Privacy Policy

We at TRK GLOBAL LIMITED know you care about how your personal information is used and shared, and we take your privacy seriously. Please read the following to learn more about how we collect, store, use and disclose information about you when you interact or use our websites (collectively the “Websites”) or any related events, trade shows, sales or marketing, and/or if you use any of our products, services or applications (collectively the “Services”) in any manner.

What does this Privacy Policy cover?

This Privacy Policy covers our treatment of information that we gather when you are accessing or using our Websites or Services or when you contact us in any manner. We gather various types of information, including information that identifies you as an individual (“Personal Information”) from our users, as explained in more detail below.

What information does TRK GLOBAL LIMITED Collect?

Information You Provide to Us:

When you use our website We may collect any Personal Information that you choose to send to us or provide to us, for example, on our “Newsletter” (or similar) online form or if you register for a TRK GLOBAL LIMITED Membership Account. If you contact us through the Websites, we will keep a record of our correspondence.

When you use the Services: We receive and store information you provide directly to us. For example, when setting up new users, we collect Personal Information, such as name and e-mail address, to provide them with Services. The types of information we may collect directly from our customers include: name, username, email address, postal address, phone number, transactional information (including Services purchased), as well as any other contact or other information they choose to provide us or upload to our systems in connection with the Services.

Information We Automatically Collect:

When you use the Websites: When you visit the Websites, we collect certain information related to your device, such as your device’s IP address, referring website, what pages your device visited, and the time that your device visited our Website.

When you use the Services: 

Usage information: we keep track of user activity in relation to the types of Services our customers and their users use and performance metrics related to their use of the Services.  

Log information: we log information about our customers and their users when you use one of the Services including Internet Protocol (“IP”) address. 

Information collected by cookies and other similar technologies: we use various technologies to collect information which may include saving cookies to users’ computers.

For further information, please see the section below headed „Cookie Policy”.

How do we use the information?

Websites: We will use the information we collect via our Websites:

• To administer our Website and for internal operations, including troubleshooting, data analysis, testing, statistical and survey purposes;
• To improve our Website to ensure that content is presented in the most effective manner for you and for your computer;
• To analyze customers’ use of the Websites for trend monitoring, marketing and advertising purposes;
• For purposes made clear to you at the time you submit your information – for example, to provide you with information you have requested about our Services
• As part of our efforts to keep our Website safe and secure.

Services: We may use the information we collect from our customers and their users in connection with the Services we provide for a range of reasons, including to:

• Set up a user/membership account;
• Provide, operate and maintain the Services;
• Process and complete transactions, and send related information, including transaction confirmations and invoices;
• Manage use of the Services, respond to inquiries and comments and provide customer service and support;
• Send customers technical alerts, updates, security notifications, and administrative communications;
• Investigate and prevent fraudulent activities, unauthorized access to the Services, and other illegal activities; and

For any other purposes about which we notify customers and users.

We may also use the information you send to us via the Websites and/or Services, to communicate with you via email and, possibly, other means, regarding products, services, offers, promotions and events we think may be of interest to you or to send you our newsletter, if this is in accordance with your marketing preferences.  However, you will always be able to opt-out of such communications at any time (see the “Your Choices” section below).

How do we share and disclose information to third parties?

We do not rent or sell your Personal Information to anyone. We may share and disclose information (including Personal Information) about our customers in the following limited circumstances:

Vendors, consultants and other service providers: We may share your information with third party vendors, consultants and other service providers who we employ to perform tasks on our behalf.

If TRK GLOBAL LIMITED has received your Personal Information in the United States and subsequently transfers that information to a third party agent or service provider for processing, TRK GLOBAL LIMITED shall remain responsible for ensuring that such third party agent or service provider processes your Personal Information to the standard required by law (see the section below headed „International Data Transfers”). Unless we tell you otherwise and you consent, our vendors do not have any right to use the Personal Information we share with them beyond what is necessary to assist us.

Business Transfers: We may choose to buy or sell assets, and may share and/or transfer customer information in connection with the evaluation of and entry into such transactions. Also, if we (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information could be one of the assets transferred to or acquired by a third party.

Protection of TRK GLOBAL LIMITED and Others: We reserve the right to access, read, preserve, and disclose any information as necessary to comply with law or court order; enforce or apply our agreements with you and other agreements; or protect the rights, property, or safety of TRK GLOBAL LIMITED, our employees, our users, or others.

Disclosures for National Security or Law Enforcement: Under certain circumstances, we may be required to disclose your Personal Information in response to valid requests by public authorities, including to meet national security or law enforcement requirements.

Your California Privacy Rights

This portion of our Privacy Notice advises California residents of the applicable rights as provided in the California Consumer Privacy Act (“CCPA”) and how to exercise these rights by communicating with us. We provide you with the rights described below when you use our Services. Please note that we will seek to verify your identity when we receive an individual rights request from you in order to ensure the security of your personal information.

For purposes of this section, “Personal Information” is defined as information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

If a California resident wishes to make any of the requests described below, such as access and deletion, he or she may contact us as provided in Section 13 (How to Contact Us) below.

Right to Deletion of Personal Information – California Consumers

California residents have the right to request the deletion of Personal Information as prescribed in Section 1798.105(a) of the CCPA. TRK GLOBAL LIMITED may not delete some or all Personal Information if such Personal Information is necessary for us, or our service providers or affiliates, to:

• Complete the transaction for which the Personal Information was collected, provide a good or service requested by the consumer, or reasonably anticipated within the context of TRK GLOBAL LIMITED’s ongoing business relationship with the consumer, or otherwise perform a contract between TRK GLOBAL LIMITED and the consumer
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity
• Debug to identify and repair errors that impair existing intended functionality
• Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law
• Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code
• Enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the consumer’s relationship with TRK GLOBAL LIMITED
• Comply with a legal obligation
• Otherwise use the consumer’s Personal Information, internally, in a lawful manner that is compatible with the context in which the consumer provided the Personal Information.

If you would like to access, review, update, rectify, and delete any Personal Information we hold about you, or exercise any other data subject right available to you under the EU General Data Protection Regulation (GDPR) and California Consumer Privacy Act (CCPA), you can revoke consent, or edit data here.

Right of Access: Right to Request Disclosure of Data Collection and Sharing Practices – California Consumers

You may request to receive details about how we collect, use, and share your Personal Information. Specifically, you may request to receive the specific pieces of information that we have collected about you by contacting us as provided in Section 13 (How to Contact Us) below.

You may also request to receive:

• the categories of Personal Information that we have collected about you
• the categories of Personal Information that we have disclosed for a business purpose
• the categories of sources from which we collected the Personal Information
• our purposes for collecting that Personal Information
• the categories of parties with whom we share your Personal Information.

Right to not be Discriminated Against for Exercising your Rights -California Consumers

We do not discriminate against you for exercising any of your CCPA rights, such as your access and deletion rights described above. However, we may offer you rewards (such as through our loyalty program) or benefits (such as customizing your experience at a resort) which we need your data to provide, but we will only provide those rewards or benefits if their value to you is reasonably related to the value provided to TRK GLOBAL LIMITED by your Personal Information.

Categories of Personal Information Collected about California Consumers and the Purposes of Such Collection

We collect identifiers that you may choose to provide to us, such as your name, email address and phone number. We use this information to communicate with you, market goods and services, and to provide you with goods and services.

Categories of Personal Information Sold about California Consumers

TRK GLOBAL LIMITED does not sell consumers’ Personal Information.

Categories of Personal Information Disclosed for a Business Purpose – California Consumers

TRK GLOBAL LIMITED discloses identifiers (e.g., name or email address), internet activity, consumer history, and consumers’ preferences to provide marketing and analytics services to its business partners.

TRK GLOBAL LIMITED discloses identifiers, consumer history, and consumers’ preferences to our franchisees and licensees to offer our Services.

TRK GLOBAL LIMITED may share your personal information with third party service providers that perform a variety of services on our behalf, such as the development and analysis of our social media pages, operating and maintaining our websites, offering or managing promotions, and market research purposes.

TRK GLOBAL LIMITED may share your personal information with other entities for purposes of a sale, merger, or other related corporate event. An entity that buys us or a part of our business may continue to use your personal information in accordance with this Privacy Notice.

Is Personal Information about me secure?

We use  technical, organizational and administrative security measures to protect all information we hold in our records from loss, misuse, and unauthorized access, disclosure, alteration and destruction.  Unfortunately, no company or service can guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information. Among other practices, your account is protected by a password for your privacy and security. You must prevent unauthorized access to your account and Personal Information by selecting and protecting your password appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account.

Cookie Policy

Manage Cookies

A cookie is a small piece of data (text file) that a website – when visited by a user – asks your browser to store on your device in order to remember information about you, such as your language preference or login information. Those cookies are set by us and called first party cookies. We also use third party cookies – which are cookies from a domain different than the domain of the website you are visiting – for our advertising and marketing efforts.

More specifically, we use cookies and other tracking technologies for the following purposes:

• Assisting you in navigation
• Assisting in login and your ability to provide feedback
• Analyzing your use of our products, services or applications
• Assisting with our promotional and marketing efforts. 

Below is a detailed list of the cookies we use on our Website. Our Website is scanned with our cookie scanning tool regularly to maintain a list as accurate as possible. We classify cookies in the following categories:

• Strictly Necessary Cookies
• Statistics Cookies

You can change cookie settings here

Strictly Necessary Cookies

These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms.

You can set your browser to block or alert you about these cookies, but some parts of the site will not work. These cookies do not store any personally identifiable information.

• TRK GLOBAL LIMITED – this website

Statistics Cookies

These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us know which pages are the most and least popular and see how visitors move around the site. They may be set by us or by third party providers whose services we have added to our pages. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites.

They do not store personal information directly, but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.

• Facebook API – facebook.com
• Google Analytics – google.com

Your Privacy Rights

What choices do I have?

You can always choose not to disclose information to us, but keep in mind some information may be needed to register with us or to take advantage of some of our features.

Cookies

You can accept or reject cookies through our Privacy Preference Centre, accessible by clicking the “cookie settings” button in our cookie policy. You can also do so by adjusting your web browser controls. Please consult our Cookie Policy for more information about our use of cookies and how to accept and reject them.

Marketing Communications

You can opt-out of receiving certain promotional or marketing communications from us at any time by using the unsubscribe link in the emails communications we send.

If you have any account for our Services, we will still send you non-promotional communications, like service related emails.

How can I update and access my information (Exercise my Data Subject Rights)?

If you would like to access, review, update, rectify, and delete any Personal Information we hold about you, or exercise any other data subject right available to you under the EU General Data Protection Regulation (GDPR) and California Consumer Privacy Act (CCPA), you can email us at contact@trkglobal.ro.

Our Privacy team will examine your request and respond to you as quickly as possible!

Please note that we may still use any aggregated and de-identified Personal Information that does not identify any individual and may also retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.California residents are entitled to ask us for a notice identifying the categories of Personal Information that we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to: contact@trkglobal.ro

International Data Transfers

Personal Information you submit on the Websites or through the Services is sent to the United States and will be primarily processed by us in the United States and potentially in other countries, on our servers or on our hosted service providers cloud servers on our behalf. These countries may not have similar data protection laws to those in your country of residence. However, we will always protect your information in accordance with this Privacy Policy wherever it is processed. To request this capability, contact contact@trkglobal.ro

Linked Websites

For your convenience, hyperlinks may be posted on the Websites that link to other websites (the “Linked Sites”). We are not responsible for, and this Privacy Policy does not apply to, the privacy practices of any Linked Sites or of any companies that we do not own or control. Linked Sites may collect information in addition to that which we collect on the Websites. We do not endorse any of these Linked Sites, the services or products described or offered on such Linked Sites, or any of the content contained on the Linked Sites. We encourage you to seek out and read the privacy policy of each Linked Site that you visit to understand how the information that is collected about you is used and protected.

Children

Our Services are not directed to children under the age of 13. We adhere to the Children’s Online Privacy Protection Act (“COPPA”) and will not knowingly collect personal information from any child under the age of 13, unless a parent or guardian consents to our collection and use of this information. If a parent or guardian becomes aware that his or her child has provided us with personal information without his or her consent, he or she should contact us contact@trkglobal.ro If we become aware that a child under 13 has provided us with personal information, we will take steps to delete the information from our files.

Will TRK GLOBAL LIMITED ever change this Privacy Policy?

We’re constantly improving our Websites and Services, so we may need to change this Privacy Policy from time to time as well. We will alert you to material changes by, for example, placing a notice on our Websites and/or by sending you an email (if you have registered your e-mail details with us) when we are required to do so by applicable law. You can see when this Privacy Policy was last updated by checking the date at the top of this page. You are responsible for periodically reviewing this Privacy Policy.

What if I have questions about this policy?

If you have any questions or concerns regarding our privacy policies, please send us a detailed message to contact@trkglobal.ro and we will try to resolve your concerns.