Date of last revision: January 20, 2020
At Redtrack Technologies Ltd, we are committed to respect the privacy choices of our clients and Website visitors.
You will also find below the important information about your rights in relation to your personal data, so please read the policy carefully.
Redtrack Technologies Ltd (“Redtrack Technologies”, “us”, or “we”) acts as controller of your personal data. Company registration number HE 397054, with its address Spyrou Kyprianou, 38CCS BUILDING, 2nd floor, Kato Polemidia, 4154, Limassol, Cyprus,, email firstname.lastname@example.org.
By accessing the Website or using our Services, you become subject to this Policy. Your acceptance of the terms of this Policy, in their entirety, shall be effective to your employees, if any.
1. WHAT INFORMATION WE COLLECT AND HOW WE USE IT
“Personal data ” is any information relating to natural person, who can be identified directly or indirectly.
We collect the following personal data about you:
1.1. Information we use to provide services
Contact Information. When you register / sign up for the Services, we may collect certain contact information from you, such as your first name, email address, or other similar contact details to help you with your experience.
Billing Information. When purchasing Services, you will be required to provide additional information that may include first and last name, organization name, city, state and zip code, phone number, a credit card number or other banking or payment information. This information is required by us to verify your identity, to establish your company’s account, and set up your Services.
Service Information. In order to provide Services to you and to improve our Services, we may collect information that is created or provided by you in connection with your use of the Services, including order information, chat logs, email logs and information about your actions in various client areas on the Website.
Third Party Information. We may obtain information about you from other open sources, like LinkedIN / Facebook / Telegram and add it to your account Contact Information. This combined information may be used by us to enhance our ability to provide Services to you.
We will use your Contact Information and Billing Information to provide Services and to provide you with access to the Services you have ordered, as well as support services, technical updates or updates on changes in our usage policies. The legal basis for us to use your Contact Information, Billing Information and Service Information is the agreements you enter into with us in connection with the Services (the “Services Terms”).
1.2. Use of information for direct marketing
We may also use your name, address, email to send you company updates and marketing offers about Services you use or similar services which we provide. You may opt out of receiving such communication by pressing unsubscribe at the end of the message or sending an email to us (see Section 9).
We may use any information collected from you:
- to personalize user’s experience;
- to improve our Service in order to better serve you and/or to provide Services more effectively;
- to allow us to better service you in responding to your customer service requests,
- to ensure continuous improvement and development of the Services;
- to administer the Website and to diagnose possible problems;
- to administer a contest, promotion, survey or other Website feature;
- to send periodic emails regarding your orders or your use of services.
We use Service Information to market our Services to you in a more personalized manner and to allow us to deliver the type of content and product offerings in which you are most interested, to advertise or market our business, and to tailor offers, promotions, etc.
Legal basis for such processing is our legitimate interests to increase our sales.
When you give consent, we may also provide you, even if you are not a client, with the offers and marketing communication of our partners, or our Services which are not similar to those you use. You can freely decide whether to provide consent or not. No negative consequences shall arise due to your refusal to provide such consent.
1.3. Browsing information and cookies
“Cookies” are small files that the Website or its service provider transfers (if you allow) to your computer’s hard drive through your Web browser that enables the Website’s or service provider’s systems to recognize your browser and capture and remember certain information.
We use Local Storage (HTML5), and our third party utility partner uses Local Shared Objects (Flash cookies) and Local Storage (HTML5) to store content information and preferences, and to display advertising based on your web browsing activity. Various browsers may offer their own management tools for removing HTML5.
You may set your browser to notify you or decline the receipt of Cookies; however, certain features of our Website or Services may not function properly or be available if your browser is configured to disable Cookies.
1.4. Tracking Technologies on our Website
Facebook Social Plugins
This website uses social plugins (“plugins”) from the social network facebook.com which is operated by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA (“Facebook”). The plugins are identified by one of the Facebook logos or the amendment “Facebook social plugin”. The list and the look of the Facebook social plugins can be viewed here: https://developers.facebook.com/docs/plugins/.
If you are a Facebook member and do not want Facebook to collect data on you via our website and to combine such data with your Facebook membership data, you need to log off from Facebook before accessing our website. Furthermore, you may also block social plugins by downloading and installing add-ons for your browser, such as the Facebook blocker: http://webgraph.com/resources/facebookblocker/
We use Lucky orange to visually analyze selected cases of RedTrack.io users interacting with our web-site and application. This data is used to improve RedTrack.io usability and your user experience.
We use Mailerlite to deliver you e-mail messages, including updates, onboarding e-mails, notifications, etc.
2. TO WHOM WE DISCLOSE YOUR PERSONAL DATA
2.1. We use third-party suppliers/vendors to perform the following business-related functions: data storage services, database maintenance services and payment processing. There suppliers and vendors may receive or have access to your personal data. When we employ such third party suppliers/vendors to perform services on our behalf, we will only provide them with access to personal data that they need to perform their specific function. We will put our reasonable efforts that each third party supplier/vendor will be required by contract to keep such personal data confidential and not to use it for any purpose other than providing services to us.
2.2. We may share personal data with the owner of intellectual property rights to the Website and software used on it and to the extent needed to perform certain business-related functions (e.g. updates, maintenance, support, etc.) for the purpose of providing Services to you.
2.3. We may share personal data with entities that are controlled by or under common control with Redtrack Technologies (each, an “Affiliate”) for the purpose of assisting Redtrack Technologies in providing its Services to you. In that event, any such Affiliate will use personal data solely as permitted under this Policy.
2.4. We may disclose personal data to public authorities if required to do so by law or to comply with a legal obligation. If we are requested by law to disclose any of your personal data, we will use reasonable efforts to provide you with notice of that disclosure requirement, unless we are prohibited from doing so by statute, court or administrative order.
2.5. We reserve the right to sell, assign or transfer our business or assets. In any such event or similar event, including but not limiting to a corporate sale, merger, reorganization, dissolution, etc., personal data may be part of the transferred assets. You acknowledge that such transfers may occur and that any acquirer or successor of Redtrack Technologies may continue to use your personal data as set forth in this Policy.
2.6. Our employees have access to your personal data only to the extent their functions are required to provide our service or otherwise act on our behalf as set forth in this Policy.
3. DATA STORAGE PERIOD
personal data will be stored for as long as the personal data is required to provide Services or requested Website functionality or until (if) consent is withdrawn or other data subject’s rights are exercised. In some cases, personal data may be stored for a period longer than indicated or despite the withdrawal of consent or request to erase personal data, if the storage of personal data is required in order to protect our or third parties’ legitimate interests.
We will retain your information for as long as is necessary to provide you with the services that you have requested from us or for as long as we reasonably require to retain the information for our lawful business purposes (such as for the purposes of exercising our legal rights), or for as long as the law otherwise permits.
We operate a data retention policy and look to find ways to reduce the amount of information we hold about you and the length of time that we need to keep it.
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.
4. YOUR RIGHTS
Redtrack Technologies will respect your legal rights to your data. Below is the list of your rights that you have under the law, and what we do to protect those rights:
4.1 The right to be informed.
4.2 The right of access
You have the right to access your Information. You have the right to request a copy of your data that we hold about you by contacting us.
4.3 The right to rectification
Redtrack Technologies encourages you to contact us if any of your personal data is not accurate or not complete so that we can keep your personal data up-to-date.
4.4 The right to be forgotten
In some circumstances you have the right to the erasure of your data without undue delay, specifically when:
- the data is no longer necessary in relation to the purposes for which they were collected or otherwise processed;
- you withdraw consent to consent-based processing;
- the processing is for direct marketing purposes; and the data has been unlawfully processed.
There are certain general exclusions of the right to be forgotten, specifically, processing is necessary for
- exercising the right of freedom of expression and information;
- compliance with a legal obligation;
- the establishment, exercise or defense of legal claims.
4.5 The right to restriction processing
You have the right to restrict the processing of your data when
- you contest the accuracy of the data;
- processing is unlawful but you oppose erasure;
- we no longer need the data for the purposes of our processing, but you require data for the establishment, exercise or defense of legal claims;
- you have objected to processing, pending the verification of that objection.
Where processing has been restricted on this basis, we may continue to store your data. However, we will only otherwise process it:
- with your consent;
- for the establishment, exercise or defense of legal claims;
- for the protection of the rights of another natural or legal person;
- for reasons of important public interest.
4.6 The right to data portability
Redtrack Technologies must allow you to obtain and reuse your personal data for your own purposes across Services in a safe and secure way without it affecting the usability of your data. This right only applies to personal data that you have provided to us as the data Controller.
The data must be held by us by consent or for the performance of a contract and the processing is carried out by automated means.
4.7 The right to object
In certain circumstances, you have the right to object to the processing of your personal data where, for example, your personal data is being processed on the basis of legitimate interests and there is no overriding legitimate interest for us to continue to process your personal data , or if your data is being processed for direct marketing purposes.
4.8 The right to withdraw consent
You have the right to withdraw your consent at any time, and Redtrack Technologies has to stop processing your data unless we have other Legal Ground for processing of your data. The withdrawal of consent does not affect the compliance of the processing which was made on its basis before the withdrawal of consent.
4.9 The right to complain to a Supervisory Authority
You have the right to lodge a complaint with the Supervisory Authority in particular if you feel that Redtrack Technologies has not responded to your requests to solve a problem. See section 9.5. for details
We maintain industry-standard physical, electronic and procedural safeguards designed to protect data in our possession from loss, misuse, and unauthorized access. When we transmit highly confidential information (such as a credit card number) over the Internet, we protect it through the use of encryption, such as the Secure Socket Layer (SSL) protocol.
We operate a policy of “privacy by design” by looking for opportunities to minimize the amount of personal information we hold about you. We use appropriate technological and operational security measures to protect your information against any unauthorized access or unlawful use, such as:
- ensuring the physical security of our offices, or other sites;
- ensuring the physical and digital security of our equipment and devices by using appropriate password protection and encryption;
- maintaining an internal data protection policy for, and delivering data protection training to, our employees; and
- limiting access to your personal information to those in our company who need to use it in the course of their work.
However, no method of transmission or method of electronic storage is 100% secure. We regularly test and update our technology to help protect your data. However, such precautions do not guarantee that our Website or the data stored during your use of the Services is invulnerable to hacking and will not be subject to a security breach. We make no warranty, guarantee, or representation that the Website or the Services are or will be protected from all viruses, security threats or other vulnerabilities or that your information will always be secure.
6. LINKS TO OTHER SITES
For the convenience of our visitors and clients, the Website may contain links to other sites, such as those of our partners or vendors, which are subject to different privacy policies. The Policy will not apply to your use of other websites. While we generally try to link only to sites that share similar high standards and respect for privacy, we have no responsibility or liability for the content, products or services offered, independent actions, or the privacy and security practices employed by these other independent sites. We encourage you to ask questions and review the applicable privacy policies found on such other websites, services and applications to understand how your information may be collected and used on these independent sites before disclosing information to third parties.
7. SOCIAL MEDIA AND WIDGETS
We will never knowingly collect any personal data and personal information about individuals under eighteen (18) years of age. IfRedtrack Technologies obtains actual knowledge that it has collected personal information about an individual under eighteen (18) years of age, that information will be immediately deleted from our platform.
9. YOUR RIGHTS, QUESTIONS, AND COMPLAINTS
9.1. You have a right to request rectification of personal data in our database (including Contact and Billing Information that you have provided to us) by contacting us at email@example.com. If you delete personal data or it is erased under your request, we will only retain such copies of the information as are necessary for us to protect our or third parties’ legitimate interests, comply with governmental orders, resolve disputes, troubleshoot problems, or enforce any agreement you have entered into with us.
9.2. In certain cases, you may have a right to restrict processing of your personal data or to object to the processing of your personal data. These rights can be exercised by contacting us at firstname.lastname@example.org
9.3. In cases where processing of personal data is based on your consent, you have the right to refuse and revoke consent to the processing of your personal data by contacting us at email@example.com. Upon termination of processing of your personal data it can be difficult or impossible to provide Services to you
9.4. You can request information about all personal data we have stored about you by contacting us at firstname.lastname@example.org. By contacting us at the aforementioned address, you may also exercise your right to data portability.
9.5. If you have any questions, concerns or complaints regarding the way we collect and handle your information, please contact us by email at email@example.com or Redtrack Technologies Ltd, registration number HE 397054, with its address Spyrou Kyprianou, 38CCS BUILDING, 2nd floor, Kato Polemidia, 4154, Limassol, Cyprus. If you are unsatisfied with processing of your personal data or our handling of your complaints, you have a right to approach a supervisory authority – The Commissioner for personal data protection, at http://www.dataprotection.gov.cy
9.6. Our data protection officer can be contacted by email at firstname.lastname@example.org