Effective Date: September 10, 2018
Trax Technology Solutions Pte Ltd. (“Trax“, “we“, “our” or “us“) develops and provides advanced computer vision and deep learning solutions for in-store optimization, shelf strategy and retail management (the “Platform“).
Our Platform, our website available at www.traxretail.com (the “Site“) and the Trax mobile application (the “App“, and together with the Site and Platform – the “Services“) allow manufacturers and retailers (each, our “Customer“) to easily photograph and upload in-store or in-venue images of product shelves, and analyze such images to optimize their product planning, marketing, distribution and sales.
Specifically, it describes our practices regarding –
You are not legally required to provide us with any Personal Data (defined below), but without it we will not be able to provide you with the full range of Services or with the best user experience when using our Services.
We collect Personal Data regarding our Users as well as data regarding Visitors to our Site. Such data is typically collected and generated through the Visitor’s or User’s interaction with our Services, through automatic means or directly from our Customers or such Visitor or User.
Specifically, we collect the following categories of data (which, if it could be used to identify a specific person, or is linked to such identifying data, will be deemed as “Personal Data“):
Such data mainly consists of connectivity, technical and aggregated usage data, such as IP addresses, non-identifying data regarding a device, operating system, browser version, locale and language settings used, the cookies and pixels installed on such device and the activity (clicks and other interactions) of Visitors and Users in connection with our Services. Such data does not enable us to learn a person’s true identity or contact details. We mainly use such data to gain a better understanding on how Users typically use our Services and how we could improve their user experience, and to optimize our marketing campaigns and ad management, as well as the overall performance of our Services.
We use Personal Data as necessary for the performance of our Services; for complying with applicable law; and to support our legitimate interests in maintaining and improving our Services and offerings, understanding how our Services are used, optimizing our marketing, customer service and support operations, and protecting and securing our Users, Customers, ourselves and our Services.
Specifically, we use Personal Data for the following purposes:
Data Location and Retention
Data Location: Your Personal Data may be maintained, processed and stored by Trax and our authorized affiliates and Service Providers (defined below) in the United States of America and other jurisdictions, as necessary for the proper delivery of our Services, or as may be required by law.
Trax is based in a jurisdiction which is considered by the European Commission to be offering an adequate level of protection for the Personal Data of EU Member State residents.
Trax’s US subsidiary has applied to self-certify with the EU-US and Swiss-US Privacy Shield Frameworks with respect to Personal Data it receives or processes which concerns individuals residing in the European Union (EU) or Switzerland. We will update this section once our application is granted. All Personal data received from EU member countries and Switzerland will be processed in reliance on the applicable Privacy Shield Framework and in accordance with the Framework’s applicable principles. To learn more about the Privacy Shield Framework, please visit www.privacyshield.gov.
Data Retention: We retain Users’ Personal Data for as long as their Customer’s agreement with us is in effect, or for as long as their account is active, and we have not been notified otherwise, or as long as we consider necessary for the purposes described herein.
We keep Visitors’ Personal Data for as long as we reasonably need in order to maintain and expand our relationship and to provide them with our Services.
We will also retain your Personal Data for as long as is required in order to comply with our legal and contractual obligations, or to protect ourselves from any potential disputes (i.e. as required by laws applicable to records and bookkeeping, as necessary for allowing the Users you engaged with via our Services to meet their own obligations or legitimate needs, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), in accordance with our data retention policy.
Please note that except as required by applicable law, we will not be obligated to retain your Personal Data for any particular period, and we are free to securely delete it for any reason and at any time, with or without notice to you. If you have any questions about our data retention policy, please contact us by email at firstname.lastname@example.org.
Legal Compliance: We may disclose or allow government and law enforcement officials access to your Personal Data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations. Such disclosure or access may occur if we believe in good faith that we are legally compelled to do so, or that disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing.
Service Providers: We may engage selected third party companies and individuals to perform services complementary to our own (e.g. hosting services, data analytics services, marketing and advertising services, data and cyber security services, payment processing services, user engagement services, e-mail distribution and monitoring services, session recording, and our business, legal and financial advisors) (collectively, “Service Providers“). These Service Providers may have access to your Personal Data, depending on each of their specific roles and purposes in facilitating and enhancing our Services, and may only use it for such purposes.
Sharing Users Personal Data with our Customers: We may share the Personal Data of Users with their Customer organization (including data and communications concerning their Services user account). In such cases, sharing such data means that other individuals from your organization may receive it on its behalf, and will be able to monitor, process and analyze your Personal Data and associated content. Please note that Trax is not responsible for and does not control any further disclosure, use or monitoring by or on behalf of your organization, who is the “Data Controller” of such data (as further described in Section 10 below).
Protecting Rights and Safety: We may share your Personal Data with others if we believe in good faith that this will help protect the rights, property or personal safety of Trax, any of our Users or Customers, or any members of the general public.
For the avoidance of doubt, Trax may share your Personal Data in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so, or if we have successfully rendered such data non-personal and anonymous. We may transfer, share or otherwise use non-personal data at our sole discretion and without the need for further approval.
Cookies and Tracking Technologies
Our Services and some of our Service Providers utilize “cookies”, anonymous identifiers and other tracking technologies which help us provide, secure and improve our Services, personalize your experience and monitor the performance of our activities and campaigns. A “cookie” is a small text file that is used, for example, to collect data about activity on our Site. Some cookies and other technologies serve to recall Personal Data, such as an IP address, previously indicated by the User.
A list of the cookies we use can be found here:
_utma – Google Analytics – https://www.google.com/analytics/ – Website Analytics
_utmb – Google Analytics – https://www.google.com/analytics/ – Website Analytics
_utmc – Google Analytics – https://www.google.com/analytics/ – Website Analytics
_utmt – Google Analytics – https://www.google.com/analytics/ – Website Analytics
_utmz – Google Analytics – https://www.google.com/analytics/ – Website Analytics
_ga – Google Analytics – https://www.google.com/analytics/ – Website Analytics
_vwo_uuid_v2 – Wingify – https://vwo.com/ – A/B Testing and Conversion Optimization
wordpress_test_cookie – Trax – Inhouse
_cfduid – Cloudflare – http://cloudflare.com – Website Caching
How to Adjust Your Preferences Regarding Cookies and Interest-based Advertising
If you wish to prevent the use of your mobile device’s advertising ID, you may change your device settings to reset such advertising ID (typically, this is available under the “Privacy” or “Ads” section of your device settings). You may also change your browser settings to reset or block cookies (typically, this is available under the “Settings” or “Help” section of your browser menu).
Service Communications: We may contact you with important information regarding our Services. For example, we may notify you (through any of the means available to us) of changes or updates to our Services, billing issues, service changes, password-retrieval notices, etc. We, or our Customers, may also send you notifications, messages and other updates. Typically, you will not be able to opt-out of receiving such service communications while using our Services, as they are integral to such use.
Notifications and Promotional Communications: We may send you notifications concerning messages and other updates in your user account. We may also send you notifications about new features, offerings, events and special opportunities or any other information we think our Users will find valuable. We may provide such notices through any of the contact means available to us (e.g. phone, mobile or e-mail), through the Services, or through our marketing campaigns on any other sites or platforms.
If you do not wish to receive such promotional communications, you may notify Trax at any time by sending an email to email@example.com or by following the “unsubscribe”, “stop”, “opt-out” or “change e-mail preferences” instructions contained in the promotional communications you receive.
In order to protect your Personal Data held with us and our Service Providers, we are using industry-standard physical, procedural and electronic security measures, including encryption as appropriate. However, please be aware that regardless of any security measures used, we cannot and do not guarantee the absolute protection and security of any Personal Data stored with us or with any third parties as described in Section 4 above.
Data Subject Rights
If you wish to exercise your rights under any applicable law, including the EU General Data Protection Regulation (GDPR), to request access to, and rectification or erasure of your Personal Data held with Trax, or to receive a portable copy of such Personal Data – please contact us by email at firstname.lastname@example.org.
Please note that once you contact us by e-mail, we may require additional information and documents, including certain Personal Data, in order to authenticate and validate your identity and to process your request. Such additional data will be then retained by us for legal purposes (e.g. as proof of the identity of the person submitting the request), in accordance with Section 3 above.
Our Services Are Not Designed to Attract Children Under the Age of 18. We do not knowingly collect Personal Data from children and do not wish to do so. If we learn that a person under the age of 18 is using the Services, we will prohibit and block such use and will make all efforts to promptly delete any Personal Data stored with us with regard to such child.
If you believe that we might have any such data, please contact us by email at email@example.com.
Certain data protection laws and regulations, such as the GDPR, typically distinguish between two main roles for parties processing Personal Data: the “Data Controller”, which determines the purposes and means of processing, and the “Data Processor”, which processes the data on behalf of the Data Controller. Below we explain how these roles apply to our Services, to the extent that such laws and regulations apply.
If a Customer submits any Personal Data concerning any of its Users, or otherwise has any of its Users submit or upload Personal Data in connection with our Services, such Customer shall be deemed the “Data Controller” of its Users’ data, and we will only process such data on our Customer’s behalf, as its “Data Processor”. This means that in such cases, we will only process such Users’ data on behalf of our Customer and in accordance with its reasonable instructions, subject to our Terms of Service and other commercial agreements. The Customer will be solely responsible for meeting any legal requirements applicable to Data Controllers (such as establishing a legal basis for processing and responding to Data Subject Rights requests concerning the data they control).
If you are a User on behalf of any of our Customers, please note that Trax only processes your data solely on such Customer’s behalf. If a User would like to make any requests or queries regarding their Personal Data, he/she should contact such Customer directly. For example, if you are a User who wishes to access, correct, or delete data processed by Trax on behalf of a Customer, please direct your request to the relevant Customer (who is the “Data Controller” of such data). If requested to remove any User’s Personal Data, we will respond to such request within thirty (30) days. Unless otherwise instructed by our Customer, we will retain their Users’ Personal Data as set forth in Section 3 above.
Trax Retail Ltd. has been designated as Trax’s representative in the European Union for data protection matters pursuant to Article 27 of the GDPR. Trax Retail Ltd. may be contacted only on matters related to the processing of Personal Data. To make such an inquiry, please send an email to firstname.lastname@example.org. If you are a GDPR-protected individual, you also have the right to lodge a complaint with an EU supervisory authority.