Protecting consumer privacy is important to the Company and we adhere to the Safe Harbor Agreement concerning the transfer of personal data from the European Union (“EU”) to the United States of America. Accordingly, we follow the Safe Harbor Principles published by the U.S. Department of Commerce (the “Principles”) with respect to all such data. If there is any conflict between the policies in this statement and the Principles, the Principles shall govern. This statement outlines our general policy and practices for implementing the Principles, including the types of information we gather, how we use it and the notice and choice affected individuals have regarding our use of and their ability to correct that information.
This statement applies to all personal information collected or received by the Company through our website and TRACT platform.
“Personal Information” or “Information” means information that (1) is transferred from the EU to the United States; (2) is recorded in any form; (3) is about, or pertains to a specific individual; and (4) can be linked to that individual.
“Sensitive Personal Information” means personal information that reveals race, ethnic origin, sexual orientation, political opinions, religious or philosophical beliefs, trade union membership or that concerns an individual’s health.
TRACT Platform role
TRACT collects information under the direction of our Clients, and has no direct relationship with the individuals whose personal data it processes. If you are a customer of one of our Clients and would no longer like to be contacted by one of our Clients that use our service, please contact the Client that you interact with directly. We may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the service agreements with our Clients.
An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his query to the Client (the data controller). If requested to remove data, we will respond within a reasonable timeframe.
We will retain personal data we process on behalf of our Clients for as long as needed to provide services to our Client. We will retain this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Should we ask you to provide certain information by which you can be identified when using our websites, you can be assured that it will only be used in accordance with this privacy statement.
What we collect or receive?
The following types of personal information may be collected or received for various purposes, including identifying users of TRACT services and to better serve the users such as for billing and subsequent payment processing for the services consumed.
- Email address
- Phone number
- Company Name
- Demographic information such as post-code, preferences, and interests
- Payment Information (billing name, address, and credit card information)
- Other information relevant to customer surveys and/or offers
Additional information such as business or organization name, type of business, number of employees, annual revenues, cash balances and related financial information may be collected.
What we do with the information we gather?
Information collected through our websites is used to understand your needs and provide you with better service, and in particular for the following reasons:
- Internal record keeping
- To improve our products and services including our websites to suit to your interests and needs
- Send promotional emails about new products, special offers or information you may find interesting from us or our partners
- To conduct market research
The information collected or received through TRACT is used only to fulfill the functions and services subscribed to via TRACT. We do not share this information with outside parties except to the extent necessary to fulfill the services.
Email or personal or business addresses are not used for any other purpose and are not shared with outside parties.
We never use or share the personal information collected or received in ways unrelated to the ones described above without also providing an opportunity to opt-out or otherwise prohibit such unrelated uses.
Finally, we will never sell your information to anyone whosoever.
A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyze web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
We use traffic log cookies to identify which pages are being used. This helps us analyze data about web page traffic and improve our websites in order to tailor it to your needs. We only use this information for statistical analysis purposes and then the data is removed from the system.
Overall, cookies help us provide you with a better user experience. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share.
Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. Note that this may prevent you from taking full advantage of the website and a better user experience.
Links to other websites
Our websites may contain links to enable you to visit other websites of interest easily. However, once you have used these links to leave our site, you should note that we do not have any control over the linked website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide while visiting such sites.
Such sites are not governed by this privacy statement and may or may not be compliant to privacy laws. You should exercise caution and look at the privacy statement, if available, of the website in question.
Controlling your personal information on our websites
You may choose to restrict the collection or use of your personal information in the following ways:
Whenever you are asked to enter your personal information, look for the box that you can click on to indicate that you do not want the information to be used by anybody for direct marketing purposes.
If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by writing to us at, Transverse, 620 Congress Ave, Suite 200, Austin, TX 78701, or emailing us at email@example.com
You may request details of personal information which we hold about you under the Data Protection Act, 1998. If you would like a copy of the information held on you, please write to the address above. A small fee may be payable.
If you believe that any information we are holding on you is incorrect or incomplete, please write to or email us as soon as possible, using the contact information provided above. We will promptly correct any information found to be incorrect.
We employ several preventive, detective and corrective technology and processes to safeguard information from attackers. These safeguards help prevent unauthorized access, maintain data privacy and ensure the appropriate use of data.
TRACT requires unique user names and passwords that must be entered each time a customer logs on. Any information entered in to TRACT is encrypted using transport layer security (TLS).
We only process Personal Information in a way that is compatible with and relevant for the purpose for which it was collected or authorized by our clients. To the extent necessary for those purposes, we take measures to ensure that Personal Information is accurate, complete, current and reliable for its intended use.
See the section above regarding “Controlling your personal information” for details on how to restrict or obtain a copy or correct your personal information we may hold.
We use a self-assessment approach to assure compliance with this statement and periodically verify that the policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented and accessible and in conformity with the Principles. We encourage interested persons to raise any concerns using the contact information provided and we will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of Personal Information in accordance with the Principles.
If a complaint or dispute cannot be resolved through our internal process, we agree to dispute resolution using (an independent resource mechanism) as a third party resolution provider.
This statement may be amended from time to time consistent with the requirements of the Safe Harbor. We will post any revised policy on our websites.
Information Subject to Other Policies
The Company is committed to following the Principles for all Personal Information within the scope of the Safe Harbor Agreement. However, certain information is subject to policies of the Company that may differ in some respects from the general policies set forth in this statement.
The U.S.-EU Safe Harbor Guide to Self-Certification
U.S. Department of Commerce
To learn more about the Safe Harbor program, please visit http://www.export.gov/safeharbor/
Questions, comments or complaints regarding the Company’s Safe Harbor Policy or data collection and processing practices can be mailed to:
Transverse, 620 Congress Ave, Suite 200, Austin, TX 78701.
Effective date: June 1, 2016