PRIVACY POLICY

This is the Privacy Policy for trackingdays.com, the TrackingDays App on iOS, the TrackingStates App on iOS and the TrackingDays App on Android.

This Privacy Policy was reviewed on 26th June 2024.

As the operators of the TrackingDays app (“App”), Lauco Trading Limited ("We", “Us”) is committed to protecting and respecting your privacy. This Privacy Policy (“Policy”) sets out the basis on which the personal data collected from you, or that you provide to us will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

For the purpose of the General Data Protection Regulation, the Data Controller is Lauco Trading Limited.

YOUR PERSONAL INFORMATION

We may collect and process the following information from you:

  • Your name and contact information, including email address and telephone number, and company details.

  • Information that you provide by filling in forms on our App. This includes information provided at the time of registering to use our App or requesting further information or services. We may also ask you for information when you report a problem with our App.

  • Location data – specifically, the country you come from, the amount of time you spend and the longest time you spend in specific countries.

  • If you contact us, we may keep a record of that correspondence.

  • We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.

  • Details of your use of the App including, but not limited to, traffic data, location data, weblogs and other communication data, and the resources that you access.

Except data from completion of surveys, the provision of the above data is required from you to enable Us to provide the App and our services to you. We will inform you at the point of collecting information from you, whether you are required to provide the information to Us.

USES MADE OF YOUR INFORMATION

Lawful basis for processing

We rely on performance of a contract with you the lawful basis on which We collect and use your personal data, except in relation to data from surveys and details of your use of the App, and any data used for marketing purposes.

In relation to data from surveys, and details of your use of the App, we rely on our legitimate interests as the lawful basis on which We collect and use your personal data. Our legitimate interests are to understand our customer base and provide a better service.

In relation to direct marketing, we rely on consent as the lawful basis on which We collect and use your personal data.

Purposes of processing

We use information held about you in the following ways:

  • To provide you with our services.

  • To ensure that content on our App is presented in the most effective manner for you and for the device(s) you use to access and view the content on our App.

  • To provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes.

  • To carry out our obligations arising from any contracts entered into between you and us.

  • To allow you to participate in interactive features of our App, when you choose to do so.

  • To notify you about changes to our App.

Marketing

In addition to the above uses, we may use your information (and, where you have consented, permit selected third parties to use your information), to notify you other mobile applications or services which may be of interest to you.

For such uses we will only contact you by electronic means (e-mail or SMS) if you have consented to such communication when we collect your data, OR if the contact relates to mobile applications developed by us similar to the App and which we think may be of interest to you.

If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please either (i) tick the relevant box situated on the form on which We collect your data (for example, the registration form); (ii) unsubscribe from our electronic communications using the method indicated in the relevant communication, or (iii) inform Us at any time by contacting Us as the contact details set out below.

DISCLOSURE OF YOUR INFORMATION

We may pass your information to our third party service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf (e.g. to host our servers).

We may disclose your personal information to any member of our corporate group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006 (where applicable).

We may disclose your personal information to third parties:

  • in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets; or

  • if we or substantially all of our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets; or

  • if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our App Terms and Conditions and other agreements; or

  • to protect the rights, property, or safety of Lauco Trading Limited, the App, our users and any third party we interact with the to provide the App.

Other than as set out above, and save insofar as is necessary in order for Us to carry out our obligations arising from any contracts entered into between you and Us, We will not share your data with third parties unless we have procured your express consent to do so.

STORING YOU PERSONAL DATA

Security

We take appropriate measures to ensure that any personal data are kept secure, including security measures to prevent personal data from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal data to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where We are legally required to do so.

Unfortunately, the transmission of information via the internet is not completely secure. Although We will do our best to protect your personal data, We cannot guarantee the security of your data when transmitted to our App; any transmission is at your own risk. Once We have received your information, We will use strict procedures and security features to try to prevent unauthorised access.

If your personal details change you may update them by accessing the relevant section of the App. If you have any questions about how We use data collected which relates to you, please contact Us by sending a request by email to the contact details below.

How long we keep your personal data

We will hold the data set out above for a reasonable time having regard to the nature of the personal data and the purpose for which it was collected. In particular:

  • Where we hold your personal data in connection with the performance of a contract with one of our customers or suppliers, we will hold your data, and in particular any communications between you and us in relation to the negotiation or performance of the contract by either party for so long as that contract is in force and for a period of at least 7 years after;

  • Where we hold your data in connection with the marketing or promotion of our business, we will hold your data for up to 2 years, or for up to 2 years after you last communicated with us, if later;

  • In respect of website usage data, we hold your data for 5 years from the date of collection.

Where we store your personal data

All information We hold about you is stored on secure servers in Switzerland.

The European Commission has given a formal decision that both Jersey, where the company is based, and Switzerland, where the data is stored, provide adequate levels of data protection similar to those which apply in the EEA.

If you would like further information please contact Us (see ‘Contact’ below). We will not otherwise transfer your personal data outside of the EEA.

YOUR RIGHTS

You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking/ticking certain tick boxes we use to collect your data. You can also exercise the right at any time by contacting us using our contact details set out below.

The App may, from time to time, contain links to and from websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and terms of use and that we do not accept any responsibility or liability for these policies and terms of use. Please check these policies before you submit any personal data to these websites.

ACCESS TO INFORMATION

Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:

  • access to your personal data and to certain other supplementary information that this Policy is already designed to address;

  • require Us to correct any mistakes in your information which We hold;

  • require the erasure of personal data concerning you in certain situations;

  • receive the personal data concerning you which you have provided to Us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations;

  • object at any time to processing of personal data concerning you for direct marketing;

  • object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you;

  • object in certain other situations to our continued processing of your personal data;

  • otherwise restrict our processing of your personal data in certain circumstances; and

  • claim compensation for damages caused by our breach of any data protection laws.

For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.

If you would like to exercise any of those rights, please:

Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:

  • email, call or write to Us;

  • let Us have enough information to identify you (e.g. account number, user name, registration details);

  • let Us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and

  • let Us know the information to which your request relates, including any account or reference numbers, if you have them.

CHANGES TO OUR PRIVACY POLICY

We reserve the right to modify this Privacy Policy at any time. Any changes we may make to our Policy in the future will be notified and made available to you using the App. Your continued use of the App shall be deemed your acceptance of the varied Privacy Policy.

CONTACT

All questions, comments and requests regarding this Privacy Policy should be submitted to us via our Help Center here, or by visiting trackingdays.zendesk.com.