PRIVACY POLICY
Effective date: 2024-10-15
1. Introduction
Welcome to Trak Global Security Solutions.
When you are using Trak Global Security Solutions ’TrakShield', we want you to
understand what personal data we collect from you and how we are using it. This policy
explains how we collect, safeguard and disclose information that results from your use
of our Service.
We use your asset location data to provide and improve our Service. By using our
Service, you agree to the collection and use of information in accordance with this
policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy
Policy have the same meanings as in our Terms and Conditions.
Our Terms and Conditions (“Terms”) govern all use of our Service and together with the
Privacy Policy constitutes your agreement with us (“agreement”).
2. Definitions
PERSONAL DATA means data about a living individual who can be identified from that
data (or from those and other information either in our possession or likely to come into
our possession).
ASSET DATA means the is data collected from the telematic device that provides us the
location data of the asset that will allows us to perform our Service.
USAGE DATA is data collected automatically either generated by the use of the Service
or from the Service infrastructure itself (for example, the duration of a page visit).
COOKIES are small files stored on your device (computer or mobile device).
DATA CONTROLLER means a natural or legal person who (either alone or jointly or in
common with other persons) determines the purposes for which and the manner in
which any personal data are, or are to be, processed. For the purpose of this Privacy
Policy, we, Trak Global Security Solutions, are a Data Controller of your data.
DATA PROCESSORS (OR SERVICE PROVIDERS) means any natural or legal person who
processes the data on behalf of the Data Controller. We may use the services of various
Service Providers in order to process your data more effectively.
DATA SUBJECT is any living individual who is the subject of Personal Data.
THE USER is the individual using our Service. The User corresponds to the Data
Subject, who is the subject of Personal Data.
3. Information Collection and Use
We collect several different types of information for various purposes to provide and
improve our Service to you.
The law requires us to have a legal basis for collecting and using your personal data. We
rely on one or more of the following legal bases:
• Performance of a contract with you (“Contract”): Where we need to perform
the contract we are about to enter into or have entered into with you.
• Legitimate interests: We may use your personal data where it is necessary to
conduct our business and pursue our legitimate interests, for example to prevent
fraud and enable us to give you the best and most secure customer experience.
We make sure we consider and balance any potential impact on you and your
rights (both positive and negative) before we process your personal data for our
legitimate interests. We do not use your personal data for activities where our
interests are overridden by the impact on you (unless we have your consent or
are otherwise required or permitted to by law).
• Legal obligation: We may use your personal data where it is necessary for
compliance with a legal obligation that we are subject to. We will identify the
relevant legal obligation when we rely on this legal basis.
• Consent: We rely on consent only where we have obtained your active
agreement to use your personal data for a specified purpose, for example if you
subscribe to an email newsletter.
4. Types of Data Collected
Personal Data
While using our Service, we may ask you to provide us with certain personally
identifiable information that can be used to contact or identify you (“Personal Data”).
Personally identifiable information may include, but is not limited to:
1. Name
2. Address
3. Telephone Number
4. Email address
5. Vehicle Licence Number
We use this data to provide features of our Service, to improve and customize our
Service.
Usage Data
We may also collect information that your browser sends whenever you visit our Service
or when you access Service by or through any device (“Usage Data”).
This Usage Data may include information such as your computer’s Internet Protocol
address (e.g. IP address), browser type, browser version, the pages of our Service that
you visit, the time and date of your visit, the time spent on those pages, unique device
identifiers and other diagnostic data.
When you access Service with a device, this Usage Data may include information such
as the type of device you use, your device unique ID, the IP address of your device, your
device operating system, the type of Internet browser you use, unique device identifiers
and other diagnostic data. . We use this data to provide features of our Service, to
improve and customize our Service.
Images & Files
We may use the user's camera / gallery to access images / files / documents if you give
us permission to do so . We use this data to provide features of our Service, to improve
and customize our Service.
Location Data
We may use and store information about the location of your asset ( “Asset Data’). We
use this data to provide features of our Service, to improve and customize our Service.
We do not collect, track or use any indivudal location data that from the mobile device
used to access the Service.
Tracking Cookies Data
We use cookies and similar tracking technologies to track the activity on our Service
and we hold certain information.
Cookies are files with a small amount of data which may include an anonymous unique
identifier. Cookies are sent to your browser from a website and stored on your device.
Other tracking technologies are also used such as beacons, tags and scripts to collect
and track information and to improve and analyse our Service.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being
sent. However, if you do not accept cookies, you may not be able to use some portions
of our Service.
Examples of Cookies we use:
0.1. Session Cookies: We use Session Cookies to operate our Service.
0.2. Preference Cookies: We use Preference Cookies to remember your preferences
and various settings.
0.3. Security Cookies: We use Security Cookies for security purposes.
0.4. Advertising Cookies: Advertising Cookies are used to serve you with
advertisements that may be relevant to you and your interests.
5. Use of Data
We use the collected data for various purposes, the legal basis for each activity is
stated in brackets:
0.1. to provide and maintain our Service (Contract/Legitimate Interests);
0.2. identify you as a user in our system (Contract/Legitimate Interests);
0.3. to notify you about changes to our Service (Contract/Legitimate Interests);
0.4. to allow you to participate in interactive features of our Service when you choose to
do so (Contract/Legitimate Interests);
0.5. to provide customer support (Contract/Legitimate Interests);
0.6. to gather analysis or valuable information so that we can improve our Service
(Legitimate Interests);
0.7. to monitor the usage of our Service (Legitimate Interests);
0.8. to detect, prevent and address technical issues (Contract/Legitimate Interests);
0.9. to fulfil any other purpose for which you provide it (Contract/Legitimate Interests);
0.10. to carry out our obligations and enforce our rights arising from any contracts
entered into between you and us, including for billing and collection
(Contract/Legitimate Interests);
0.11. to provide you with notices about your account and/or subscription, including
expiration and renewal notices, email-instructions, etc. (Contract/Legitimate Interests);
0.12. to provide you with news, special offers and general information about other
goods, services and events which we offer that are similar to those that you have
already purchased or enquired about unless you have opted not to receive such
information (Contract/Legitimate Interests/Consent);
0.13. in any other way we may describe when you provide the information
(Contract/Legitimate Interests/Consent);
0.14 to carry out vehicle identification checks (Contract/Legitimate Interests/Consent/
Legal Obligation);
0.15. for any other purpose with your consent (Consent).
6. Retention of Data
We will retain your Personal Data only for as long as is necessary for the purposes set
out in this Privacy Policy. We will retain and use your Personal Data to the extent
necessary to comply with our legal obligations (for example, if we are required to retain
your data to comply with applicable laws), resolve disputes, and enforce our legal
agreements and policies.
We will also retain Usage Data for internal analysis purposes. Usage Data is generally
retained for a shorter period, except when this data is used to strengthen the security or
to improve the functionality of our Service, or we are legally obligated to retain this data
for longer time periods.
7. Transfer of Data
Your information, including Personal Data, may be transferred to – and maintained on –
computers located outside of your state, province, country or other governmental
jurisdiction where the data protection laws may differ from those of your jurisdiction.
If you are located outside India and choose to provide information to us, please note
that we transfer the data, including Personal Data, to India and process it there.
Your consent to this Privacy Policy followed by your submission of such information
represents your agreement to that transfer.
Trak Global Security Solutions will take all the steps reasonably necessary to ensure
that your data is treated securely and in accordance with this Privacy Policy and no
transfer of your Personal Data will take place to an organization or a country unless
there are adequate controls in place. We will only transfer your personal data to:
• countries that have been deemed by the UK to provide an adequate level of
protection for personal data; or
• third parties that agree to specific standard contractual terms approved for use
in the UK which give the transferred personal data the same protection as it has
in the UK.
8. Disclosure of Data
We may disclose personal information that we collect, or you provide as follows:
0.1. Disclosure for Law Enforcement.
Under certain circumstances, we may be required to disclose your Personal Data if
required to do so by law or in response to valid requests by public authorities.
0.2. Business Transaction.
If we or our subsidiaries are involved in a merger, acquisition or asset sale, your
Personal Data may be transferred.
0.3. Other cases. We may disclose your information also:
0.3.1. to our subsidiaries and affiliates;
0.3.2. to contractors, service providers, and other third parties we use to support our
business;
0.3.3. to fulfill the purpose for which you provide it;
0.3.4. for the purpose of including your company’s logo on our website;
0.3.5. for any other purpose disclosed by us when you provide the information;
0.3.6. with your consent in any other cases.
We require all third parties to respect the security of your personal data and to treat it in
accordance with the law. We do not allow our third-party service providers to use your
personal data for their own purposes and only permit them to process your personal
data for specified purposes and in accordance with our instructions.
9. Security of Data
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.
Data security includes data encryption, hashing, tokenization, and key management
practices that protect data across all applications and platforms.
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.
10. Your Data Protection Rights Under General Data Protection Regulation (GDPR)
If you are a resident of the UK, the European Union (EU) and European Economic Area
(EEA), you have certain data protection rights, covered by GDPR.
We aim to take reasonable steps to allow you to correct, amend, delete, or limit the use
of your Personal Data.
If you wish to be informed what Personal Data we hold about you and if you want it to be
removed from our systems, please email us at infosec@trakglobalss.com.
In certain circumstances, you have the following data protection rights:
0.1. the right to access, update or to delete the information we have on you. This
enables you to receive a copy of the personal data we hold about you and to check that
we are lawfully processing it;
0.2. the right of rectification. You have the right to have your information rectified if that
information is inaccurate or incomplete though we may need to verify the accuracy of
the new data you provide to us;
0.3. the right to object. You have the right to object to our processing of your Personal
Data where we are relying on a legitimate interest (or those of a third party) as the legal
basis for that particular use of your data (including carrying out profiling based on our
legitimate interests). In some cases, we may demonstrate that we have compelling
legitimate grounds to process your information which override your right to object;
0.4. the right of restriction. You have the right to request that we restrict the processing
of your personal information in one of the following scenarios:
• If you want us to establish the data's accuracy;
• Where our use of the data is unlawful but you do not want us to erase it;
• Where you need us to hold the data even if we no longer require it as you need it
to establish, exercise or defend legal claims; or
• You have objected to our use of your data but we need to verify whether we have
overriding legitimate grounds to use it;
0.5. the right to data portability. You have the right to be provided with a copy of your
Personal Data in a structured, machine-readable and commonly used format. Note that
this right only applies to automated information which you initially provided consent for
us to use or where we used the information to perform a contract with you.;
0.6. the right to withdraw consent. You also have the right to withdraw your consent at
any time where we rely on your consent to process your personal information. This will
not affect the lawfulness of any processing carried out before you withdraw your
consent. If you withdraw your consent, we may not be able to provide certain products
or services to you. We will advise you if this is the case at the time you withdraw your
consent;
0.7 the absolute right to object any time to the processing of your personal data for
direct marketing purposes.
0.8 the right to request erasure of your personal data in certain circumstances. This
enables you to ask us to delete or remove personal data where there is no good reason
for us continuing to process it. You also have the right to ask us to delete or remove your
personal data where you have successfully exercised your right to object to processing
(see below), where we may have processed your information unlawfully or where we are
required to erase your personal data to comply with local law. Note, however, that we
may not always be able to comply with your request of erasure for specific legal reasons
which will be notified to you, if applicable, at the time of your request.
Please note that we may ask you to verify your identity before responding to such
requests. Please note, we may not be able to provide Service without some necessary
data.
You will not have to pay a fee to access your personal data (or to exercise any of the
other rights). However, we may charge a reasonable fee if your request is clearly
unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your
request in these circumstances.
We try to respond to all legitimate requests within one month. Occasionally it could 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.
You have the right to complain to a Data Protection Authority about our collection and
use of your Personal Data. For more information, please contact your local data
protection authority. In the UK this is the Information Commissioner’s Office (ICO), the
UK regulator for data protection issues (www.ico.org.uk). We would, however,
appreciate the chance to deal with your concerns before you approach the ICO so
please contact us in the first instance.
11. Service Providers
We may employ third-party companies and individuals to facilitate our Service
(“Service Providers”), provide Service on our behalf, perform Service-related services
or assist us in analysing how our Service is used.
These third parties have access to your Personal Data only to perform these tasks on
our behalf and are obligated not to disclose or use it for any other purpose.
12. Analytics
We may use third-party Service Providers to monitor and analyse the use of our Service.
13. CI/CD tools
We may use third-party Service Providers to automate the development process of our
Service.
14. Payments
We may provide paid products and/or services within Service. In that case, we use thirdparty services for payment processing (e.g. payment processors).
We will not store or collect your payment card details. That information is provided
directly to our third-party payment processors whose use of your personal information
is governed by their Privacy Policy. These payment processors adhere to the standards
set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint
effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS
requirements help ensure the secure handling of payment information.
15. Links to Other Sites
Our Service may contain links to other sites that are not operated by us. If you click a
third-party link, you will be directed to that third party’s site. We strongly advise you to
review the Privacy Policy of every site you visit.
We have no control over and assume no responsibility for the content, privacy policies
or practices of any third party sites or services.
16. Children’s Privacy
Our Services are not intended for use by children under the age of 18 (“Child” or
“Children”).
We do not knowingly collect personally identifiable information from Children under 18.
If you become aware that a Child has provided us with Personal Data, please contact
us. If we become aware that we have collected Personal Data from Children without
verification of parental consent, we take steps to remove that information from our
servers.
17. Changes to This Privacy Policy
We may update our Privacy Policy from time to time. We will notify you of any changes
by posting the new Privacy Policy on this page.
We will let you know via email and/or a prominent notice on our Service, prior to the
change becoming effective and update “effective date” at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to
this Privacy Policy are effective when they are posted on this page.
