PRIVACY POLICY
Traceable Inc. (“Traceable,” “we,” “us,” or “our”) has prepared this Privacy Policy to explain what Personal Data (defined below) we collect, how we may collect, use, retain or disclose your personal information in connection with your use of the Traceable websites (the “Site”), the Traceable software, and any Traceable products or services that reference or otherwise incorporate this Privacy Policy (the “Product”) as well as your attendance at, or participation in, Traceable events (collectively the “Services”).
This Privacy Policy explains what Personal Data (defined below) we collect, how we use and share that data, and your choices concerning our data practices. This Privacy Policy is incorporated into and forms part of our http://traceable2024.wpengine.com/terms-of-service.
Before using the Services or submitting any Personal Data to Traceable, please review this Privacy Policy carefully and contact us if you have any questions. By using the Services, you agree to the practices described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not access the Site or otherwise use the Services.
1. PERSONAL DATA WE COLLECT
We collect information that alone or in combination with other information in our possession could be used to identify you (“Personal Data”) as follows:
Personal Data You Provide: Most of the Personal Data we collect or maintain about you is provided directly by you to us. For example, we receive and store personal information you voluntarily enter on our Services or otherwise provide to us (e.g., when you register for and use the Services, when you make payments to us, or submit requests for support to us or when you have a direct communication with us).
Personal Data we collect directly from you includes:
- Identifiers (such as real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name or other similar identifiers);
- Commercial and payment information (such as products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies, credit card numbers (collected by our payment processors), financial account information, and other payment details);
- Audio/visual information;
- Professional, educational or employment related information; and
- Any other personal information that you elect to communicate to us directly during your communications with us or use of the Services.
When you are asked to provide Personal Data, you may decline. As further described below, in certain cases, you may use web browser or operating system controls to prevent certain types of automatic data collection. However, if you choose not to provide or allow personal information that is necessary for certain services or features, those services or features may not be available or fully functional.
If you choose to provide us with Personal Data about another person, you shall ensure that you have obtained the consent of that person to share their information with us.
Social Media Data: We have pages on social media sites like Instagram, Facebook, Medium, Twitter, and LinkedIn (“Social Media Pages”). When you interact with our Social Media Pages, we will collect Personal Data that you elect to provide to us, such as your contact details. In addition, the companies that host our Social Media Pages may provide us with aggregate information and analytics regarding the use of our Social Media Pages.
Internet Activity Data: When you visit, use, and interact with the Service, we may receive certain information about your visit, use, or interactions. For example, we may monitor the number of people that visit the Service, peak hours of visits, which page(s) are visited, the domains our visitors come from (e.g., google.com, yahoo.com, etc.), and which browsers people use to access the Service (e.g., Chrome, Firefox, Microsoft Internet Explorer, etc.), broad geographical information, and navigation pattern. In particular, the following information is created and automatically logged in our systems:
- Log Data: Information that your browser automatically sends whenever you visit the Site or Services. Log Data includes your Internet Protocol address, browser type and settings, the date and time of your request, and how you interacted with the Site.
- Cookies Data: Please see the “Cookies” section below to learn more about how we use cookies.
- Device Data: Includes name of the device, operating system, and browser you are using. Information collected may depend on the type of device you use and its settings.
- Usage Data: We collect information about how you use our Service, such as the types of content that you view or engage with, the features you use, the actions you take, and the time, frequency, and duration of your activities.
- Location Data: We derive a rough estimate of your location from your IP address.
- Email Open/Click Data: We use pixels in our email campaigns that allow us to collect your email and IP address as well as the date and time you open an email or click on any links in the email.
Personal Data We Process on Behalf of Our Business Customers: In order to provide the Service, subject to your enterprise customer agreement with Traceable. Traceable uses the Product installed on your systems to collect information on the operation and status of your application and system infrastructure and analyzes that information to detect active or potential security threats and possible performance issues. Through those connections, we may receive Personal Data about employees and customers of our business customers that such business customers make available to us, such as names, emails, phone numbers, billing details, product information, order information and other personally identifiable information as may be a part of API request and response of the business customer information system and is not explicitly redacted by the business customer. We process that information pursuant to our enterprise customer agreements with our business customers. We have no direct relationship with the individuals whose Personal Data we process on behalf of our business customers. If you are such an individual and would no longer like your data to be used by one of our business customers that use our Service or you would like to access, correct, or request deletion of your data, please contact the business customer that you interact with directly.
Personal Data from Third-Party Sources. In certain cases, the Personal Data we obtain is from third party sources, including:
- Data brokers. Data brokers and aggregators from which we obtain personal information to supplement the data we collect.
- Third party partners. Third party applications and services, including those you choose to connect with or interact with through our services.
- Co-branding/marketing partners. Partners with which we offer co-branded services or engage in joint marketing activities.
- Service providers. Third parties that collect or provide personal information in connection with work they do on our behalf, for example companies that determine your device’s location based on its IP address.
- Publicly available sources. Public sources of personal information such as open government databases.
Cookies: We use cookies to operate and administer our Site, gather usage data on our Site, and improve your experience on it. A “cookie” is a piece of information sent to your browser by a website you visit. Cookies can be stored on your computer for different periods of time. Some cookies expire after a certain amount of time, or upon logging out (session cookies), others survive after your browser is closed until a defined expiration date set in the cookie (as determined by the third party placing it), and help recognize your computer when you open your browser and browse the Internet again (persistent cookies). For more details on cookies please visit All About Cookies.
On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive a notification when you are receiving a new cookie and how to turn cookies off. Please see here for guidance on how to modify your web browser’s settings on the most popular browsers.
Please note that if you limit the ability of websites to set cookies, you may be unable to access certain parts of the Site and you may not be able to benefit from the full functionality of the Site.
Advertising networks may use cookies to collect Personal Data. Most advertising networks offer you a way to opt out of targeted advertising. If you would like to find out more information, please visit the Network Advertising Initiative’s online resources at http://www.networkadvertising.org and follow the opt-out instructions there.
If you access the Site on your mobile device, you may not be able to control tracking technologies through the settings.
Analytics: We use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help us analyze how users use the Site and enhance your experience when you use the Site. For more information on how Google uses this data, go to www.google.com/policies/privacy/partners/.
Online Tracking and Do Not Track Signals: We and our third party service providers, including Facebook, may use cookies, pixels, or other tracking technologies to collect information about your browsing activities over time and across different websites following your use of the Site and use that information to send targeted advertisements. Our Site currently does not respond to “Do Not Track” (“DNT”) signals and operates as described in this Privacy Policy whether or not a DNT signal is received. If we do respond to DNT signals in the future, we will update this Privacy Policy to describe how we do so.
1. HOW WE USE PERSONAL DATA
We may use Personal Data for the following purposes:
- To provide the Services
- To deliver information about Traceable.ai’s products and services for the purposes of evaluation and purchasing and general education on cloud security issues. Account-focused personal information will be used to associate individual users to the business customer account and allow authorized access. ;
- To respond to your inquiries, comments, feedback, or questions;
- To send administrative information to you, for example, information regarding the Service and changes to our terms, conditions, and policies;
- To analyze how you interact with our Services;
- To maintain and improve the Services;
- To develop new products and services;
- To prevent fraud, criminal activity, or misuses of our Service, and to ensure the security of our IT systems, architecture, and networks; and
- To comply with legal obligations and legal process and to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or other third parties.
Aggregated Information. We may aggregate Personal Data and use the aggregated information to analyze the effectiveness of our Services, to improve and add features to our Services, and for other similar purposes. In addition, from time to time, we may analyze the general behavior and characteristics of users of our Services and share aggregated information like general user statistics with prospective business partners. We may collect aggregated information through the Services, through cookies, and through other means described in this Privacy Policy.
Marketing. We may use your Personal Data to contact you to tell you about products or services we believe may be of interest to you. For instance, if you elect to provide your email or telephone number, we may use that information to send you special offers. You may opt out of receiving emails by following the instructions contained in each promotional email we send you. In addition, if at any time you do not wish to receive future marketing communications, you may contact us. If you unsubscribe from our marketing lists, you will no longer receive marketing communications but we will continue to contact you regarding management of your account, other administrative matters, and to respond to your requests.
Legal bases for processing. Some applicable laws require that Traceable has a “legal basis” for its processing of personal information. We rely on different legal bases for collecting and processing personal information about you, depending on the particular context. Generally, where we are acting as a data controller under applicable laws, we process your Personal Data only: (i) where the processing is in our legitimate interests (which are not overridden by your data protection interests or fundamental rights and freedoms); (ii) in connection with the creation (at your request) or performance of a contract with you; (iii) where such processing is necessary for our compliance with a legal obligation to which we are subject; or (iv) where we have collected your consent to do so.
For the sake of clarity, where we are using your personal information based on the legal basis of consent, we will seek consent from you independent of this Privacy Policy. You can withdraw such consent at any time by contacting us at: legal@traceable.ai.
Data Retention. We will retain your personal information in accordance with applicable law and, unless otherwise provided by applicable law, for no longer than necessary to provide the Services and fulfill the transactions you have requested, comply with our legal obligations, resolve disputes, enforce our agreements, and in furtherance of our other business purposes outlined hereunder.
Because these needs can vary for different types and uses of personal information, actual retention periods can vary based on criteria such as user expectations or consent, the sensitivity of your personal information, the availability of automated controls that enable you to delete data, and our legal or contractual obligations.
Where there are technical limitations that otherwise prevent the deletion or anonymization of your personal information, we will safeguard and limit the use of your personal information as required by applicable law.
2. SHARING AND DISCLOSURE OF PERSONAL DATA
Traceable does not sell your Personal Data. In certain circumstances we may share the categories of Personal Data described above without further notice to you, unless required by the law, with the following categories of third parties:
● Vendors and Service Providers: To assist us in meeting business operations needs and to perform certain services and functions, we may share Personal Data with vendors and service providers, including providers of hosting services, cloud services, and other information technology services providers, event management services, email communication software and email newsletter services, advertising and marketing services, payment processors, customer relationship management and customer support services, and web analytics services. Pursuant to our instructions, these parties will access, process, or store Personal Data in the course of performing their duties to us. We take commercially reasonable steps to ensure our service providers adhere to the security standards we apply to your Personal Data.
● Business Transfers: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of all or a portion of our assets, or transition of service to another provider (collectively a “Transaction”), your Personal Data and other information may be shared in the diligence process with counterparties and others assisting with the Transaction and transferred to a successor or affiliate as part of that Transaction along with other assets.
● Legal Requirements: If required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, including to meet national security or law enforcement requirements, (ii) protect and defend our rights or property, (iii) prevent fraud, (iv) act in urgent circumstances to protect the personal safety of users of the Service, or the public, or (v) protect against legal liability.
● Affiliates: We may share Personal Data with our current and future affiliates, meaning an entity that controls, is controlled by, or is under common control with Traceable. Our affiliates may use the Personal Data we share in a manner consistent with this Privacy Policy.
1. UPDATE YOUR INFORMATION
Please log in to your account or contact us if you need to change or correct your Personal Data.
2. CHILDREN
Our Service is not directed to children who are under the age of 16. Traceable does not knowingly collect Personal Data from children under the age of 16. If you have reason to believe that a child under the age of 16 has provided Personal Data to Traceable through the Service please contact us and we will endeavor to delete that information from our databases.
3. LINKS TO OTHER WEBSITES
The Service may contain links to other websites not operated or controlled by Traceable, including social media services (“Third Party Sites”). The information that you share with Third Party Sites will be governed by the specific privacy policies and terms of service of the Third Party Sites and not by this Privacy Policy. By providing these links we do not imply that we endorse or have reviewed these sites. Please contact the Third Party Sites directly for information on their privacy practices and policies.
4. SECURITY
You use the Service at your own risk. We implement commercially reasonable technical, administrative, and organizational measures to protect Personal Data both online and offline from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent to or from us may not be secure. Therefore, you should take special care in deciding what information you send to us via the Services or email. Please keep this in mind when disclosing any Personal Data to Traceable via the internet. In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the Services, or third party websites.
5. INTERNATIONAL USERS
By using our Services, you understand and acknowledge that your Personal Data will be transferred from your location to, and processes in, our facilities and servers in any other country or region where we or our Affiliates or service providers have a presence or maintain data processing facilities, including the United States and India.
We will comply with all applicable laws relating to the processing of your Personal Data in such location. Where applicable law requires consent for such international processing or transfer, we will seek consent from you independent of this Privacy Policy.
Location of Processing of European personal information. We may transfer personal information from the European Economic Area (EEA), United Kingdom (UK), and Switzerland to other countries, some of which have not been determined by the European Commission to have an adequate level of data protection. When we do so, we take all steps reasonably necessary to ensure that your data is subject to appropriate safeguards, such as relying on a recognized legal adequacy mechanism, and that it is treated securely and in accordance with this privacy policy. To learn more about the European Commission’s decisions on the adequacy of personal information protections, please visit: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en.
You may be entitled by applicable laws to request more information about the details of international transfers of your information and the security measures taken by us in connection with that transfer. To obtain more information about exercising such rights, please contact us at: legal@traceable.ai.
6. YOUR CHOICES
In certain circumstances providing Personal Data is optional. However, if you choose not to provide Personal Data that is needed to use some features of our Services, you may be unable to use those features. You can also contact us to ask us to update or correct your Personal Data. You may also delete your personal account, though not your organizational account. Please note that we will need to verify that you have the authority to delete the account and certain activity generated prior to deletion may remain stored by us and may be shared with third parties as detailed in this Privacy Policy.
Individual rights for California consumers. If you are a California consumer, you may have additional rights under the California Consumer Privacy Act as amended by the California Privacy Rights Act (“the CCPA”), including:
- Notice at Collection. At or before the time of collection, you have a right to receive notice of our practices, including the categories of personal information and sensitive personal information to be collected, the purposes for which such information is collected or used, whether such information is sold or shared, and how long such information is retained. You can find those details in this Privacy Policy.
- Right to Know. You have a right to request that we disclose to you the personal information we have collected about you. You also have a right to request additional information about our collection, use, disclosure, or sale of such personal information. Note that we have provided much of this information in this Privacy Policy.
- Rights to Request Correction or Deletion. You also have the right to request that we correct inaccurate personal information and that we delete personal information under certain circumstances, subject to a number of exceptions.
- Right to Opt-Out / “Do Not Sell or Share My personal information”. You have a right to opt-out from future “sales” or “sharing” of personal information as those terms are defined by the CCPA. Note that we do not “sell” or “share” personal information as defined by the CCPA and have not done so in the past 12 months.
- Right to Limit Use and Disclosure of Sensitive Personal Information. You have a right to limit our use of sensitive personal information for any purposes other than to provide the services or goods you request or as otherwise permitted by law. Note that we do not use sensitive personal information for any such additional purposes.
- Right against discrimination. Finally, you have a right to not be discriminated against for exercising these rights set out in the CCPA.
Residents of Switzerland, the United Kingdom and the European Union. If you are in Switzerland, the United Kingdom or the European Union, you may have the right to:
- Request access to or correction or erasure of your personal information;
- Object to processing of your personal information under certain circumstances;
- Request the restriction of processing of your personal information;
- Transfer or receive a copy of your personal information in a usable and portable format where such personal information is subject to automated processing or processing is based on your consent or a contract with you;
- Withdraw consent at any time for future processing of your personal information where such processing is based on consent; and
- For residents of France, send us specific instructions regarding the use of your personal information after your death.
Additionally, you may have the right to file a complaint with your applicable supervisory authority.
7. CHANGES TO THE PRIVACY POLICY
The Services and our business may change from time to time. As a result we may change this Privacy Policy at any time. When we do we will post an updated version on this page, unless another type of notice is required by the applicable law. By continuing to use our Service or providing us with Personal Data after we have posted an updated Privacy Policy, or notified you by other means if applicable, you consent to the revised Privacy Policy and practices described in it.
8. CONTACT US
If you have any questions about our Privacy Policy or information practices, please feel free to contact us at our designated request address: legal@traceable.ai, or at our primary mailing address of 548 Market St., PMB83903, San Francisco, CA 94104.