TrackGo Privacy Policy - Data Protection and Your Rights

1.1 This Privacy Policy governs the manner in which TrackGo.app website, mobile applications, services, devices and other software, any and all parent, subsidiary or associate company (the Site, "Owner") collects, uses, maintains and discloses information collected from users (each, a "User") of the TrackGo.app website. This privacy policy applies to the Site and all products and services offered by TrackGo (all references to 'we' 'us' and 'our' refer to TrackGo.app).

1.2 We are committed to protecting your privacy and complying with our data protection obligations under the Data Protection Act 2018 (the DPA 2018), the General Data Protection Regulation 2016/679 (the GDPR) and any other applicable UK legislation (together, Data Protection Law). We take your privacy seriously and want you to know about the Privacy Policy we have in place to protect your personal information. This Private Policy also applies through our services and products via mobile devices, either through mobile applications or mobile-optimized websites.

1.3 When you interact with us or use the Site, we act as the data controller of your personal data. This means that we are responsible for processing your personal data and deciding how to use it. This privacy and cookies notice explains the types of personal data we may collect about you when you interact with us, why we collect it, what we use it for and what rights you have over that data. Personal data is any information about an identifiable person. Processing is anything we do with your personal data, including using, storing, sharing and deleting it.

1.4 This notice was last updated on the date shown at the top. We may change this notice at any time by posting an updated version on the Site and will make reasonable efforts to bring any material changes to your attention. You may wish to check it before using the Site as any changes will be effective from the date that they are made.

By visiting our Site, you accept the practices described in this Privacy Policy:

3.1 We collect, store and use the types of personal data set out in the table at the end of this notice.

(i) Information you provide to us on the Websites or otherwise: Certain parts of our Websites may ask you to provide Personal Information voluntarily. For example, we may ask you to provide certain Personal Information (such as your name, contact details) in order to connect you to "rent-2-own" home ownership service providers, or otherwise submit inquiries to us. We may also collect Personal Information, such as your contact and feedback, when you take part in surveys, or through other business or marketing interactions we may have with you. You may choose to provide additional information when you communicate with us or otherwise interact with us, and we will keep copies of any such communications for our records and for marketing purposes.

The Personal Information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your Personal Information. We will also let you know prior to collection whether the provision of the Personal Information we are collecting is compulsory or may be provided on a voluntary basis and the consequences, if any, of not providing the information.

(ii) Information we collect automatically through the Websites: When you visit our Websites, we may also collect certain information automatically from your device. In some countries, including countries in the European Economic Area, this information may be considered Personal Information under applicable data protection laws.Specifically, the information we collect automatically may include your IP address, your operating system, your browser ID, your browsing activity, and other information about your system and connection and how you interact with our Websites and other websites. We may collect this information as a part of log files as well as through the use of cookies or other tracking technologies. Our use of cookies and other tracking technologies is discussed more below, and in more detail in our Cookie clause.

4.1 The purposes of processing The Data concerning the User is collected to allow the Owner to provide its Services, as well as for the following purposes: Contacting the User, Managing contacts and sending messages, Sending periodic emails, Analytics, Platform services and hosting, Heat mapping and session recording, Advertising, Content commenting, Interaction with external social networks and platforms, Remarketing and behavioural targeting, Commercial affiliation, User Registration and authentication.

Users can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the table at the end of this notice.

4.2 We profile our visitors and subscribers so that we can find out more information about their purchase preferences and market the most relevant products to them. To do this, we compile a profile of information on you which includes your age, gender, purchase history, pages you visit and how you respond to direct marketing communications.

4.3 Subject to paragraph 8.5, you have the right to object to profiling activities where these are carried out for the purposes of direct marketing, for our legitimate interests or for a task which is in the public interest.

5.1 We may sell, trade, or otherwise transfer to outside parties your personally identifiable information for the purpose of sending you marketing messages. We may also share your information with website hosting partners and other parties who assist us in operating our website, conducting our business, or servicing you, so long as those parties agree to keep this information confidential. We may also release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect ours or others' rights, property, or safety. We may share personal information with other trusted advertisers, third party marketers, our affiliated entities for their online and/or offline marketing programs. As a result, you may receive information on additional products, services and offers that may be of interest to you via email. When we share personal data, we do so in accordance with Data Protection law. We may share certain personal data:

5.1.1 with parties who provide products or services to us, such as, user analytics, email services, advertising, user notification and feedback functionality, delivery couriers, marketing companies who help us manage our communications with you, data insight companies etc;

5.1.2 with government or quasi-governmental organisations, law enforcement and other regulatory authorities or third parties when required or permitted by law, including but not limited to in response to court orders, for the prevention and detection of crime and to protect intellectual property and any other legal rights;

5.1.3 if the Company or part of the business is sold, transferred or integrated with another business, with our advisers, a prospective purchaser, a prospective purchaser’s advisers or the new owner of the Company to facilitate the process; and

5.2 We may also provide third parties with aggregated but anonymised information and analytics about our customers. Before we do so we will make sure that it does not identify you.

5.3 In some cases, when we share personal data, it will involve the transfer of that personal data to countries outside the EEA which have different data protection standards to those which apply in the EEA.

5.4 Where we transfer personal data outside the EEA we will ensure that there are adequate safeguards to protect your privacy rights under Data Protection Law.

6.1 We and our third-party service providers use cookies and similar technologies to collect information about, and relevant to, your usage of the Site. Cookies are small text files that are stored on your computer when you visit the Site. It is standard practice to use cookies to make your experience better when using a website.

6.2 We use the following categories of cookies and similar technologies on this Site:

6.2.1 Strictly necessary cookies: These cookies are essential to enable you to move around the Site and use its features. Without these cookies, services you have asked for (such as remembering your login details or the items you placed in your basket) cannot be provided.

6.2.2 Analytics cookies: These cookies collect information about how you use the Site, for instance which pages you go to most often, what searches you perform and if you get error messages from web pages. Information these cookies collect can be used to improve how the Site works.

6.2.3 Customization cookies: These cookies allow the Site to remember choices you make (such as your user name) and provide enhanced, more personal features. These cookies cannot track your browsing activity on other Sites.

6.2.4 Security cookies: These cookies form part of our security features, for example, by helping us detect malicious activity or violations of our terms of use.

6.2.5 Social media cookies: These cookies allow you to share your activity on the Site on social media such as Facebook and Twitter. These cookies are not within our control. Please refer to the privacy policies of the social networks in question for information regarding how their cookies work.

6.2.6 Targeting or advertising cookies, including Facebook Pixel: These cookies record your visit to the Site, the pages you have visited and the links you have followed. We use this information to make our Site and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose. We have the Facebook pixel installed. While the Facebook pixel does not collect any personally identifiable information (such as name and email address), it may be used to match up visitors to ProMarketScout.com to defined audience segments in the Facebook advertising tool, providing demographic and interests information regarding visitors to the site. The information the Facebook Pixel collects is used to customize ads on the Facebook platform for interest based advertising.

Facebook’s Privacy Policy

Facebook participates in the Webchoices opt-out tool

6.2.7 Analytics cookies, including Google Analytics and other analytics tracking solutions, to analyze the use of our website. Analytics tracking systems do not collect personally identifiable information (such as name and email address) on our site visitors. The information gathered includes browser type, IP address, URLs visited and location information. The data collected is used to create trending reports and to analyze behavior on the website with a goal to improve the user experience of the site as well as to improve the traffic of the site. You can opt out of Google Analytics using a browser extension that Google provides (see below).

Google’s Privacy Policy

Google Analytics Opt-out Browser Extension

6.3 When you visit the Site for the first time (and periodically after that), we will request your consent to the setting of all cookies other than strictly necessary cookies.

6.4 You can delete existing cookies and disable some or all types of cookies in future if you wish. To disable some or all types of cookies, you will have to change the settings on your browser. If you change your mind, you can enable cookies again at any time. Disabling cookies on your browser may stop the Site from working properly.

6.5 To find out more about cookies please visit www.allaboutcookies.org.

8.1 We respect your rights to privacy and will respond to requests for access or control over information about you in accordance with Data Protection Law. We may require you to verify your identity before we take any action.

8.2 Depending on the reason we have your personal data, you have a right to:

8.2.1 access the personal information we hold about you (commonly known as subject access);

8.2.2 request that we correct or complete personal information we hold about you that is inaccurate or incomplete;

8.2.3 request that we erase your personal information in some circumstances, or object to our processing it as detailed at paragraph 8.5;

8.2.4 restrict how we use your personal information, in certain circumstances;

8.2.5 request that we provide you with copies of your personal information in a machine-readable format or transfer it across different services; and

8.2.6 where we have asked for your consent to process your data, to withdraw this consent.

8.3 These rights are limited in some situations under Data Protection Law – for example, where we can demonstrate that we are under a legal obligation to process your data.

8.4 If you wish to exercise any of these rights, please contact us using the details in paragraph 2 above.

8.5 Your right to object

You have a right to object to our processing of your personal data and ask us to stop doing so. If we are processing your personal data or direct marketing purposes (which includes profiling to the extent that it is related to such direct marketing) and you object to this, we will stop processing your personal data immediately.

If our processing of your personal data is in the public interest or pursuant to our legitimate interests and you object to this, we will stop processing your personal data unless we have compelling reasons which override your interests, or our use of your personal data is for the establishment, exercise or defence of legal claims.

8.6 We hope that we can satisfy any queries you may have about the way we process your data. However, if you have unresolved concerns you also have the right to complain to the data protection authorities of the country of residence (in the UK, the Information Commissioner’s Office).

9.1 Your personal data will only be kept for as long as necessary for the purposes they have been collected for. Specific periods are set out in the table at the end of this notice. Therefore:

(i) Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.

(ii) Personal Data collected for the purposes of the Owner's legitimate interests shall be retained as long as needed to fulfil such purposes. Typically, our legitimate interests include improving, maintaining, providing, and enhancing our technology, products, and services; ensuring the security of the Services and our Websites; and for our marketing activities.

Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn.

Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority. Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

10.1 We process your personal data in accordance with the following principles:

10.1.1 we process your personal data lawfully, fairly and in a transparent way;

10.1.2 we collect your personal data for specified, explicit and legitimate purposes; any further processing we do is compatible with the original purposes for which for which we collected it;

10.1.3 we only process personal data which is adequate, relevant and limited to what is necessary to achieve the purpose for which it is processed;

10.1.4 we take reasonable steps to ensure that all personal data is accurate and kept up to date where necessary;

10.1.5 we do not store personal data in a form which identifies you for any longer than is necessary for the purposes of processing; and

10.1.6 we process personal data securely and in a way that protects against unauthorised or unlawful processing, accidental loss, destruction or damage.

10.2 When we ask for your personal data we will tell you whether you are required by law or contract to provide it, and what will happen if you do not provide the data.

10.3 Any request for consent to the processing of your personal data will be made directly to you and will include information about why we require the personal data and what will be done with it.

11.1 We will only process personal data when we have a lawful basis for doing that processing. The table at the end of this notice sets out the lawful basis we rely on for each type of data we process.

11.2 We will choose one of the lawful bases in the GDPR to justify how we use your personal data. These are:

11.2.1 Consent: You have given consent to the processing of your personal data for one or more specific purposes.

11.2.2 Contract: The processing is necessary for the performance of a contract with you or in order to take steps at your request before entering into a contract.

11.2.3 Legal obligation: We need to process your personal data to comply with a legal obligation.

11.2.4 Vital interests: The processing is necessary to protect the vital interests of you or another person.

11.2.5 Public interest: Processing is necessary for the performance of a task carried out in the public interest or in the exercise of some official authority.

11.2.6 Legitimate interests: Processing is necessary for the purposes of legitimate interests pursued by us or someone else, except where such interests are overridden by your interests or fundamental rights and freedoms requiring the protection of your personal data.

12.1 The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.We collect your email address in order to:

12.1.1 Send information, respond to inquiries, and/or other requests or questions.

12.1.2 Market to our mailing list or continue to send emails to our clients after the original transaction has occurred.

12.2 To be in accordance with CANSPAM we agree to the following:

12.2.1 NOT use false, or misleading subjects or email addresses.

12.2.2 Identify the message as an advertisement in some reasonable way.

12.2.3 Include the physical address of our business or site headquarters.

12.2.4 Monitor third party email marketing services for compliance, if one is used.

12.2.5 Honor opt-out/unsubscribe requests quickly and allow users to unsubscribe by using the link at the bottom of each email. if at any time you would like to unsubscribe from receiving future emails, you can contact us via the Contact Form. Otherwise, follow the instructions at the bottom of each email and we will promptly remove you from ALL correspondence.

Alipay SDK to authorize login via Alipay and account connection. This might involve collection of users’ device identification information.
Google Sign-In SDK to authorize login via Google account and account connection.This might involve collection of users’ device identification information.
Firebase SDK to push notifications, analyze and count the application errors. This might involve collection of users’ device identification information.
Yandex Mobile AdsSDK to place and manage ads in different formats in the app. This might involve collection of users’ device identification information.
Yandex AppMetrica SDK to analyze and count the application errors. This might involve collection of users’ device identification information.