1. IntroductionThis notice applies to citizens of the United States of America and supplements the information contained in the Privacy Notice of Traka and its subsidiaries (collectively, “we,” “us,” or “our”) and applies solely to visitors, users, and others who reside in the United States of America when you visit the Traka website or provide contact information to receive Traka services (collectively, our “Services”). We adopt this notice to comply with state regulations such as the California Consumer Privacy Act of 2018 (“CCPA”) and other member state laws such as Nevada Privacy Law. Any terms defined in the CCPA have the same meaning when used in this notice. 2. CookiesThis website uses cookies and other cookie tracking technologies (referred as "cookies"). As explained in our Traka Cookie Notice, when visiting our website you can choose to accept cookies and enable sharing of your cookie-related personal data. Please read our cookie notice to be informed about the use of cookies on our website. We have agreements with other companies that place and use cookies. Parties on these agreements are to be considered as independent data “business” (per CCPA definition). We recommend that you read the privacy statements of these companies. 3. Cookie ConsentA pop-up with the purpose of the cookies will show up when you visit our website for the first time. You do have the right to opt-out and to object to the further use of non-essential cookies. To change your preferences please follow the URL to the Traka Cookie Notice and click on ‘Cookie Settings’. You can also disable the use of cookies via your browser; note this might cause our website to no longer work properly. 4. Personal InformationTraka takes your privacy seriously and does not monetize your personal information. Certain states such as California and Nevada define the “sale” of data broadly, including the sharing of data with third parties. Under CCPA using cookie related technologies to display personalized advertisements to our website visitors such as with Google Ads may be defined as a “sale”. The following section describe the “collection, sharing, disclosing, selling” of personal information. Personal Information We Collect We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months: |
Category | Examples | Collected |
A. Identifiers | A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name. | YES |
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code §1798.80(e)) | A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. | YES |
C. Protected classification characteristics under California or federal law | Age, race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). | NO |
D. Commercial information | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | NO |
E. Biometric information | Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. | NO |
F. Internet or other similar network activity | Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement. | YES |
G. Geolocation data | Physical location or movements. | YES |
H. Sensory data | Audio, electronic, visual, thermal, olfactory, or similar information. | NO |
I. Professional or employment-related information | Current or past job history or performance evaluations. | NO |
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)) | Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. | NO |
K. Inferences drawn from other personal information | Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | NO |
Sources of personal information:
Use of Personal Information We may use or disclose the personal information we collect for one or more of the business purposes describe in Section 1.2 ‘Use of your personal data’ in our Privacy Notice. Sharing Personal Information Traka takes your privacy seriously and does not monetize your personal information. Certain states such as California and Nevada define the “sale” of data broadly, including the sharing of data with third parties. Under CCPA using cookie related technologies to display personalized advertisements to our website visitors such as with Google Ads may be defined as a “sale”. The following section describe the “sharing, disclosing, selling of personal information. We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
We disclose your personal information for a business purpose to the following categories of third parties:
In the preceding twelve (12) months, we have sold the following personal information.
5. Your rights with respect to personal dataYou have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. You may submit a request:
Once we receive and confirm your verifiable consumer request, we will disclose to you the requested information. You may be asked to provide additional proof of identification so that we can verify your identity, and we may require that you validate the request. Please note that you are limited by law in the number of requests you may submit per year. We may deny your deletion request if retaining the information is necessary for us if we have a valid legal reason such as, to provide you with goods or services you have requested, for security reasons, customer support or comply with other legal obligations. To exercise these rights, please refer to the contact details at the bottom of this statement. If you have a complaint about how we handle your data, we would like to hear from you. 6. Non-DiscriminationWe will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
7. Changes to Our Privacy NoticeWe reserve the right to amend this Privacy Notice at our discretion and at any time. The date this Privacy Notice was last updated is identified at the bottom of this page. You are responsible for periodically visiting the Traka website and this Privacy Notice to check for any changes. 8. Authorized AgentsTo the extent that you elect to designate an authorized agent to make a request on your behalf, they must provide appropriate documentation including a written signed permission form from you, proof of your identity, and verification of their identity; or a valid, designated power of attorney, as required under the California Probate Code. We may require additional proof of authority or may need to contact you directly to validate the request. 9. Contact DetailsFor questions and/or comments about our policies and this statement, please contact us by using the following contact details: Requests to exercise your rights should be addressed to: “Attn.: Traka Data Protection Manager” e-Mail: info@trakausa.com Last updated: 2022-01-11 |