Privacy Policy

This Privacy Policy explains how wetracked.io Ltd. (“Company”, “we”, “us” or “our”) collects, uses, discloses, and otherwise processes Personal Information (as defined below) in connection with our website located at wetracked.io (the “Site”) and the related content, platform, services, and other functionality offered on or through the online services (collectively, the “Services”). It does not address our privacy practices relating to job applicants, employees and other personnel.

Information We Collect

We collect Personal Information three ways: (1) directly from an individual when an individual provides us information when interacting with us in some way, (2) automatically when an individual interacts with our Services; and (3) from third-party sources, which may be even before our first direct interaction with the user.

Information You Provide to Use Directly

In registering for email, signing up for any account with us, placing orders via the Site or through other means, and for communicating with us about our products, you provide, and we, in turn, collect some Personal Information about you, which means information that can directly or indirectly associate or otherwise identify you as a natural person. While, at some times, you may be providing this information or otherwise engaging with us as an employee of another company, the information you provide and that we may collect, may include information including your name, personal or work email, personal or work physical address, personal or work phone number, billing information, information about the products/services you are/have been interested in or otherwise purchased or returned.

Additionally, when you make a purchase or attempt to make a purchase through the Site, we collect certain information from you. When you interact with us, below are the categories of information we collection, including Personal Information:

• Contact Information, including name, email address, phone number and communication preferences. If you give us your mobile telephone number (including for SMS text messaging services), we will also collect and store that number.
• Inquiry Information, including information provided in custom messages sent through the forms or contact information provided on our Site.
• Account Information, including name, industry, employer, title, company logo, email address, phone number, username and password, profile information, payment and purchase history information, and any other information you provided to us, including any data you provide to us to calculate metrics. Please note we utilize a third-party provider to process payments on our behalf and do not accept payment directly through our Site.

Information We Collect Automatically

As is true of most digital platforms, we and our third-party providers may also collect Device Information, which includes your browsing actions and site usage patterns that are collected automatically when you visit or interact with our Site. This data, which, depending on where you are located, can include Personal Data, and may include: log data (such as internet protocol (IP) address, operating system, browser type, browser ID, the URL entered and the referring page/campaign, date/time of visit, time zone, the amount of time spent on our Site, errors that occurred during the Site visit, analytics data (such as the electronic path taken to our Site, through our Site and when exiting our Site, as well as usage and activity on our Site), and location data (such as general geographic location based on the log data we or our third-party providers collect).

We collect Device Information using the following technologies:

• “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.
• “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
• “Web beacons,” “tags,” and “pixels” are electronic files used to record information about how you browse the Site.

Our Site uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”), to collect and view reports about the traffic on our Site. More information about the use of Google Analytics for these analytical and non-advertising purposes can be obtained by visiting Google’s privacy policy here and Google’s currently available opt-out options are available here.

To manage cookies, an individual may change their browser settings to: (i) notify them when they receive a cookie, so the individual can choose whether or not to accept it; (ii) disable existing cookies; or (iii) automatically reject cookies. Please note that doing so may negatively impact an individual’s experience using our Site, as some features and offerings may not work properly or at all. Depending on an individual’s device and operating system, the individual may not be able to delete or block all cookies. In addition, if an individual wants to reject cookies across all browsers and devices, the individual will need to do so on each browser on each device they actively use. An individual may also set their email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether they have accessed our email and performed certain functions with it.

Information We Obtain From Third Parties

We also obtain Personal Information from third parties, which we often combine with Personal Information we collect either automatically or directly from an individual.

We may receive the same categories of Personal Information as described above from the following third parties:

• Business Partners: When an individual interacts with our Services through or in conjunction with our business partners, we may receive some information about individuals that they permit our business partners to share with third parties. For example, if you link or access your Ramp account through the Services, we may receive your information from these business partners.
• Social Media: When an individual interacts with our Services through various social media networks, such as when someone logs in through a social network, connects their Google or Facebook account to our Services, “Likes” us on Facebook or follows us or shares our content on Google, Facebook, Twitter, or other social networks, we may receive some information about individuals that they permit the social network to share with third parties. The data we receive is dependent upon an individual’s privacy settings with the social network. Individuals should always review and, if necessary, adjust their privacy settings on third-party websites and social media networks and services before sharing information and/or linking or connecting them to other services.
• Service Providers: Our service providers that perform services solely on our behalf, such as survey and marketing providers, collect Personal Information and often share some or all of this information with us.
• Information Providers: We may from time to time obtain information from third-party information providers to correct or supplement Personal Information we collect. For example, we may obtain updated contact information from third-party information providers to reconnect with an individual.
• Publicly Available Sources: We collect Personal Information about individuals that we do not otherwise have, such as contact information, employment-related information, and interest-in-services information, from publicly available sources. We may combine this information with the information we collect from an individual directly. We use this information to contact individuals, to send advertising or promotional materials or to personalize our Services and to better understand the demographics of the individuals with whom we interact.

‍How We Use Your Personal Information
‍
We generally use information that we collect for the purposes of fulfilling our contractual obligations to you, in furtherance of our legitimate interests in operating the
Services and our business and/or where you have consented to such usage. More specifically, however, we use your Personal Information in the following ways:

− Fulfill or meet the reason the information was provided, such as to fulfill our contractual obligations, to deliver the Services you have requested and to process transactions;

you

• Manage our organization and its day-to-day operations;
• Connect and input data from your third-party accounts;
• Communicate with individuals, including via email, text message, social media
  and/or telephone calls;
• Notify you about changes to our Services;
• Provide you with notices about your account and/or subscription, including
  expiration and renewal notices, and email instructions;
• Request individuals to complete surveys about our organization, organizations we
  partner with, and Services;
• Market our Services to individuals, including through email, direct mail, phone or
  text message;
• Provide you with news, special offers and general information about goods,
  services and events you may be interested in;
• Administer, improve and personalize our Services, including by recognizing an
  individual and remembering their information when they return to our Site;
• Process payment for our Services;
• Facilitate client benefits and services, including customer support through our
  command center services;
• Identify and analyze how individuals use our Site and Services;
• Conduct research and analytics on our client base and our Services;
• Improve and customize our Services to address the needs and interests of our
  client base and other individuals we interact with;
• Test, enhance, update and monitor the Services, or diagnose or fix technology
  problems;
• Help maintain the safety, security and integrity of our property and Services,
  technology assets and business;
• Defend, protect or enforce our rights or applicable contracts and agreements;
• Prevent, investigate or provide notice of fraud or unlawful or criminal activity;
• In the context of business transactions or proposed business transactions wherein we may be contemplating a merger or acquisition;

‍‍Comply with legal obligations; and
For any other reason for which you give us consent or that we otherwise notify that we may use your Personal Information.

Where an individual chooses to contact us, we may need additional information to fulfill the request or respond to inquiries. We may provide additional privacy disclosures where the scope of the inquiry/request and/or Personal Information we require fall outside the scope of this Privacy Policy. In that case, the additional privacy disclosures will govern how we may process the information provided at that time.

The legal basis for the associated processing of your Personal Information is Art. 6 (1)(f) GDPR (balancing of interests, based on our legitimate interest in constantly and profitably improving the content, functionality and attractiveness of the app by analyzing your usage) as well as Art. 6 (1)(b) GDPR (performance of a contract) and Art. 6 (1) a) GDPR (your consent).

How We Share or Otherwise Disclose Your Personal Information

We do not sell, rent or lease and Personal Information and have not in the immediate 12 months preceding the effective date of this Privacy Policy.

We may share, transfer and/or disclose your Personal Information to or with third parties in order to provide the Services or products requested or purchased by you, and under the following circumstances:

• Affiliates: We may share Personal Information with other companies owned or controlled by Company, and other companies owned by or under common ownership as Company, which also includes our subsidiaries (i.e., any organization we own or control) or our ultimate holding company (i.e., any organization that owns or controls us) and any subsidiaries it owns, particularly when we collaborate in providing the Services.
• Business Partners: We share Personal Information with our operations, sales and marketing, and finance business partners.
• Marketing Providers: We coordinate and share Personal Information with our marketing providers in order to communicate with individuals about the Services we make available.
• Customer Service and Communication Providers: We share Personal Information with third parties who assist us in providing our customer services and facilitating our communications with individuals that submit inquiries.
• Other Service Providers: In addition to the third parties identified above, we engage other third-party service providers that perform business or operational services for us or on our behalf, such as website hosting, infrastructure provisioning, IT services, analytics services, administrative services.
• Other Business As Needed To Provide Services: We may share Personal Information with third parties that an individual engages with through our Services or as needed to fulfill a request or transaction including, for example, payment processing services.
• Business Transaction or Reorganization: We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose Personal Information to a third party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal Information may also be disclosed in the event of insolvency, bankruptcy or receivership.
• Legal Obligations and Rights: We may disclose Personal Information to third parties, such as legal advisors and law enforcement:
  undefinedundefinedundefined
• * to detect, suppress, or prevent fraud;
• *  to protect the health and safety of us and others; or
• *  as otherwise required by applicable law.

− Otherwise with Consent or Direction: We may disclose Personal Information about an individual to certain other third parties or publicly with their consent or direction. For example, with an individual’s consent or direction we may post their testimonial on our Site or service-related publications.

EEA/EU Data Subject Data Protection Rights Under the General Data Protection Regulation (GDPR)

If you are a resident of the European Economic Area (EEA) or European Union (EU), you have certain data protection rights. We aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Information.

If you wish to be informed about what Personal Information we hold about you, have a copy of it, correct or otherwise rectify it, and/or if you want it to be removed from our systems, please contact us using the contact information set out below.

In certain circumstances, you have the following data protection rights:

• Request access to your Personal Information (commonly known as a “data subject access request”). This enables you to receive a copy of the Personal Information we hold about you where we are the data controller and to check that we are lawfully processing it.
• Request correction of the Personal Information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected, though we may need to verify the accuracy of the new information you provide to us.
• Request erasure of your Personal Information. This enables you to ask us to delete or remove Personal Information where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove your Personal Information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Information to comply with local law. Note, however, that we may not always be able to comply with your request for erasure for specific legal reasons, which will be explained to you, if applicable, at the time of your request.
• Object to processing of your Personal Information. You have the right to object where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground, as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.‍
• Request that we restrict the processing of your Personal Information. This enables you to ask us to temporarily stop the processing of your Personal Information in the following scenarios: (a) if you have concerns about the accuracy of your information and want to have it rectified; (b) where you believe our use of your information may be unlawful but you do not want us to erase it; (c) where you need us to hold the information for the purposes of defending or exercising your rights with respect to a legal claim even though we may no longer need it; or (d) you have objected to our use of your information but we need to verify whether we have overriding legitimate grounds to keep it.‍
• Request the transfer of your Personal Information to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.‍
• Withdraw consent at any time where we are relying on consent to process your Personal Information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority in the EEA.

If you wish to exercise any of the rights set out above, please contact us using the contact details below.

You will not have to pay a fee to access your Personal Information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in such circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure designed to ensure that Personal Information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

California Data Subject Rights‍

Shine the Light Law

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of personal Information that we share with our affiliates and/or third parties for marketing purposes and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request via email to: support@wetracked.io. We will respond to one request per California customer each year, and we do not respond to requests made by means other than as set forth above.

Notice to California, Nevada, and Utah residents

We do not disclose a user’s personal data to any third party for such third-party’s direct marketing purposes nor do we sell, rent or lease your Personal Information. California, Nevada and Utah allow their residents to opt-out of the sale of their Personal Information, however, we do not sell any such information at this time. If you are a California, Nevada or Utah resident we want you to know that, in the event we sell your Personal Information, you will have choices and can opt-out and can affect them by contacting us via email to: support@wetracked.io.

Do Not Track (Including California Do Not Track Disclosure)

Do Not Track is a privacy preference that users can set in their web browsers. When a user turns on the Do Not Track signal, the browser sends a message to websites requesting them not to track the user. At this time, we do not respond to Web browser “do not track” settings or signals. We deploy cookies and other technologies on our Service to collect information about you and your browsing activity, even if you have turned on the Do Not Track signal.

Children’s Privacy

Our Services are not directed to, and we do not intend to, or knowingly, collect or solicit Personal Information from children under the age of 13 (16 in the EEA/EU). If an individual is under the age of 13 (16 in the EEA/EU), they should not use our Services or otherwise provide us with any Personal Information either directly or by other means. If a child under the age of 13 (16 in the EEA/EU) has provided Personal Information to us, we encourage the child’s parent or guardian to contact us to request that we remove the Personal Information from our systems. If we learn that any Personal Information we collect has been provided by a child under the age of 13 (16 in the EEA/EU), we will promptly delete that Personal Information.

Links to Third-Party Website Via Our Site and/or Services

Our Site and Services may include links to third-party websites, plug-ins and applications. Except where we post, link to or expressly adopt or refer to this Privacy Policy, this Privacy Policy does not apply to, and we are not responsible for, any Personal Information practices of third-party websites and online services or the practices of other third parties. To learn about the Personal Information practices of third parties, please visit their respective privacy policies.

Data Retention

We will retain your Personal Information for as long as is reasonable or appropriate for the purposes set out in this Privacy Policy. We will also retain and use your Personal Information to the extent necessary or reasonable to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

We will also retain Device Information for internal analysis purposes. Device Information then the security or to improve the functionality of our Services, or we are legally obligated to retain this data for longer time periods.

Transfer of Personal Information

Your information, including Personal Information, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those in your jurisdiction.

If you are located outside the United States, please note that we transfer data, including Personal Information, to the United States and process it there.

By using the Services, you understand and acknowledge that your Personal Information will be transferred to and processed in the United States, which may have different data protection rules than in your country.

We will take steps reasonably designed to treat your Personal Information securely and in accordance with this Privacy Policy.

Protecting Your Information

We implement security measures designed to maintain the security of your Personal Information. These security measures are implemented both during transmission of Personal Information and once received. The security of your Personal Information is important to us. Certain sensitive information submitted, such as credit card information, is encrypted using secure layer technology (SSL). However, no method of safeguarding information is completely secure. While we use measures designed to protect Personal Information, we cannot guarantee that our safeguards will be effective or sufficient. In addition, you should be aware that Internet data transmission is not always secure, and we cannot warrant that information you transmit utilizing the Services is or will be secure.

We also implement encryption and tokenization of all personal data, making it unreadable. As wetracked.io never uses your customer personal data for other use, than matching to a certain source of revenue.

Communications Opt-Out

You may opt out of receiving marketing or other communications from us at any time by following the opt-out link or other unsubscribe instructions provided in any email message received, or by contacting us using the contact information provided below. If you wish to opt

out by sending us an email to the address provided below, please include “Opt-Out” in the email’s subject line and include your name and the email address you used to sign up for communications in the body of the email. Note that, even if you opt out of receiving marketing communications from us, we will still send you order confirmations and other non-marketing related messages.

Updates or Changes to This Privacy Policy

We will update this Privacy Policy from time to time. When we make changes to this Privacy Policy, we will change the date at the beginning of this Privacy Policy. If we make material changes to this Privacy Policy, we will notify individuals by email to their registered email address, by prominent posting on this Site or our Services, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided.

For users in the EEA, the EU, the United Kingdom, or Switzerland, any changes or modifications will be effective upon your express consent, as you will be notified of any changes by virtue of a pop-up, banner, or other notification mechanism when you seek to access the Site or Services after we issue a change or modification. Upon consent, the revisions on the Site or Services shall apply to all use of the Site or Services and all acts or omissions occurring after the effective date of the revised Privacy Policy.

Severability and Enforceability

To the extent any provision of this Privacy Policy is found by a competent tribunal to be invalid or unenforceable, such provision shall be severed to the extent necessary for the remainder to be valid and enforceable.

Our Contact Information

If you have any questions or requests in connection with this Privacy Policy or other privacy-related matters, please send an email to support@wetracked.io.‍

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