Last updated: 6th of August 2019
Please read our Privacy Policy (“Privacy Policy”) carefully as it describes our collection, use, disclosure, retention, and protection of your personal information. This Privacy Policy applies to any website, application or service which references this Privacy Policy. Where you provide us with your personal information in any of the ways described in section 2 below, you agree that we may collect, store and use it:
(a) in order to perform our contractual obligations to you;
(b) based on our legitimate interests for processing (i.e. for internal administrative purposes, data analytics and benchmarking – see section 3 below for more information- direct marketing, maintaining automated backup systems or for the detection or prevention of crime); or
(c) based on your consent, which you may withdraw at any time, as described in this Privacy Policy.
This Privacy Policy applies to all products, applications, and services offered by ONTRACK DIGITAL SRL (Romanian company, ID RO368767621 and whose registered office address is Strada Victoriei, nr. 29, Targu-Jiu, Romania.
To the extent permissible under applicable law, we collect information about you and any other party whose details you provide to us when you:
We will also collect your information where you only partially complete and/or abandon any information inputted into our website and/or other online forms and may use this information to contact you to remind you to complete any outstanding information and/or for marketing purposes.
We also collect information from your devices (including mobile devices) and applications you or your users use to access and use any of our websites, applications or services (for example, we may collect the device identification number and type, location information and connection information such as statistics on your page views, traffic to and from the sites, referral URL, ad data, your IP address, your browsing history and your weblog information) and we will ask for your permission before we do so. We may do these using cookies or similar technologies (as described in section 14 below).
We may enhance the personal information we collect from you with information we obtain from third parties that are entitled to share that information; for example, information from credit agencies, search information providers or public sources (e.g. for customer due diligence purposes), but in each case, as permitted by applicable laws.
If you provide us with personal information about someone else, you are responsible for ensuring that you comply with any obligation and consent obligations under applicable data protection laws in relation to such disclosure. In so far as required by applicable data protection laws, you must ensure that you have provided the required notices and have obtained the individual’s explicit consent to provide us with the information and that you explain to them how we collect, use, disclose and retain their personal information or direct them to read our Privacy Policy.
To the extent permissible under applicable law, we use your information to:
To the extent permitted by applicable law, we retain information about you after the closure of your ONTRACK+ account, if your application for an ONTRACK+ account is declined or if you decide not to proceed. This information will be held and used for as long as permitted for legal, regulatory, fraud prevention and legitimate business purposes.
Our website, applications (including mobile applications) and services may contain technology that enables us to:
We may also use the information we gather to deliver targeted advertising, marketing (including in-product messaging) or information to you which may be useful, based on your use of the website, applications or services or any other information we have about you (depending on the websites, applications or services, you may be able to configure these features to suit your preferences).
We may monitor and record our communications with you, including e-mails and phone conversations. Information which we collect may then be used for training purposes, quality assurance, to record details about our website, applications and services you order from us or ask us about, and in order to meet our legal and regulatory obligations generally.
We may use the information generated and stored during your use of our services for our legitimate business interests to enable us to give you the best service and/or solutions and the best experience. These purposes include to:
You have the right to object to processing based on our legitimate interests, and if you wish to do so, please contact us at hello@ontrack.plus to discuss this further. If you object, this may affect our ability to provide certain services and/or solutions for your benefit.
We may share your information with:
We may share non-personally identifiable information about the use of our website, applications, products or services publicly or with third parties but this will not include information that can be used to identify you.
From time to time, we may use your information to contact you with details about our applications, products and services which we feel may be of interest to you. We may also share your information with our group companies and carefully selected third parties so that they (or we) may contact you with information about their products or services which we feel may be of interest to you. We or they may wish to contact you for this purpose by telephone, post, SMS or email. You have the right at any time to stop us from contacting you for marketing purposes. You may also request at any time that we do not share your information with third parties referred to in this paragraph. If you wish to exercise these rights you can do so by selecting your contact preferences at the point where you provide us with your information on our websites, applications or services, using any preference centers we give you access to or by sending us an email to hello@ontrack.plus. You can also unsubscribe from any email marketing using the links provided in the emails we send to you.
Where you respond to communications we post on third-party platforms (such as Facebook, Google, LinkedIn and Twitter), we may also share your information with those third parties in order to serve targeted advertising/content to you via the relevant third party platform based on your profile/interests. Your information is used by the third-party platform provider to identify your account and serve advertisements to you. You can control what advertisements you receive via the privacy settings on the relevant provider’s platform and you should consult the third party’s help/support center for more information.
If you are based within the EEA or within another jurisdiction having similar data protection laws, in certain circumstances you have the following rights:
If you request a copy of your information you may be required to pay a statutory fee.
If we hold any information about you which is incorrect or if there are any changes to your details, please let us know so that we can keep our records accurate and up to date.
If you withdraw your consent to the use of your personal information for the purposes set out in our Privacy Policy, we may not be able to provide you with access to all or parts of our website, applications, and services.
We will retain your personal information for the duration of our business relationship and afterward for as long as is necessary (maximum 5 years) and relevant for our legitimate business purposes. Where we no longer need your personal information, we will dispose of it in a secure manner (without further notice to you).
We may change this Privacy Policy from time to time. However, we will not reduce your rights under this Privacy Policy. We will always update this Privacy Policy on our website, so please try to read it when you visit the website (the ‘last updated’ reference tells you when we last updated this Privacy Policy).
We will keep your information secure by taking appropriate technical and organizational measures against its unauthorized or unlawful processing and against its accidental loss, destruction or damage. We will do our best to protect your personal information but we cannot guarantee the security of your information which is transmitted to our website, applications or services or to other websites, applications, and services via an internet or similar connection. If we have given you (or you have chosen) a password to access certain areas of our websites, applications or services please keep this password safe – we will not share this password with anyone.
We offer the use of a secure server. All supplied sensitive/credit information is transmitted via Secure Socket Layer (SSL) technology and then encrypted into our Payment Gateway provider’s database only to be accessible by those authorized with special access rights to such systems, and are required to keep the information confidential. After a transaction, your private information (credit cards etc.) will not be stored on our servers.
If you believe your account has been compromised, please contact us at hello@ontrack.plus
Personal information in the European Union is protected by data protection laws but other countries do not necessarily protect your personal information in the same way. When you send an email to us, this will also be stored on our email servers which are hosted in the European Union.
We may use service providers based outside of the EEA to help us provide our website, applications, and services to you (for example, platform and payment providers who help us deliver our applications and services, or advertising or execute your payments) and this means that we may transfer your information to service providers outside the EEA for the purpose of providing our applications, advertising, and services to you.
We take steps to ensure that where your information is transferred outside of the EEA by our service providers and hosting providers, appropriate measures, and controls in place to protect that information in accordance with applicable data protection laws and regulations. For example, we may share information with our group companies or affiliates based outside the EEA for the purposes envisaged by this Privacy Policy. In each case, such transfers are made in accordance with the requirements of Regulations (EU) 2016/679 (the General Data Protection Regulations or “GDPR”) and may be based on the use of the European Commission’s Standard Model Clauses for transfers of personal data outside the EEA.
By using our website, products or services or by interacting with us in the ways described in this Privacy Policy, you consent to the transfer of your information outside the EEA in the circumstances set out in this Privacy Policy. If you do not want your information to be transferred outside the EEA you should not use our website, applications or services.
If you follow a link from our website, application or service to another site or service, this Privacy Policy will no longer apply. We are not responsible for the information handling practices of third party sites or services and we encourage you to read the Privacy Policy appearing on those sites or services.
Our websites, applications or services may enable you to share information with social media sites, or use social media sites to create your account or to connect your social media account. Those social media sites may automatically provide us with access to certain personal information retained by them about you (for example any content you have viewed). You should be able to manage your privacy settings from within your own third party social media account(s) to manage what personal information you enable us to access from that account.
What are cookies?
A cookie is a small text file that a website saves on your computer or mobile device when you visit the site. It enables the website to remember your actions and preferences (such as login, language, font size and other display preferences) over a period of time, so you don’t have to keep re-entering them whenever you come back to the site or browse from one page to another.
How do we use cookies?
Our cookies may be session cookies (temporary cookies that identify and track users within our websites, applications or services which are deleted when you close your browser or leave your session in the application or service) or persistent cookies (cookies which enable our websites, applications or services to “remember” who you are and to remember your preferences within our websites, applications or services and which will stay on your computer or device after you close your browser or leave your session in the application or service).
We use the following different types of cookies:
Strictly necessary cookies
These are cookies which are needed for our websites, applications or services to function properly.
Performance cookies and analytics technologies
These cookies collect information about how visitors and users use our websites, applications, and services, for instance, which functionality visitors use most often, and if they get error messages from areas of the websites, applications or services. These cookies don’t collect information that identifies a visitor or user. All information these cookies collect is aggregated and therefore anonymous. We only use these cookies on how to improve our website, applications, and services work.
Functionality cookies
These cookies allow our websites, applications, and services to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customize. They may also be used to provide services you have asked for. The information these cookies collect may be anonymized and they cannot track your browsing activity on other websites.
Targeting or advertising cookies
These cookies are used to deliver adverts more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They are usually placed by advertising networks with the website operators’ permission. They remember that you have visited a website and this information is shared with other organizations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organization.
IP Address and Traffic Data
We keep a record of traffic data which is logged automatically by our servers, such as your Internet Protocol (IP) address, device information, the website that you visited before ours and the website you visit after leaving our site. We also collect some site, application and service statistics such as access rates, page hits, and page views. We are not able to identify any individual from traffic data or site statistics.
Find out more about the individual cookies and analytics technologies that we use.
Description | Purpose |
---|---|
Google, Google Analytics, Google Adwords | Google Analytics, Adwords use “cookies”, to help the website analyze how users use the websites, applications or services. The information generated by the cookie about your use of the websites, applications or services (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the websites, applications or services compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser or within the application, however, please note that if you do this you may not be able to use the full functionality of this website. By using our websites, applications or services you consent to the processing of data about you by Google in the manner and for the purposes set out above. To find out more, see “How Google uses data when you use our partners’ sites or apps”, (located at www.google.com/policies/privacy/partners/, or any other URL Google may provide from time to time). To opt out of being tracked by Google Analytics across all websites visit: http://tools.google.com/dlpage/gaoptout. (Retention period: Session/2 years) |
Intercom | We use third-party analytics services to help understand your usage of our services. In particular, we provide a limited amount of your information (such as sign-up date and some personal information like your email address) to Intercom, Inc. (“Intercom”) and utilize Intercom to collect data for analytics purposes when you visit our website or use our product. As a data processor acting on our behalf, Intercom analyzes your use of our website and/or product and tracks our relationship by way of cookies and similar technologies so that we can improve our service to you. For more information on Intercom’s use of cookies, please visit https://www.intercom.com/terms-and-policies#cookie-policy. We may also use Intercom as a medium for communications, either through email, or through messages within our product(s). As part of our service agreements, Intercom collects publicly available contact and social information related to you, such as your email address, gender, company, job title, photos, website URLs, social network handles and physical addresses, to enhance your user experience. For more information on the privacy practices of Intercom, please visit https://www.intercom.com/terms-and-policies#privacy. Intercom’s services are governed by Intercom’s terms of use which can be found at https://www.intercom.com/terms-and-policies#terms. If you would like to opt out of having this information collected by or submitted to Intercom, please contact us. |
These types of cookies are used for retargeting, so we can show you relevant ads based on your activity on our Site after you leave it. Information collected includes an identifier, and sometimes your geolocation, device type, and IP address. (Retention: 90 days) |
How to control cookies?
You may be able to configure your browser or our website, application or service to restrict cookies or block all cookies if you wish. However, if you disable cookies you may find this affects your ability to use certain parts of our website, applications or services. For more information about cookies and instructions on how to adjust your browser settings to accept, delete or reject cookies, see the http://allaboutcookies.org/ website.
If you have any queries about how we treat your information, the contents of this Privacy Policy, your rights under local law, how to update your records or how to obtain a copy of the information that we hold about you, please send an email to hello@ontrack.plus