TRACKVIA, INC. PRIVACY POLICY

This privacy policy describes how TrackVia, Inc. (“TrackVia,” “we,” “us,” “our”) collects, uses, and shares personal information in connection with our website www.trackvia.com (“Website”), and our  proprietary web-based data management application (“TrackVia Service”).

When we receive information for our own purposes, such as from visitors of our Website, or the contact or billing information of our clients who use our TrackVia Service, the processing of that information is described by this privacy policy.  When we receive or process information on behalf of one of our clients who use our TrackVia Service, the privacy practices that apply to the processing of that information is governed by our client’s privacy policy.

Types of Information We Collect
Use and Processing of Information
Sharing of Information
Your Choices
How We Protect Personal Information
Transmission of Information to Other Countries
Privacy Shield Framework
Miscellaneous

Types of Information We Collect
We provide web-based data management application services through our TrackVia Service (https://go.trackvia.com/).  In that capacity, we receive personal information from our clients and process that information on behalf of our clients.  In other situations we receive personal information for our own use.  The following provides examples of the type of information that we collect and how we use that information.

Context Types of Data Primary Purpose for Collection
and Use of Data
Account Information and Information about Clients We collect the name, and contact information, including email and phone, of our clients and their employees with whom we interact. We have a legitimate interest in contacting our clients and communicating with them concerning normal business administration such as products, services, and billing.
Client Information We provide web-based data management application services.  In that role we may receive personal information from one of our clients. When we receive personal information from one of our clients in order to carry out a service we process that information on their behalf.  When we act in this capacity, our client determines the purpose for which the information was collected and how we should use it.
Cookies and First Party Tracking We use cookies. “Cookies” are small pieces of information that a website sends to a computer’s hard drive while a web site is viewed. See our Cookie Policy for more information. We have a legitimate interest in making our website operate efficiently, and to enable certain application features and functionality.
Cookies and Third-Party Tracking We participate in behavior-based advertising, this means that a third party uses technology (e.g., a cookie) to collect information about your use of our website so that they can provide advertising about products and services tailored to your interests on our website, or on other websites.  See our Cookie Policy for more information. We have a legitimate interest in engaging in behavior-based advertising.
Distance Information When you use one of our Apps we collect your location from the GPS, Wi-Fi, and/or cellular technology in your device to determine your location. We have a legitimate interest in understanding our users and providing tailored services.  In some contexts our use is also based upon your consent to provide us with geo location information.
Email Interconnectivity If you receive email from us, we use certain tools to capture data related to when you open or interact with our messages. We have a legitimate interest in understanding how you interact with our communications to you.
Employment If you apply for a job posting, or become an employee, we collect information necessary to process your application or to retain you as an employee.  This may include, among other things, your Social Security Number.  Providing this information is required for employment. We use information about current employees to perform our contract of employment, or the anticipation of a contract of employment with you.  In some contexts, we are also required by law to collect information about our employees.  We also have a legitimate interest in using your information to have efficient staffing and work force operations.
Feedback/Support If you provide us feedback or contact us for support we will collect your name and e-mail address, as well as any other content that you send to us, in order to reply. We have a legitimate interest in receiving, and acting upon, your feedback or issues, and resolving support inquiries.
Mailing List When you sign up for one of our mailing lists we collect your email address or postal address. We have a legitimate interest in sharing information about our products or services.
Mobile Applications We collect information from your mobile device such as unique identifying information broadcast from your device when visiting our website or using our application.  We use mobile analytic software that records information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded form. We have a legitimate interest in identifying unique visitors, in understanding how users interact with us on their mobile devices, and in better understanding the functionality of our mobile software on your phone.
Online Registration We collect your name and contact information when you create an online account.  We also collect information relating to the actions that you perform while logged into your account. We have a legitimate interest in providing account relating functionalities to our users.
Online Marketing Forms When you register (by submitting a form) to download content from our website, we collect your email address, first and last name, company name, phone, company HQ state and industry. We have a legitimate interest in sharing future information about our products or services via email and phone.
Surveys When you participate in a survey we collect information that you provide through the survey.  If the survey is provided by a third-party service provider, the third party’s privacy policy applies to the collection, use, and disclosure of your information. We have a legitimate interest in understanding your opinions, and collecting information relevant to our organization.
Web logs We collect information, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to a computer when the Internet is used), domain name, click-activity, referring website, and/or a date/time stamp for visitors. We have a legitimate interest in monitoring our networks and the visitors to our websites. Among other things, it helps us understand how to improve our service, provide content, and develop applications and services that are useful to our clients.


In addition to the information that we collect from you directly, or from our clients, we may also receive information about you from other sources, including third parties, business partners, our affiliates, or publicly available sources.  For example, if you submit a job application, or become an employee, we may conduct a background check.

Use and Processing of Information
In addition to the purposes and uses described above, we use information in the following ways:

  • • To identify you when you visit our websites.
  • • To provide products and services.
  • • To improve our services and product offerings.
  • • To conduct analytics.
  • • To respond to inquiries related to support, employment opportunities, or other requests.
  • • To send marketing and promotional materials, including information relating to our products, services, sales, or promotions.
  • • For internal administrative purposes, as well as to manage our relationships.

 
Although the sections above describe our primary purpose in collecting your information, in many situations we have more than one purpose.  For example, if you retain us to provide professional services we may collect your information to perform our contract with you, but we also collect your information because we have a legitimate interest in understanding who are clients are and what services we perform on their behalf.  As a result, our collection and processing of your information is based in different contexts upon your consent, our need to perform a contract, our obligations under law, and/or our legitimate interest in conducting our business.

Sharing of Information
In addition to the specific situations discussed elsewhere in this policy, we disclose information in the following situations:

  1. 1. Affiliates and Acquisitions. We may share information with our corporate affiliates (g., parent company, sister companies, subsidiaries, joint ventures, or other companies under common control). If another company acquires our company, business, or our assets, we will also share information with that company.
  2. 2. Other Disclosures with Your Consent. We may ask if you would like us to share your information with other unaffiliated third parties who are not described elsewhere in this policy.
  3. 3. Other Disclosures without Your Consent. We may disclose information in response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws. We may also share your information in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies, or to comply with your request for the shipment of products to or the provision of services by a third-party intermediary.
  4. 4. Public. Our website may provide the opportunity to post comments, or reviews, in a public forum such as a bulletin board, blog or chat room.  If you decide to submit information on these pages, that information may be publicly available.  We also post customer testimonials on our website which may contain personally identifiable information such as the customer’s name.  We do obtain the customer’s consent prior to posting the testimonial along with their name.  If you wish to update or delete your testimonial, or request removal of your personally information from our blog or community forum, contact us at privacy@trackvia.com.  In some cases, we may not be able to remove your personally identifiable information, in which case we will let you know if we are unable to do so and why.
  5. 5. Service Providers. We may share your information with service providers. Among other things service providers may help us with our business activities, including administering our website, providing technical support, and processing payments.



Your Choices
You can make the following choices regarding your personal information:

  1. 1. Promotional Emails. You may choose to provide us with your email address for the purpose of allowing us to send free newsletters, surveys, offers, and other promotional materials to you, as well as targeted offers from third parties. You can stop receiving promotional emails by following the unsubscribe instructions in e-mails that you receive.  You may also send a letter to TrackVia at 1675 Larimer Street, Suite 500, Denver, CO 80202 requesting removal from our email list, or you may call 303.278.1223 to ask that your name be removed.  If you decide not to receive promotional emails, we may still send you service related communications.
  2. 2. Promotional Mailings. If at any time you do not want to receive offers and/or circulars from us you can remove yourself from our mailing lists by emailing us (our contact information is below) with “NO USPS MAIL” in the subject line along with your name, address and zip code. Please note that our mailings are prepared in advance of their being sent. Although we will remove your name from our mailing list after receiving your request, you may still receive mailings from us that had been initiated prior to your name being removed.
  3. 3. Push Notifications. We send you push notifications from time-to-time in order to update you about any events or promotions that we may be running.  If you no longer wish to receive these types of communications, you may turn them off at the device level.
  4. 4. Access to Your Personal Information. For information that we collect on our own behalf we will grant you, where required by law, reasonable access to the personal information that we have about you. You may request access to your personal information by contacting us at the address described below.  If we are processing your information on behalf of one of our clients we will forward your request to that client and await instructions on whether access should be granted.
  5. 5. Changes to Your Personal Information. You can contact us at the address described below in order to request that your information be modified. You may also log into your password-protected TrackVia account and update your personal information by clicking on the My Info link in the right-hand side of your account.  Make the necessary updates, corrections or deletions and click update user information. Your user information will be updated immediately. If we are processing your information on behalf of one of our clients we will forward your request to that client and await instructions on any changes that they believe are appropriate.
  6. 6. Deletion of Your Personal Information. We typically retain personal information that we collect on our own behalf for the period necessary to fulfill the purposes outlined in this policy unless a longer retention period is required or permitted by law. You may request information about how long we keep a specific type of information, or request that we delete your personal information, by contacting us at the address described below.  If we are processing your information on behalf of one of our clients we will forward your request to that client and await instructions from them on whether your information should be deleted.
  7. 7. Revocation of Consent or Objections. You may revoke consent to processing (where our processing is based upon consent), or object to our processing (where our processing is not based upon your consent) by contacting us at the address described below.  If you revoke your consent / object we may no longer be able to provide you services. In some cases we may limit or deny your request to revoke consent / object if the law permits or requires us to do so, or if we are unable to adequately verify your identity.  If we are processing your information on behalf of one of our client we will forward a revocation of consent to that client and await instructions from them on whether the processing to your information should cease.
  8. 8. Online Tracking. We do not currently recognize automated browser signals regarding tracking mechanisms, which may include “Do Not Track” instructions.
  9. 9. California Residents. California residents may be entitled to ask us for a notice describing what categories of personal information (if any) we share with third parties or affiliates for direct marketing.  If you are a California resident and would like a copy of such notice, please submit a written request to us using the information in the “Contact Information” section below.

How We Protect Personal Information
No method of transmission over the Internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your personal information from unauthorized access, use, or disclosure, we cannot guarantee the security of your personal information. In the event that we are required by law to inform you of any unauthorized access to your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.

Some of our websites permit you to create an account.  When you do you will be prompted to create a password.  You are responsible for maintaining the confidentiality of your password, and you are responsible for any access to or use of your account by someone else that has obtained your password, whether or not such access or use has been authorized by you.  You should notify us of any unauthorized use of your password or account.

Transmission of Information to Other Countries
TrackVia is a U.S. based company.  As a result your information may be processed in a foreign country where privacy laws may be less stringent than the laws in your country.  Nonetheless, where possible we take steps to treat personal information using the same privacy principles that apply pursuant to the law of the country in which we first received your information.  By submitting your personal information to us you agree to the transfer, storage and processing of your information in a country other than your country of residence including, but not necessarily limited to, the United States.  If you would like more information concerning our attempts to apply the privacy principles applicable in one jurisdiction to data when it goes to another jurisdiction you can contact us using the contact information below.

Privacy Shield Framework
TrackVia complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union (EU) to the United States.  TrackVia has certified to the Department of Commerce that it adheres to the Privacy Shield Principles.  To learn more about the Privacy Shield Framework, and to view our certification, please visit https://www.privacyshield.gov/list.

TrackVia is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. TrackVia complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.

With respect to personal data received or transferred pursuant to the Privacy Shield Framework, TrackVia is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission.

In compliance with the Privacy Shield Principles, TrackVia commits to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact TrackVia at: privacy@trackvia.com.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third-party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

Under certain conditions, more fully described on the Privacy Shield website (https://www.privacyshield.gov/welcome), you may invoke binding arbitration when other dispute resolution procedures have been exhausted.

Miscellaneous
The following additional information relates to our privacy practices:

  • • Changes to this Privacy Policy. We may change our privacy policy and practices over time.  To the extent that our policy changes in a material way, the policy that was in place at the time that you submitted personal information to us will generally govern that information unless we receive your consent to the new privacy policy.
  • • Third-Party Links and Social Media Widgets. Our website includes links to third-party websites, Social Media Features, such as the Facebook and Twitter buttons, and Widgets. Your interactions with these third-party websites and Features are governed by the privacy policy of the company providing it. We have no control over its use and encourage you carefully read the privacy policy of any website you visit or company you decide to share information with.

Contact Information.  If you have any questions, comments, or complaints concerning our privacy practices please contact us at the appropriate address below. We will attempt to respond to your requests and to provide you with additional privacy-related information.

TrackVia, Inc.
Attention: Legal Department
1675 Larimer Street, Suite 500
Denver, CO 80202
Phone: 303.278.1223
Email: privacy@trackvia.com

If you are not satisfied with our response, and are in the European Union, you may have a right to lodge a complaint with your local supervisory authority.

Effective Date: October 31, 2018


TRACKVIA, INC. COOKIE POLICY

TrackVia, Inc. (“TrackVia,” “we,” “us,” “our”) uses different types of cookies for different things, such analyzing trends, and giving you a better, more personalized experience.  This cookie policy describes how and when we use different types of cookies in connection with our website.

What Are Cookies?
Cookies are small text files that are stored within your internet browser by the websites that you visit.  They are widely used in order to make websites work, or work in a better, more efficient way.  They can do this because websites can read and write these files, enabling them to recognize you and remember important information that will make your use of a website more convenient (for example by remembering preference settings).  In a similar way to many other websites, we place cookies on your computer or device to understand more about your visit and to help us to enhance your experience.

What Types of Cookies Do We Use?
The following describes the types of cookies that we use:

Cookie Type Description
Advertising Cookies We partner with third parties to either display advertising on our website or to manage our advertising on other websites.  Our third-party partners may use cookies to gather information about your activities on our website and other websites in order to provide you advertising based upon your browsing activities and interests.
Analytics Cookies These are software tools that allow us to study, and then improve, how customers interact with our website.  This is known as website analytics.  Analytics cookies allow us to understand more about how many visitors we have to our websites, how many times they visit us and how many times a user viewed specific webpages within our website.  Although analytics cookies allow us to gather specific information about the pages that you visit and whether you have visited our website multiple times, we cannot use them to find out details such as your name or address.  Examples of an analytical tool that we use is Google Analytics.
Third-Party Cookies These are cookies set by third parties (someone other than the owner of the website).  Aside from setting cookies ourselves, we also allow third parties to set cookies during your visit to our website.  These organizations provide us with information on how you use our website.  They may also use cookies to promote our newest products and latest offers to you on other websites based on your activity on our website, or your activity on other websites that use the same cookies.  For example, you may see products that you viewed on our website presented on other websites as you move around the internet. Some of our partners will use your location to provide more relevant messaging.  We have no control over third-party cookies.

How Can I Manage My Cookies?
If you do not want to accept cookies while on our website, you can change your browser settings so that cookies are not accepted.  If you choose to do this, please be aware that our website may no longer function as intended.  Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you access our website.

For more information about how we use the information you submit on this website, or how to contact us with questions, please read our Privacy Policy.