Privacy Policy
Effective Date: July 05, 2022
Table of Contents
1. Introduction and Applicability of This Policy
2. Data We Collect and Receive
3. How We Use Data
4. Who We Share Your Data With
5. Third-Party Websites and Services
6. How We Protect Your Data
7. Storing of Your Data
8. International Data Transfers
9. Your Rights and Options
10. Changes to This Privacy Policy
11. Contact Us
1. Introduction and Applicability of This Policy
1.1. Throughout this document, “Company”, “We”, “Us”, “Our” and “Ours” refer to:
Tracksy - Gofreeride di Simon Critchell (also referred to as "Data Controller")
Via Fontegrossa n°36, L’Aquila
Contact E-mail: tracksycontact@gmail.com
Contact Phone: +393334929871
The identity and the contact details of Company representative for European Union users:
Simon Critchell
Via Fontegrossa n°36
67100 (AQ)
L’Aquila - ITALIA
Data protection officer of European Union users tracksycontact@gmail.com
1.2 This Privacy Policy describes how We collect, store, use, and manage the personal information you provide to Us or that We collect in connection with https://tracksy.io ( the "Site"), Mobile App “Tracksy VR” (referred to as the "Application" and collectively with the Site and all services provided through the Site and Applications, as the “Services”), as well as your choices and rights concerning the collection and use of personal information.
The Privacy Policy is applied to all visitors and users who use the Services (here and after – “Users” or "You"). Some of our Services are intended for Outdoor Enthusiast. This Privacy Policy is also part of the Terms of Use located at https://tracksy.io/mobile-apps-terms-and-conditions-consent (the “Terms of Use”), which You, or if you have not reached the age of majority in your jurisdiction, a parent or legal guardian on Your behalf, must read and accept. The Terms of Use explain your rights and the responsibilities of the Company when you use the Services. Capitalized terms that are not defined in this Privacy Policy have the meaning given them in our Terms of Use.
Before accessing or using Our Services, please ensure that You have read and understood how We collect, store, use, and disclose Your personal information as described in this Privacy Policy.
2.Data We Collect and Receive
2.1. In order to provide You with Our Services, We may collect or receive data, which may include personal information voluntarily provided during the registration process, subscription to the Service, publication of materials or information collected automatically during the course of providing the Services.
2.2. We collect the following types of information about You:
2.2.1. Registration and Account Data
The “Tracksy VR” app, which is intended for adults only, allows Participants to be invited to participate in Outdoor Activities enhancing their own safety. When You join such a profile, We may collect Your personal information, such as email address, gender, or cell phone number. We also may collect Your general location data such as country or region (We do not collect your precise geolocation).
2.2.2. Communication Data
When You communicate with Us or submit a report about problems with the Services, post any content or messages, or provide any other information within the Services, We may process all of this information. This data may include:
- data sent through “Tracksy VR”;
- data You provide through our support channels.
2.2.3. Data Collected Through Use of the Services
2.2.3.1. When You use any of Our Services, the following types of information may be processed:
- general location data, which includes your country, region, city (includes your precise location data);
- location usage in the background to allow you to sleep mode your mobile phone to save battery;
- our “live tracking” and “help-me” features uses your location;
- “Tracksy VR” only collects location data when the app is in use.
2.2.3.2. We may collect the following types of personal information regarding users of the “Tracksy VR”
- Geolocation (precise geolocation): we collect and use the unique user ID and location of the mobile device on which the “Tracksy VR” app is installed using GPS triangulation in order to get the location of the mobile device to provide our Services. We only store the geolocation data as long as it is reasonable to provide the Service, and then We delete the geolocation data related to Your profile in the “Tracksy VR” app. The Company may maintain geolocation data for a longer period of time only in order to analyse cumulative trends and indicators (improvement of our Services). During the app's set up, We will ask You whether You want to turn the geolocation tracking on. You can later change your choice within the settings of the device.
- Fitness data or activity recognition data: this information may be displayed within the “Tracksy” map connected with the profile.
The Company does not store sound around the device or audio data, usage statistics, fitness data, or activity recognition data on any servers.
2.2.4. Data Collected Automatically via Cookies and Related Technologies
When you visit our website or use our mobile software, We and Our business partners may collect certain data about your PC or device using technologies such as cookies, web cookies, log files, or any other tracking/recording tools. The information We collect using the tracking technologies includes but is not limited to the IP addresses, browser information, links to/exits and URLs, streaming data and information regarding how you interact with the web links, website, mobile software or Service, domain names, landing pages, page views, cookies data which allow us to uniquely identify your browser and monitor the behaviour of your browser at Our website, type of mobile device or other permanent identifiers. Some or all of this data may be combined with other personally identifying information specified above.
When You access our Service via a mobile device, We may receive or collect and store unique identification numbers associated with Your device or Our mobile app (including, for example, UDID, a unique identifier ("IDFA")) device type, model and manufacturer, brand and model of the mobile operating system.
We may use first-party cookies that belong to us and that we place on your device and third-party cookies that another party places on your browsing device when You visit our site. Third parties setting cookies on Our website will be providing a service to Us or a function of the Site, but We do not always control how third-party cookies are used. You should check the third party’s website for more information about how they use cookies.
Cookies or similar technologies stored on your computer or device through which You use the Services have amongst others but without limitation, the following functions: Authentication. If you’re signed in to our Services, cookies help us show you the right information and personalize your experience.
Security. We use cookies to enable and support our security features, and to help us detect malicious activity.
Preferences and Features. Cookies or similar technologies can tell us which language you prefer and what your communications preferences are. They can help you fill out forms on our Sites more easily. They also provide you with features, insights, and customized content.
Performance, Analytics, and Research. Cookies or similar technologies help us learn how well our Sites and Services perform, diagnose or fix technology problems reported by the users or developers. We also use cookies or similar technologies to understand, improve, and research products, features, and services, including to create logs and record when you access our Sites and Services from different devices, such as your computer or your mobile device.
We may use third-party analytics providers software to allow us to better understand the functionality of our software on your device, including but not limited to, Google Analytics, Yandex, AppMetrica, Firebase, Facebook Analytica (collectively “Third Party Analytics Providers”). This software may record information such as how often You use the Services, the events that occur within the Services, aggregated usage, performance data, and where our Software was downloaded from. We do not link the information we store within the analytics software to any personal data You submit within the Services.
The following is the non-exhaustive list of third parties that we use for analytics:
Firebase (a country of the owner of this service depends on your country)Firebase helps us understand clearly how Users behave, which enables You to make informed decisions regarding app marketing and performance optimizations. For more information about Firebase privacy practices, please see https://firebase.google.com/terms/analytics.
Google AnalyticsGoogle Analytics collects information such as how often Users visit this Site, what pages they visit when they do so, and what other sites they used prior to coming to this Site. Google’s ability to use and share information collected by Google Analytics about your visits to our Services is restricted by the Google Analytics Terms of Use (as amended for government websites) and the Google Privacy Policy. You can prevent Google Analytics from recognizing You on return visits to this Site by disabling cookies on your browser or mobile device. For more information about Google Analytics, please see Google Privacy (https://policies.google.com/privacy?hl=en). To prevent Google Analytics from using your data through a web browser, you can get the Google Analytics Opt-out Browser Add-on (https://tools.google.com/dlpage/gaoptout/).
Facebook Analytics (a country of the owner of this service depends on your country)Solution for analytics that helps to understand how You use our Services. For more information about Facebook Analytics privacy practices, please see thehttps://www.facebook.com/full_data_use_policy.
2.2.6. Anonymous data
about visitors to and use of Our Services for the purposes of creating aggregate statistics or reporting purposes. However, no single individual will be identifiable from the anonymised details we collect for these purposes.
2.2.7. Sensitive Information
We do not collect or process any sensitive information, such as information related to the racial or ethnic origin, political opinions, religious beliefs, physical or mental health or condition, crime or court records, etc.
3. How We Use Data
3.1. To Provide the Services to You
To provide the Service to You and to perform Our contract with You, we use Your information, which is necessary:
1. ● to register and administer Your User Account, and to verify Your details,
2. ● to provide You with the Service upon Your request;
3. ● to verify and confirm Your payments;
4. ● to communicate with You including via email or push notification about Your account or transactions with Us and send You information about features on Our Services or changes to Our policies;
5. ● to provide support including, but not limited to, product updates, product patches, fixes, and other similar communications;
3.2. To make the Service more suitable for Our users
To provide a great Service to Our users, We have a legitimate interest in collecting and processing the necessary information to
1. ● update and develop User profiles;
2. ● develop and improve the Service and User experience;
3. ● manage our relationship with you;
4. ● customize your Service experience;
5. ● respond to your comments and questions and provide User support;
6. ● notify you and provide you with information about the features of our Services, new releases and service developments, and to advertise our products and services;
7. ● provide you with special offers inside the Service as well as in other websites and services, and by email;
8. ● send you related information, including via email or push notification, such as updates, security alerts, and support messages.
You may opt-out of receiving promotional communications from us. To find out how to do this, please refer to section 10.6. (Opt-Out of Direct Marketing).
3.3. To Keep The Services Safe And Fair
In order to keep the Service and its features safe and fair, to prevent and fight fraud and cheating, and to ensure acceptable use, we have a legitimate interest in processing the necessary data to
1. ● analyze and monitor the use of the Services;
2. ● take action against fraudulent, cheating, or disruptive Users;
If the data can be used to prove that cheating, fraudulent activity, or Terms of Use violation has occurred, we will further store the data for the establishment, exercise, or defense of the legal claims for the duration of the applicable statute of limitations.
3.4. With Your Consent
3.4.1. We are not required to obtain Your consent for most of the processing activities that we undertake in respect of Your own personal information.
We may, however, need Your consent for certain processing activities. If we need Your consent, we will notify You of the personal information We intend to use and how We intend to use it. With Your consent, we may process Your information for additional specific purposes.
3.4.2. If you have consented to Our use of information, You have the right to change Your mind at any time and withdraw your consent, but this will not affect any processing that has already taken place. To find out how to withdraw Your consent please see section 10.7 (Withdraw consent).
Where we are using your information because we have a legitimate interest in doing so, You have the right to object to that use. However, in some cases, this may mean that You will no longer be eligible to use the Services.
4. Who We Share Your Data With
4.1. We share information we collect about You in the ways discussed below and only when necessary for the performance of a contract with You, compliance with a legal obligation to which we are subject or based on our legitimate interests. We are not in the business of selling information about You to advertisers or other third parties. While a third party may have access to Your personal data in connection with the performance of services for the Company, it may not use such information for any purpose other than providing its services.
4.2. Hosting Services: we may use third-party companies to host information or provide the infrastructure that helps with the delivery of Our Services.
4.3. Customer Support Services: we engage third parties to help Us provide customer support for some territories and products. Such companies may have access to Your personal data, including personal data that You may provide in your customer support requests. Such partners include: Intercom, Inc.
4.4. Email service providers. We use the (“Clicksend”) partner to send You email notifications; such partner may have access to Your email address.
We reserve the right to disclose your personally identifiable information as required by any law and also when we believe that disclosure is necessary to protect Our rights and/or to comply with judicial proceedings, court orders, or legal process.
5. Third-Party Websites and Services
5.1. Third parties may collect Your information. There are a number of places on or through the Services where You may click on a link to access other websites, services or web resources that are not affiliated or connected with Us and do not operate under this Privacy Policy. For example, if You click on an ad, you may be taken to a website that we do not control. These third-party websites may independently collect information, including Your personal information, from You. We advise you to check the privacy policies of all third-party websites you visit.
6. How We Protect Your Data
6.1. The Company takes precautions - including legal, organizational, administrative, technical and physical measures in order to protect the personal data of the User, from any unauthorized or accidental access to them, destruction, modification, blocking, copying, distribution, as well as from other illegal actions of third parties. In order to make sure that Your personal data is safe, we communicate confidentiality and security standards to the Company's employees and strictly monitor the implementation of confidentiality measures within the Company.
7. Storing of Your Data
7.1. We do not store personal data that can be used to identify a User beyond the time period necessary to complete the function for which information was collected. We store your personal data for as long as Your User account is active, or as long as is needed to provide You with the Service.
Note that if you ask us to remove Your personal data, we may retain your information as necessary for our legitimate business interests, such as to comply with our legal obligations, resolve disputes, and enforce our agreements.
7.2. Storing of the information for marketing purposes: If you have elected to receive marketing notifications from Us, we store information about Your marketing preferences for a reasonable period of time from the date you last expressed interest in our Services.
We store information derived from cookies and other tracking technologies for a reasonable period of time from the date when such information was created and in accordance with conditions provided in section 2.2.4. (Data Collected Automatically via Cookies and Related Technologies).
8. International Data Transfers
8.1. Our Service is global by nature and Your data can therefore be transferred to anywhere in the world. We transfer, process, and store Your information outside of Your country of residence, to wherever We or Our third-party service providers operate for the purpose of providing you the Services. Whenever we transfer Your information, We take steps to protect it.
8.2. International transfers to third parties. Some of the third parties described in this privacy policy that provide services to Us under contract, are based in other countries that may not have privacy and data protection laws equivalent to those of the country in which you reside. When we share the information of customers in the European Economic Area or Switzerland, we make use of the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks, European Commission-approved standard contractual data protection clauses, or other appropriate legal mechanisms to safeguard the transfer. We will provide you with a copy of the standard data protection clauses upon your request.
9. Your Rights and Options
9.1. You have certain choices available to You when it comes to your information. Below is a summary of those rights, how to exercise them, and any limitations.
9.2. Your requests and choices may be limited in certain cases, such as when fulfilling Your request would reveal information about another person, or if You ask to delete information which We are permitted by law or have compelling legitimate interests to keep.
9.3. Right to Know Your Personal Data Processed (Right of Access)If you request, upon verification of your identity, we will provide you a copy of your personal data in a structured, electronic format. Below, we describe the processes for making these requests. You may contact us as explained in section 12 (Contact Us) to request assistance.
9.4. Change or Correct Your Personal Data (Right to Rectification)If available, you can edit some of your personal data through your account. You can also ask us to change, update, or fix your data in certain cases, particularly if it’s inaccurate, by contacting us as explained in section 12 (Contact Us).
9.5. Delete Your Personal Data (Right to Erasure):You can ask us to erase or delete all or some of your personal data (e.g. if it is no longer necessary to Provide Services to you). As a result of deleting your Account, you will lose access to most Services, including the Account and service-related information linked to the Account and the possibility to access the services for which you are using the Account. Please note that once your Account has been deleted, you will lose your user history and all related information.
9.6. Opt-Out of Direct Marketing: You can also opt-out of our use of your information for marketing purposes by following instructions in promotional communications or by contacting us, as explained in section 12 (Contact Us). When you make such requests, we may need time to investigate and facilitate your request. To change or delete push notifications, visit the settings section on your device and select the appropriate setting, or change the settings on your browser if you are accessing any of our websites. You can also stop receiving promotional emails from us by clicking on the “unsubscribe” link provided in such emails. You cannot deactivate the messages related to the functionality of the Service (for example, account verification, notification of parental consent, order confirmation, change or update of the Service features, technical and security notifications).
You can opt-out of interest-based advertising on mobile applications by checking the privacy settings of your Android or iOS device and selecting "limit ad tracking" (Apple iOS) or "opt-out of interest-based ads" (Android).
9.7. Withdraw Consent: You may withdraw consent where the processing of your personal information is based on consent, by contacting us as explained in the section “Contact us.” If you withdraw your consent, it will not affect the lawfulness of processing based on your consent before its withdrawal.
9.8. In most instances, we will respond to all requests within one calendar month. If we are unable to deal with your request fully within a calendar month (due to the complexity or number of requests), we may extend this period by a further two calendar months. Should this be necessary, we will explain the reasons for such a delay. If you make your request electronically, we will, where possible, provide the relevant information electronically unless you request otherwise.
9.9. You have the right to complain to the Data Protection supervisory authority for unresolved complaints.
9.10. European Union users have additional specific rights:
9.10.1. Request That We Stop Using Your Data (Right to Object): Where the processing of your Personal Data is based on legitimate interests, you can use your right to object at any time. If you object, we will no longer process your Personal Data unless there are compelling and prevailing legitimate grounds for the processing or the data is necessary for the establishment, exercise, or defense of legal claims.
9.10.2. Data Portability: Data portability is the ability to obtain some of your personal information in a format that you can move from one service provider to another (for instance, when you transfer your email address to another carrier). Depending on the context, this applies to some, but not to all of your data.
10. Changes to This Privacy Policy
10.1. We may change this privacy policy from time to time. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice by adding a notice within the Services or by sending you a notification. We encourage you to review our privacy policy whenever you use the Services to stay informed about our information practices and the ways you can help protect your privacy.
11. Contact Us
11.1. If you have any questions regarding the Company's Privacy Policy or the processing of data by the Company, you can contact us at:
Tracksy - Gofreeride di Simon Critchell
Via Fontegrossa n°36, 67100, AQ, L’Aquila ( ITALIA )
Contact E-mail: tracksycontact@gmail.com