1000TRAX respects your privacy. This Privacy Statement describes your privacy rights and our obligation to secure your personal data.
1000TRAX is a European company with legal entities, business processes, management structures and technical systems across borders. 1000TRAX provides software and services to private companies (Customers) in Europe. 1000TRAX's head office is located 83 Roberts Road
Colchester, Essex, CO2 7FQ in United Kingdom, and 1000TRAX is subject to European Personal Data Law, including the General Data Protection Regulation (GDPR).
Scope and acceptance
This Privacy Statement applies to all business processes and to all 1000Trax websites, domains, mobile solutions, cloud services and communities, and 1000Trax branded websites. Service-specific supplements can be found in 1000TRAX Terms, Data Processing Agreements or equivalent information for that specific service.
The Privacy Statement provides information about the data processing carried out by 1000TRAX when 1000TRAX determines for what purpose and assistive means the processing is carried out (1000TRAX acts as controller). It also provides information about the data processing that 1000TRAX performs on behalf of our Customers based on their instructions (Customer as Data Controller and 1000TRAX as Data Processor).
Personal data is information that can identify you as a person, such as email address, postal address or telephone number, etc. It is necessary for us to process your personal data in order to serve our Customers. Please do not use 1000TRAX Pages or our Mobile App if you are unable to accept the way we process personal data under this Privacy Statement.
Who's data we process
— Who's personal data does 1000TRAX process?
1000TRAX processes personal information about contacts or software users associated with our Customers. We also process personal data about people who make up potential Customers (Leads) and who address us through 1000TRAX Pages or through other channels. Our statement in these respects can be found in the section '1000TRAX as data controllable'.
We also process data on behalf of our Customers, where the Customer controls the processing. Our statement in these respects can be found in the section '1000TRAX as data processor. '
In this Privacy Statement, data subjects may also be referred to as persons or you/you.
1000TRAX as a Data Controller
— How does 1000TRAX process personal data in its role as a data controller?
1000TRAX acts as a data controller in scenarios where 1000TRAX collects personal data, in the context of you being a representative of a Customer or a Level, or when you are a software user.
Why we process personal data
About Customer Contacts and Software Users
In order to generally manage our Customer Relations and to meet our Customer obligations, 1000TRAX needs information about you in your role as a Customer Contact or User of a Service. The purposes of processing this personal data are:
(a) to carry out the sales and contract process to Customers
(b) provide the requested offers of products and services to Customers
(c) to complete deliveries in accordance with agreements concluded with you or Customers
d) to offer support to users of our products and services
e) improve and develop the quality, functionality and user experience of our products, services and 1000TRAX Pages
(f) detect, limit and prevent security threats and carry out maintenance, troubleshooting and debugging
(g) prevent misuse of our products and services;
(h) process orders, invoicing, payments and other financial follow-up
(i) to create interest profiles to promote relevant products and services;
The legal basis for processing personal data according to the purposes stated above in letter (a) to (i) is primarily based on the fact that from a business perspective 1000TRAX has a legitimate interest in processing your personal data in a manner which, in our opinion, is not in conflict with your rights regarding privacy and self-determination.
1000TRAX processes personal data on Leads for marketing purposes. In order to deliver targeted and relevant content to potential Customers, 1000TRAX builds an interest profile based on your activity and choices and actions on 1000TRAX Pages as well as your response to marketing content by email. The legal basis for such processing is primarily your consent.
In the sections below you can read how we form such profiles, how you can adjust the profile, as well as how to revoke your consent.
About Software User
You are a Software user when you, as a registered user, use 1000TRAX or 1000TRAX Mobile App. The legal basis for such processing is your consent.
How we collect your personal data
Generally, 1000TRAX collects personal data directly from you or other persons associated with our Customer. These individuals can be a manager or colleague.
In some cases, we may also collect information about you from other sources. These sources may be 1000TRAX's marketing partners, public sources or third-party social networks. 1000TRAX will be able to combine personal data about you collected from one source with information obtained from another source. This gives us a more complete picture of you, which also allows us to serve you in a more relevant way with a higher level of personalization.
What personal data we process
The type of personal data 1000TRAX processes about you may be:
> Basic contact information, such as name, address, phone number and email
> Feedback, comments or questions regarding 1000TRAX or our products and services
> Usage Patterns in Listening Behavior.
> Unique user information, such as login ID, username, password and security questions
> Financial information, such as credit card information
> ClickStream behavior and activity on 1000TRAX Pages and in our products and services
> Email behavior, such as which emails from 1000TRAX you open when and how
> Other personal data contained in your profile that you have freely provided on third-party social networks, such as LinkedIn etc.
As a data controller, 1000TRAX does not process sensitive personal data about you.
How we share your personal data
1000TRAX may share your personal data with external third parties in the following contexts:
1000TRAX may share your personal information with our partners if this is legitimate from a business perspective and is in accordance with applicable data protection laws. For example, if you purchase, on behalf of your employer, a product or service that 1000TRAX provides through one of our certified partners. In this regard, 1000TRAX and our partner may share personal data in order to be able to provide the product or service to the Customer.
Police and other authorities may require personal information from 1000TRAX to be handed over. In these cases, 1000TRAX will only disclose the information if there is a court order, etc., bidding to do so.
What rights do you have?
The right to opt out of marketing communications.
You can unsubscribe from 1000TRAX news emails and marketing at any time with a click on our link in our newsletter or by writing to email@example.com
Please note that even if you opt out of receiving marketing communications, you may still receive administrative notices from 1000TRAX, such as order confirmations and notifications necessary to manage your account or the services provided to our Customers.
You have the right to access your personal data by requesting an overview of personal data about you, and you may have a right to data portability. You also have the right to request 1000TRAX to correct inaccuracies in your personal data. If you have an account with 1000TRAX, this can usually be done through the appropriate “your settings” or “your profile” sections on the appropriate 1000TRAX Page or in the application.
You also have the right to request the deletion of personal data and to limit or object to our processing of your personal data under this Privacy Statement or other service-specific terms.
Please use firstname.lastname@example.org to submit all requests as mentioned in this section. Finally, you also have the right to lodge a complaint with the Data Protection Authority regarding our processing of your personal data.
Data security and storage
— How does 1000TRAX secure and store your personal data?
How we secure your personal data
1000TRAX takes the trust you and our Customers show us very seriously. 1000TRAX undertakes to avoid unauthorized access, disclosure or other deviant processing of personal data. 1000TRAX must ensure the confidentiality of the personal data we process, maintain integrity of personal data and ensure its availability in accordance with applicable privacy laws.
As part of our obligations, we take reasonable and appropriate organizational, technical and physical procedures and precautions to protect the information we collect and process, taking into account the type of personal data and the risk you and our Customers are exposed to by As there is a high likelihood that the root causes of personal data breaches can be found internally, we believe that building a strong corporate culture where respect for and vigilance about data protection among our employees is fundamental to to ensure the lawful processing and protection of your information. The following precautions are of particular importance in this regard:
> E-learning courses in data protection, which are mandatory for all employees.
> Data processing agreements with subcontractors that process data on behalf of 1000TRAX.
> Classification of personal data that ensures the implementation of security measures at the level of risk assessment.
> Assess the use of encryption and pseudonymization as risk mitigation measures.
> Restrict access to personal data to those persons who need it for the fulfillment of obligations arising from agreements or legislation concluded, etc.
> Use systems that detect, prevent and warn of any breach of personal data security.
> Use security reassessments to analyze whether existing technical and organizational measures are sufficient for the protection of personal data in the light of the requirements set out in applicable data protection legislation.
> Locations are protected by access control and video surveillance systems.
How long do we keep your personal data?
1000TRAX will retain your personal data only for as long as necessary for the purposes stated, while taking into account our need to respond to inquiries and resolve issues and comply with legal requirements under applicable law.
This means that 1000TRAX may retain your personal data for a reasonable period of time after your and our Customer's last interaction with us. When the personal data we have collected is no longer needed, we delete it. We may process data for statistical purposes, but in such cases the data will be pseudonymized or anonymized.
1000TRAX as a data processor
— How does 1000TRAX process personal data in its role as a data processor?
1000TRAX provides many different services to our Customers. Most of our services involve processing Customers' data, including their personal data. The purposes of processing are determined by our customers, not by 1000TRAX. This makes the Customer the controller. In such cases 1000TRAX acts as a data processor and processes the data on behalf of and in accordance with instructions given by the Customer. The relationship between the Customer as Data Controller and 1000TRAX as Data Processor shall be governed by a Data Processor Agreement.
Customer's and 1000Trax's liabilities
When the Customer acts as Data Controller, the Customer shall, in accordance with applicable data protection laws, ensure the legal basis for processing personal data. The customer must also assess and establish the ownership of the risks to which data subjects are exposed through the processing of their personal data. Another important aspect of Customer's obligations as data controller is to comply with the disclosure obligation in relation to data subjects.
1000TRAX is a natural part of Customer's obligations as Data Controller in the sense that 1000Trax's services constitute parts of the processing of personal data that the Customer must ensure is in compliance with applicable data protection laws. Thus, when 1000TRAX processes personal data on behalf of its Customers, we must do so in accordance with applicable data protection laws for data processors.
In short, the Customer and 1000TRAX are obliged to cooperate to ensure the privacy of data subjects. 1000TRAX provides the necessary information to the Customer so that it can act in accordance with applicable data protection laws.
Subcontractors and export of personal data
— To what extent does 1000TRAX use subcontractors?
1000TRAX uses subcontractors to process personal data and, in this regard, may export your or our Customers' data to a non-EU location. These subcontractors are typically vendors of cloud services or other IT hosting services.
When using subcontractors, 1000TRAX will enter into a data processing agreement (DPA) with subcontractors to secure your personal data rights and to fulfill our obligations to our Customers. When subcontractors are located outside the EU, 1000TRAX ensures the legal basis for such international transfers on behalf of you or our Customers, including by endorsing Privacy Shield (US) or by making use of EU Model Clauses.
1000TRAX supports some strategic external third parties that support our business processes and provide our cloud services.
Changes to this Statement
If we change our Privacy Statement, we will publish the revised statement here with an updated audit date. We encourage you to review the Statement regularly. If we make significant changes to our Statement that significantly alter our privacy practices, we may also communicate this to you in other ways, such as by sending an email or by posting a notice on our Group website and/or at social media before the changes take effect.
This Privacy Statement was updated on June 24, 2022.
How to contact
We value your opinion. If you have any comments or questions regarding our Privacy Statement, unresolved privacy and data usage issues, or a possible breach of your privacy, please send them to email@example.com.
We will process your requests confidentially. Our representative will contact you to deal with your issues and outline the options for resolving these. It is our aim to ensure that complaints are resolved in a timely and appropriate manner.