Privacy Policy

 

Date of last revision: May 23, 2018

 

At Aditec Solutions, we are committed to respect the privacy choices of our clients and Website visitors.

 

This Privacy Policy (the “Policy”) describes how we use and to whom we disclose personal data that is collected by us or provided by you when you visit our website located at www.redtrack.io (the “Website”) or use our services (the «Services»).

 

You will also find below the important information about your rights in relation to your personal data, so please read the policy carefully.

Aditec Solutions UAB (“Aditec Solutions”, “us”, or “we”) acts as controller of your personal data. Company code is 304284444, address Gedimino ave. 20, Vilnius, Lithuania, phone +370-68-403156, email privacy@affise.com.

 

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:

 

 

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 may use Cookies, web beacons and other technical means to collect and analyze certain information about how you and other visitors use the Website. This technical information includes Internet Protocol (IP) addresses, browser information, and the preceding and succeeding websites you have visited, among other things. We may also keep a record of which pages of the Website you visit, and how long you spend on each page. Cookies can also be used to help us understand your preferences based on previous or current Website activity, which enables us to provide you with improved Services. We also use Cookies to help us compile aggregate data about site traffic and site interaction so that we can offer better Website experiences and tools in the future. We use Google Analytics for collecting website browsing statistics.

 

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.

 

Legal basis for use of cookies and other information stored on your devices is your consent, which you may freely refuse to give. To learn more about our cookie policy, please visit https://redtrack.io/cookie-policy/

 

1.4. Tracking Technologies on our Website

 

Google Analytics

 

In order to optimize this website, we use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses “cookies”, which are text files placed on your computer, to help the website analyze how you use this website. The information generated by the cookie about your use of this website (including your IP address) will be transmitted to and stored by Google on servers in the United States. If the IP anonymization is activated on this website, your IP address will previously be truncated by Google within the EU member states or EEA member states. Only in exceptional cases will the IP address be transferred to Google on a server in the United States and thereafter be truncated. On behalf of the website operator, Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. The IP address that was transmitted by your browser will not be combined by Google with any other data. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. You may also prevent the collection of the data that was generated by the cookie and that is related to the use of the website (including your IP address) as well as its processing by Google by downloading and installing a browser plugin that is available under the following link: http://tools.google.com/dlpage/gaoptout?hl=de. Additional information thereto is available at http://tools.google.com/dlpage/gaoptout?hl=de and http://www.google.com/intl/de/analytics/privacyoverview.html (general information to Google Analytics and privacy). This Website uses Google Analytics with its extension code “gat._anonymizeIp()“ so that IP addresses will therefore only be processed in a shortened form to prevent persons from being identified.

 

Google GDPR Compliance

 

Google AdWords

 

We as a Google AdWords customer also use Google Conversion Tracking, a web analytics service provided by Google, Inc. (“Google”). Google AdWords places a cookie in your browser (“Conversion Cookie”) if you have accessed our website via a Google ad. These cookies are valid for 30 days. If you access some of our sites and the cookie is still valid, we and Google can recognize that somebody has clicked on the ad and thereafter was transferred to our website. Every AdWords customers uses a different cookie, and therefore it is not possible to track cookies via the websites of AdWords customers. The information obtained via the Conversion Cookie is used in order to assemble conversion reports for AdWords customers. The AdWords customers receive the number of users that have clicked on their ad and have been transferred to a site that includes the Conversion Tracking Tag but they do not receive any information that would allow them to identify the user. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website.

 

Google GDPR compliance

 

LinkedIn

 

Our website includes include social media features, such as Linkedin button. This Feature may collect your IP address, which page you are visiting on our website, and may set Cookies to enable the Feature to function properly. Your interactions with this feature are governed by the privacy policy of the company providing it. See the LinkedIn Privacy Policy here https://www.linkedin.com/legal/privacy-policy.

 

LinkedIn GDPR Compliance

 

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 access a page on our website that includes such a social plugin, your browser sets up a direct connection to the Facebook servers. Facebook transfers the social plugin’s content directly to your browser which will then integrate it into the website. Therefore we have no influence on the extent of the data that Facebook collects via its social plugins, and thus, can only inform you based on our state of knowledge: Through integration of the plugin, Facebook obtains the information that you have accessed the respective page on our website, even if you are not a registered user of Facebook or are not logged into Facebook. This information as well as your browser’s IP address is transferred to Facebook’s server in the United States and is being stored there. According to Facebook, only anonymized IP addresses are stored from non-registered users in Germany. If you are logged in to Facebook, Facebook can allocate the visit to our website to your Facebook account. Facebook receives such information irrespective of whether you interact with the social plugins or not. If you do interact with the social plugins, e.g. by using the «Like-it-Button» or by posting a commentary, your browser will transfer such information directly to Facebook where it is being stored. Such information will also be published on Facebook and be displayed to your Facebook friends. For information on the purpose and extent of data collection, the further processing and use of such data by Facebook, as well as your rights in this regard and your setting options for the protection of your privacy, please refer to Facebook’s privacy policy: http://www.facebook.com/about/privacy

 

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/

 

Facebook GDPR Compliance

 

Lucky Orange

 

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.

 

Read more about Lucky Orange security and Lucky Orange GDPR compliance

 

Zendesk

 

We use Zendesk with the goal to improve communication with our cliens and make sense of massive amounts of data and documentations for Affise platform. Zendesk uses cookies and other information gathering technologies for a variety of purposes. These technologies may collect personal information, information about devices and networks you utilize to access their website. For detailed information about the use of cookies in their website, please read and review Zendesk Cookie Policy found here.

 

Zendesk GDPR Compliance

 

BrainTree

 

BrainTree is a PayPal service we use as a billing service for our customers at Affise. BrainTree collects information about you that you voluntarily provide to them when you: (i) contact them to learn more about Braintree, the Braintree Services, or other opportunities you indicate are of interest at the time; (ii) access or use the Braintree Service; or (iii) contact customer service. This information may include, for example, your name, mailing address, business name, and any other information that you choose to provide to them. This also includes technical data, such as IP addresses and device identifiers that are commonly generated in establishing a connection with the Braintree Services. See the BrainTree Privacy Policy here https://www.braintreepayments.com/en-cy/legal/braintree-privacy-policy.

 

BrainTree GDPR Compliance

 

MailerLite

 

We use Mailerlite to deliver you e-mail messages, including updates, onboarding e-mails, notifications, etc.

 

Read more about MailerLite Privacy Policy All emails we distribute through MailerLite contain unsubscribe link.

 

 

2. TO WHOM WE DISCLOSE YOUR PRSONAL 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 Aditec Solutions (each, an “Affiliate”) for the purpose of assisting Aditec Solutions 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 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 Aditec Solutions 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 withdrawal of consent or request to erase personal data , if 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

 

 

Aditec Solutions 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.

 

We are publishing this Privacy Policy and Cookies Policy to keep you informed of what we do with your Personal Information and to be transparent about how we use it .

 

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

 

Aditec Solutions 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:

 

 

There are certain general exclusions of the right to be forgotten, specifically processing is necessary for

 

 

4.5 The right to restriction processing

 

You have the right to restrict the processing of your data when

 

 

Where processing has been restricted on this basis, we may continue to store your data. However, we will only otherwise process it:

 

 

4.6 The right to data portability

 

Aditech Solutions 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 Aditech Solutions 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 Aditech Solutions has not responded to your requests to solve a problem. See section 9.5. for details

 

 

5.  SECURITY

 

 

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 minimise the amount of personal information we hold about you. We use appropriate technological and operational security measures to protect your information against any unauthorised access or unlawful use, such as:

  1. ensuring the physical security of our offices, or other sites;
  2. ensuring the physical and digital security of our equipment and devices by using appropriate password protection and encryption;
  3. maintaining an internal data protection policy for, and delivering data protection training to, our employees; and
  4. 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

 

 

Our Website includes and/or may include social media features and widgets, such as the Facebook, Twitter or Linkedin button (the “Features”). These Features may collect your IP address, which page you are visiting on our Website, and may set Cookies to enable the Feature to function properly. Features are either hosted by a third party or hosted directly on our Website. Your interactions with these Features are governed by the privacy policy of the company providing it. We undertake no responsibility and shall have no liability with respect to these Features.

 

 

8. MINORS

 

 

We will never knowingly collect any personal data  and personal information about individuals under eighteen (18) years of age. If Aditec Solutions 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 support@redtrack.io. 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 processing of your personal data . These rights can be exercised by contacting us at support@redtrack.io

 

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 support@redtrack.io. 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 support@redtrack.io. 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 support@redtrack.io or Aditec Solutions UAB, Gedimino pr. 20, Vilnius, the Republic of Lithuania. 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 – State data protection inspectorate, responsible for the supervision of data protection related matters in Lithuania, at www.ada.lt.

 

9.6. Our data protection officer can be contacted by email at privacy@redtrack.io

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