TRACT PRIVACY NOTICE

We are committed to safeguarding and respecting your privacy and providing you with the information, options and choices necessary for you to control how we use your information. That is why in this privacy and cookie notice (“Notice”) we describe how we collect, process and use your personal data. This Notice applies to all personal data we process about you when you visit our website www.tract.eco, use the TRACT platform or otherwise interact with us as described below. We process and protect your personal data (“Personal Data”) as defined by the General Data Protection Regulation (“GDPR”) and the Dutch GDPR Implementation Act with the utmost care. By “you” we refer to any natural person within the scope of this Notice, particularly visitors our website and social media platforms, TRACT Platform users and job applicants. While processing your Personal Data, we comply with requirements imposed by GDPR and other applicable laws and regulations.  

1. Who we are 

   Tract B.V. is a Dutch private company with limited liability, based at Lighthouse Building, floor 6., Basisweg 32, 1043 AP, Amsterdam, The Netherlands, (hereafter: “TRACT”, “we” and “our”). We process your Personal Data as a data controller which means that the main decisions are made by TRACT about the purposes and means with regard to the processing of Personal Data and we are responsible for the collection and use of your Personal Data as described in this Notice. We may also process your Personal Data related to your access and use of the TRACT Platform on behalf of our customer as a data processor in accordance with the applicable Data Processing Agreement and underlying Master User Agreement we signed with the customer.  

2. Information we collect and process about you

   1. The Personal Data we collect and process, as well as the purpose, will depend on the services provided to you. The legal meaning of the term 'processing' is very broad and includes, among other things: the collection, storage, consultation, use and deletion of personal data. You are free to share your Personal Data with us, however  in some cases, if you fail to provide us with the required information, we may not be able to provide you with our services or access to certain information. 

      We will collect and process Personal Data about you in the following situations: 

   • TRACT Website Visit: we collect information about you when you visit our website (www.tract.eco) to learn more about us, download materials, register for a webinar or otherwise connect with us. You may always change the communication preferences with us as explained in Section 8 of this Notice. Personal Data we collect about you may include your full name, email, position, company name, phone number and cookies. 

   • TRACT Sales and Marketing Activities: we collect information that you give us directly when you interact with us related to our sales and marketing communication activities such as providing you with promotional materials and information or a commercial offer, online or offline campaigns, events and webinars, commenting on our blogs, posts and other social media activities. You may always change the communication preferences with us as explained in Section 8 of this Notice. Personal Data we collect about you includes your full name, email, position, company name and phone number. 

   • TRACT Recruitment and Hiring: If you apply directly for a job with us, or if you have been engaged with us via an external recruitment agency, we will process the following Personal Data of you that we receive directly from you or extract from your CV or other materials that is shared with us: your first and your last name, your date of birth, your address, your phone number, your email address, your LinkedIn profile and other professional public social media profiles, your personal identification or passport number, date of entry to the Netherlands. 

   • TRACT Platform Use: we process Personal Data about you on behalf of our customer as a data processor so that you can access and use the TRACT Platform and related services according to the signed Data Processing Agreement and underlying Master User Agreement. This information includes your full name, position, company name, email, phone number, IP address and log-in credentials. You may reach out to the administrator of your TRACT account in case you need more information. 

3. Purposes of processing your Personal Data 

   The main purposes for which we process your Personal Data are as follows: 

   • Provide and improve our products and services to you; 

   • Sales and marketing communication purposes, based on your communication preference; 

   • For administrative and statistical purposes; 

   • For record keeping and to comply with statutory legal and fiscal obligations; 

   • For recruitment and hiring process (internships, employment) to hold a job interview, to conclude an internship or employment agreement, to pay out rewards.  

4. Legal basis

   We process your Personal Data on the basis of consent, performance of a contract, to comply with legal obligations or if it is in our legitimate interests.  

   When we process your Personal Data for our legitimate interest, we will also take you into account and ensure that the further processing of your Personal Data is performed in accordance with the legal requirements. As such we will also look into ensuring that processing for this purpose is compatible with the purpose for which the Personal Data were initially collected. This does not apply when such processing is performed due to a legal obligation. Our legitimate interests are for example: improving our product and services, reducing our costs, improving our newsletters and website or ensuring the integrity of our services and facilities. 

5. Information sharing with Third Parties 

   It is possible that your Personal Data is shared with trusted third parties that perform business functions or provide services to us for the execution of the purposes listed in this Notice. All such third parties will be required to adequately safeguard your Personal Data, subject to agreements that correspond to the requirements of applicable laws. We conclude a data processing agreement with such trusted third parties that process your Personal Data on our behalf to ensure at least the same level of security and confidentiality of your Personal Data as provided by TRACT. TRACT remains responsible for these processing operations. 

   Our website may contain hyperlinks to third party websites. TRACT is not responsible for the content of any such third-party websites and their content and offers. 

   TRACT engages the following third parties that are qualified as our sub-processors to provide (parts of) services on its behalf. We will update the below list as applicable.