Privacy and Data Policy

ISSUED BY TRADETRACKER

Last Updated: 6th January 2020

1. Introduction and general terms

These terms apply to the websites and other products offered by TRADETRACKER INTERNATIONAL B.V. and its subsidiaries referring to this policy (‘TT’/‘we’/‘us’). Our registered office is at De Strubbenweg 7, 1327 GA Almere, Netherlands. We are a company registered in the Netherlands, with company number 39092006.

This privacy and data policy (“Privacy Policy”) applies and has effect in respect of all online services and other software and services made available by us (together the "Service(s)"), as well as any other online features relating to the Services including our websites for events and product promotions (the “Websites”).  Together the Service(s) and Website(s) are referred to as the “Online Services”.

If you have any questions or comments about this Privacy Policy or if  you would like to opt-out from tracking, please contact us at privacy@tradetracker.com. For more information about our cookies and how we use them, please refer to this page 'How we use cookies' or About Cookies if you're looking for  information about cookies in general.

We are committed to protecting and respecting your privacy. The Privacy Policy explains the basis on which personal information we collect from you will be processed by us or on our behalf. Where we decide the purpose or means for which personal data you supply through these Online Services is processed, we are the “data controller”. We will comply with all applicable data protection laws, including the General Data Protection Regulation2016/679.

In some instances, we may be a joint data controller, with advertisers and publishers which participate in our network from time to time (our “Partners”).  You can find information on our Partners on our Websites. If you would like to know more about how one of our Partners makes use of your personal data, please ask to see their privacy policy.

Please read this Privacy Policy carefully as it contains important information about the following:

- What information we may collect about you;

- How we will use information we collect about you;

- Whether we will disclose your details to anyone else; and

- Your choices and rights regarding the personal information you have provided to us.

This Privacy Policy forms a part of and should be read in conjunction with our terms of use in respect of the Service, if you have entered them in a personal capacity.

If you would like to know more about how we use cookies, please view our cookie policy which can be found оn page How we use cookies.

Our Website may contain hyperlinks to services owned and operated by third parties. These third party services may have their own privacy policies and we recommend that you review them. We do not accept any responsibility or liability for the privacy practices of such third party services and your use of these is at your own risk.

We may make changes to this Privacy Policy in future, which will be posted on this page. You should check this page from time to time to ensure you are aware of any changes. Where appropriate we may notify you of changes through the Services.

2. Our online services

We operate an affiliate marketing network. This means we have established a network of online merchants who want to promote their products and services online, and we are able to connect them with a network of online publishers which are able to display advertisements for those products and services. Publishers may operate websites, apps or other (digital)services.

Our role is to help advertisers and publishers understand which advertisements displayed by publishers have generated which sales, leads or other actions for advertisers. This allows advertisers to pay a publisher only when the advertisement displayed (or any alternative required action) by the publisher refers an individual to the advertiser and that individual makes a purchase.

We use data, including cookies, to achieve this understanding. This data relates to individuals, but does not identify them by name. It relates to a single referral by an individual from one website to another, and then a confirmation that a purchase was made.  We also maintain a database of references to individual’s devices, so that we can understand whether an advertisement viewed on one device, for example a phone, caused a purchase to be made by that individual on one of their other devices, for example a laptop.  This database does not allow people to be identified by name.

We do not build profiles which show individuals internet usage over a period of time. We also do not target individuals with advertisements for products and services based on their perceived interests. Our role is simply to measure the effectiveness of specific online advertisements.

Therefore, if you click on an advertisement on one website, and then complete a transaction on the website to which you were referred, we may process your personal data so the publisher of the advertisement can be paid for displaying that advertisement.

If you would like to know more about our Services and how we comply with data laws, you can read  our Whitepaper.

We also operate our own website and we consider how users navigate that website so we can improve it, make it more useful and appealing, and remove bugs or other errors.

3. Information we may collect about you

When you use our Online Services we collect and process the following information which may include your personal data.

Information provided by you when using Partner Websites

(“Partner Information”)

We will maintain a record of your journey from one website to another for up to 365 days, and also a confirmation of whether you have completed a purchase from the second website as a result of that journey.

This takes the form of a cookie, and other information to allow us to identify your devices. This may be achieved by recording device IDs or by recognising combinations of device attributes.

Finally, advertisers will tell us information about what products and services you may have bought, but they do not provide information that could allow us to identify you.

Information collected for the purposes of providing analytics (“Analytics”)

We may collect technical information about your use of the Website through the use of tracking technologies and analytics. This information does not allow us to identify you.

4. Why we collect information about you

To provide our Services

We will use Partner Information to provide our Services to Partners, as described above. We also use Partner Information to prevent fraud.

We do this on the basis that it is in our legitimate interests to do so, having considered any consequent impact on your rights to privacy.

In some instances, advertisers ask us to collect other data from their website and relating to website users. We only do this on instruction from our advertisers.

To operate our Website

We will use Analytics for delivering our Website to you. This may include learning how individuals tend to use our Website, so we can make improvements. We do this on the basis that it is in our legitimate interests to do so, having considered any consequent impact on your rights to privacy.

5. Data sharing

We will share your information with third parties only in the ways that are described in this Privacy Policy

Partners: We are engaged by Partners to provide Services to them. You may have submitted Partner Information to us as part of your use of any of our Partners websites or other online services. We will share that data with the Partner in accordance with any agreements we have entered with the Partner.

Group members, personnel, suppliers or subcontractors: We keep your information confidential, but may disclose it to any member of our group (which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006), our personnel, suppliers or subcontractors insofar as it is reasonably necessary for the purposes set out in this Privacy Policy. However, this is on the basis that they do not make independent use of the information, and have agreed to safeguard it.

Required by law: In addition, we may disclose your information to the extent that we are required to do so by law (which may include to government bodies and law enforcement agencies); in connection with any legal proceedings or prospective legal proceedings; and in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention).

Enforcement: We may also disclose your personal information to third parties in order to enforce or apply the terms of agreements, to investigate potential breaches, or to protect the rights, property or safety of TradeTracker.com, our customers, or others.

6. Your rights in relation to personal data which we process relating to you

You have the following rights over the way we process personal data relating to you, as set out below. We aim to comply without undue delay, and within one month at the latest.

To make a request, please let us know by sending an email to privacy@tradetracker.com.

Ask for a copy of data we are processing about you and have inaccuracies corrected

You have the right to request a copy of the personal information we hold about you and to have any inaccuracies corrected.

We will use reasonable efforts to the extent required by law to supply, correct or delete personal information held about you on our files (and with any third parties to whom it has been disclosed to).

Object to us processing data about you

You can ask us to restrict, stop processing, or to delete your personal data if:

- you consented to our processing the personal data, and have withdrawn that consent;

- we no longer need to process that personal data for the reason it was collected;

- we are processing that personal data because it is in the public interest or it is in order to pursue a legitimate interest of TT or a third party, you don’t agree with that processing, and there is no overriding legitimate interest for us to continue processing it;

- the personal data was unlawfully processed;

- you need the personal data to be deleted in order to comply with legal obligations;

Obtain a machine readable copy of your personal data, which you can use with another service provider

- If we are processing data in order to perform our obligations to you, or because you consented, if that processing is carried out by automated means, we will help you to move, copy or transfer your personal data to other IT systems.

- If you request, we will supply you with the relevant personal data in CSV format. Where it is technically feasible, you can ask us to send this information directly to another IT system provider if you prefer.

If you deem this appropriate, you have the right to file a complaint with the Data Protection Authority.

7. Data retention

We will hold your personal information on our systems for as long as is necessary for the relevant service, or as otherwise described in this Privacy Policy.

8. Children

We do not use our Online Services to knowingly solicit information from or market to children under the age of 13. Our terms of use prohibit users aged under 13 years from accessing our Online Services. In the event that we learn that we have collected personal information from a child under 13 years of age we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13 years of age please contact us at privacy@tradetracker.com.

9. Security

We will take all reasonable technical and organisational precautions to prevent the loss misuse or alteration of your personal information. For example, our databases are password protected and limited to essential employees only (such as TradeTracker management or employees whose main role requires system access).

Please be aware that, although we endeavour to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches.

10. International data transfers

Our servers are located in Ireland.

It is possible that your personal information may be transferred outside of the EU by any of our Partners. We recommend that you refer to their privacy policies and/or terms and conditions if you are concerned about your data being transferred outside the EU.

Where we transfer your information outside of the EU, we have agreements in place with those parties which include standard data protection clauses adopted by a data protection regulator and approved by the European Commission to ensure that appropriate safeguards are in place to protect your personal data. If you would like to find out more about these safeguards, please let us know by writing to privacy@tradetracker.com.

Contact information

All questions, comments or enquiries should be directed to TradeTracker at privacy@tradetracker.com. We will endeavour to respond to any query or questions within five business days.

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