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1. ACKNOWLEDGMENT OF THIS POLICY
By installing, accessing and/or using our application or interacting with our services you agree to the collection and use of your information in accordance with the terms of this privacy policy, please read the following carefully to understand our practices regarding your personal data and how we will treat it. If you do not agree to this privacy policy, please uninstall or do not install, access or use our application or services.
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2. INTRODUCTION
This privacy policy describes how TRACKINFO (“we”, “us”, “our” or “TRACKINFO”) collect, use, process and share personal information about you, in accordance with data protection and privacy laws and regulations applicable to us or to our processing of your personal information (“Data Protection Legislation”). This privacy policy applies to all of the applications we have developed, whether used on mobile devices or other platforms. It also applies to our marketing and advertising activities on all devices and platforms and other services we offer in relation to the applications from time to time. In this privacy policy we refer to our applications and our related a products or services as “Services”.
This privacy policy together with any additional terms of use incorporated by reference in the Terms of Use applies to your use of the Services. Terms of use are available here.
This privacy policy will help you understand what personal data we collect from you or your devices when using the Services; how we use and share that personal data; and how you can exercise your privacy rights. If you have any questions about this privacy policy, please contact us using the information in Section 14 below.
We keep our privacy policy under regular review. If we make changes to this privacy policy, we will change the “Last Updated” date above and post the revised privacy policy. The new privacy policy may be displayed on-screen and you may be required to read and accept the changes to access our Services. -
3. ABOUT US
TRACKINFO is a private company registered in France with company number 753046598000. Our registered office is at 49 Impasse du Haras, 33190 Lamothe-Landerron, France. For the purpose of the Data Protection legislation and this policy, we are the “data controller” which means that we are responsible for deciding how we hold and use personal information about you.
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4. PARENTS & CHILDREN
Our Services are designed for users 18 and above. If our Services are not categorised as Family Friendly, the Services are not intended for or directed at, children and we do not knowingly or intentionally collect or process data relating to any such children who may be using the Services.
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5. INFORMATION THAT WE COLLECT OR RECEIVE
We collect and receive information from and about you by different means as described below.
Information provided by you.
We collect the following information if provided by you:
• Username
• Email address
• Data input necessary for the use of the applications (e.g. you have the possibility of allowing access to your camera & photo album) Information input
• Your Contacts: Contacts and links We will collect and process information about you which you provide to us when you contact us by email, telephone, post or social media in relation to the Services such as for the purposes of customer support, completing a survey or entering a competition. If you submit an enquiry to us then, depending on the nature of your enquiry, we may collect further details from you so as to understand the context in which you are making the enquiry and/or to understand which of our Services may be of interest to you.This information may include the following:
• Identity Data: Includes your personal details such as your name, address and other contact details;
• Communication Data: Includes details of any contact we have had with you in relation to the provision, or the proposed provision, of our Services; our correspondence and communications with you; information about any complaints and enquiries you may have submitted to us;
• Service Data: Includes details of any Services you have received from us;
• Marketing: Includes information from any research or surveys conducted by us in which you may have participated; information from any marketing activities to which you may have responded or in which you may have participated;
• Public: Information we receive from other sources such as publicly available information.No special category data
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). We also do not collect any information about criminal convictions and offences. -
6. DELETING YOUR ACCOUNT PERMANENTLY
Right to Delete: You may submit a verifiable request for us to delete any personal information we have collected about you. To submit a request, please contact us using the information in section 15 below. We will confirm receipt of your request. We will provide a response within 45 calendar days, unless we need more time, in which case we will notify you. If we need additional information to verify your identity, we will contact you to request that information. If we are not able to verify your identity, we will deny your request to delete. If we deny your request, even if only in part, we will explain the reason in our response. In either case, we will maintain a record of your request and our response.
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7. HOW WE USE YOUR DATA
We will only use your personal information for certain specified reasons and only where we have a lawful basis to do so. The lawful bases are as follows:
• Contract: We may process your personal data for purposes necessary for the performance of our contract with you, or for steps preparatory to entering into a contract with you, and to comply with our legal obligations.
• Legitimate Interests: We may process your personal data for the purposes of our own legitimate interests provided that those interests do not override any of your own interests, rights and freedoms which require the protection of your personal data. This includes processing for marketing, business development, statistical and management purposes.
• Legal Obligation: We may process your personal data to meet our legal obligations under applicable.
• Consent: We may process your personal data for certain additional purposes with your consent, and in these limited circumstances where your consent is required for the processing of your personal data then (i) we will request such consent from you separately, and (ii) you have the right to withdraw your consent to processing for such specific purposes.
Please note that we may process your personal data on more than one lawful bases depending on the specific purpose for which we are using your personal data.Situations in which we will use your personal data
We may use the personal information we collect about you for:
• Services: make the Services available to you, including to operate the Services; to communicate with you about your access to and use of the Services; to respond to your enquiries; to fulfil your orders and requests; to provide troubleshooting and other technical support; for other customer service and support purposes; and to tailor content we send or display while you are using our Services (e.g., for your geographic area);
• Security and integrity of the Services: verify your identity; to detect and prevent fraud, cheating and unauthorised activities; to facilitate software updates; to secure our systems and the Services; to prevent hacking, cheats and spamming; to enforce the terms of the Terms of Use and other applicable terms; and to protect the rights and safety of our users;
• Development: analyse and improve our Services, including to better understand how you access and use the Services; to evaluate and improve the Services; to develop new applications, features, offerings and services; and for other internal research and analytical purposes.
• Marketing and Advertising: improve our advertising, marketing and promotions; to evaluate, measure and improve the effectiveness of our advertising campaigns; to contact you about our Services or our other products or information we think may interest you; and at times, to administer promotions and contests;
• Legal: defend our legal rights, including to manage and respond to actual and potential legal disputes and claims and to otherwise establish, defend or protect our rights or interests, including in the context of anticipated or actual litigation with users or third parties; and
• Compliance: conduct necessary auditing, reporting, corporate governance, and internal operations; and to comply with legal obligations, including as part of a judicial proceeding; to respond to a warrant, court order, or other legal process; or as part of an investigation or request, whether formal or informal, from law enforcement or a governmental authority.
If you refuse to provide us with certain information when requested, we may not be able to perform some or all of the Services. Alternatively, we may be unable to comply with our legal or regulatory obligations. We may also process your personal information without your knowledge or consent, in accordance with this notice, where we are legally required to do so. -
8. INFORMATION SHARING AND TRANSFERS
This section explains how we may share the information we collect with third parties.
Why might you share my personal information with third parties?
We will share your personal information with third parties where it is necessary to complete any transaction or to provide you with the Services you have requested.Which third-party service providers process my personal information?
“Third parties” includes third-party service providers. The following activities are carried out by third- party service providers: IT, server and data storage services, software development services, professional advisory services, online and mobile analytics and performance diagnostics services, marketing, advertising and campaign services and administration services.
All of our third-party service providers are required to take commercially reasonable and appropriate security measures to protect your personal information. We only permit our third-party service providers to process your personal data for specified purposes and in accordance with our instructions. The third parties we engage varies depending on the Services. -
9. TRANSFERRING INFORMATION OUTSIDE THE UNITED KINGDOM (UK)
9. TRANSFERRING INFORMATION OUTSIDE THE UNITED KINGDOM (UK) The section applies if you live in the UK.
When information we control is transferred or transmitted to, or stored and processed outside the UK, for example in the United States or third countries outside the UK, we ensure that a similar degree of protection is afforded to it by relying on the following transfer safe guarding mechanisms:
• Adequacy Decisions: We may transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the UK Secretary of State; and
• Standard Contractual Clauses: Where we use certain service providers, we may use specific contracts approved by the UK Secretary of State which provide appropriate safeguards for personal data; and -
10. TRANSFERRING INFORMATION OUTSIDE THE EUROPEAN ECONOMIC AREA (EEA)
The section applies if you live in the EEA.
When information we control is transferred or transmitted to, or stored and processed outside the EEA, for example to the UK, United States or third countries outside the EEA, we ensure that a similar degree of protection is afforded to it by relying on the following transfer safe-guarding mechanisms:
• Adequacy Decisions: We may transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; and
• Standard Contractual Clauses: Where we use certain service providers, we may use specific contracts approved by the European Commission which provide appropriate safeguards for personal data. -
11. DATA RETENTION
We will only retain your personal data for as long as is necessary to fulfil the purposes for which it is collected. When assessing what retention period is appropriate for your personal data, we take into consideration:
• our requirements;
• the purposes for which we originally collected the personal data;
• the lawful grounds on which we based our processing;
• the types of personal data we have collected; the amount and categories of your personal data; and
• whether the purpose of the processing could reasonably be fulfilled by other means. In some circumstances (for example when we collect statistical data about users’ actions and patterns when using particular Services) we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
In some circumstances you can also ask us to delete your data: see below for further information. -
12. YOUR PRIVACY RIGHTS
Under certain circumstances by law, you have the right to:
• Request access to your personal data. This enables you to receive details of the personal information we hold about you and to check that we are processing it lawfully.
• Request correction of the personal data we hold about you. You may ask us to correct personal data we hold about you if it is inaccurate or incomplete.
• Request erasure of your personal data. In some circumstances, such as where we no longer need it or if you withdraw your consent (where applicable), you may ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).
• Request the restriction processing of your personal data. You may ask us to suspend the processing of your personal data in certain circumstances, such as where you contest the accuracy of the data or object to our use or stated legal basis.
• Object to our processing of your personal data. Where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
• Request the transfer of your personal information to another party.
• Withdraw your consent. If your personal data is processed based on your consent, you have the right to withdraw that consent at any time, in which case we must stop processing the data unless we have another legitimate basis for process for doing so in law. You may also ask us to explain the consequences of denying or withdrawing your consent.
If you wish to exercise any of the above rights, please contact us using the information in section 14 below.
You will not usually have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it. -
13. CALIFORNIA CONSUMERS’ RIGHTS
If you are a resident of California you have the following additional rights set out in this section.
CALIFORNIA SHINE THE LIGHT LAW
California residents may request information from us concerning any disclosures of personal data we may have made in the prior calendar year to third parties for their own direct marketing purposes. If you are a California resident and you wish to request information about our compliance with this law or our privacy practices, please write us using the information in section 15 below and specify that you are making a “California Shine the Light” request.CATEGORIES OF PERSONAL INFORMATION SOLD OR DISCLOSED
In the last 12 months, we have not sold, rented, released, disclosed, disseminated, made available, transferred, or otherwise communicated your personal information to another business or third party for monetary or other valuable consideration.RIGHTS OF CALIFORNIA RESIDENTS
• Right to Know. If you are a California resident, you may submit, free of charge, but no more than twice in a 12 month period, a verifiable request for the following information:
• The specific pieces of personal information we have about you;
• The categories of personal information we collected, sold or disclosed for a business purpose about you within the last 12 months;
• The categories of sources from which the personal information was collected;
• The purposes for which the information was collected or sold; and
• The categories of third parties to which the information was sold, disclosed for a business purpose, or otherwise shared.
• If possible, we will provide this information to you in a readily usable format that allows transmission to another entity.
• To submit a request, please contact us using the information in section 14 below. We will let you know we received your request. We will provide a response within 45 calendar days, unless we need more time, in which case we will notify you. If we need additional information to verify your identity, we will contact you to request that information. If we are not able to verify your identity, we will deny your request, but if applicable, we will refer you to the applicable sections of this Policy that address our data collection and use practices. If we deny your request, even if only in part, we will explain the reason in our response.
• Right to Delete: You may submit a verifiable request for us to delete any personal information we have collected about you. To submit a request, please contact us using the information in section 14 below. We will confirm receipt of your request. We will provide a response within 45 calendar days, unless we need more time, in which case we will notify you. If we need additional information to verify your identity, we will contact you to request that information. If we are not able to verify your identity, we will deny your request to delete. If we deny your request, even if only in part, we will explain the reason in our response. In either case, we will maintain a record of your request and our response.
• Right to be Free from Discrimination: We may not discriminate against you because you have chosen to exercise your rights, including, for example, by denying you access to the Services or charging you different rates or prices for the same online services, unless that difference is reasonably related to the value provided by your data.
• Exercising Your Rights: To submit a verifiable request or to otherwise contact us for more information about how to exercise your rights, please follow the instructions above.
If you would like to designate an authorized agent to make a request on your behalf, you must (i) provide the agent signed permission to do so, (ii) provide proof of your identity, and (iii) directly confirm you provided the authorized agent permission to submit the request. If we do not receive the above, we will deny the request. -
14. NEVADA CONSUMERS’ RIGHTS
If you are a resident of Nevada this section applies.
Nevada law requires each business to establish an email address or other means by which Nevada consumers may submit requests directing the business not to sell certain kinds of personal information that the business has collected or will collect about the consumer. A sale under Nevada law is the exchange of certain kinds of personal information for monetary consideration by the business to a third party for the third party to license or sell the personal information to other third parties. If you are a Nevada consumer and wish to submit a request relating to our compliance with Nevada law, please contact us using the information in section 14 below. -
15. CONTACT US
We are happy to answer any questions you have about this Policy, address any complaints, or help you exercise your privacy rights.
Please contact us at: TRACKINFO, 49 Impasse du Haras, 33190 Lamothe-Landerron, France. TRACKINFO@ORANGE.FR
You also have the right to make a complaint to the Information Commissioner’s Office (ICO: www.ico.org.uk), the UK supervisory authority for data protection issues, at any time. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.