1. INTRODUCTION

We are the controller of your personal data collected from this website. For more information on controllers and their responsibilities, please see our guidance on data protection principles, definitions, and key terms.

TrackBack acts on behalf of our customers as the data processor. Our customers may use our services to contact you, with consent, by telephone, email or WhatsApp.

This privacy notice tells you what to expect us to do with your personal information.

• Contact details
• What information we collect, use, and why
• Lawful bases and data protection rights
• Where we get personal information from
• How long we keep information
• Who we share information with
• Sharing information outside the UK
• How to complain.

2. WHAT INFORMATION WE COLLECT, USE, AND WHY

We collect or use the following information to provide services and goods, including delivery:

• Names and contact details
• Addresses
• Website user information (including user journeys and cookie tracking)
• IP addresses
• Information relating to compliments or complaints

We collect or use the following information to prevent, detect, investigate or prosecute crimes:

• Names and contact information
• Customer or client accounts and records

We collect or use the following information for service updates or marketing purposes:

• Names and contact details
• Addresses
• Marketing preferences
• IP addresses
• Website and app user journey information

We collect or use the following information to comply with legal requirements:

• Name
• Contact details
• Any other personal information required to comply with legal obligations

We collect or use the following personal information for dealing with queries, complaints or claims:

• Names and contact details
• Address
• Account information
• Purchase or service history
• Correspondence.

3. LAWFUL BASES AND DATA PROTECTION RIGHTS

3.1 UK DATA PROTECTION LAW

Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.

Which lawful basis we rely on may affect your data protection rights which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:

• Your right of access - You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. Read more about the right of access.
• Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. Read more about the right to rectification.
• Your right to erasure - You have the right to ask us to delete your personal information. Read more about the right to erasure.
• Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information. Read more about the right to restriction of processing.
• Your right to object to processing - You have the right to object to the processing of your personal data. Read more about the right to object to processing.
• Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. Read more about the right to data portability.
• Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. Read more about the right to withdraw consent.

If you make a request, we must respond to you without undue delay and in any event within one month.

To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.

3.2 OUR LAWFUL BASES FOR THE COLLECTION AND USE OF YOUR DATA

Our lawful bases for collecting or using personal information to provide services and goods are:

• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
• Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

Our lawful bases for collecting or using personal information to prevent, detect, investigate or prosecute crimes are:

• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
• Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

Our lawful bases for collecting or using personal information for service updates or marketing purposes are:

• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

Our lawful bases for collecting or using personal information for legal requirements are:

• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
• Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:

• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

4. WHERE WE GET PERSONAL INFORMATION FROM

• Directly from you
• Our customers, as per business terms, where we act as a data Processor. Strict user opt-in requirements apply.

5. HOW LONG WE KEEP INFORMATION

Analytics retention is controlled via Google Analytics settings.

Form submission retention is controlled within Formspark.

CRM data is retained only for as long as necessary to fulfil its purpose, manage enquiries, or meet legal and regulatory requirements.

WhatsApp communications are stored for as long as required by our customers’ business terms.

For more information on how long we store your personal information or the criteria we use to determine this please contact us using the details provided above.

6. WHO WE SHARE INFORMATION WITH

6.1 Google

This data processor does the following activities for us: Website Analytics.

6.2 Webflow

This data processor does the following activities for us: Website Hosting provider.‍

6.3 Formspark

This data processor does the following activities for us: Form Handling.

6.4 HubSpot

This data processor does the following activities for us: Hosted CRM Provider.‍

6.5 Vimeo

This data processor does the following activities for us: Website usage analytics.

6.6 Meta Platforms, Inc.

This data processor does the following activities for us: WhatsApp communications.

6.7 Twilio Inc.

This data processor does the following activities for us: WhatsApp, SMS and telephone communications.

6.8 Nasstar

This data processor does the following activities for us: Telephone communications.

6.9 Vonage

This data processor does the following activities for us: SMS and telephone communications.

6.10 Others we share personal information with

Organisations we’re legally obliged to share personal information with.

7. SHARING INFORMATION OUTSIDE THE UK

Where necessary, we will transfer personal information outside of the UK. When doing so, we comply with the UK GDPR, making sure appropriate safeguards are in place.

For further information or to obtain a copy of the appropriate safeguard for any of the transfers below, please contact us using the contact information provided above.

7.1 Google

Category of recipient: Web Analytics

Country the personal information is sent to: United States

How the transfer complies with UK data protection law: The country or sector has been assessed as providing adequate protection to data subjects (also known as Adequacy Regulations or UK data bridge)

7.2 Meta Platforms, Inc.

Category of recipient: WhatsApp Communications

Country the personal information is sent to: United States

How the transfer complies with UK data protection law: The country or sector has been assessed as providing adequate protection to data subjects (also known as Adequacy Regulations or UK data bridge).

7.3 Twilio Inc.

Category of recipient: Production of Billing Information (please note, this does not include personal financial details).

Country the personal information is sent to: United States

How the transfer complies with UK data protection law: The country or sector has been assessed as providing adequate protection to data subjects (also known as Adequacy Regulations or UK data bridge).

7.4 Vonage

Category of recipient: SMS Communications, Production of Billing Information (please note, this does not include personal financial details).

Country the personal information is sent to: United States

How the transfer complies with UK data protection law: The country or sector has been assessed as providing adequate protection to data subjects (also known as Adequacy Regulations or UK data bridge).

8. HOW TO COMPLAIN

If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.

If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.

The ICO’s address:          

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113

Website: https://www.ico.org.uk/make-a-complaint

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