Privacy Policy for trackwire

1. Who is responsible (Controller)

The controller for the processing described in this policy is Luke Joseph, sole proprietor (Einzelunternehmer), operating as "trackwire". Our legal and contact details are available on the Impressum page of our website. You can also contact us directly at support@trackwire.io.

For data processed to operate the platform (accounts, billing, security), trackwire acts as the controller.
For data processed on behalf of Clients about their End Users (for example, purchases or interactions on a Client's Pro Site), the Client is the controller, and trackwire acts as their processor.

2. Data We Collect

• Account and profile data: name, artist or alias, email address, country, and plan details.
• Transaction data: purchase amounts, currency, payment status, and invoices (we do not store full card data).
• Content and creative data: files, artwork, text, and metadata you upload or publish through the Services.
• Technical data: IP address, device type, operating system, browser type, referrer, pages visited, and activity logs.
• Communications: messages or support requests you send us and our responses.
• End User checkout data: email, product details, and order information submitted during checkout on a Client's Pro Site.

For cookies and similar technologies, see our Cookie Policy.

3. How We Collect Data

• Directly from you when you register, configure your Pro Site, upload content, or contact support.
• From End Users when they purchase or interact with a Client's Pro Site.
• Automatically through cookies and log files when you browse or use the dashboard.
• From third-party services that help us deliver the platform, such as secure payment processors and hosting providers.

4. Why We Process Data and Legal Bases

• Provide and operate the Services (Pro Sites, hosting, checkout, payouts) - performance of a contract.
• Account and customer support - performance of a contract and legitimate interests.
• Security, fraud prevention, and compliance - legitimate interests and legal obligations.
• Billing and accounting - legal obligations.
• Service improvement and performance monitoring (for example, aggregated usage patterns from technical logs) - legitimate interests.
• Marketing communications - consent where required; you can unsubscribe at any time.

5. Payments

Payments and payouts are processed by a secure third-party payment provider. We do not store full card details. The payment provider receives and processes payment information directly to complete the transaction and provides us with status and reference data for receipts, compliance, and payouts. Your use of payment services is subject to that provider's terms and privacy policy.

6. Analytics

We currently do not use third party analytics tools that place non-essential cookies or track individual users for marketing or profiling. We may use aggregated technical data from our own logs to understand general performance, detect abuse, and improve the stability of the Services. This processing is based on our legitimate interests in operating a secure and reliable platform. If we introduce additional analytics tools in the future, we will update this Privacy Policy and our Cookie Policy accordingly.

7. Who We Share Data With

We share personal data only when necessary to operate the Services or as required by law, with:

• Cloud hosting and storage providers for secure data and media delivery.
• Payment processors for payment and payout operations.
• Content delivery and security networks for site performance and protection.
• Email and communication providers for service and marketing emails.
• Professional advisors and regulatory authorities when required by law.
• Business successors in case of merger, acquisition, or restructuring, under appropriate safeguards.

When we act as a processor for a Client, we process End User data only under that Client's instructions.

8. International Transfers

Some service providers may process data outside the European Economic Area (EEA), the UK, or Switzerland. When this occurs, we rely on lawful transfer mechanisms such as adequacy decisions or EU Standard Contractual Clauses (SCCs), and we apply additional safeguards where required to ensure your data is adequately protected.

9. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes described above or as required by law. Account and billing records are typically retained for statutory periods. Technical logs and aggregated usage data are stored for shorter periods. When data is no longer needed, it is deleted or anonymized according to our retention policies.

10. Your Rights

You may have the following rights under applicable data protection law:

• Access your personal data and receive a copy.
• Rectify inaccurate or incomplete information.
• Request deletion ("right to be forgotten").
• Restrict or object to certain processing.
• Request data portability where applicable.
• Withdraw consent at any time (for example, for marketing emails).

To exercise your rights, contact us at support@trackwire.io.
When we process End User data on behalf of a Client, please contact that Client directly; we will assist them in responding to your request.
You also have the right to lodge a complaint with your local supervisory authority.

11. Security

We implement reasonable technical and organizational measures to protect personal data against unauthorized access, loss, alteration, or disclosure. No system can be guaranteed completely secure, and you use the Services at your own risk. Keep your account credentials confidential and notify us immediately of any suspected misuse.

12. Children

The Services are not directed to children under 16. We do not knowingly collect personal data from anyone under 16. If you believe that a child has provided us with personal data, please contact us so we can delete it.

13. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in law, technology, or our practices. The most recent version will always be available on our website. Material updates may also be communicated by email or in your dashboard.

14. Contact

If you have any questions or concerns about this policy or our handling of personal data, please contact us at support@trackwire.io. You can also find our legal details on the Impressum page.