Track IT Privacy Notice

You may contact us via email at [email protected] or our mailing address below.

RAKwireless Technology Limited
Room 1002 10/F, Easey Commercial Building 253-261 Hennessy RD Wan Chai, Hong Kong

1. General

The Application was built with privacy in mind. We do our best to make the Application as privacy friendly as reasonably feasible for such types of applications. We also take all reasonable measures to ensure the security of processing personal data within the Application. In addition, we endeavour to provide you as much control over your data as feasible.

2. Functionality

The Application provides you with the ability to see your current location, manage and locate trackers connected to the Application (“tracking devices”), and share location of the tracking devices with other users of the Application.

3. RAK ID Account

In order to use the Application you should have a registered RAK ID account (the “RAK ID Account”), which is operated by us or a company from our group. More information regarding the RAK ID Account and personal data processed within the RAK ID Account is available in RAK ID Privacy Notice (the “RAK ID Notice”), which is available on the RAK ID website (the “RAK ID Website”).
If you try to log in the Application without a RAK ID Account, you will be offered to register a RAK ID Account. The registration of a RAK ID Account is subject to the RAK ID Notice. We suggest you to read the RAK ID Notice before registering and using the RAK ID Account. Further processing of the personal data associated with your RAK ID Account within the Application is also subject to this Notice.
When you log in the Application with your existing RAK ID Account, we will receive only your email address. Email address is necessary to consider you our user and the part of your email address before “@” sign serves as your default nickname in the Application. You may change the nickname when you log in the Application for the first time or later in the Application settings. The nickname could be a pseudonym, there is no need to enter your real name in the Application.

We collect and process the following groups of personal information:

•   Profile Data: includes the email address and nickname and any additional information that you choose to provide within your Application profile (the “Profile”);
•   Location Data: includes the location data of the tracking devices and associated history of the location;
•   Contact Data: includes the personal information you provide to us when you contact our support team or us via the contact details provided in this Notice or within the Application;
•   Automatically-Collected Data: includes the information generated from your activities when you use the Application (this does not include the Profile Data, Location Data, or Contact Data).

1. Profile Data

As described above, you can use the Application only if you log in with your RAK ID Account. Accordingly, we received your email address associated with your RAK ID Account. Please note that the Application does not receive your RAK ID Account password. The Application receives only the information that the entered password is correct or wrong.

The Profile Data includes the following information:

It is not possible to use the Application without providing or collecting mandatory data. The optional data may be provided or recalled at your own discretion. Please note that you can modify the nickname and modify/delete the optional data within the Application interface. However, you cannot change the email address within the Application; in this case you should refer to the RAK ID Website.

Emergency Information

Generally, the emergency information is not processed on our servers. It is stored on the users’ devices and is shared with us only when the emergency functionality is used. In such a case, our servers retransmit the emergency information to the appropriate recipients, however, we do not access or store such information as it is retransmitted in a coded form.

If the emergency functionality is used, the emergency information is transmitted to the following recipients:

•   If in LoRaWAN mode — to the owner of the tracking device (i.e., to the host); 
•   If in LoRa P2P mode — to every user connected to the P2P mode in the range of LoRa transmission.

You should always inform the persons to whom the emergency information relates that you will provide their personal data in the emergency information within the Application. You should endeavor to notify such persons before entering such information within the Application. We do not inform such persons that their emergency information is included in the Application since we do not have access to such data.

Important notice for the persons whose personal data is provided within the emergency information:

We do not know whether and when your personal data is provided within the Application as emergency information. Such information is stored locally on the respective user’s device and we may process it (in coded form) when the emergency functionality is used; in this case, we only retransmit the emergency information to the appropriate recipients. We are not reasonably able to notify you that your personal data is included as emergency information.

2. Location Data

The Application provides users with the ability to see your current location and manage the tracking devices. To fully utilize the functionality of the Application, you should consent to share the location of the tracking devices with the Application, which may include permission to use location data and Bluetooth data. If you do not provide the Application with permission to use your location or Bluetooth data, certain functionality of the Application would be unavailable for your use. 

Please note that if you do not provide the Application with the above data, certain functionality of the Application may not be available to you. For example, if you do not provide the Application with your location data, the Application will not be able to demonstrate to you your current location or the location of the tracking devices. Location history is also an integral part of the Application functionality, as it allows to see where the tracking devices were during a certain period of time.

To provide you with the precise location data and let you use the maps within the Application, we use the Mapbox services provided by Mapbox, Inc. registered at 740 15th Street NW, 5th Floor, Washington DC 20005, United States. For more information, please review Mapbox Privacy Documentation. Note that competent US state authorities may have access to the personal data provided to Mapbox.

Third-party servers

Please note that within the Application you may choose to process the location/bluetooth data by third-party servers (meaning your own servers or servers provided by third parties) instead of our servers. In such a case, we do not process the location/Bluetooth data and it is processed by the respective third-party servers. Accordingly, we would not be the data controller with respect to the location/Bluetooth data which is processed not by our servers. This implies that we would not be able to influence or control such data and this Notice does not apply to the processing of such location/bluetooth data. We suggest you to read the data processing and privacy documentation (agreement, notice, policy, or statement) of the respective third party, which provides the server solution, before deciding to share the location data with them.

3. Contact Data

You may contact us via the contact details indicated in this Notice or by making a support request within the Application. When you contact us or submit a request, you may provide us with certain additional personal information. Such information may include your email address (other than the email associated with RAK ID Account) or any other personal information that you choose to provide to us. When you submit a request within the Application from an IOS device, we will also automatically receive the log file containing the device details (type, version of the operation system, version of the Application).

This data is necessary to address your issue, answer your request, contact you back, or address you properly, where and as applicable depending on the type of personal information. The legal basis for processing such data — our legitimate interest to assist you with your request regarding the Application.

When you send a request via the Application, the requested data is also processed by Zendesk, who helps us to receive and process your inquiries. Zendesk’s details are: Zendesk, Inc. registered at 989 Market Street, San Francisco, CA 94103, United States; for more details please see their website available at https://www.zendesk.com/ Each time you submit a support request via the Application, Zendesk creates a ticket on that request for us containing the ticket data (date/time of request and other details), user data who made a request, and the request details.

Note that competent US state authorities may have access to the personal data processed by Zendesk. For more information on how Zendesk processes personal data, please check Zendesk Privacy Documentation.

4. Automatically-Collected Data

Certain personal data is collected automatically when you access and use the Application. For this purpose we use the Firebase, a solution owned by Google, Inc. registered at 1600 Amphitheatre Parkway, Mountain View, CA 09043. We use Firebase Crashlytics in order to improve our services and ensure continuous and undisturbed work of the Application. The Firebase collects crash stack traces to help us to debug crashes.

The following personal information is collected with Firebase Crashlytics:

•   crashlytics Installation UUIDs;
•   crash traces;
•   breakpad minidump formatted data (NDK crashes only).

Firebase Crashlytics uses crash stack traces to associate crashes with the Application, send email alerts to us and display them in the Firebase Console, and help us to debug crashes. It also uses Crashlytics Installation UUIDs to measure the number of users impacted by a crash and minidump data to process NDK crashes. The minidump data is stored while the crash session is being processed and then discarded.

Note that competent US state authorities may have access to the personal data collected via Firebase Crashlytics. In addition, Google may use this personal data for any of its own purposes, such as profiling and cross-platform tracking.

The legal basis for using Firebase Crashlytics and processing related data is our legitimate interest to improve our services, ensure continuous and undisturbed work of the Application, and to debug crashes within the Application.

Within the Application, you may have an opportunity to participate in a chat and communicate with the other Application users. The Communication Data (meaning the correspondence within the chat) is not stored by us, it is stored locally on the device of each chat participant.

To start chatting with other users, we provide you with the entry security code (randomly generated six digits). To invite other users into a chat you must share the respective entry security code. Please ensure that the code is safe and is not transmitted to an unauthorised person. Anybody having the code can join the chat. Please kindly note that a new chat user will not see the communication of the users that existed before such a user entered the chat.

You are not able to delete or alter the Communication Data, as it is stored simultaneously on several devices. If you leave a chat, respective Communication Data will be automatically deleted from your devices. If all chat participants leave the chat, the respective Communication Data will be permanently erased.

The data is stored in Frankfurt, Europe. The following table describes the storage period for each personal data item separately:

In particular cases we may also process your personal data longer than described above if it is required under the applicable law. We may also delete your personal data if it is required under the applicable law.

We do not sell or rent out your personal data. However, we may share your personal data if it is reasonably necessary for the performance of our undertakings with you and our legitimate interest in maintaining and developing the Application. In particular, your personal information is shared with the following categories of recipients:

•   our affiliates if necessary due to our corporate structure; 
•   our subcontractors and team members, e.g., support team, technical team, etc.; 
•   third-party solutions integrated within the Application, e.g.: Amazon Web Services that provide us with the data storage facilities that are physically located in Frankfurt, Germany; Zendesk, when you contact us via the Application; Mapbox, when you use location tracking and in-application maps; Firebase, when you use the Application;
•   government institutions that may request access to your personal data.

Please note that we and the aforementioned recipients may be located in jurisdictions that may not ensure the same level of data protection as the country of your residence. We will endeavor to protect your personal data while it is processed, stored, or transferred. If and to the extent we are subject to the European Union General Data Protection Regulation, when we transfer personal data to a country that does not ensure the same level of data protection as the country of your residence, we will use additional safeguards, namely, Standard Contractual Clauses.

Within the Application, you may also be able to share certain personal data with other users of the Application. In particular, you may invite the users to see your Location Data. You may independently add or delete users who have access to such data. You may also share certain personal data within the chats available within the Application. Please see more regarding the chat functionality in the section “Communication Data” above.

You are also able to share your Location Data with third-party network servers. If you switch to process your Location Data to third-party network servers, we would no longer be in control of your Location Data and we will no longer act as the controller of your Location Data. Accordingly, we would not be able to change, erase, or transfer such data by ourselves. The operator of third- party network servers is deemed an independent controller of the Location Data.

According to the applicable data protection legislation, you may have the following data protection rights:

1.  Right to access

You are able to request whether we process your personal data and request access to such personal data. Among other you may ask us regarding:

• the purposes for collecting personal information about you;
• categories of personal information concerned;
• who receives your personal information or categories of such recipients;
• how long we are going to store the information about you and if not possible criteria to determine the storage period;
• the right to lodge a complaint with a supervisory authority;
• when your personal information was obtained not from you directly, the source where it came from;
• the existence of either profiling activities or automated decision-making based on your personal information. Where such activities are performed, we should also inform you about their importance and expected consequences of them.

You may also request us a copy of your personal information being processed.

2.  Right to rectification

You have the right to correct inaccurate (for example, old or incorrect) personal information related to you. Please note that you may personally correct certain Profile Data within the Application.

3.  Right to erasure or the right to be forgotten

You have, under certain circumstances, the right to request the erasure of your personal information. Please note, that this right only applies to the data available at the time of request and is not applicable for future data.

Request to the erasure of personal information is possible when:

• personal information is no longer needed for the purposes it was primarily collected or processed;
• when you have already withdrawn your consent for processing your personal data, and we do not have other legal ground to process it;
• when your personal data is processed under legitimate interest and you object to such legal ground. Moreover, there is no overriding legitimate interest to proceed with the processing of your personal data;
• your personal information was unlawfully processed;
• when your personal data has to be erased due to legal obligation. 

Please note that you may delete your RAK ID Account (including the RAK ID Account Data) at any time using the respective functionality available on the RAK ID Website. Also, you may delete your Profile within the Application using similar functionality within the Application interface. In this case, we will delete all the information related to your Profile, including the Location Data.

4.  Right to restrict processing

You may request us to stop processing your personal information when:

• you have reasonable doubts that your information is accurate, and we are verifying the accuracy of such information;
• your personal information was unlawfully processed;
• the purpose of your personal information collection no longer exists, but you wish to store it longer to defend a legal claim.

Moreover, you may request us to stop processing your personal data while we are working on a rectification request or request to object to processing your personal information.

5.  Right to data portability

You have the right to obtain from us and further, reuse your personal data for your own purposes within other services. You will also be able to transfer your personal information from one IT environment to another in a safe and secure way when the following conditions apply:

• processing is based on your consent or is necessary for the performance of a contract; and
• the processing is made electronically, without any paper-based files included.

6.  Right to object

You have the right to object to the processing of your personal information. This allows you to stop or prevent us from processing your personal information. This right is not absolute and applies when one of the following conditions are met:

• your personal information is used for direct marketing purposes;
• the processing is based on our legitimate interest;
• we are performing tasks carried out for the public interest or by governmental authority;
• your personal information was processed for either research or statistical purposes.

7.  Right not to be subject to automated decision making and profiling

Currently, neither we nor the Application use your personal data for profiling or decisions made solely by automated means.

8.  Right to lodge a complaint with a supervisory authority

You have a right to lodge a complaint with a data protection authority in a country you either reside, permanently live, work or in a country where data protection infringement takes place.

The Application is not intended for the use of children (under 18 years old or older, if the country of your residence determines a higher age restriction). You do not have the right to use and you are hereby prohibited from using the Application and tracking devices with respect to children. The Application does not knowingly process, collect, or use personal data of children, and in case we receive such data, we will erase it within the reasonable timeframe.

We keep this Notice under regular review and may update it at any time. If we make any changes to this document, we will change the “Last Updated” date above. Please, review this Notice regularly, or follow the updates within the Application.