Traackr, Inc. (“we”, “us” or “our”) respects your privacy and is committed to protecting your Personal Data.
This privacy notice sets out the basis on which any Personal Data we collect from you, or that you provide to us, through www.traackr.com and any sub-domain thereof (“our website”), will be processed by us in accordance with applicable Data Protection Laws. Please read the following carefully to understand our views and practices regarding your Personal Data and how we will treat it.
Our website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
When your affiliated organization signs up to use our Platform, we may receive Personal Data about you directly from your affiliated organization, which will only be used as necessary to provide the Platform to your affiliated organization and to you and as otherwise specified in this privacy notice. We will act as a ‘processor’ on behalf of your affiliated organization in respect of that Personal Data. Your affiliated organization will act as a ‘controller’ in respect of that Personal Data and is responsible for obtaining all necessary consents and providing you with all requisite information as required by applicable Data Protection Laws (as defined below).
In this privacy notice the following words and phrases shall have the following meanings:
“Applicable Law” means (a) any law, statute, regulation, bylaw or subordinate legislation in force from time to time to which we are subject; (b) the common law and laws of equity as applicable to us from time to time; (c) any court order, judgment or decree which is binding on us; (d) any industry code, policy or standard which is applicable to us; (e) any applicable direction, policy, rule or order that is binding on us and that is made or given by any regulatory body having jurisdiction over us;
“Data Protection Laws” means any Applicable Law relating to the processing, privacy, and use of Personal Data, including but not restricted to (a) the General Data Protection Regulation (EU) 2016/679 (GDPR) and (b) any judicial or administrative interpretation of any such Applicable Law, and any guidance, guidelines, codes of practice, approved codes of conduct or approved certification mechanisms issued by any relevant regulatory or supervisory authority;
“Data” means information which is stored electronically, on a computer, or in certain paper-based filing systems;
“Personal Data” means any information relating to an identified or identifiable natural person (a “Data Subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person and where referred to in this notice includes special categories of Personal Data; and
“Platform” means our Influencer Relationship Management Platform.
Traackr, Inc. is a company based in the United States of America. Our main office is at 244 California Street, Suite 204 San Francisco, CA 94111, United States of America. We have developed and manage our market-research database and our Platform, which allow users to manage, expand, validate and scale their networks with influencers.
We will collect and process the following Data about you:
This is information about you that you give us when you correspond with us by telephone, e-mail or otherwise, including when you report a problem with our website. The information you give us may include your name, address, e-mail address and social media username (or ‘handle’).
With regard to each of your visits to our website we will automatically collect, or will collect through a third party acting on our behalf, the following information:
We are working closely with, and receive Personal Data from, third parties (such as business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers and credit reference agencies). For further details about these other sources please contact us using the details provided below.
We will only use your Personal Data to the extent that the law allows us to do so. Most commonly, we will use your Personal Data in the following circumstances:
We use information held about you as set out below:
We will use this information when you:
We will use this information:
We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).
7.1 You agree that we have the right to share your Personal Data with selected third parties including business partners, suppliers and sub-contractors in connection with our business, including without limitation to allow us to provide access to our website. Without limitation of the foregoing, we may share your Personal Data with professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
7.2 In addition to the above, we may disclose your Personal Data to third parties in the following ways:
In addition to the above, third parties may directly collect personally identifiable and non-personally identifiable information about our users’ online activities over time and across different websites.
8.1 Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your Data transmitted through out website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
8.2 Our external third party providers may be based outside the European Economic Area (EEA) so their processing of your Personal Data will involve a transfer of Data outside the EEA.
8.3 Whenever we transfer your Personal Data out of the EEA, we ensure a similar degree of protection is afforded to it. Where we use certain service providers, we may use specific contracts approved by the European Commission which give Personal Data the same protection it has in the EEA under the GDPR. If we rely on another basis to transfer your Personal Data outside of the EEA (such as your consent), we will keep you updated or contact you as required.
8.4 Please contact us if you want further information on the specific mechanism used by us when transferring your Personal Data out of the EEA.
Our website, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any Personal Data to these websites.
10.1 We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality.
10.2 We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
11.1 We will only retain your Personal Data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
11.2 To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.
You have the right to:
In order to exercise any of your rights please contact us using the contact details provided in section 20 of this notice.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
If you have any complaints about the way in which we process your Personal Data please do contact us, as set out below. Alternatively you have the right to lodge a formal complaint with your data protection supervisory authority.
17.1 We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
17.2 If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
17.3 Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
The term “Do Not Track” refers to a HTTP header offered by certain web browsers to request that websites refrain from tracking the user. We take no action in response to Do Not Track requests.
Any changes we make to our privacy notice in the future will be posted to this section of our website and, where appropriate, notified to you by e-mail. We will not make changes that result in significant additional uses or disclosures of your personally identifiable information without allowing you to ‘opt in’ to such changes. We may also make non-significant changes to this privacy notice that generally will not significantly affect our use of your personally identifiable information, for which your opt-in is not required. Please check back frequently to see any updates or changes to our privacy notice.
Questions, comments and requests regarding this privacy notice are welcomed and should be addressed to our compliance team using the following email address: email@example.com.
Effective as of May 25, 2018. Last updated on July 10, 2018.