Privacy Policy

Introduction
1. Trackbee is an Enschede-based company focused on developing, producing and delivering software. It is operated in the legal form of a private limited company under the name EC Solutions Software B.V. and is registered with the Chamber of Commerce under number: 87446898 (hereinafter: "Trackbee"). Trackbee's contact details are as follows:
  - Location/visiting address: Boulevard No. 1945 47.
  - Postal code: 7511 NG Enschede.
  - E-mail: info@trackbee.io.
2. In this privacy statement, Trackbee explains, inter alia, which personal data it processes, for what purposes such personal data is processed and by extension on which legal basis. In addition, Trackbee shall explain, inter alia, what rights a data subject has.
Personal data
1. Both on the website (www.trackbee.io) and in the course of its business, Trackbee processes personal data. For the processing of personal data on the website, Trackbee thereby acts, in principle, as a data controller within the meaning of the General Data Protection Regulation ("GDPR"). For processing personal data for the performance of its activities, Trackbee thereby acts, in principle, as a processor within the meaning of the GDPR.
2. Common personal data processing operations include the collection, recording, storage, modification, retrieval, consultation, use, disclosure and deletion or destruction of personal data.
3. The data subjects of who Trackbee is processing personal data can be divided into the following categories:
  - Business customers.
  - Website users.
4. Trackbee collects personal data from a data subject in the following way(s)
  - Where the relevant data subject has provided such personal data tot Trackbee via the website (e.g. by signing up via the website).
  - By contacting Trackbee with a request for information about Trackbee's services and/or products.
  - Using software developed, produced and delivered by Trackbee.
  - For monitoring purposes and website security.
  - Provision of third-party data based on legal or contractual obligations.
  - As generated from the relevant data subject's use of Trackbee's website, including but not limited through cookies.
5. The personal data that Trackbee processes from business customers shall relate to the following categories of personal data:
  - Company name.
  - Name and address details.
  - Date of birth.
  - (Profile) picture.
  - E-mail address.
  - Telephone number.
  - Payment information.
  - Data related to the device, such as IP address.
  - Communication preferences.
  - Information obtained through cookies about browsing behaviour.
  - Other data whose processing is necessary in view of laws and regulations.
6. The personal data that Trackbee processes from website users relates to the following categories of personal data:
  - Name and address details.
  - Date of birth.
  - (Profile) picture.
  - E-mail address.
  - Telephone number.
  - Payment information.
  - Data related to the device, such as IP address.
  - Communication preferences.
  - Information obtained through cookies about browsing behaviour.
  - Other data whose processing is necessary in view of laws and regulations.
7. If a data subject is obliged to provide certain (personal) data, he/she will be informed of the possible consequences if they are not provided. A data subject is never obliged to provide personal data. However, if a data subject provides his or her personal data from time to time identified as mandatory, Trackbee may not be able to provide a data subject with its products and/or services.
Purposes and bases for processing personal data
1. Trackbee shall process a data subject's personal data solely on the basis of one the bases in the GDPR. These bases are as follows:
  - Consent.
  - Performance of an Agreement with a data subject.
  - Compliance with a legal obligation.
  - Legitimate interest of Trackbee or a third party.
2. Trackbee processes certain personal data to pursue its legitimate interests. Trackbee's legitimate interests include marketing, advertising, research of its own products and/or services, IT management and security and sharing personal data with Trackbee’s affiliates.
3. Trackbee processes personal data of business customers for the following purposes, based on the bases stated therein:
  Purpose
  Base
  Offering the products and/or services or maintaining a relationship, which also includes differentiating users on the platform or software, offering customer service or technical support and processing requests related to the products and/or services.
  - Performance of an agreement
  - Legitimate interest
  Improving the products and/or services offered, including by analysing their use.
  - Performance of an agreement
  - Legitimate interest
  Establishing and maintaining a customer relationship with a data subject, for example for sending informative messages about products and/or services or responding to questions and request from a data subject.
  - Performance of an agreement
  - Legitimate interest
  Handling, management and billing.
  - Performance of an agreement
  - Legitimate interest
  Internal management.
  - Performance of an agreement
  - Legitimate interest
  - Legal obligation
  Sending information regarding Trackbee, including but not limited to sending the newsletter.
  - Performance of an agreement
  - Consent
  Providing targeted ads based on user interests, using cookies and similar technologies to collect the relevant information about user.
  - Performance of an agreement
  - Consent
  The implementation or application of laws and regulations.
  - Performance of an agreement
  - Legal obligation
4. Trackbee processes personal data of business customers for the following purposes, based on the bases stated therein:
  Purpose
  Base
  Offering the products and/or services or maintaining a relationship, which also includes differentiating users on the platform or software, offering customer service or technical support and processing requests related to the products and/or services.
  - Performance of an agreement
  - Legitimate interest
  Improving the products and/or services offered, including by analysing their use.
  - Performance of an agreement
  - Legitimate interest
  Establishing and maintaining a customer relationship with a data subject, for example for sending informative messages about products and/or services or responding to questions and request from a data subject.
  - Performance of an agreement
  - Legitimate interest
  Handling, management and billing.
  - Performance of an agreement
  - Legitimate interest
  Internal management.
  - Performance of an agreement
  - Legitimate interest
  - Legal obligation
  Sending information regarding Trackbee, including but not limited to sending the newsletter.
  - Performance of an agreement
  - Consent
  Providing targeted ads based on user interests, using cookies and similar technologies to collect the relevant information about user.
  - Performance of an agreement
  - Consent
  The implementation or application of laws and regulations.
  - Performance of an agreement
  - Legal obligation
Sharing of personal data
1. Trackbee shall in principle not provide data subject's personal data to third parties unless:
  - The personal data is provided to processors engaged by Trackbee with whom a processing agreement has been concluded or independent processors, e.g. IT, hosting, HR or other service providers, external consultants, accountants or lawyers.
  - Trackbee is obliged on the basis of a legal obligation to transfer personal data to competent authorities, e.g. regulators or other public authorities.
  - Personal data is provided to a company belonging to an affiliate of Trackbee and/or third party or within Trackbee's company.
  - Other third parties, with the consent of the data subject.
2. Provision of personal data to the above parties shall only be made for the purposes mentioned and described in this privacy statement, and to the extent permitted under this privacy statement and applicable laws and regulations, or if Trackbee has a legal obligation to provide personal data to a competent authority.
3. Parties to whom personal data is provided shall be solely responsible for compliance with privacy laws. Trackbee shall not be responsible nor liable for the processing of personal data by such parties.
4. In order to provide products and/or services, Trackbee may be required to transfer personal data to countries outside the European Economic Area. Where this is the case, Trackbee shall take appropriate safeguards to lawfully transfer personal data to such countries. Trackbee may do so by entering into a (model) contract – approved by the European Commission or national regulator – with the recipient of the personal data.
Cookies
1. Trackbee uses so-called 'cookies'. Cookies are small text files placed by websites on the computer or peripherals with which a data subject visits a website. With these cookies, Trackbee automatically collects, in accordance with the preferences specified by data subject, certain data about the history of data subject's activities on its website and third-party apps.
2. For example, personal data of data subject may be collected while a data subject is using Trackbee's website or apps or if they are running in the background on a data subject's device. This data may be combined by Trackbee with other data about the data subject’s device, such as an IP address. If this requires the consent of a data subject, Trackbee will seek it in advance.
3. Most browsers will accept our cookies by default, but a data subject can of course decide whether to accept or reject cookies. If a data subject (deletes and) disables cookies, this may affect the functionality of Trackbee's website. In that case, certain parts of the website may not be displayed or function entirely. The person concerned may disable or delete her/his cookies by consulting your browser's manual. Trackbee uses the following cookies:
  - __cfduid:
    These cookies are set to recognise the reliability of internet traffic. These cookies cannot recognise individual users, nor do these cookies store any personal data. The retention period for these cookies is up to one year.
  - Google Analytics: _ga, _gat _gid:
    Google Analytics cookies are intended to map a website visitor's browsing behaviour.
    These cookies allow Trackbee to improve the functionality of its website. The retention period of these cookies is up to two years. For more information see Google's website: https://policies.google.com/privacy?hl=nl&gl=nl
Retention period
1. Personal data processed by Trackbee shall not be kept longer than necessary for the purposes mentioned and described in this privacy statement, unless required by a legal obligation. Administrative data shall be retained by Trackbee for seven years.
Security of your personal data
1. Trackbee has implemented appropriate technical and organisational security measures to safeguard the personal data of data subjects. The appropriate measures shall include, inter alia, the following:
  - Security of the servers.
  - Computers are equipped with a virus scanner and firewall.
  - Employees are subject to rules of conduct.
  - Employees are committed to confidentiality.
2. In addition, Trackbee protects data subject's personal data against data breaches. A data breach is a breach, whether accidental or unlawful, of security in which personal data has been lost, unauthorisedly modified, disclosed or accessed.
Rights of data subject
1. A data subject has the right to access, rectify and delete his or her personal data in accordance with the provisions of the GDPR. A data subject also has the right to object to the processing of his or her personal data.
2. A data subject may request Trackbee to restrict processing and data portability. The latter means that a data subject shall have the right to receive the personal data that Trackbee holds about him or her in a structured, commonly used and machine-readable form and, where appropriate, to have it transmitted by Trackbee to another party.
3. Where a data subject has given consent to the processing of his or her personal data, a data subject shall have the right to withdraw such consent at any time.
4. If a data subject wishes to exercise any of the aforementioned rights, or if a data subject has any questions regarding this privacy statement, a data subject may reach Trackbee at the contact details listed under margin number 1. A data subject may also unsubscribe from the newsletter by sending an e-mail to Trackbee.
5. Depending on the country of residence and/or establishment of a data subject, a data subject shall have the right to lodge a complaint with a supervisory authority that supervises compliance with the rules on the protection of personal data. In the Netherlands, this is the so-called Autoriteit Persoonsgegevens, based in The Hague. For more information see the website of the Autoriteit Persoonsgegevens, www.autoriteitpersoonsgegevens.nl.
Changes to this Privacy Statement
1. Trackbee reserves the right to modify this privacy statement. Any modification will be announced on this page. Trackbee therefore advises a data subject to regularly check this page to see if any modifications have been made. The current privacy statement was updated on 8 March 2023.

Privacy Policy

Introduction

Personal data

Purposes and bases for processing personal data

Sharing of personal data

Cookies

Retention period

Security of your personal data

Rights of data subject

Changes to this Privacy Statement