TRAKITRAK PRIVACY POLICY

I.Introduction / II. Overview / III. Data collections and uses / IV. Choice and transparency / V. Updates to the policy.

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I. Introduction / II. Overview / III. Data collections and uses / IV. Choice and transparency / V. Terms for certain jurisdictions / VI. Updates to this policy

I. Introduction

When you use TrakiTrak, you trust us with your personal data. We’re committed to keeping that trust. That starts with helping you understand our privacy practices.

We recommend that you read this policy to learn more about the personal data we collect, how it’s used and shared, and your choices regarding this data.

Use of TrakiTrak apps, websites, products or other services made available is at all times subject to our Terms of Use or Shopper Terms and Conditions, as applicable, each of which incorporates this Privacy Policy. Any terms we use in this Privacy Policy without defining them have the definitions given to them in the Terms of Use or Shopper Terms and Conditions, as applicable.

Last modified: January 15, 2024

II. Overview

A. Scope

This policy describes how TrakiTrak and its affiliates collect and use personal data. This policy applies to all users of our apps, websites, features, or other services anywhere in the world.

Our practices are subject to applicable laws in the places in which we operate. This means that we engage in the practices described in this policy in a particular country or region only if permitted under the laws of those places.

This policy also governs TrakiTrak other collections of personal data in connection with its services. For example, we may collect the contact information of owners or employees of stores or other merchants.

All those subject to this policy are referred to as “users” in this policy.

B. Data controller and transfer

Delivery Technologies, S.A.R.L., is the data controller for the personal data collected in connection with accessing or using the services.

Questions, comments, and complaints about TrakiTrak’s data practices can be submitted to our Data Protection Officer at [email protected].

III. Personal data collections and uses

A. Sources of personal data

The following personal data is collected by or on behalf of TrakiTrak:

1. Data provided by users. This includes:

  • when users provide such information directly to us, and

  • when personal data about users is automatically collected in connection with access to or use of the services, such as through our use of cookies when users use our Platform.

2. Data provided by third parties

  • when they provide us with personal data about users. Third Parties that share user personal data with us include service providers. For example, we may use analytics service providers to analyze how users interact and engage with the services, or third parties may help us provide users with customer support.

3. Data provided by networks connected to our Platform

  • when users provide your third-party account credentials to us or otherwise sign in to access or use the services through a third-party site or service (such as Facebook), some content and/or information in those accounts may be transmitted into a user’s account with us.

B. Categories of personal data

The following categories of personal data are collected by or on behalf of TrakiTrak:

  • Personal identifiers, including name, email address, telephone number, delivery address/current location . We collect personal identifiers from users, third parties and affiliates.

  • Information protected against security breaches under state law, including name, email address, telephone number, delivery address/current location, payment information (including card number). We collect such information from users, third parties and affiliates.

  • Commercial information, including purchase details and history. We collect commercial information from users.

  • Internet or other similar network activity information, including Interactions with the Platform, Cookies, device data (such as device ID, manufacturer, operating system, language), search, and purchase history.

  • Geolocation data, including current location, which you can choose whether or not to share. We collect geolocation data from users.

  • Sensory data, including customer service calls (voice recordings), which we collect from users.

C. How we use personal data

We use personal data to operate, improve, understand and personalize the services, including:

  • To meet or fulfill the reason you provided the information to us.

  • To communicate with you about the services, including service announcements, updates or offers.

  • To provide support and assistance for the services.

  • To create and manage your account.

  • To personalize website content and communications based on your preferences, including targeted offers and ads served through the services.

  • To process orders or other transactions, including payment transactions.

  • To respond to user inquiries and fulfill user requests.

  • To improve and develop the services and Platform, including testing, research, analysis and product development.

  • To protect against or deter fraudulent, illegal or harmful actions and maintain the safety, security and integrity of the services.

  • To comply with our legal or contractual obligations, resolve disputes, and enforce our Terms of Use.

  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

  • For any other business purpose stated when collecting your personal data or as otherwise set forth in applicable data privacy laws.

D. Cookies and third-party technologies

TrakiTrak uses cookies and similar technologies such as pixel tags, web beacons, clear GIFs, and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser and tell us how and when you visit and use the services, to analyze trends, learn about our user base and operate and improve the services. Cookies are small pieces of data– usually text files – placed on your computer, tablet, phone, or similar device when you use that device to visit the Platform. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s). Please note that because of our use of Cookies, the Platform does not support “Do Not Track” requests sent from a browser at this time.

We use the following types of Cookies:

  • Essential Cookies, which are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of the Platform. Disabling these Cookies may make certain features and services unavailable.

  • Functional Cookies, which are used to record your choices and settings regarding the services, maintain your preferences over time and recognize you when you return to the Platform. These Cookies help us to personalize our content for you, greet you by name, and remember your preferences (for example, your choice of language or region).

  • Performance/Analytical Cookies, which allow us to understand how visitors use the services such as by collecting information about the number of visitors to the Platform, what pages visitors view on the Platform and how long visitors are viewing pages on the Platform. Performance/Analytical Cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the services’ content for those who engage with our advertising.

Google, Inc. (“Google”) uses cookies in connection with its Google Analytics services. Google’s ability to use and share information collected by Google Analytics about your visits to the Platform is subject to the Google Analytics Terms of Use and the Google Privacy Policy. You have the option to opt-out of Google’s use of cookies by visiting the Google advertising opt-out page at https://policies.google.com/technologies/ads or the Google Analytics Opt- out Browser Add-on at https://tools.google.com/dlpage/gaoptout/

You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your computer. If you do this, however, you may have to manually adjust some preferences every time you visit a site and some services and functionalities may not work.

To explore what Cookie settings are available to you, look in the “preferences” or “options” section of your browser’s menu. To find out more information about Cookies, including information about how to manage and delete Cookies, please visit https://www.allaboutcookies.org/

For mobile users, you have controls in your device's operating system that enable you to choose whether to allow cookies, or share your advertising ID with companies like Trakitrak or our advertising service providers. For information on controlling your mobile choices, you can visit https://thenai.org/opt-out/mobile-opt-out/

E. Data sharing and disclosure

1. Purposes of data disclosure

TrakiTrak may share personal data for the purposes of:

  • Auditing related to a current interaction and concurrent transactions.

  • Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.

  • Debugging to identify and repair errors that impair existing intended functionality.

  • Short-term, transient use of personal data that is not used by another party to build a consumer profile or otherwise alter your consumer experience outside the current interaction.

  • Performing services on our behalf, a retailer store’s behalf or an advertiser’s behalf, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider.

  • Undertaking internal research for technological development and demonstration.

  • Undertaking activities to verify or maintain the quality or safety of a service or device that we own or control.

  • Complying with any legal obligation or regulatory requirement.

  • Enforcing our contractual terms with users and any other agreement.

  • Protecting our rights or the rights of others, including to prevent fraud or other crimes.

2. Recipients of personal data

TrakiTrak may share personal data with:

  • Service providers, including:

    • Payment processors

    • Security and fraud prevention consultants

    • Legal and other professional advisors

    • Hosting and other technology and communications providers

    • Analytics providers

    • Contract personnel

  • Parties who acquire your personal data through an acquisition or other change of control. Personal data may be transferred to a third party if we undergo a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of TrakiTrak assets, whether as a going concern (such as through an acquisition), or as part of a bankruptcy, liquidation, or similar proceeding or transaction in which that third party assumes control of our business (in whole or in part).

  • Other parties at your direction or with your consent, including:

    • Other users (where you post information publicly or as otherwise necessary to effect a transaction initiated or authorized by you through the services), which may include Shoppers and/or drivers.

    • Third-party business partners who you access through the services, such as retail stores and advertisers.

    • Other parties authorized by you.

  • Parties that require personal data to be disclosed for legal reasons (such as pursuant to subpoenas or other legal process).

F. Data retention

We retain personal data about you for as long as you have an open account with us or as otherwise necessary to provide you services or fulfil the purposes for which we have collected the personal data, and afterwards for six (6) months to respond to any follow-up questions or concerns relating to your account. Thereafter, we may retain personal data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. Afterwards, we may retain some information in a depersonalized or aggregated form but not in a way that would identify you personally.

G. Account safety

We recommend appropriately selecting and protecting your password and/or other sign-on mechanism, limiting access to your computer or device and browser, and signing off after you have finished accessing your account to help keep your account safe. Although we work to protect the privacy of your account and other personal data that we hold in our records, no method of transmitting data over the Internet or storing data is completely secure. We cannot guarantee the complete security of any personal data you share with us, and we are not responsible for the theft, destruction, loss or inadvertent disclosure of your information or content except as otherwise required under applicable law.

IV. Choice and transparency

A. Device permissions

Most mobile device platforms (iOS, Android, etc.) have defined certain types of device data that apps cannot access without the device owner’s permission, and these platforms have different methods for how that permission can be obtained. Please check the available settings on your device or check with your provider.

B. Marketing and notification choices

We may communicate with you if you’ve provided us the means and any legally required consent to do so. For example, if you’ve given us your email address, we may send you promotional email offers or email you about your use of the services.If you wish to revoke your consent or do not wish to receive communications from us, indicate your preference by contacting our support both in chat and at our email [email protected] to request the stop of sending notifications. You may also opt out of receiving emails and other messages from TrakiTrak by following the unsubscribe instructions in those messages. Please note that if you decline to receive essential account communications (such as receipts), you may no longer be able to use some or all features of the services.

C. To delete your account

  • Open the app and login into your account, then navigate to "Profile" under the “Account” section,

  • Initiate account deletion by selecting the option to delete your account,

  • Follow the prompts to confirm your account deletion request. Please note that upon confirmation, your account will be permanently deleted. However, to permanently delete your personal information previously collected by us, please send an email to [email protected].

V. Updates to this policy

We may occasionally update this policy. If we make significant changes, we will notify users in advance of the changes through the TrakiTrak app or through other means, such as email. We encourage users to periodically review this policy for the latest information on our privacy practices.

Use of our services after an update constitutes consent to the updated policy to the extent permitted by law.

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