Last updated: 19 May 2021
TracAce is committed to protecting your personal information and respecting data protection laws around the world. This privacy notice explains how we do this, and it applies to your use of our website and apps.
How we use your personal information
We use personal information in order to promote and provide our services, to ensure the security of our website and software, and to run our business. We have set out below more information on:
– the categories of personal information that we collect;
– the specific ways in which that personal information is processed by us;
– the legal bases which permit us to do this;
– the types of partners with whom we share your personal information; and
– your rights with respect to your personal data.
In some cases where we ask for your personal information, we do so in order to provide our services and will only collect and process any such personal information for the purposes which it is collected for and any other compatible purposes. If you do not provide that personal information, we may not be able to process your personal data where it is required for the purpose of providing our services or any other purpose communicated to you.
What personal information do we collect?
We collect and process different personal information and personal sensitive information according to the context in which you interact with us. This information includes:
|Type of interaction||Personal information collected|
|End-users of TracAce Explorer apps (Explorer End Users)||A unique device identifier associated with the device that you use to access the TracAce Explorer app; details of the operating system and device you use to access the TracAce Explorer app; your GPS location whilst you are using the Explorer app; your name and contact details if you provide them to use whilst you are using the Explorer app.|
|End-users of TracAce Race apps (Race End Users’)||Name; phone number; email address; a unique device identifier associated with the device that you use to access the TracAce Race app; details of the operating system and device you use to access the TracAce Race app; your GPS location whilst you are using the Race app.|
|TracAce clients who deploy our software for use by End Users (“Clients”)||Names and email addresses and other contact details of your staff with whom we engage; any payment details you provide to us. In addition, for Client staff who use our restricted client website andsoftware, we may process user login details; records of your use of our website, including pages accessed, time and duration of usage; information related to the browser or device you use to access our website, including IP address and related identifiers; and any information you provide to us through contact forms or live chats.|
|Individuals on our marketing database who aren’t our customers||Name; email address; telephone number; records of participation in our promotional campaigns; and your marketing preferences, including any consents you may have given us.|
|Applicants for job vacancies||We may process: any details provided in your job application, including name, address, email address, telephone number, education, employment history; and sensitive equality and diversity information such as race, social background, ethnic origin and sexual orientation.|
|Users of the public-facing TracAce website||We may process data about your use of our website and services which we obtain through our analytics tracking systems such as your IP address; geographical location; browser type and version; operating system; referral source; length of visit; page views and website navigation paths; and information about the timing, frequency and pattern of your service use. We may also process your name and contact details if you provide them to us through any forms on our website.|
We collect this information when you provide it to us directly, or from your interaction with our services.
Please note that for End Users of our apps, we endeavour to minimise the amount of personal data that we collect from you, and we keep the data anonymised wherever possible.
How do we use your information?
We use your information as follows:
– To fulfil a contract with End Users:
· providing access to our software to enable you to use it;
– To fulfil a contract with Clients:
· providing access to our software to enable you to use it
· providing information and technical support if you ask for this;
· contacting you with information about changes to our services;
· processing payments for our services and fraud prevention.
– As required by us to conduct our business and pursue our legitimate interests, in particular:
· giving our End Users and Clients access to our services;
· contacting End Users and Clients with regards to anything in connection with our services;
· providing dynamic content within our services, depending on how you use such services;
· letting you know about our services by post, email, and phone in accordance with your marketing preferences and law relating to direct marketing; ·
analysing how you use our services so we can improve our levels of service and develop future products and services, including through the use of surveys and research studies;
· ensuring the security of our website and information technology systems and protecting our rights; and/or
· reviewing and progressing your job application (if applicable).
– Where you have provided your consent:
· if we need your consent in order to send marketing or otherwise provide our services to you; and/or;
· to place cookies on your device(s) and use similar technologies.
– For purposes which are required by law:
· we may share your personal information in order to comply with legal obligations to which we are subject.
– Other purposes:
· in order to protect your vital interests or those of another individual; and/or
· for the purposes of record-keeping and hosting, back-up and restoration of our systems.
How will we share your information?
We share your personal details:
· with people within our organisation who are involved in carrying out the processing described above;
· with third party service providers who process your information on our behalf for the purposes above – such as IT hosting providers, payment service providers, data analytics specialists and other professionals retained by us; and
· in relation to data collected using our TracAce Explorer app, with our Clients, provided that the data has been anonymised first.
We will also share your personal information:
· if we think this is necessary to in order to protect the rights, property, or safety of our business, our employees, our partners, or our customers. This includes sharing information for the purposes of fraud protection and credit risk reduction;
· any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006;
· third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal information in the same way as set out in this policy; and/or
· with government authorities and/or law enforcement officials if required by law.
We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.
Giving and withdrawing your consent and updating your personal information
Where your consent is required for us to process your personal information, we will ask for your consent at the point at which you provide your data. You have the right to withdraw that consent at any time. You can also update your personal information at any time. If you wish to do either, contact us at email@example.com.
Storing your personal information; transfers outside the EEA and data retention
We may use our secure servers to store your personal data. We take appropriate physical, electronic and procedural measures to ensure that we keep your information secure, accurate and up to date in accordance with this policy.
Your personal information may be stored and processed outside of the country where it is collected, including outside of the European Economic Area (EEA). When transferring information to others, within the EEA or otherwise, we ensure that appropriate and suitable safeguards and technical measures are in place to protect your personal data. To do this, we make use of standard contractual clauses that have been approved by the European Commission, or we implement other similar measures required by laws around the world. If you would like further information about this, please contact us at firstname.lastname@example.org.
We will only keep records of your personal information for as long as is reasonably necessary for the purposes for which we have collected it, and in order to comply with any statutory or regulatory obligations in relation to retention of records. We respect requests to stop processing your personal data for marketing purposes. This includes keeping a record of your request indefinitely so that we can respect your request in future.
We may retain your personal data longer:
· to comply with law;
· to protect your vital interests or those of another individual; or
· in connection with any legal claims (to the extent those claims are continuing after the end of the relevant retention period).
Finally, we may create anonymised or aggregated records relating to demography or the use of our website or services, from which no individual is identifiable. We may retain those records, which are not personal data, indefinitely, and use them for our own business purposes without restriction.
Personal data relating to someone else
Prior to providing to TracAce any personal information concerning another individual, you must (unless we agree otherwise):
· inform the individual that you wish to share their personal data and refer them to this privacy notice; and
· obtain their permission (where possible) to share their personal information with us in accordance with this notice.
You have the right to request access to and rectification or erasure of personal information, the right to restrict processing of your personal information, and the right to object to processing of your personal information. You have the right to object to your personal information being processed on the grounds of our legitimate interests. You have the right to object to us sending you direct marketing and profiling you for the purposes of direct marketing. You can contact us by email at email@example.com in relation to any of the rights described in this paragraph, or if you have any questions regarding this privacy notice.
If you have a complaint or concern about how TracAce use your personal information, please contact TracAce in the first instance and we will attempt to resolve the issue as soon as possible. You have the right to lodge a complaint regarding our processing of your personal information with a data protection supervisory authority in a country where you live, work, or where you believe a breach may have occurred. In the United Kingdom, that is the Information Commissioner’s Office (www.ico.org.uk).
Contacting us The data controller for our website and services is TracAce, whose registered address Highbury, Highbury Hill, Northam, Bideford, England, EX39 1NJ. We can be reached by email at firstname.lastname@example.org.