Details on how Trackflow processes and stores your data.
Last updated: October 7, 2020
Trackflow Inc. provides a software solution that monitors api logs in mobile applications and programs under the direction of its Customers, to provide session, error and crash data. We know you care about how your Personal Information is used and shared and we take your privacy seriously.
This Policy applies to all Trackflow’s operating divisions and affiliates, and any additional subsidiary or affiliate of Trackflow that we may subsequently form. Trackflow has put in place mechanisms to verify ongoing compliance with this Policy. Any Trackflow employee who violates this Policy will be subject to disciplinary procedures.
The types of Personal Information we may collect (directly from you or from Third-Party sources) and our privacy practices depend on the nature of the relationship you have with Trackflow and the requirements of applicable law. Some of the ways that Trackflow may collect Personal Information include:
We endeavor to collect only that information which is relevant for the purposes of Processing. Below are the ways we collect Personal Information and how we use it.
Trackflow collects Personal Information regarding its current, prospective, and former clients, customers, users, visitors, and guests (collectively “Individuals”).
Information You Provide Directly to Us. When you use the Services or engage in certain activities, such as registering for an account with Trackflow, purchasing a Plan from Trackflow, requesting Services or information, or contacting us directly through the “Contact Us” feature or by some other method, we may ask you to provide some or all of the following types of information:
Information from Other Sources. We may receive information about you from other sources, including through Third Party services and organizations to supplement information provided by you (for example, lead or data enrichment services). This supplemental information allows us to verify information that you have provided to Trackflow and to enhance our ability to provide you with information about our business, products, and Services. Through cookies we place on your browser or device, we may also collect information about your online activity after you leave our Site. We use this information to improve the Site and customize your online experience.
Event Data Information. The Trackflow Services monitor errors in web, mobile and server applications and programs under the direction of its Customers, to provide session, error and crash data (“Event Data”). We discuss this in more detail in Section 3.2.
No Sensitive Data or Sensitive Personal Information. Trackflow does not collect Sensitive Data as defined under the laws of the European Union.
Each Trackflow Customer provides Trackflow with Event Data and in some cases this Event Data may include Personal Information of the individuals who use the Customer’s applications. Not all Customers provide Personal Information about their end users to Trackflow. Customers can use the Services dashboard to control or block the use of end user Personal Information by the Services.
Trackflow itself does not collect this end user Personal Information provided with Event Data and Trackflow has no direct relationship with these individuals. For example, a Customer may direct Trackflow to log certain software application’s end user information associated with Event Data, such as the end user’s device ID, email and name. Trackflow is a data processor and follows the instructions of the Customer in these cases.
To find out more about how our Customers issue these instructions to us and handle this Personal Information you will need to review the privacy policies of each Customer. An individual who wants to correct, amend or delete inaccurate data should direct his or her request to Trackflow’s Customer (the data controller). Separately, if our Customer requests that we remove Event Data from the Services then we will respond promptly to this request.
If you are a Customer then you are responsible for obtaining permission from your end users to share any data that may contain the end users’ Personal Information with the Trackflow Platform.
We acquire, hold, use, and Process Personal Information about Individuals for a variety of business purposes, including:
To Provide Products, Services, or Information Requested. Trackflow may use information about you to fulfill requests for products, Services, or information, including information about potential or future Services, including to:
Administrative Purposes. Trackflow may use Personal Information about you for its administrative purposes, including to:
Marketing Trackflow Products and Services. Trackflow may use Personal Information to provide you with materials about offers, products, and Services that may be of interest, including new content or Services. Trackflow may provide you with these materials by phone, postal mail, facsimile, or email, as permitted by applicable law. Such uses include:
You may contact us at any time to opt-out of the use of your Personal Information for marketing purposes, as further described in Section 5 below.
Research and Development. Trackflow may use Personal Information to create non-identifiable information that we may use alone or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our existing products and Services or develop new products and Services. For example, we use survey responses to help us better serve Individuals by learning more about their needs and the quality of the products and Services we provide. We also may share anonymous aggregate data for research and analysis purposes.
Direct Mail, Email and Outbound Telemarketing. Individuals who provide us with Personal Information, or whose Personal Information we obtain from Third-Parties, may receive periodic emails, newsletters, mailings, or phone calls from us with information on Trackflow’s or our business partners’ products and services or upcoming special offers/events we believe may be of interest. We offer the option to decline these communications at no cost to the Individual by following the instructions in Section 5 below.
Business Partners. Trackflow may share Personal Information with our business partners, and affiliates for our and our affiliates’ internal business purposes or to provide you with a product or Service that you have requested. Trackflow may also provide Personal Information to business partners with whom we may jointly offer products or services, or whose products or services we believe may be of interest to you. In such cases, our business partner’s name will appear, along with Trackflow. Trackflow requires our affiliates and business partners to agree in writing to maintain the confidentiality and security of Personal Information they maintain on our behalf and not to use it for any purpose other than the purpose for which Trackflow provided them.
Disclosures to Protect Us or Others (e.g., as Required by Law and Similar Disclosures). We may access, preserve, and disclose your Personal Information, other account information, and content if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) respond to your requests; (iii) protect yours’, ours’ or others’ rights, property, or safety; (iv) to enforce Trackflow policies or contracts; (v) to collect amounts owed to Trackflow; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if we, in good faith, believe that disclosure is otherwise necessary or advisable.
In addition, from time to time, server logs may be reviewed for security purposes – e.g., to detect unauthorized activity on the Services. In such cases, server log data containing IP addresses may be shared with law enforcement bodies in order that they may identify users in connection with their investigation of the unauthorized activities.
Law Enforcement. Your Personal Information may also be accessible to law enforcement or other authorities pursuant to a lawful request.
We have implemented safeguards to ensure an adequate level of data protection where Personal Information of residents of the EEA is transferred to countries outside the EEA, such as standard contractual clauses for the transfer of Personal Information as approved by the European Commission (Art. 46 GDPR). As applicable, Trackflow relies upon standard contract clauses, the European Commission’s adequacy decisions about certain countries, and your consent for these data transfers. Please note that although the Court of Justice of the European Union has invalidated the EU-US Privacy Shield Framework as a mechanism for transfers of Personal Information between the EU and US in Case C-311/18, Trackflow remains committed to complying with the Privacy Shield Principles.
When we receive formal written complaints regarding the transfer of your Personal Information we respond by contacting the person who made the complaint. We work with the appropriate regulatory authorities, including local data protection authorities, to resolve complaints we cannot resolve directly with you.
You have the right to opt-out of certain uses and disclosures of your Personal Information. Where you have consented to Trackflow’s Processing of your Personal Information or Sensitive Personal Information, you may withdraw that consent at any time and opt-out to further Processing by contacting us at email@example.com.
Trackflow may occasionally send you push notifications through our mobile applications with information that may be of interest to you. You may at any time opt-out from receiving these types of communications by changing the settings on your mobile device. Trackflow may also collect location-based information if you use our mobile applications. You may opt-out of this collection by changing the settings on your mobile device.
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
Although Trackflow makes good faith efforts to provide Individuals with access to their Personal Information, there may be circumstances in which Trackflow is unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the Individual’s privacy in the case in question or where it is commercially proprietary. If Trackflow determines that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, Trackflow will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.
By using the Site or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Site. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Site or sending an e-mail to you. You may have a legal right to receive this notice in writing.
The Services are not directed to children under 13 (and in certain jurisdictions in the EU under the age of 16) years of age, and Trackflow does not knowingly collect Personally Identifiable Information from children under 13 (and in certain jurisdictions in the EU under the age of 16) years of age. If you are under the age of 18, you must have your parent’s permission to access the Services. Trackflow urges parents to instruct their children never to give out their real names, addresses, or phone numbers, without parental permission, when online. If you learn that your child has provided us with Personal Information without your consent, you may alert us at firstname.lastname@example.org. If we learn that we have collected any Personal Information from children under 13 (and in certain jurisdictions in the EU under the age of 16), we will promptly take steps to delete such information and terminate the child’s account.
By email: email@example.com
The following capitalized terms shall have the meanings herein as set forth below.