- Why we process personal data
- Legal grounds for processing personal data
- European union user rights under the GDPR and how to exercise them
- Contact information for Trackimo data controllers
- Contact information for the Trackimo data protection officer in the European union
Categories of Personal Data Processed by Trackimo
Personal data that is processed when you create a Trackimo account:
When you create a Trackimo account, we ask you to provide your email address and name. You can choose to provide only your first name or a nickname instead of your full name if you wish.
PURPOSES AND LEGAL GROUNDS:
- (a) Trackimo processes your email address because you use your email address and your password to sign in to your account. The legal ground for processing your email address for this purpose is based on Trackimo’s legitimate interest in protecting the security of your account.
- (c) If you provide your opt-in consent to receiving marketing information from Trackimo, Trackimo will also process your email address for the purpose of sending you marketing information about Trackimo products and apps. The legal ground for processing your email address for this purpose is your consent. You may withdraw your consent at any time by changing your preferences in your Trackimo account or through the unsubscribe link at the bottom of our marketing emails. The marketing emails you receive from Trackimo are based on the preferences you provide in your Trackimo account, the locale indicated by your Internet Protocol (IP) address, the types of Trackimo devices you have added to your Trackimo account, and any subscriptions included in your Trackimo account. The legal ground for processing this data for this purpose is Trackimo’s legitimate interest in reducing the number of marketing emails sent to each particular customer by selecting which customers receive a particular marketing email rather than sending every marketing email to every customer who has consented to receiving marketing emails.
- (d) Trackimo also processes your email address to associate it with your Trackimo account when you interact with our customer support representatives. The legal ground for this processing is our legitimate interest in providing quality customer support.
Personal data that is processed when you sign in to your Trackimo account with Social Media Credentials if you choose:
- You may choose to sign in to your Trackimo account using your social media sign in credentials (e.g., your Facebook sign in credentials). If you choose to do this, the first time you do so you will be asked whether you agree that the social media provider may provide certain information to Trackimo, such as your name, email address, profile photo, posts, comments and other information associated with your social media account.
- All of this information is made available to Trackimo by the social media provider due to the way the social sign-on configuration works. However, the only information Trackimo retains and processes is your email address. If you do not want your information to be shared with Trackimo by the social media provider, then you can simply sign in to your Trackimo account using your Trackimo account credentials instead of your social media account credentials.
PURPOSE AND LEGAL GROUND:
- Trackimo associates the email address provided by the social media provider with your Trackimo account so that you can use your email address to sign in to your Trackimo account in the future if you no longer wish to sign in using your social media account credentials. The legal ground for processing this information for this purpose is Trackimo’s legitimate interest in providing you an alternative sign in method and in securing your account.
- Personal data that is processed when you sync your Trackimo device:
- When you sync your device, we log data about the transmission, such as the IP address used when syncing, the sync time and date, crash/diagnostic logs, geographic location of the device, information about your device, information about the network used to sync (e.g., Wi-Fi or cellular) and device battery level.
PURPOSE AND LEGAL GROUND:
- We process this information to help identify and resolve errors or syncing issues. The legal ground for processing this information for this purpose is Trackimo’s legitimate interest in resolving errors or syncing issues and providing quality product support.
Personal data that is processed when you communicate with Trackimo:
- When you interact with our customer support representatives via email, telephone, online or in person, we collect personal data, such as your name, mailing address, phone number, email address and contact preferences; and information about the Trackimo products you own, such as their device ID and date of purchase. We also may create event logs that are useful in diagnosing product or app performance-related issues, and capture information relating to the support or service issue. To improve customer service, subject to applicable laws, we may also record and review conversations with customer support representatives, and analyze any feedback provided to us through voluntary customer surveys. With your consent, our customer support representatives may sign in to your Trackimo account, if appropriate, to help troubleshoot and resolve your issue.
PURPOSE AND LEGAL GROUND:
We use this information to provide you with customer and product support and to monitor the quality and types of customer and product support we provide to our customers. The legal ground for processing this information for these purposes is Trackimo’s legitimate interests in providing quality product support. The legal ground for signing in to your Trackimo account, if appropriate, to help troubleshoot and resolve your issue is consent, which you may withdraw.
Personal data that is processed when you use your Trackimo auto navigation device or app:
- If you use a Trackimo device or app and provide your consent, then Trackimo will collect and upload from your device data such as location, speed, direction, and time and date of recording. If you provide your consent when asked, then Trackimo may also share this aggregated data with or sell this data to third parties to enhance the quality of the traffic, parking and other features enabled by content providers.
PURPOSE AND LEGAL GROUND:
- This data is aggregated with data from other consenting users and is used to enhance the quality of our products and apps and the traffic, parking and other features enabled by Trackimo or third parties. The legal ground for processing this data for this purpose is consent, which you may withdraw at any time within the settings of your Trackimo device or app.
Personal data that is processed when you purchase a product on a Trackimo website:
PURPOSE AND LEGAL GROUND:
- We collect your name, mailing address and telephone number so we can process your order and fulfill your purchase. The legal ground for processing your name, mailing address and telephone number for these purposes is performance of a contract. We also process your personal data as part of our fraud detection processes. The legal ground for processing your personal data for that purpose is our legitimate interest in protecting Trackimo and our customers from attempts to engage in fraudulent transactions.
Categories of Recipients of Personal Data
Your Tracki-friends invitees:
Tracki-friends is a feature available on some Trackimo devices that enables you to send a link to people of your choice that allows them to see the real-time location of your device. Because anyone with access to the link will be able to see the real-time location of your Trackimo device, you should use caution in determining to whom you want to send the link and be sure that you trust them to not send the link to others whom you do not want to be able to view the location of your Trackimo device.
Other service providers:
Trackimo uses cloud services from third parties to assist in sending emails. Those services track the activities associated with these emails, such as whether they were opened, whether links in the emails were clicked on, and whether purchases were made following clicks on those links. Trackimo uses this data to analyze the level of engagement with its emails. Trackimo uses third-party service providers to ship purchased products to customers and to help us better understand our customers needs.
Transfers of Personal Data
Trackimo is a global business. To offer our products, apps and services, we may need to transfer your personal data to other Trackimo companies in other countries. When you create a Trackimo account, add personal data in your account profile, or upload data to your Trackimo account, your personal data will be collected and stored on Trackimo servers in the United States or in Europe, as configured per your Trackimo device. Personal data regarding individuals who reside in a country in the European Economic Area or in Switzerland is controlled by Trackimo’s European Affiliate and processed on its behalf by Trackimo Inc.
Any transfers of personal data from Trackimo companies in the European Economic Area (“EEA”) or Switzerland to Trackimo Inc. in the United States are done pursuant to European Commission approved Model Contractual Clauses.
All Trackimo companies are required to follow the privacy practices set forth in this Privacy Statement.
Cookies and Similar Technologies
If you do not want information collected through the use of these technologies, there is a simple procedure in most browsers that allows you to automatically decline many of these technologies, or to be given the choice of declining or accepting them.
Trackimo Mobile apps:
We also collect data from users about their usage of Trackimo mobile apps. The types of analytical information that are collected include the date and time the app accesses our servers, app version, the location of the device, language setting, what information and files have been downloaded to the app, user behavior (e.g., features used, frequency of use), device state information, device model, hardware and operating system information, and information relating to how the app functions. Trackimo uses this data to improve the quality and functionality of our mobile apps, to develop and market products and features that best serve you and other users; and to help identify and fix app stability issues and other usability problems as quickly as possible.
The legal ground for processing this analytical information is our legitimate interest in understanding how our customers interact with our products, apps and websites so we can enhance the user experience and functionality of our products, apps and websites.
Here are examples of third-party providers of analytics and similar services we currently use:
- Google: Google Analytics is used to track site statistics and user demographics, interests and behavior on websites. We also use Google Search Console to help understand how our website visitors find our website and to improve our search engine optimization. Find out more information about how this analytics information may be used, how to control the use of your information, and how to opt-out of having your data used by Google Analytics.
Application Performance Monitoring:
Trackimo uses various software tools to analyze and monitor the performance of our complex ecosystem. To provide such services, our app receives basic request information, including IP address, necessary to detect and diagnose anomalous errors and response times.
The Trackimo device is not intended to be purchased by anyone under the age of 13 years old. When a parent and or legal guardian purchases a device for use by a child and to locate a child the parent is acknowledging that any personal information transmitted to Trackimo is solely the parents and not that of a child under the age of 13. We do not knowingly collect personal information from children under 13 years of age. If we learn that we have collected personal information from a child under age 13, we will delete that information as quickly as possible. If you believe that we might have any information from a child under age 13, please contact us through firstname.lastname@example.org
Retention of Personal Data
We will retain your personal data as long as your Trackimo account is considered to be active. In addition, see below under “Your Rights” for a description of your right of erasure.
Data Controller and Data Protection Officer
If you reside in a country in the European Economic Area or in Switzerland, then your personal data collected by Trackimo is controlled by Trackimo Europe, which is located within the offices of NDM Network GmbH, at addredd: Grafenberger Allee 277-287 , 40237 Duesseldorf, Germany.
Trackimo’s EU Data Protection Officer is located at the same address and can also be reached by email at email@example.com.
If you reside outside of the European Economic Area and Switzerland, then the personal data collected by Trackimo is controlled by Trackimo, Inc., 450 Seventh Ave NYC NY 10123 which you can also contact by email at firstname.lastname@example.org
If you reside in the European Union, you have the right under the General Data Protection Regulation to request from Trackimo access to and rectification or erasure of your personal data, data portability, restriction of processing of your personal data, the right to object to processing of your personal data, and the right to lodge a complaint with a supervisory authority. If you reside outside of the European Union, you may have similar rights under your local laws.
To request access to or rectification, portability or erasure of your personal data, or to delete your Trackimo account, write your request by email to email@example.com and make sure to include all the details about your Trackimo account such as the log-in email and the device ID(s) of your Trackimo devices.
If you live in the European Union and you wish to exercise your right to restriction of processing or your right to object to processing, contact Trackimo’s EU Data Protection Officer at Trackimo Europe in Germany or by email at firstname.lastname@example.org. If you do not live in the European Union but you believe you have a right to restriction of processing or a right to object to processing under your local laws, please contact Trackimo, Inc. at privacy@Trackimo.com.