PRIVACY POLICY

This Privacy Policy describes the ways we collect, store, use, and manage any Personal Data you provide to us or we collect in connection with your use of TrackHead, accessible at our website and any other websites on which this Policy appears (the 'Site').

When we say 'Personal Data' we mean identifiable information about you, like your email address, username, portfolio information, comments, and so on. If you can't be identified (for example, when Personal Data has been aggregated and anonymized), then this Policy does not apply.

BY REGISTERING ON THE SITE AND/OR BY USING THE SITE YOU AGREE TO THIS PRIVACY POLICY and the processing of your Personal Data in the manner provided in this Policy. If you do not agree to the terms of this Privacy Policy, please do not use the Site.

1. Information We Collect

1.1. Information You Provide to Us Directly: When you visit or use some parts of our Site, we might ask you to provide Personal Data to us. For example, we need your email address to set up your account and authenticate your login using magic links or third-party authentication like Google and GitHub. We do not collect or store any passwords. Additionally, users can provide portfolio information, remarks, and names for wallets. This information will not be shared with third parties or other users.

1.2. Information We Collect Automatically: We collect some information about you automatically when you visit and use our Site, such as your IP address, device type, browser type, operating system, and your activity on the Site. This information is collected using cookies and other tracking technologies like Google Analytics to help us enhance the app and provide a better user experience.

2. Cookies and Other Tracking Technologies

A cookie is a small piece of text sent to your browser by a website you visit. It helps our Site to remember information about your visit. We use both session cookies, which are temporary and disappear after you close your browser, and persistent cookies, which remain after you close your browser and may be used on subsequent visits to our Site.

We use our own cookies (first-party cookies) to remember your preferences, recognize you when you visit the Site, and perform security measures. In addition, we work with reputable companies who use their cookies (third-party cookies) to help us analyze how the Site is used and to compile reports for improving the Site.

For example, we use Google Analytics to collect Site-specific usage data. Google Analytics collects anonymous information and does not identify you personally. The information collected by Google Analytics is subject to the Google Analytics Terms of Service and Google Privacy Policy.

Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org or www.allaboutcookies.org.

If you choose to use the Site without blocking or disabling cookies, you consent to our use of these cookies and the collection of information using these technologies. If you do not consent to the use of cookies, please be sure to block or disable them using your browser settings.

3. Legal Bases to Process Personal Data

3.1. Performance of a Contract: We may process your Personal Data where it is necessary for the performance of a contract entered into between you and us, or when we need to take steps related to such a contract.

3.2. Legal Obligations: We may process your Personal Data where it is necessary for compliance with a legal obligation to which we are subject.

3.3. Legitimate Interests: We may process your Personal Data where it is necessary for our legitimate interests or the legitimate interests of a third party, provided such interests are not overridden by your rights and interests.

3.4. User Consent: In certain cases, we may process your Personal Data based on your consent.

4. Why We Process Personal Data

4.1. Service Delivery and Functionality: To deliver and maintain the functionality of the Site.

4.2. User Interaction with the Site: To facilitate your interactions with the Site and enhance user experience.

4.3. Analytical and Statistical Purposes: To analyze usage patterns and improve the Site.

4.4. Improvement and Development of Services: To develop new features and improve existing ones.

4.5. Compliance with Laws: To comply with applicable laws, regulations, and legal processes.

4.6. Security and Fraud Prevention: To ensure the security of the Site and prevent fraud.

4.7. Internal Administrative Purposes: To manage our internal business operations.

4.8. Sending Related Information: To send you newsletters, special offers, confirmations, updates, and security alerts related to our services.

5. How Long We Retain Information

5.1. Duration of Data Storage: We will retain your Personal Data for as long as your account is active or as needed to provide you with our services. We may also retain your Personal Data for longer periods if it is necessary to comply with legal obligations, resolve disputes, and enforce our agreements.

5.2. User Rights to Correct or Delete Data: You have the right to access, correct, or delete your Personal Data at any time. You can make changes to your information through your account settings or by contacting us directly.

5.3. Conditions for Longer Retention: In certain circumstances, we may retain your Personal Data for longer periods, such as to comply with legal obligations, prevent abuse, or if required in connection with a legal claim or proceeding.

6. Disclosure of Information

6.1. Internal Data Sharing: We may share your Personal Data within our company to help provide and improve our services.

6.2. Third-Party Service Providers and Partners: We may share your Personal Data with third-party service providers and partners who assist us in the provision of the Site or who help with our business operations.

6.3. Legal and Regulatory Disclosures: We may disclose your Personal Data to law enforcement agencies, government bodies, courts, or other third parties where we believe it is necessary to comply with applicable laws or regulations, or to exercise, establish, or defend our legal rights.

6.4. Business Transfers: In the event of an actual or proposed purchase, merger, or acquisition of any part of our business, we may disclose your Personal Data to an actual or potential buyer and its agents and advisers.

6.5. User Consent for Data Sharing: We will not share your Personal Data with third parties for their marketing purposes without your explicit consent.

7. Your Rights

When the EU General Data Protection Regulation (GDPR) applies to our relations (e.g. you are located in the EU), you have the following rights with respect to your Personal Data that we process:

7.1. Right to Access: You have the right to access (and obtain a copy of, if required) your personal data that we process.

7.2. Right to Rectification: You have the right to update your personal data or to correct any inaccuracies.

7.3. Right to Erasure: You may have the right to request that we delete your personal data in certain circumstances, such as when it is no longer necessary for the purpose for which it was originally collected.

7.4. Right to Restriction of Processing: You may have the right to request that we restrict the use of your personal data in certain circumstances, such as when you have objected to our use of your personal data but we need to verify whether we have overriding legitimate grounds to use it.

7.5. Right to Data Portability: You have the right to transfer your personal data to a third party in a structured, commonly used, and machine-readable format, in circumstances where the personal data is processed with your consent or by automated means.

7.6. Right to Object: You may have the right to object to the use of your personal data in certain circumstances, such as the use of your personal data for direct marketing.

7.7. Right to Complain: You have the right to complain to your local data protection authority. This right may not be available to you if there is no authority dealing with data protection in your country.

7.8. How to Exercise These Rights: You can exercise your rights at any time by making adjustments in your account settings or by contacting us at support@trackhead.com.

8. Security of Personal Data

We are committed to protecting your personal data and have implemented appropriate technical and organizational measures to protect it from loss, misuse, unauthorized access, disclosure, alteration, and destruction.

8.1. Technical and Organizational Measures: We process all personal data using industry-standard techniques and implement measures such as encryption and secure storage.

8.2. Access Restrictions: We restrict access to personal data to employees, contractors, and agents who need that information to process it. Access is granted on a need-to-know basis.

8.3. Continuous Monitoring and Threat Management: Our security team continuously monitors security systems, event logs, notifications, and alerts from all systems to identify and manage threats.

9. International Data Transfers

When we process and share data, it may be transferred to and processed in countries other than your own. These countries may have laws different from what you are used to.

9.1. Data Transfer to Countries Outside Your Own: Your data may be transferred to countries outside your own for processing and storage.

9.2. Safeguards for International Transfers: Where personal data is transferred outside the EEA, it will be transferred to countries where we have compliant transfer mechanisms in place to protect your personal data, in particular by implementing the European Commission’s Standard Contractual Clauses to the contracts with the entities to which the data is transferred.

10. Links to Other Sites

Our Service may contain links to other sites. Note that these external sites are not operated by us. Therefore, we strongly advise you to review the Privacy Policy of these websites.

11. Children's Privacy

Our Services do not address anyone under the age of 13. We do not knowingly collect personally identifiable information from children under 13. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us so that we will be able to take necessary actions.

12. Modifications to the Privacy Policy

10.1. Right to Modify the Policy: We reserve the right to modify or revise this Privacy Policy at any time by posting the amended policy on the Site. Please check the most current policy.

10.2. Notification of Changes: We will notify you of any significant changes to this Privacy Policy through the Site or via email.

10.3. User Responsibility to Review Updates: It is your responsibility to review this Privacy Policy periodically for any updates or changes.

13. Contact Information

If you have any questions or concerns about this Privacy Policy or our data practices, please contact us at support@trackhead.com.

Last updated: May 25, 2024.

TrackHead

Contact: support@trackhead.app

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