This Privacy Policy applies to all visitors and users of the TracPoint Wireless, Inc. website, as well as any and all TracPoint Wireless, Inc. mobile applications.
Information We Collect
We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular user, consumer, household, or device ("Personal Information"). Personal Information does not include:
- Publicly available information from government records;
- Deidentified or aggregated consumer information;
- Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA), clinical trial data, or other qualifying research data; or
- Personal Information covered by certain sector-specific privacy laws, including but not limited to the Fair Credit Reporting Act (FCRA) and the Gramm-Leach-Bliley Act (GLBA).
In particular, we have collected the following categories of Personal Information from consumers within the last twelve (12) months:
| Category | Examples | Collected |
|---|---|---|
| Identifiers | Internet Protocol addresses. | Yes |
| Personal Information | A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state ID number, insurance policy number, education, employment, employment history, bank account, credit or debit card number, or other financial, medical, or health insurance information. | No |
| Protected classification characteristics under federal law | Age (40+), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, pregnancy or childbirth), sexual orientation, veteran or military status, genetic information. | No |
| Commercial information | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | No |
| Biometric information | Genetic, physiological, behavioral, and biological characteristics or activity patterns used to extract a template or identifier, such as fingerprints, faceprints, voiceprints, iris or retina scans, keystroke or gait patterns, and sleep, health, or exercise data. | Yes |
| Internet or other similar network activity | Browsing history, information on a consumer's interaction with a website and/or mobile application, or advertisement. | Yes |
| Geolocation data | Physical location or movements. | Yes |
| Sensory data | Audio, electronic, visual, thermal, olfactory, or similar information. | No |
| Professional or employment-related information | Current or past job history or performance evaluations. | No |
| Non-public education information | Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, schedules, student ID codes, financial information, or disciplinary records. | No |
| Inferences drawn from other Personal Information | A profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | No |
We obtain the categories of Personal Information listed above from the following categories of sources:
- Directly from you — for example, from forms you complete.
- Indirectly from you — for example, from observing your actions on our website and/or mobile applications, internet service providers, data analytics providers, and operating systems and platforms.
Cookies and Similar Technologies
In some instances, we may collect non-personal information through the use of cookies and other similar technologies. These technologies help us better understand and improve the usability and effectiveness of our website and/or mobile applications by (i) telling us which parts of our website and/or mobile applications you have visited and (ii) measuring the effectiveness of advertisements and web searches. Acceptance of these technologies may allow us to access information about your browsing history, which helps us to personalize your experience. While we do not treat this information as Personal Information, to the extent that Internet Protocol ("IP") addresses and the like are considered Personal Information by law, we will regard this information as Personal Information as well. Indeed, the only Personal Information these technologies can gather is information that you have supplied yourself. To the extent that non-personal information and Personal Information are combined, we will treat that combined information as Personal Information. You may decline the use of these technologies, but doing so may negatively affect the functionality of our website and/or mobile applications.
Use of Personal Information
We may use, or disclose, the Personal Information we collect for one or more of the following purposes:
- To fulfill or meet the reason you provided the information — for example, to respond to a price quote or product inquiry, process a payment, or facilitate delivery, order, or return;
- To provide, support, personalize, and develop our website and/or mobile applications, products, and services;
- To create, maintain, customize, and secure your account with us;
- To process your requests, purchases, transactions, and payments and prevent transactional fraud;
- To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses;
- To personalize your website and/or mobile applications experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads (with your consent, where required by law);
- To help maintain the safety, security, and integrity of our website and/or mobile applications, products and services, databases, and other technology assets and business;
- For testing, research, analysis, and product development;
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
- As described to you when collecting your Personal Information; and/or
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, in which Personal Information held by us is among the assets transferred.
We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information
We may share your Personal Information by disclosing it to a third party for a business purpose. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the Personal Information confidential, and prohibit using the disclosed information for any purpose except performing the contract. In the preceding twelve (12) months, we have disclosed Identifiers, Biometric Information, Internet or other similar network activity, and Geolocation data to service our clients. We do not sell personal information.
Your Rights and Choices
Right to Know and Data Portability. You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive your request and confirm your identity, we will disclose the categories of Personal Information we collected, the categories of sources, our purpose for collecting it, the categories of third parties with whom we share it, and — for a data portability request — the specific pieces of Personal Information we collected about you. We do not provide a right to know or data portability disclosure for B2B Personal Information.
Right to Delete. You have the right to request that we delete Personal Information we collected from you and retained, subject to certain exceptions, including where retention is necessary to complete a transaction, detect security incidents or fraud, debug products, exercise free speech or another legal right, comply with the California Electronic Communications Privacy Act, conduct research you consented to, enable internal uses reasonably aligned with your expectations, or comply with a legal obligation. We do not provide these deletion rights for B2B Personal Information.
Exercising Your Rights. To exercise your rights to know or delete, submit a request by calling 800-404-4450 or emailing privacy@tracpoint.com. Only you, or someone legally authorized to act on your behalf, may make a request. Your request must provide sufficient information for us to verify your identity and describe the request with enough detail for us to understand, evaluate, and respond to it. We will confirm receipt of your request within ten (10) business days and endeavor to substantively respond within forty-five (45) days, extendable by another forty-five (45) days when necessary. We do not charge a fee to process a verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.
Non-Discrimination
We will not discriminate against you for exercising any of your privacy rights. Unless permitted by applicable law, we will not deny you goods or services, charge different prices or rates, provide a different level or quality of goods or services, or suggest that you may receive a different price, rate, or quality as a result of exercising your rights.
Changes to Our Privacy Policy
We reserve the right to amend this Privacy Policy at our discretion and at any time. When we make changes, we will post the updated notice on the website and/or mobile applications and update the notice's effective date. Your continued use of our website and/or mobile applications following the posting of changes constitutes your acceptance of such changes.
Contact Information
If you have any questions or comments about this notice, the ways in which TracPoint collects and uses your information, your choices and rights regarding such use, or wish to exercise your rights under applicable data privacy laws, please contact us at:
Phone: 800-404-4450
Email: privacy@tracpoint.com
Postal Address: TracPoint, Inc., Attn: President, 35 Village Rd, Suite 100, Middleton, MA 01949
If you need to access this policy in an alternative format due to a disability, please contact us at privacy@tracpoint.com or 800-404-4450.