us to understand how you use and interact with our Services, compile aggregated statistics about usage of our Services, and help personalize your experience of our website and Services;
• to send your marketing communications in our legitimate interests to develop and improve our business or with your consent (where required);

Where permitted in our legitimate interest or with your prior consent (where required by law) we will use your personal information for marketing analysis or to provide you with promotional update communications by email about our products, events, newsletters and services. You can change your preferences and object to receiving further marketing at any time by checking and updating your contact details within your account, or selecting the “unsubscribe” link at the end of all our marketing and promotional update communications to you, or by sending us an email to: privacy@trackonomysystems.com

You have the right under certain circumstances:

• to find out what information we hold about you;
• to be provided with a copy of your personal data;
• to request the correction or deletion of your personal data;
• to request that we restrict the processing of your personal data (while we verify or investigate your concerns with this information, for example);
• to object to the further processing of your personal data, including the right to object to marketing (as mentioned above);
• to request that your provided personal data be moved to a third party; or
  you may opt out at any time from allowing further access by us to your location data, however this may mean we cannot supply some services to you.

Your right to withdraw consent:

• Where the processing of your personal information by us is based on consent, you have the right to withdraw that consent without detriment at any time.

You can exercise the rights listed above at any time by contacting us using the information provided below. Your personal data may be transferred from the UK or the EEA to or accessed by us in the United States and other locations outside of the UK and EEA. Wherever we store or process personal data pursuant to this Policy, we take measures to ensure that the personal data is processed in accordance with this Policy and in compliance with applicable law.

If you have any concerns, you have the right to make a complaint to a personal data protection supervisory authority. If you are in the UK, the supervisory authority is the Information Commissioner’s Office (“ICO”). You can visit their webpage at www.ico.org.uk. If you are in the EEA, you can find your local data protection authority at https://edpb.europa.eu/about-edpb/about-edpb/members_en