Last Update: October 1st, 2023

Privacy Policy

Introduction and Scope

Ecomtrak s.r.o a Qiriq Company (we, us, our), a Software As A Service (SAAS) - business to business (b2b)- tracking pixel that allows marketers to match online sales of their products to the right campaigns and scale ads with certainty. Marketing pixels, aka (“tracking pixels”), are essentially tiny snippets of code that allow you to gather information about visitors on a website—how they browse, what type of ads they click on, etc.

The Ecomtrak marketing pixel (software, service) is used to capture a marketing campaign’s performance, track conversions, and report on the attribution/lookback window of the sale by gathering information about visitors on a website from paid media. Information from the Ecomtrak tracking pixels allows companies to know how many visitors their site has and how many people have seen their digital ad and purchased products.

The Ecomtrak, tracking pixel provides personal data insights into ad interactions while adhering to all privacy and compliance laws, including GDPR, HIPAA, CCPA, and all the State Data Privacy Laws in the US. As used in this Privacy Policy, “Personal Data” means information that relates to and to an identifiable individual, as defined under applicable data protection laws.

This Privacy Policy applies to the Processing of Customer’s Personal Data when you use our Services and any additional interactions and communications between you and Ecomtrak. The software privacy policy describes how we handle user information and privacy practices for protecting our users. We believe you have the right to know what information we collect about you, how the information collected is being used, and how you can access or change any of this information.

Contacting Us

If you have any questions or comments about this Privacy Policy, please contact us using the following contact information:

Ecomtrack - A Qiriq Company - 6 Landmark Square, Suite 400. Stamford CT 06902helpdesk@ecomtrack.io

Protecting Your Privacy

Ecomtrak is committed to protecting the privacy of our users. We process personal data on behalf of our clients (their, they, business) who use our tracking pixel platform and we are considered a data processor. In those situations, it is the client who determines the purposes and means of the processing of personal data. Whilst there is a written contract in place between us and our client which sets out our data protection obligations, we neither control what personal data our clients collect nor how they use it. We are not responsible for their privacy statements.

This Privacy Policy neither applies to such clients` use of personal data, nor to our processing of such personal data for such clients. Please consult the terms and conditions and privacy policy of the relevant client to find out how they use your information and to establish whether and for what purpose they collect it.

Privacy Policy

This privacy policy (“Privacy Policy”) describes the collection of personal information by Ecomtrack s.r.o., (“Company,” “we,” “us”, or “our”) from users (“you”, “your”) of our website at www.ecomtrack.io (our “Site”) along with our related websites, partner website, networks, applications, platforms, and other services provided by us and on which a link to this Privacy Policy is displayed (collectively, our “Service” or “Services”). This Privacy Policy also describes our use and disclosure of such information.

For the purposes of EU and United Kingdom data protection laws ("Data Protection Legislation"), Ecomtrack s.r.o. is a data processor (i.e., responsibility to provide you (the data controller) with the means to fulfill data subject’s access to their own data and, in general, to implement responsible data collection practices).

Please read this Privacy Policy carefully to understand our practices regarding you and your clients (customers) personal information and how we will use it. By accepting this Privacy Policy and Terms and Conditions, you agree to our collection, storage, use and disclosure of you and your clients personal information from your websites as described in this Privacy Policy.

Privacy

  • 2.1 Privacy: For information about how we collect, use, share, or otherwise process information about you and your use of our Services and Software, please see the privacy policy. You have the option to manage information preferences.
  • 2.2 Data Protection Agreements: In some countries, the law requires that we put a data protection agreement in place with you if we handle Personal Data (as defined in the applicable agreement) for you as part of our Services and Software. These agreements are the EU Data Processing Agreement or Data Protection Terms, found in the following locations:
  • (A) European Union (“EU”) Data Processing Agreement (or “DPA”). The DPA terms apply where you provide Personal Data (as defined in the DPA) collected from individuals from countries in the European Economic Area (“EEA”) and the UK and where you are a “Controller” and Ecomtrak is a “Processor”under the General Data Protection Regulation (EU) 2016/679 (“GDPR”) or any successor for the GDPR associated with the withdrawal of the United Kingdom from the EU.
  • Our Data Processing Agreement sets out the additional terms, requirements and conditions on which Ecomtrak will process Personal Data when providing services under the Terms of Service Agreement pursuant to a SAAS License agreement order placed by the Customer. This Agreement contains the mandatory clauses applicable to Personal Data subject to and required by:

  • (a) Article 28(3) of the General Data Protection Regulation ((EU) 2016/679) (EU GDPR) for contracts between controllers and processors;
  • (b) Article 28(3) of the retained EU law version of the General Data Protection Regulation ((EU) 2016/679) (UK GDPR) for contracts between controllers and processors
  • (B) Data Protection Terms. The Data Protection Terms apply where you provide Personal Data (as defined in the Data Protection Terms) collected from individuals outside of the EEA and the UK and where Ecomtrak is Processing (as defined in the Data Protection Terms) this data at your instruction and on your behalf.

    2.3 Sensitive Personal Information. You agree not to collect, process, or store any Sensitive Personal Information (as defined below) using the Services and Software, except as (A) directly authorized by Ecomtrak, (B) intended by the Services and Software, or (C) governed by the Additional Terms, as applicable. You agree not to transmit, disclose, or make available Sensitive Personal Information to Ecomtrak or Ecomtrak’s third-party providers. “Sensitive Personal Information” means an individual’s financial information, data concerning an individual’s sexual behavior or sexual orientation, medical, or health information protected under any health data protection laws, biometric data, personal information of children protected under any child data protection laws (such as the personal information defined under the U.S. Children’s Online Privacy Protection Act (“COPPA”)) and any additional types of information included within this term or any similar term (such as “sensitive personal data” or “special categories of personal information”) as used in applicable data protection or privacy laws. If you are a Business, you also agree to ensure Business Users’ compliance with this section 2.4 (Sensitive Personal Information).

    2.4 Transfer of Personal Information. We process and store information in the U.S. and other countries. By using our Services and Software, you authorize Ecomtrak to transfer your personal information across national borders and to other countries where Ecomtrak and its partners operate.

    3. Use of Services and Software.

    3.1 License. Subject to your compliance with the Terms and applicable law, we hereby grant you a non-exclusive, limited, revocable right for you to install, access and use the Services and Software that we make available to you, and that you license from us. Each license is to be used by only one (1) person and cannot be shared. At the end of your license term, your license(s) will expire as set forth in your order document(s), or the Subscription and Cancellation Terms. The version(s) of the Services and Software available at your renewal date may be different from the version(s) available when you first licensed them from Ecomtrak. The versions of the Services and Software that Ecomtrak supports. You agree that your decision to use, access, or license the Services and Software is not contingent on the delivery of any future functionality or features, or dependent on any oral or written public comments made by us regarding future functionality or features.

    3.2 Ecomtrak Intellectual Property. We (and our licensors, as applicable) remain the sole owner of all right, title, and interest in the Services and Software. Except as stated in the Terms, we do not grant you any rights to patents, copyrights, trade secrets, trademarks, or any other rights in respect to the items in the Services or Software. This means you may not use our trade names, trademarks, service marks or logos in connection with any product or service that is not ours, or in any manner that is likely to cause confusion. We reserve all rights not granted under the Terms.

    What Information does Ecomtrak collect on the Websites?

    When you visit our websites, and your use of our Services and Software our marketing tracking tags collect data on user behavior and track marketing campaigns. We collect, store and process non-PII information about you and your computer or device log files and sessions. This information is shared with our b2b clients / customers with data insights and other third-party sites who help us analyze overall activity trends for purchasing products. We may receive reports from third party sites based on the use of these technologies from these companies on an individual or aggregated basis. For more information about cookies and tracking pixels, and how to disable them, please seehttps://support.google.com/chrome/answer/2790761

    Here are the different categories of information that may be collected from your device by the Websites, or by partners, affiliates, and other vendors acting on our behalf:

    • The type of browser you used to access the Websites

    • The times you accessed the Websites

    • The IP address of the device you used to access the Websites

    • The pages on the Websites that you viewed

    • The pages you visited before navigating to the Website(s).

    • Information about the computer or mobile device you use to access the Websites, including hardware model, operating system and version, and mobile network information.

    Cookies and similar technologies

    The Service uses cookies and similar technologies to distinguish you from other users of the Service. This enables us to provide you with the service specifically linked to your user profile and is required for the Service to function. Cookies are small files that allow for personalization of the Service experience by saving your information such as user ID and other preferences. The service also uses a related technology called local storage which allows preferences and session information to be stored locally on your computer or mobile device.

    Our Access to Your Content. We will only access, view, or listen to your Content in limited ways, and only as permitted by law. For example, in order to provide the Services and Software, we may need to access, view, or listen to your Content to (A) respond to Feedback or support requests; (B) detect, prevent, or otherwise address fraud, security, legal, or technical issues; and (C) enforce the Terms.

    Our automated systems may analyze your Content using techniques such as machine learning in order to improve our Services and Software and the user experience. Machine learning describes a subset of artificial intelligence in which a computing system uses algorithms to analyze and learn from data without human intervention to draw inferences from patterns and make predictions. The system may continue to learn and improve over time as it receives more data.

    We use machine learning to develop and improve our products and services, enabling us to deliver innovative and cutting-edge solutions. We also use machine learning to provide product features and customize our products and services.

    Collection and processing of sensitive information

    The Service does not collect or process ‘sensitive information’ defined as data consisting of racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, data concerning health or data concerning a natural person's sex life or sexual orientation. As such, you should not provide any such information as part of your user profile, as part of any correspondence, or by any other means with your use of the Service.

    How do we use personal information?

    We collect personal information when you create an account with the Services, when you update your account information, or otherwise correspond with us. We use your personal information for the following purposes:

    • To facilitate the creation of your account with the Service, to secure and personalize your interaction with the Service, and to provide the Services you have requested.

    • To send you administrative email notifications, such as security or support and maintenance advisories.

    • We may also use the personal information you provide to contact you regarding your use of the Service or to solicit feedback.

    • When you communicate with us using one of the methods described in this Privacy Policy, we may also keep a record of the time and date of any correspondence, and also organize this correspondence in one or more of an electronic filing system, an email system or a customer relationship management system.

    • We link this personal information to data about the way you use our Service and the pages you visit to help enhance, improve, operate, and maintain our Service, our platforms, websites, and other systems.

    • To prevent fraudulent use of our Service and other systems.

    • To prevent or take action against activities that are, or may be, in violation of our Terms and Conditions or applicable law.

    • We may also use the personal information you provide for direct marketing of our Services to you. We allow you to opt-out from receiving marketing communications from us as described in the “Communication choices” section below, and also at the time you sign up and create an account with the Service. Even if you opt-out, we may continue to send you administrative emails, including, for example, periodic updates to this Privacy Policy.

    • To display personalized or targeted content to you, and to display targeted advertising on third party websites.

    • For internal product development purposes to develop new products and services, and to improve existing ones.

    • To respond to your inquiries related to employment opportunities with us, or other general inquiries.

    Legal basis for processing in the EU and the United Kingdom

    If you are resident in the EU or the United Kingdom, we need to inform you about the legal basis on which we collect and use your personal information. In the EU and the United Kingdom, the purposes for which we process your personal information are:

    • Where we need to perform the contract we are about to enter into or have entered into with you for the Service.

    • For the purposes of legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

    • Where we need to comply with a legal or regulatory obligation in the EU and the United Kingdom.

    The legal basis depends on the category of personal information being processed, and the purpose for that processing. The following table indicates each category of personal information we process, and the legal bases we rely on to do so. Where legitimate interest has been used as the legal basis for processing, the specific legitimate interest we use has been described.

    Please contact us at helpdesk@ecomtrack.io if you need details about the specific legal basis we are relying on to process your personal information where one or more legal bases has been indicated.

    When do we share personal information?

    Except as described in this Privacy Policy, we will not disclose your personal information that we collect on the Service to third parties without your consent. We may disclose information to third parties if you consent to us doing so, as well as in the following circumstances:

    • Service Providers: We may disclose personal information to third-party service providers (e.g., web hosting providers and other SaaS providers) that assist us in our work. We limit the personal information provided to these service providers to that which is reasonably necessary for them to perform their functions, and we require them to agree to maintain the confidentiality of such personal information.

    • Business Transfers: Information about our users, including personal information, may be disclosed and otherwise transferred to an acquirer, successor or assignee as part of any merger, acquisition, debt financing, sale of company assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.

    • To Protect our Interests: We also disclose personal information if we believe that doing so is legally required or is in our interest to protect our property or other legal rights (including, but not limited to, enforcement of our agreements), or the rights or property of others, or otherwise to help protect the safety or security of our Service and other users of the Service.

    • To Comply with the Law: We may also disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

    Links to external sites

    The Service may contain links to other websites, products, or services that we do not own or operate. The Service also may contain links to Third-Party Sites such as social networking services. If you choose to visit or use any Third-Party Sites or products or services available on or through such Third-Party Sites, please be aware that this Policy will not apply to your activities or any information you disclose while using those Third-Party Sites or any products or services available on or through such Third-Party Sites. We are not responsible for the privacy practices of these Third-Party Sites or any products or services on or through them. Additionally, please be aware that the Service may contain links to websites and services that we operate but that are governed by different privacy policies. We encourage you to carefully review the privacy policies applicable to any website or service you visit other than the Service before providing any personal information on them.

    How long do we keep your personal information for?

    Unless otherwise specifically stated elsewhere in this Privacy Policy, we will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

    Aggregated and anonymized data that no longer identifies the user of the Service is maintained for the purposes necessary to provide the Service.

    Communication Choices

    If you receive marketing emails from us, you may unsubscribe at any time by following the instructions contained within the email. You may also opt-out from receiving marketing emails from us, and any other promotional communications that we may send to you from time to time (e.g., by postal mail) by sending your request to us by email at helpdesk@ecomtrack.io or by writing to us at the address given in the ‘Contacting Us’ section of this Privacy Policy.

    Please be aware that if you opt-out of receiving marketing email from us, it may take up to ten business days for us to process your opt-out request, and you may receive marketing email from us during that period. Additionally, even after you opt-out from receiving marketing messages from us, you will continue to receive administrative and transactional messages from us regarding your use of the Service.

    Through your use of the Services, you may have provided us with a mobile telephone number. We may use this telephone number to send automated text/SMS messages, for example to send you reminders for various events, webinars, and strategy sessions you have signed up for. You may opt-out of receiving these messages by replying with a request to opt-out. You may also opt-out of receiving these messages by sending your request to us by email at helpdesk@ecomtrack.io or by writing to us at the address given in the ‘Contacting Us’ section of this Privacy Policy.

    Rights to access

    If you have a user account and profile on our Service, you have the ability to access and update many categories of personal information that you provide to us by logging in to your account and accessing your account settings. If you wish to access or amend any other personal information we hold about you, you may contact us at helpdesk@ecomtrack.io. If you request that we delete your account with our Service, we will do so within a reasonable period of time, but we may need to retain some of your personal information in order to satisfy our legal obligations, or where we reasonably believe that we have a legitimate reason to do so.

    EU privacy rights

    If you are located in the EU, you have the following Data Subject Access Rights with respect to your personal information that we hold:

    Right of access: You have the right to access the personal information that we hold about you.

    Right to rectification: You may have the right to require us to correct any inaccurate or incomplete personal information we hold about you.

    Right to erasure: In certain circumstances, you may have the right to the erasure of your personal information we hold about you (for example where it is no longer necessary in relation to the purposes for which it was collected or processed).

    Right to restriction: You may have the right to request that we restrict processing of your personal information in certain circumstances (for example where the accuracy of the personal information is contested by you, for a period enabling us to verify the accuracy of that personal information).

    Right to portability: In some limited circumstances, you may have the right to portability which allows you to move, copy or transfer personal information from one organization to another.

    Right to object: You have a right to object to us processing your personal information when the processing is based on legitimate interests and also to stop us from sending you direct marketing.

    Rights in relation to automated decision making and profiling: You have the right not to be subject to a decision that affects you based solely on automated processing. We do not perform any automated decision making and profiling.

    If you wish to exercise one of these rights, please contact us at helpdesk@ecomtrack.io or via ‘Contacting us’ section of this Privacy Policy.

    California privacy disclosures

    California law requires us to let you know how we respond to web browser Do Not Track (DNT) signals. Because there currently isn’t an industry or legal standard for recognizing or honoring DNT signals, we don’t respond to them at this time. We await the result of work by the privacy community and industry to determine when such a response is appropriate and what form it should take.

    A California resident who has provided personal information to a business with whom he/she has established a business relationship for personal, family, or household purposes (“California Customer”) is entitled to request information about whether the business has disclosed personal information to any third parties for the third parties’ direct marketing purposes, subject to certain exceptions, as defined in California Civil Code Sec. 1798.83. In general, subject to certain exceptions, if the business has made such a disclosure of personal information, upon receipt of a request by a California Customer, the business is required to provide, free of charge, a list of all third parties to whom personal information was disclosed in the preceding calendar year, as well as a list of the categories of personal information that were disclosed. California Customers may request further information about our compliance with this law by sending an email to.

    Other US State privacy disclosures

    Our Data Processing Agreement (Agreement) sets out the additional terms, requirements, and conditions on which Ecomtrack.io will process Personal Data when providing services under the Terms of Service Agreement in accordance with the Customer. This Agreement contains the mandatory clauses applicable to Personal Data subject to the new data protection laws, which apply to the collection and processing of personal information forCalifornia, Connecticut, Colorado, Nevada, Virginia, and Utah as required by US state laws.

    What is our policy on children

    Children’s safety is important to us, and we encourage parents and guardians to take an active interest in the online activities of their children. Our Services are not directed to users under the age of 16, and we do not knowingly collect personal information from children under the age of 16 without obtaining parental consent. If we learn that we have collected personal information from a child under the age of 16 on our Services, we will delete that information as quickly as possible. If you believe that we may have collected any such personal information on our Services, please notify us at helpdesk@ecomtrack.io.

    Where do we store and process your personal information?

    International Transfers: Our servers and data centers are located in the United States (US). If you choose to use the Service from outside the US, then you should know that you are transferring your personal information outside of your region and into the U.S. for storage and processing. We may also transfer your data from the U.S. to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating the Service. You should know that each region can have its own privacy and data security laws, some of which may be less stringent as compared to those of your own region. If you are located in the European Union (EU) or the United Kingdom (UK), then the countries we may transfer your data to, including the US, may not have data protection laws as comprehensive as those in the EU and the UK. To ensure your data is protected, and that we comply with the applicable data protection laws, we have implemented the following measures:

    Standard Contractual Clauses: We use the Standard Contractual Clauses (SCCs) for transfers of personal information to us, and also for transfer of personal information to third-party service providers. These clauses require the recipients to protect the personal information they receive in accordance with European data protection laws and regulations. Details of our use of SCCs can be provided upon request.

    Derogations: In certain circumstances we may transfer personal information based on the decorations contained in Article 49 of the General Data Protection Regulation (GDPR).

    Adequacy Decisions: Where applicable, we may rely on adequacy decisions provided by the European Commission under Article 45 of the GDPR to transfer your personal information outside of the EU or UK.

    Note that we no longer rely on the EU-US Privacy Shield Framework or the Swiss-US Privacy Shield Framework for the purposes of transferring data outside of the EU and United Kingdom, however we remain certified and committed to the Privacy Shield Framework principles, and this commitment is described in the next section. By providing your personal information to us through your use of the Services, you agree to the various measures we have implemented.

    Privacy Shield Notice: We comply with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information received from European Union countries, the United Kingdom, and Switzerland (the "Privacy Shield"). We have certified that we adhere to the Privacy Principles of notice, choice, and accountability for onward transfer, security, data integrity, purpose limitation, access, and recourse, enforcement, and liability ("Principles"). If there is any conflict between the policies in this Privacy Policy and the Privacy Shield Principles, the Principles shall govern. In cases of onward transfers of data received pursuant to the EU-U.S. and Swiss-U.S. Privacy Shield, we are potentially liable. To learn more about Privacy Shield, please visit the U.S. Department of Commerce Privacy Shield website:https://www.privacyshield.gov/. For more information regarding our Privacy Shield certification, please see:https://www.privacyshield.gov/list.

    How do we secure your personal information?

    To help protect your data, we use commercially reasonable steps to protect the data that we collect, including your personal information. The reasonable steps include protecting this data against accidental loss, unauthorized use, disclosure, and restricting access to personal information by our staff. The Service is hosted by a third-party hosting company that we have determined maintains adequate security controls and utilizes TLS encryption for all internet communication with the Service. We also require all staff that administer and develop the Service follow industry-standard controls, including strong passwords, the use of anti-virus and anti-malware software, disk encryption and other best practices.

    We use various 3rd party processors to enable us to provide the Service, and as part of our vendor due-diligence, we review the security controls these processors have in place and ensure they meet industry standards appropriate for the type of data we collect.

    You should keep in mind, however, that the Service utilizes software, hardware, and networks, which from time to time require maintenance and experience problems beyond our control. Note that no data transmission over the public internet or encryption method can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security of any information that you provide to us. You transmit information to us at your own risk.

    AGREED TERMS

    1. Definitions and interpretation

    The following definitions and rules of interpretation apply in this Agreement.

    1.1 Definitions:

    ECOMTRAK.IO Affiliate means an entity that owns or controls, is owned or controlled by or is or under common control or ownership with ECOMTRAK.IO, where control is defined as the possession, directly or indirectly, of the power to direct or cause the direction of the management and policies of an entity, whether through ownership of voting securities, by contract or otherwise.

    Applicable Data Protection Law means the data protection and privacy law, if it exists on the Effective Date of this Agreement, governing the processing, storage, transfer or other use of Personal Data and privacy of certain individuals including the California Data Privacy Legislation (as applicable to Personal Data of individuals located in California under certain circumstances), the European Data Protection Legislation (as applicable to Personal Data of individuals located in the EU), and the UK GDPR (as applicable to Personal Data of individuals located in the UK), and its associated regulations, if and when in force from time to time.

    Business Purposes means the services to be provided by ECOMTRAK.IO to the Customer as described in the Terms of Service Agreement and any other purpose specifically identified in Schedule 1.

    California Data Privacy Legislation means the California Consumer Privacy Act (California Civil Code Sec. 1798.100 et seq., also known as the California Consumer Privacy Act of 2018), the California Privacy Rights Act (California Civil Code Sec. 1798.120 et seq., also known as the California Privacy Rights Act of 2020, in effect beginning January 1, 2023), and its associated regulations, if and when in force from time to time.

    Controller: The UK GDPR defines a controller as: the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.

    European Data Protection Legislation means:

    (i) all applicable data protection and privacy legislation in force from time to time in the UK including without limitation the UK GDPR; the Data Protection Act 2018 (and regulations made thereunder) (DPA 2018); the Privacy and Electronic Communications Regulations 2003 (SI 2003/2426) as amended; and

    (ii) all applicable data protection and privacy legislation in force from time to time in the EU including Regulation 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the Processing of Personal Data and on the free movement of such data (General Data Protection Regulation) (EU GDPR); and Directive 2002/58/EC concerning the Processing of Personal Data and the protection of privacy in the electronic communications sector;

    Data Subject: The identified or identifiable living individual to whom the Personal Data relates.

    EEA means the European Economic Area.

    Personal Data means any information relating to an identified or identifiable living individual that is processed by ECOMTRACK on behalf of the Customer as a result of, or in connection with, the provision of the services under the Terms of Service Agreement ; an identifiable living individual is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of the individual.

    Processing, processes, processed, process means any activity that involves the use of the Personal Data. It includes, but is not limited to, any operation or set of operations which is performed on the Personal Data or on sets of the Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction. Processing also includes transferring the Personal Data to third parties.

    Personal Data Breach means a breach of security leading to the accidental, unauthorised or unlawful destruction, loss, alteration, disclosure of, or access to, the Personal Data.

    Processor means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the Controller.

    Records means has the meaning given to it in Clause 12.

    Standard Contractual Clauses (SCC) means the European Commission's Standard Contractual Clauses for the transfer of Personal Data from the European Union to processors established in third countries (controller-to-processor transfers), as set out in the Annex to Commission Decision 2010/87/EU, a completed copy of which comprises Schedule 2 or such alternative clauses as may be approved by the European Commission from time to time. The SCC shall only apply to the extent that the European Data Protection Legislation governs any Personal Data.

    Term means this Agreement's term as defined in the policy.

    UK GDPR means has the meaning given to it The UK's implementation of the General Data Protection Regulation (GDPR) is called the Data Protection Act 2018. The UK GDPR rules became effective on January 1, 2021. The UK GDPR absorbs the privacy compliance requirements of the EEA's GDPR.

    The following definitions and rules of interpretation apply in this Agreement.

    1.2 Applicable Data Protection Law means the data protection and privacy law, if it exists on the Effective Date of this Agreement( the date of acceptance of providing your data on the lead form), governing the processing, storage, transfer or other use of Personal Data and privacy of certain individuals including the California Data Privacy Legislation (as applicable to Personal Data of individuals located in California under certain circumstances), the Colorado, Connecticut, Nevada, Utah, Virgina, European Data Protection Legislation (as applicable to Personal Data of individuals located in the EU), and the UK GDPR (as applicable to Personal Data of individuals located in the UK), and its associated regulations, if and when in force from time to time.

    1.3 California Data Privacy - https://oag.ca.gov/privacy/ccpa Legislation means the California Consumer Privacy Act (California Civil Code Sec. 1798.100 et seq., also known as the California Consumer Privacy Act of 2018), the California Privacy Rights Act (California Civil Code Sec. 1798.120 et seq., also known as the California Privacy Rights Act of 2020, in effect beginning January 1, 2023), and its associated regulations, if and when in force from time to time. If you are a resident of the State of California and would like to learn how your “personal information” (as defined in the Shine the Light Law, Cal. Civ. Code § 1798.83) is shared with third parties, what categories of personal information that we have shared with third parties in the preceding year, as well as the names and addresses of those third parties, please e-mail us at: helpdesk@ecomtrack.io; call us at: (475) 242-4615; or send us U.S. mail to: Ecomtrak.io Inc 6 Landmark Square, Stamford, CT. Further, if you are a resident of the State of California and would like to opt-out from the disclosure of your personal information to any third-party for marketing purposes, please e-mail us at: helpdesk@ecomtrack.io; call us at: (475) 242-4615; or send us U.S. mail to: Quantum Digital Media, Inc 6 Landmark SQ, Stamford, CT.

    1.4 YOUR COLORADO PRIVACY RIGHTS - https://leg.colorado.gov/bills/sb21-190 If you are a resident of the State of Colorado and would like to opt-out from the sale of your personal information to any third party data broker, please e-mail us at: helpdesk@ecomtrack.io; call us at: (475) 242-4615; or send us U.S. mail to: Ecomtrak.io 6 Landmark Square, Stamford CT 06902.

    1.5 YOUR CONNECTICUT PRIVACY RIGHTS - https://www.cga.ct.gov/2022/ACT/PA/PDF/2022PA-00015-R00SB-00006-PA.PDF If you are a resident of the State of Connecticut and would like to opt out from the sale of your personal information to any third party data broker, please e-mail us at: helpdesk@ecomtrack.io; call us at: (475) 242-4615; or send us U.S. mail to: Ecomtrak.io 6 Landmark Square, Stamford CT 06902.

    1.6 YOUR NEVADA PRIVACY RIGHTS - https://www.leg.state.nv.us/nrs/nrs-603a.html If you are a resident of the State of Nevada and would like to opt-out from the sale of your personal information to any third party data broker, please e-mail us at: helpdesk@ecomtrack.io; call us at: (475) 242-4615; or send us U.S. mail to: Ecomtrak.io 6 Landmark Square, Stamford CT 06902.

    1.7 YOUR UTAH PRIVACY RIGHTS - https://le.utah.gov/~2022/bills/static/SB0227.html If you are a resident of the State of Utah and would like to opt-out from the sale of your personal information to any third party data broker, please e-mail us at: helpdesk@ecomtrack.io; call us at: (475) 242-4615; or send us U.S. mail to: Ecomtrak.io 6 Landmark Square, Stamford CT 06902.

    1.8 YOUR VIRGINA PRIVACY RIGHTS - https://law.lis.virginia.gov/vacode/title59.1/chapter53/ If you are a resident of the State of Virginia and would like to opt out from the sale of your personal information to any third party data broker, please e-mail us at: helpdesk@ecomtrack.io; call us at: (475) 242-4615; or send us U.S. mail to: Ecomtrak.io 6 Landmark Square, Stamford CT 06902.

    Updates to this Policy

    We may occasionally update this Policy. When we do, we will also revise the ‘last updated’ date at the beginning of the Policy. Your continued use of our Service after such changes will be subject to the then-current policy. If we change this Policy in a manner that is material, we will use reasonable efforts to notify you via the contact methods you have provided of the change prior to applying the change to any personal information that we collected from you prior to the date the change becomes effective. We encourage you to periodically review this Privacy Policy to stay informed about how we collect, use, and disclose personal information.