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Privacy Policy




TRUSTe European Safe Harbor certification

Effective Date: 09/23/2015

Overview

Tracen Technologies, Inc. (“Tracen” or the “company”) has adopted this personal data privacy protection policy (“privacy policy”) to establish and maintain an adequate level of personal data privacy protection. This policy is applicable to all records collected and used on the www.tracen.com,,www.commandmobile.com sites and the COMMANDmobile EE service platform (“Service”) that contain personal information. It also describes the choices available to you regarding our use of your personal information and how you can access and update this information. The use of information collected through our Service shall be limited to the purpose of providing the Service for which our customers have engaged Tracen.

The TRUSTe certification covers our collection, use and disclosure of information we collect through our websites [www.tracen.com, www.commandmobile.com] and our service, COMMANDmobile EE platform. The use of information collected through our service shall be limited to the purpose of providing the service for which the Client has engaged Tracen Technologies, Inc. The TRUSTe certification does not cover information collected on sharepoint.tracen.com and information that may be collected through downloadable software.

In order to view our relationship with TRUSTe please visit the validation page visible by clicking on the TRUSTe seal. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact TRUSTe here.

  • U.S.—E.U. Safe Harbor


Tracen Technologies, Inc. complies with the U.S. – E.U. Safe Harbor framework and the U.S. – Swiss Safe Harbor framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data from European Union member countries and Switzerland. Tracen has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Tracen’s certification, please visit http://www.export.gov/safeharbor/

  1. Information Collection and Use


We may collect the following personal information from you when you visit our site, use our mobile application, request information from us or become a customer:

  • Contact information such as name, email address, mailing address, phone number

  • Professional information such as your job title and name of your employer

  • Unique Identifiers such as user name, account number, password, unique device ID

  • Information about your business such as company name, company size, business type

  • Precise location data

  • Access to device’s camera sensor


We use this information to:

  • Fulfill your order

  • Send you an order confirmation

  • Assess the needs of your business to determine suitable products

  • Send you requested product or service information

  • Respond to customer service requests

  • Administer your account

  • Send you a newsletter

  • Send you marketing communications

  • Respond to your questions and concerns

  • Process a job application

  • Improve our Web site and marketing efforts

  • Conduct research and analysis

  • Allow customers to view location of their devices

  • Allow customers to review job routes

  • Allow customers to capture photos to attach to reports for their jobs


Information Related to Data Collected through COMMANDmobile EE

While Tracen services business customers and therefore does not collect information from consumers or individuals as a regular part of its business, Tracen may process certain personal data (such as location) from individuals who own or work at customer businesses, or other 3rd party individuals who otherwise have no direct relationship with Tracen. We have no ownership of this information or any direct relationship with individuals whose personally identifiable information may be processed as part of providing our Service to our customers.

An individual who seeks access, who seeks to correct, amend, delete inaccurate data or withdraw consent to further contact should direct his/her query to the Tracen customer they interact with directly (the data controller). If a Tracen customer requests that we remove personally identifiable information on their behalf, we will respond to their request within 30 days.

In addition, if you have provided us with your location data and would no longer wish to provide us with that data you can opt out at the device level or by emailing us at privacy@tracen.com.

Tracen will retain personal data we process on behalf of our customers for as long as needed to provide services and as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

  • Transfer of Data/Oversight of Service Providers


Tracen may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the provisions in this Policy regarding notice and choice and the service agreements with our Clients.

Within Tracen, personal data in the databases may be processed outside the country in which it was collected, for legitimate business activities as described under national and/or regional law in the country in which Tracen collected the data. For example, certain types of personal data may be accessed, for legitimate business purposes in any country in which Tracen operates. In addition, Tracen may store personal data in the facilities operated by the company and/or third parties on behalf of the company outside the country in which Tracen collected the data, so long as such third parties have agreed by contract to maintain an adequate level of data protection. Accordingly, personal data may be processed for legitimate business purposes in countries in which the data protection laws of the country in which Tracen collected the data do not apply.

When Tracen engages a service provider/vendor (such as a mapping provider) to perform activities that may require access to personal data, it will take steps to ensure that the service provider acts in accordance with our existing policies and procedures. At a minimum, Tracen will enter into a written agreement with the third party requiring the third party (1) to comply with applicable federal and state laws, and (2) to maintain secure systems in the transmission of information to and from Tracen.

If personal data to be transferred, processed, or otherwise shared with a third party is personal data subject to the Safe Harbor (data received from an EU Member Country), then Tracen will ensure that the third party subscribes to the Safe Harbor principles or that it is subject to the Directive or another adequacy finding, as is applicable, and Tracen will proactively notify the individuals that the data will be held or processed by a third-party if it did not do so at the time of collection of such data. As an alternative, Tracen may enter into a written agreement with the third party requiring the third party to maintain at least the same level of privacy protection as is required by the relevant principles.

  1. Information Sharing


Tracen will share your personal information with third parties only in the ways that are described in this privacy policy. We do not sell, rent, share or trade your personal information to third parties for their promotional purposes.

  • Service Providers


We may provide your personal information to companies that provide services to help us with our business activities such as processing your payment or offering customer service. These companies are authorized to use your personal information only as necessary to provide these services to us.

  • Legal Disclaimer


We may also disclose your personal information:

  • as required by law, such as to comply with a subpoena, or similar legal process

  • when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request,

  • if Tracen Technologies, Inc. is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our web site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information,

  • to any other third party with your prior consent to do so



  1. User Access and Choice


Data subjects have the right to know what information about them is included in the databases and to ensure that such information is accurate and relevant to the purposes for which Tracen collected the data. Data subjects may review their own personal data stored in the databases and correct, block or delete any data that is incorrect by making the changes within their user account portal. Additionally, requests sent to privacy@tracen.com, or to the contact information listed below to aid in personal data access, modification, correction or deletion requests, will be responded to immediately. We will respond to your request to access within 30 days.

We will retain your information for as long as your account is active or as needed to provide you services. If you choose to close your account, your personal and collected data will be removed from the server. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

  • Opt-out Preferences


If you wish to subscribe to our newsletter, blog or other promotional communications, we will use your name and email address and/or your phone number, to send these messages to you. Out of respect for your privacy, you may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails or you can contact us at privacy@tracen.com

We will send you strictly service-related announcements on rare occasions when it is necessary to do so. For instance, if our service is temporarily suspended for maintenance, we might send you an email. Generally, you may not opt-out of these communications, which are not promotional in nature. If you do not wish to receive them, you have the option to close your account.

Within our mobile app we send push notifications of new data collection assignments. If you no longer with wish to receive such communications, please adjust your settings at the device level.

  1. Tracking Technologies / Cookies


We Tracen Technologies, Inc. and our partners [specify type e.g. marketing partners], affiliates, or analytics or service providers [specify type e.g. online customer support provider, etc], use technologies such as cookies, beacons, tags, and scripts, to analyze trends, administer the website, tracking users’ movements around the website, and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual and aggregated basis.

A cookie is a small text file that is stored on a user’s computer for record-keeping purposes. We use cookies on this site to remember users’ settings. We do not link the information we store in cookies to any personally identifiable information you submit while on our site.

We use both session ID cookies and persistent cookies. A session ID cookie expires when you close your browser. Session cookies are used to collect settings and selections during use. A persistent cookie remains on your hard drive for an extended period of time. Persistent cookies are used to keep track of your preferences and profile information. You can remove persistent cookies by following directions provided in your Internet browser’s “help” directory. If you reject cookies, you may still use our site, but your ability to use some areas of our site will be limited.

  • Web Beacons / Gifs


We also employ a software technology called clear gifs (a.k.a. Web Beacons), that help us better manage content on our site by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to compile aggregate statistics on how our site is used. In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly on Web pages and are about the size of the period at the end of this sentence. We do not tie the information gathered by clear gifs to our customers’ personally identifiable information. This information is used to gauge the effectiveness of our customer communications.

  • Local Storage / HTML5


 

Third parties with whom we partner to provide certain features on our website or to display advertising based upon your web browsing activity also use HTML5 to collect and store information. Various browsers may offer their own management tools for removing HTML5.

  • Analytics / Log Files


As is true of most web sites and mobile applications, we gather certain information automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information, which does not identify individual users, to analyze trends, to administer the site, to track users’ movements around the site and mobile application and to gather demographic information about our user base as a whole. We do not link this automatically-collected data to personally identifiable information.

  • Adverstising


We partner with a third party to either display advertising on our website or to manage our advertising on other sites. Our third party partner may use technologies such as cookies to gather information about your activities on this website and other sites in order to provide you advertising based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by clicking here (or if located in the European Union click here). Please note this does not opt you out of being served ads. You will continue to receive generic ads.

  • 3rd Party Tracking


The use of tracking technologies by our service providers, technology partners or other 3rd party assets (such as social media) on the site is not covered by our privacy policy. These 3rd parties may use cookies, clear gifs, images, and scripts to help them better manage their content on our site. We do not have access or control over these technologies. We do not tie the information gathered to our Customers’ or Users’ personally identifiable information.

  1. Security


Tracen has implemented physical and technical safeguards to protect personal data from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Tracen has implemented secure authentication protocols. Among other measures, Tracen encrypts data using SSL (such as location data and when log-in credentials are entered) and has implemented strong password protection. Tracen maintains up-to-date firewall and malware protection and operates system security patches. Data owned by each customer is logically isolated from the data of other customers and from Tracen’s corporate environment to prevent unauthorized access. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security.

Once a customer relationship ends, Tracen will remove all customer data from Tracen’s network storage facilities and all media used to store such customer data will be cleaned using industry best practices or destroyed. When a staff person leaves, Tracen immediately blocks the employee’s physical and electronic access to the network and the facilities upon termination. Among other measures, Tracen will deactivate passwords and user names and collect building entry keys.

  • Data Breaches


Notwithstanding any other legal obligations Tracen may have, Tracen will promptly notify Customers in writing upon Tracen’s discovery of a breach of security of its systems or site where any data or materials containing personally identifiable information, including but not limited to Users’ IDs or passwords, have been acquired by an unauthorized person or Tracen reasonably believes that such a breach of security may have occurred. Tracen will also provide immediate feedback about any impact this possible or actual breach may/or will have on its Customers. Tracen will use commercially reasonable efforts to promptly notify its Customers of the possible or actual security breach upon detecting the possible or actual breach. The management of Tracen will track the accidental or unauthorized access to personal data described herein, and will provide notice to the appropriate parties under law and contract. Tracen personnel have an obligation to be vigilant in safeguarding customer and personnel privacy. Tracen personnel must immediately report a data breach or suspected data breach to the company via email. If you have any questions about security on our Web site, you can contact us at privacy@tracen.com

  1. Additional Information



  • Links to 3rd Party Sites


Our Site includes links to other Web sites whose privacy practices may differ from those of Tracen. If you submit personal information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any Web site you visit.

  • Testimonials


We display personal testimonials of satisfied customers on our website in addition to other endorsements. With your consent, we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at privacy@tracen.com.

  • Blog / Forum


Our Web site offers a publicly accessible blog where customers or visitors can provide comments about Tracen’s product offerings. To the extent that there is any personal information contained in these postings, Tracen’s use of such personal information will be solely to provide feedback to the company about its product offerings and will not be traced back to the source consumer account. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog or community forum, contact us at privacy@tracen.com. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.

  • Social Media Widgets


Our Web site and mobile application includes Social Media Features, such as the Facebook Like button, links to social media pages and Widgets, such as the Share this button or interactive mini-programs that run on our site. These Features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these Features are governed by the privacy policy of the company providing it.

  • Changes To This Policy


We may update this privacy policy to reflect changes to our information practices. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this Site prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

  1. Contact Us


You can contact us about this privacy policy by writing or email us at the address below:
Tracen Technologies, Inc. 9720 Capital Ct, Suite 401, Manassas, VA, United States 20110
Email: privacy@tracen.com
Phone: +1.877.258.7986

*Definitions*

“Personal data” or “personally identifiable information” is defined as data from which Tracen customers can be identified. Personal data includes a person’s first name and last name or first initial and last initial in combination with any one or more of the following data elements that relate to the person: (a) mailing address; (b) email address; or (c) credit or debit card number, with or without the security code, access code, personal identification number or password, that would permit access to a person’s financial account; provided, however, that “personal data” shall not include information that is lawfully obtained from publicly available information, or from federal, state, or local government records lawfully made available to the general public. The databases containing personal data do not contain any “sensitive information” as defined under European Union Directive 95/46/EC (personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, criminal convictions, or personal data concerning health), other than as provided by Tracen personnel pursuant to their express, informed consent. Tracen will explicitly request and receive permission from any individual to further process or otherwise use that individual’s sensitive information.



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