Effective Date: 07/02/2023
“User” - the entity or individual that is visiting trackwire.io, has contracted with trackwire to receive a free, or paid Plan or other Service Offerings.
“Controller” - means the entity that has certain legal rights to determine the purposes for which Personal Data will be Processed and the means by which that Processing will happen. We are the Controller in regards to this document.
“GDPR” - means the EU General Data Protection Regulation.
“Personal Data” - Information about an identified or identifiable individual, such as their name or contact information.
“Plan Website” - Is the website leased as part of the Service Offerings
“Platform Plan” - means a User’s subscription to the Platform.
“Platform” - means the website application found at trackwire.io and all it’s services and features.
“Processor” - means a third party entity that Processes Personal Data on behalf of a Controller.
“Process,” “Processed,” and “Processing” - refer to any operation or set of operations that can be performed on Personal Data or on sets of Personal Data. This includes, for example, recording, storage, collection, structuring, retrieval, organization, use, adaptation or alteration, consultation, disclosure by transmission, dissemination or otherwise making available, combination or alignment, restriction, destruction and erasure.
“Service Offerings” - means the Platform and trackwires related support and professional services, this includes the website leased and provisioned as part of a Platform Plan and all other services, whether free or paid.
“trackwire”, “trackwire.io”, “us”, “we”, - means Luke Joseph Website Dienste whose contact information is at the end of this privacy policy
At trackwire - Luke Joseph Website Dienste, accessible from trackwire.io, one of our main priorities is the privacy of our visitors. This Privacy Policy document contains types of information that is collected and recorded by trackwire and how we use it. By continuing to access our website you accept this privacy policy in full.
If you have additional questions or require more information about our Privacy Policy, do not hesitate to contact us through email at privacy@trackwire.io or the additional contact information at the end of this page.
trackwire.io is headquarted in Germany and processes data in compliance with German and EU Law.
We Process information you provide to us through the Platform or other methods.
The types of Personal Data we may Process include your name, artist name, email address, country of residence and any other information you choose to provide.
For example, you share information directly with us when you create an account, purchase a Platform Plan, fill out a form, communicate with us (including via third-party platforms), request customer support, or otherwise communicate with us.
We do not collect payment information directly through the Platform. To facilitate the processing of payments we rely on a Processor; Stripe. Any information you provide to facilitate such a payment is subject to the Processor’s privacy policy, and we encourage you to review this policy before you provide any information to the Processor. You can read stripe’s privacy policy here: https://stripe.com/privacy
We collect and process information as part of our free or paid Service Offerings.
The types of Personal Data we may Process include your name, artist name, email address, your content, country of residence, social media links, photos, posts (updates), music, payment gateway keys, instrumentals and any other information you choose to provide as part of the Service Offerings.
For example, you share information directly with us when you; upload photos, music, add social media links, connect payment methods, process orders, customize the Plan Website, or otherwise update and add information as part of the Service Offerings.
In some circumstances, we collect certain information automatically, including:
Transactional Information: When you purchase a Plan Website, we collect information about the transaction, such as purchase price, the date of the transaction and subscription details.
Activity Information: We collect information about your activity on our Platform, such as when you take certain actions, for example by showing interest in Service Offerings.
Information Collected by Cookies and Similar Tracking Technologies: We use tracking technologies such as cookies and web beacons. Cookies are used to store information including visitors preferences, and the pages on the website that the visitor accessed or visited. The information is used to optimize the users experience by customizing our web page content based on visitors browser type and/or other information. These cookies, web beacons and other tracking technologies help us to monitor trends in usage and deliver better and more tailored experiences for Users of the Platform and related Service Offerings.
Usage Information: We collect information about how you use our Platform and Service Offerings, including data about the device you use, IP address, unique device identifiers, browser type, and app version. We also collect information about your activity regarding our Service Offerings, such as pages viewed, access times, links clicked and the pages you visit and actions you take on those pages.
When you interact with the Platform we also collect and process data using third party services such as Google Analytics, Google Recaptcha & ActiveCampaign.
We use Google Analytics to monitor performance and usage of our Platform. This information is anonymous and helps us to fine tune and provide better Service Offerings. Google has many data and operating centers within and outside the EU.
We use Google Recaptcha to monitor how the Platform is being interacted with in order to block interaction from bots.
Google may send data outside of the EU in order to Process. You can read more about Google’s privacy policy here: https://policies.google.com/privacy
We use ActiveCampaign when you enter your email into any form on the Platform. For example when you register, add your email to a mailing list form, add your email to receive a Service Offering. We use ActiveCampaign to store information such as; your email address, name, country and activity relating to our Platform. This information is used to send you marketing and promotional email campaigns, educational emails, onboarding emails to help you get the most from the Service Offerings etc. We also use ActiveCampaign to process information when you show interest in one of our Service Offerings, for example to help facilitate the completion of a purchase. All the information we send to ActiveCampaign is in relation to the Platform, Service Offerings and your interests.
To tailor the experience to your individual needs or fine tune our Service Offerings we may derive information or draw inferences about you based on the information we collect. For example, we only supply Service Offerings to certain geographical locations and countries so we may make inferences about your location based on your IP address to know your eligibility for Service Offerings.
We use information we Process to facilitate, improve and maintain our Service Offerings and Platform. Where necessary we may use information to:
Send you information about new services, content, products and features offered by trackwire and provide other news and information we think will interest you (see Control Over Your Data below for details in how to opt out of these communications).
Establish and maintain your trackwire account.
Send you visitor messages and emails from your Plan Website. Send you security alerts, technical notices, support and administrative messages and emails.
Analyze and monitor trends, activities and usage in connection with our Platform.
Comply with our financial and legal obligations.
Process transactions and send related information, such as receipts, confirmations and user experience surveys.
Prevent security incidents and detect, investigate any other malicious, fraudulent, deceptive, or illegal activity and protect the rights and property of trackwire and others.
Repair, identify and debug errors in our Service Offerings and Platform.
Any specific purpose described to you at the time the information was collected.
We share Personal Data with companies, service providers, vendors and consultants that need access to Personal Data in order to assist us with web hosting, server deployment and maintenance, storage, and other infrastructure, payment processing, fraud prevention and security, analytics, communications, customer service and marketing.
We may share Personal Data if disclosure is required by any applicable law or legal process. This includes lawful requests by public authorities to meet national security or law enforcement requirements. If we intend to disclose your Personal Data in response to a legal request or process, we will give you notice, unless we are prohibited by law or believe doing so may endanger others or cause illegal conduct.
We may share Personal Data if we believe that your actions are in contradiction to our user agreements, terms or policies, if we believe that you have violated the law, or if we believe it is necessary to protect the rights, property and safety of trackwire, our users, the public, or others.
We share Personal Data with our lawyers and other professional advisory persons, companies or bodies where necessary to obtain advice or otherwise protect and manage our business and its interests. We may share Personal Data in connection with, or during negotiations concerning, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.
Personal Data is shared between and among trackwire and our current parents and affiliates, future subsidiaries and other companies under common control and ownership.
We also share anonymized or aggregated information that cannot reasonably be used to identify you.
We share Personal Data with your consent or at your direction.
trackwire is headquartered in Germany, and we supply Service Offerings in the EU, United States and other countries.
To facilitate the Service Offerings and the Platform we use service providers that have headquarters from outside the EU.
We currently use:
ActiveCampaign which is headquartered in Chicago, USA.
DigitalOcean which is headquartered in New York, USA.
Amazon Web Services which is headquartered in Seattle, USA.
Google which is headquartered in Mountain View, California, USA
Facebook which is headquartered in Menlo Park, California, USA
The service providers listed above have offices, branches or data centers based in the EU but we cannot guarantee that the information we Process will not processed outside of the EU. Therefore, we and our service providers may Process your Personal Data or anonymized information from outside the EU.
We will take steps to ensure that your Personal Data receives an adequate level of protection.
By default, most web browsers are set to accept cookies. You can adjust your browser settings to automatically reject or remove cookies, to find more information on this practise please consult the documentation of your particular browser. Please note that rejecting cookies could adversely affect functionality and your usability of Service Offerings and the Platform.
If you have a Plan Website, you may access, correct, update your account and payment information at any time by logging into the Platform and navigating to the Account page (Main Settings -> Account). Please note that if you choose to cancel your Plan Website, we may continue to retain certain information about you as required by law or for our legitimate business purposes.
If you decide to delete your account at trackwire, you can do so by logging into your account and requesting an account deletion by navigating to the help option. Once we receive your request for account deletion we will begin processing it immediately and will remove all identifiable Personal Data, we may continue to retain certain information about you as required by law or for our legitimate business purposes.
A trackwire account is necessary to continued functionality of Service Offerings. Therefore in order to delete your account you must first not have ongoing free or paid for Service Offerings. If you have ongoing free or paid for Service Offerings you must first cancel your Plan Website or other Service Offerings from the account page in the dashboard and then make an account deletion request after.
You may opt out of receiving certain email communications from us, such as updates, newsletters or promotions by following the instructions in those emails which is usually found at the bottom of the email. Please note that if you opt out, we may still send you administrative, transactional, security emails, visitor messages, which relate to your account or our ongoing business relations in regards to Service Offerings.
trackwire is located and headquartered in the EU and Processes data according to GDPR laws and regulations. If you are an EU citizen this section applies to your rights and applicable laws regarding the Processing of your Personal Data.
When we Process your Personal Data, we will do so on the following lawful bases:
To perform and conclude our responsibilities as is under our contract with you (e.g. providing the Service Offerings you requested and outlined in the terms and conditions and this document).
On the grounds of legitimate interest, processing your Personal Data or information in order to operate our business or protect our interests (e.g. to maintain, provide and improve our Platform and Service Offerings, conduct data analytics, and establish communication with you).
To comply with our legal obligations (e.g. maintaining records of your consents and tracking those who have opted out of non-essential and non-administrative communications).
When you consent for us to do so (e.g. when you opt in to receive non-administrative communications from us). You may withdraw such consent at any time when consent is the legal basis for our processing of your Personal Data.
We Process Personal Data associated with your trackwire account for as long as your account remains active. If you decide to delete your account, we delete your account data within 14 days. We store other Personal Data for as long as is necessary to carry out the purposes for which we originally collected it and for other legitimate business purposes, including to meet our regulatory, legal or other compliance obligations.
Subject to certain limitations, You have the right to request and receive access to the personal data we hold about you in a portable format, the right to ask that your personal data be corrected or erased, and the right to object to, or request that we restrict, certain processing. To exercise your rights:
If you sign up for a trackwire account, you may at any time request an export of your Personal Data from the Dashboard help page.
You may correct information associated with your account from the Account page, or by making a request from the help page.
You may withdraw consent by deleting your account at any time by making a request from the help page (after cancelling any active Plan Website if there is one) and to the extent trackwire is prevented by law from deleting your Personal Data.
You may object at any time to the use of your Personal Data by contacting privacy@trackwire.io.
If you have concerns about the processing of your Personal Data that we are not able to rectify or resolve for you. You have the right to lodge a complaint with the relevant Data Protection Authority where you reside. Please follow the links below:
For individuals in the EEA:
https://edpb.europa.eu/about-edpb/board/members_en
For individuals in the UK:
https://ico.org.uk/global/contact-us/
For individuals in Switzerland:
https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html
trackwire does not knowingly collect any Personal Identifiable Information from children under the age of 16. If you think that your child provided this kind of information on our website, we strongly encourage you to contact us immediately and we will do our best efforts to promptly remove such information from our records.
If you have any questions about this Privacy Policy, please contact us at privacy@trackwire.io
Luke Joseph
Luke Joseph Website Dienste
Donaustraße 13
12043
Berlin
