Updated: 15 October 2019
The websites traxfamily.com, snowtrax.io and trax.business, the Trax GPS-tracker hardware, together with the accompanying mobile/web Apps and Trax cellular data connectivity services, are made available to you by WTS – Positioning Solutions AB (hereinafter referred to as “we” or “us”).
- How We Use and Share Your Information
- Access to Your Information and Choices
- Security of Your Information
- Consent to Processing of Personal Data
- Questions and How Contact Us
Personal data is all kinds of information that, directly or indirectly, may be referable to an individual person. Such personal information, provided by you, may besides the location of your Trax GPS-tracker, include personal details such as name, mobile phone number, address, email address, company address, company phone number, company VAT number, IP address, payment method, if you are a pet owner and/or if you have any children and other information about you regarding the use of our services.
This kind of information is within the EU protected by legislation enacting General Data Protection Regulation (“GDPR”), which aims to strengthen the security and protection of personal data in the EU and harmonize EU data protection law. We will, of course, always handle personal data about you in accordance with the relevant legislation.
Data Controllers and Data Processors. Access, Rectification and Deletion
We (WTS – Positioning Solutions AB) are the Data Controller of personal data relating to the Trax products, services and the websites and you can contact us regarding privacy matters at firstname.lastname@example.org.
You are entitled to contact Data Controller for questions related to your rights of access, rectification and deletion according to GDPR and national personal data legislation.
Telenor Connexion AB, Microsoft Azure and Google Cloud Services are Data Processors pursuant to data processing agreements between these entities and WTS – Positioning Solutions AB.
All your data and personal information collected from you is subject to be processed and stored in Google Cloud hosted in Belgium and Netherlands on our behalf and we sometimes handle transfers from your home country to these services in Belgium and Netherlands.
Information That We collect and How We Use It
Information you provide to us. We collect information you provide to us, for example when you create or modify your account, register to use our websites or services, purchase products or services from us, request information from us, contact customer support, or otherwise communicate with us. This information may include:
Credit / debit card number (solely for payment purposes)
Bank or financial account number
User generated content (blog posts, feedback, comments, photos, videos, messages, social media).
Information we collect through your use of our services. We may, when we provide our services to you, or in relation to our provision of services to you, collect from you and from your devices the following types of information: service usage information, access information, cookie, IP address, mobile device identification number (device ID or IMEI), unauthorised or inappropriate access information, location information stored on your device or your location information.
Other detailed information on data we collect:
- Installation information of the Trax Apps: type of device, device token, installation ID.
- User information of the Trax Apps: username, email and password, name, surname, devices managed by the user, installation information.
- Trax GPS-tracker device information: IMEI, IMSI of the SIM card built in the device, F/W version, locations (coordination and timestamp of device location), device settings.
- In addition, we may process personal data if applicable by law, regulation, legal process or enforceable governmental request, obliges us to do so, or if GDPR art 6(1)(f) is applicable, namely in cases where we have legitimate interests that are not overridden by data protection interests.
Information we collect based on actions on your side or if you have consented. We may also collect following personal information in case that you use additional services or personalized services, or if you participate in various events we host.
- In case you win an event we will process information required to provide a gift and mailing address.
- In case you use fee-based services we will process payment information.
We do not use your personal information for direct marketing purposes, unless a freely given, specific, informed and unambiguous consent has been obtained from you.
As Trax provides access to Google Maps, information regarding users of Google Maps, including (but not limited to) identifiable information such as user name, the location of your Trax GPS-tracker and your location may be gathered, used and retained by us.
Our websites use Google Maps (AP’I) of Google LLC., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). Google Maps is a web service for displaying interactive (country) maps in order to display geographical information visually.
Google LLC, based in the United States, is certified for the US-European data protection agreement “Privacy Shield”, which guarantees compliance with the data protection level applicable in the EU.
We will also collect anonymous data during usage. This information does not contain any unique identification and is only used to improve the accuracy of the services, the maps and for creating related new services.
Protection of Personal Information
We take information security very seriously and inform all our employees of our privacy practices. We use industry standard physical, technical and administrative security measures and safeguards to protect the confidentiality and security of your personal information. However, since the Internet is not a 100% secure environment, we cannot guarantee, ensure, or warrant the security of any information you transmit to us. There is no guarantee that information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. It is your responsibility to protect the security of your login information.
Use of Personal Information
Personal data and other kinds of information is collected and used for the purpose of providing our services to you as well as developing our services. The information may also be used to send electronic communication to you, including (but not limited to) emails, push notifications, SMS (short message service), MMS (multimedia messaging service) from us or our service providers.
We may use your information to:
- provide products and access to services that you purchase using our websites or access using our services;
- respond to your inquiries or requests;
- register your user account;
- contact you about your orders;
- process credit card and debit card transactions;
- ship products to you;
- send you information about our services or our products (such as maintenance or security information, promotional materials, surveys, or other advertisements about our services or our products);
- comply with applicable law or legal process;
- investigate suspected fraud, harassment, danger to persons or property or other violations of any law, rule or regulation, or the terms or policies for our services or our business partners; share with law enforcement and other parties trying to locate a lost child;
- develop and enhance our own data, such as through tracking the location of your device, provided that any disclosures of such data does not specifically identify you, your device or your specific location;
- share non-personal or de-identified information with any number of parties, including analytics companies, technology providers and other business partners;
- or combine it with data from other sources outside of your use of our services, such as data obtained from radio frequency technologies within range of your device.
Disclosure to Third Parties
We use other companies to perform services on our behalf who in the course of providing these services may have access to your personal information. These companies are not permitted to use your personal information except for the purpose of providing the services we request of them.
We will also disclose personal information if it is required to meet any applicable law, regulation, legal process or enforceable governmental request.
For the avoidance of doubt, we will not share your personal information with third parties for marketing purposes unless you give us your consent through an opt-in.
However, we may disclose or use your personal information without your consent if there are any applicable law, regulation, legal process or enforceable governmental request that obliges us to do so. We may also transfer personal data to third parties if GDPR art 6(1)(f) is applicable, namely in cases where we have legitimate interests that are not overridden by data protection interests. We may therefore pass information about the location of your device to emergency services.
Furthermore, we may provide location information or any other usage data in a non- personal, aggregate format for statistical and research purposes to third parties. Such data is not considered as personal data.
Cookies and Other Such Technologies
Cookies are small pieces of data that are sent to your browser and stored on your hard drive for record keeping purposes. This helps us adjust the websites for your individual needs and preferences. It also helps us develop our services in order to make them more useful.
Retention of Personal Information
We retain personal data about you as long as legitimate interests and/or applicable legislation justify the storage.
Accessing and Updating Personal Information About You
You can help us ensure that the personal data and other personal information about you is correct by keeping your store account and your app account updated.
You can access and update certain information we have relating to you by
You can also require to know all data that has been collected about you by contacting us at email@example.com. You can opt-out of receiving marketing and promotional emails by using the opt-out or unsubscribe feature contained in the emails.
Web Analysis Services - Google Analytics
We use Google Analytics, a web analysis service of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). Google Analytics uses so-called cookies, which are text files stored on your computer, to help the websites analyze how users use the sites. The information generated by the cookies about your use of our websites (including the shortened IP address) is generally transmitted to a Google server in the USA and stored there.
Our websites use Google Analytics exclusively with the extension “_anonymizeIp()”, which ensures an anonymization of the IP address by shortening it and excludes a direct personal relationship. As a result of the extension, your IP address will previously be shortened by Google within member states of the European Union or in other signatory states to the Agreement on the European Economic Area. Only in exceptional cases, the full IP address will be transmitted to a Google server in the USA and shortened there. In these exceptional cases, processing is carried out in accordance with GDPR art 6(1)(f) on the basis of our legitimate interest in the statistical analysis of user behavior for optimization and marketing purposes.
On our behalf, Google will use this information to evaluate your use of the websites, to compile reports on website activity and to provide us with other services relating to website and internet use. The IP address transmitted by your browser in the context of Google Analytics is not merged with other Google data.
You may permanently refuse Google to collect data generated by cookies regarding the use of our websites (including your IP address) and to process them. You can download and install the browser plugin available under the following link: https://tools.google.com/dlpage/gaoptout?hl=en.
Online Marketing - Google Adwords Conversion Tracking
We use the online advertising program “Google AdWords” and the conversion tracking within the framework of Google AdWords, Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). We use the program of Google Adwords to draw attention to our attractive offers with the help of advertising materials (so-called Google Adwords) on external websites. We can determine, in relation to the advertising campaigns data, how successful the individual advertising measures is. We are interested in showing you advertisements that are of interest to you. We want to make our websites more interesting for you and to achieve a fair calculation of advertising costs.
The conversion tracking cookie is set on a user’s browser, if he clicks on an AdWords ad delivered by Google. Cookies are small text files that are stored on your computer system. These cookies usually lose their validity after 30 days and are not used for personal identification. If the user visits a certain page in our websites and if the cookie has not yet expired, Google and we will be able to recognize that the user clicked on the ad and was forwarded to this page. Each Google AdWords customer gets a different cookie. Thus, cookies cannot be traced via the website of AdWords customers. The information collected by the conversion cookies is used to provide aggregate conversion statistics to AdWords customers who have opted-in for conversion tracking. Customers are informed about the total number of users who clicked on the ad and were forwarded to a conversion tracking tag page. However, they do not get any information enabling them to identify users personally. If you do not want to participate in the tracking program, you can refuse the use of this program by deactivating the Google Conversion Tracking cookie via your Internet browser through the user settings. In this case, you will not be included in the conversion tracking statistics. We use Google Adwords on the basis of our legitimate interest in targeted advertising in accordance with GDPR art 6 (1)(f).
Retargeting / Remarketing / Referral Advertising
Facebook Custom Audience via the Pixel Process
Consent to the use of the Facebook pixel may only be given by users who are older than 13 years of age. If you are younger, please ask your legal guardian for permission.
Google AdWords Remarketing
Our websites use the functions of Google AdWords Remarketing, which enable us to advertise our websites in Google search results, as well as on third-party websites. Provider is Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). To this end, Google places a cookie in the browser of your terminal device, which automatically uses a pseudonymous cookie ID on the basis of pages you visited to allow interest-based advertising. Processing is based on our legitimate interest in the optimal marketing of our websites in accordance with GDPR art 6 (1)(f).
Any additional processing will only take place if you have agreed with Google that your Google Internet and app browsing history will be linked to your Google Account and information from your Google Account will be used for personalized ads you view on the web. If you are logged in to Google while visiting our websites, Google will use your data in connection with Google Analytics data to create and define target group lists for cross-device remarketing. To this end, Google temporarily links your personal data with Google Analytics data to create target groups. You can permanently disable the setting of cookies for advertising preferences. You may download and install the browser plug-in available at the following link: https://www.google.com/settings/ads/onweb/. Alternatively, you can contact the Digital Advertising Alliance at www.aboutads.info to find out how to set cookies and to make the relevant settings. Finally, you can set your browser so that you are informed about the setting of cookies and decide individually whether to accept them or to exclude the acceptance of cookies for certain cases or in general. If cookies are not accepted, the functionality of our websites may be limited.
Google LLC, based in the United States, is certified for the US-European data protection agreement “Privacy Shield”, which guarantees compliance with the data protection level applicable in the EU. Further information and the data protection regulations regarding advertising and Google can be viewed at: http://www.google.com/policies/technologies/ads/.
WTS – Positioning Solutions AB
111 24 Stockholm