Privacy Policy - Facebook Audit

Last Updated 17 Mar 2020
Traktion Audit Privacy Policy
This Traktion Audit Privacy Policy applies to Traktion (“Traktion”, “we”, or “us”), a service of Traktion Technologies Ltd, the web site at https://www.traktion.ai/business/free-facebook-ads-audit (the “Audit Site”) and other services provided by us and on which a link to this Traktion Audit Privacy Policy is displayed, and all other communications with individuals through written or oral means, such as email or phone (collectively, together with the Site, our “Service”).This Traktion Audit Privacy Policy (“Policy”) describes the information that we gather on or through the Service, how we use and disclose such information, and the steps we take to protect such information.

By visiting the Site, or by purchasing or using the Service, you accept the privacy practices described in this Policy.

This Policy is incorporated into, and is subject to, the Traktion Terms of Service.

Capitalized terms used but not defined in this Policy have the meaning given to them in the Traktion Terms of Service.

1. The Information We Collect on the Service:
We collect different types of information from or through the Service. The legal bases for Traktion processing of personal data are primarily that the processing is necessary for providing the Service in accordance with Traktion’s Terms of Service and that the processing is carried out in Traktion’s legitimate interests, which are further explained in the section “How We Use the Information We Collect” of this Policy. We may also process data upon your consent, asking for it as appropriate.

1.1 User-provided Information.
When you use the Service, as a User or as a Visitor, you may provide, and we may collect Personal Data. Examples of Personal Data include name, email address and mobile number. Personal Data also includes other information, such as geographic area or preferences, when any such information is linked to information that identifies a specific individual. You may provide us with Personal Data in various ways on the Service. For example, when you register for an Account, use the Service, interact with other users of the Service through communication or messaging capabilities, or send us customer service-related requests.

1.2 Information Collected by Users.
A User may connect User’s Client Data into the Service. Traktion has no direct relationship with the individuals whose Personal Data it hosts as part of User’s Client Data. Each User is responsible for providing notice to its Clients and third persons concerning the purpose for which Users collects their Personal Data and how this Personal Data is processed in or through the Service as part of User’s Client Data.

1.3 “Automatically Collected" Information.
When a User or Visitor uses the Service, we may automatically record certain information from the User’s or Visitor’s device by using various types of technology, including cookies, “clear gifs" or “web beacons.” This “automatically collected" information may include IP address or other device address or ID, web browser and/or device type, the web pages or sites visited just before or just after using the Service, the pages or other content the User or Visitor views or interacts with on the Service, and the dates and times of the visit, access, or use of the Service. We also may use these technologies to collect information regarding a Visitor or User’s interaction with email messages, such as whether the Visitor or User opens, clicks on, or forwards a message. This information is gathered from all Users and Visitors.

1.4 Information from Other Sources.
We may obtain information, including Personal Data, from third parties and sources other than the Service, such as our partners, advertisers, credit rating agencies, and Integrated Services. If we combine or associate information from other sources with Personal Data that we collect through the Service, we will treat the combined information as Personal Data in accordance with this Policy. 

2. How We Use the Information We Collect
We use the information we collect in a variety of ways in providing the Service and operating our business, including the following:

2.1 Operations.
We use the information to operate, maintain, enhance and provide all features of the Service, to provide the services and information that you request, to respond to comments and questions and to provide support to users of the Service.

2.2 Improvements.
We use the information - other than User’s Client Data - to understand and analyze the usage trends and preferences of our Visitors and Users, to improve the Service, and to develop new products, services, features, and functionality.

2.3 Communications.
We may use a Visitor’s or User’s email address or other information – other than User’s Client Data – to contact that Visitor or User for:

(i) administrative purposes such as customer service, to address intellectual property infringement, right of privacy violations or defamation issues related to the User’s Client Data or Personal Data posted on the Service; and

(ii) updates on promotions and events, relating to products and services offered by us and by third parties we work with. You have the ability to opt-out of receiving any promotional communications as described below under “Your Choices.”

2.4 Cookies and Tracking Technologies.
We use automatically collected information and other information collected on the Service through cookies and similar technologies to:

(i) personalize our Service, such as remembering a User’s or Visitor’s information so that the User or Visitor will not have to re-enter it during a visit or on subsequent visits;

(ii) provide customized advertisements, content, and information;

(iii) monitor and analyze the effectiveness of Service and third-party marketing activities;

(iv) monitor aggregate site usage metrics such as total number of visitors and pages viewed; and

(v) track your entries, submissions, and status in any promotions or other activities on the Service.You can obtain more information about cookies by visiting http://www.allaboutcookies.org. You can set preferences for how Google advertises to you using the Google Ad Preferences page, and if you want to you can opt out of interest-based advertising entirely by cookie settings or permanently using a browser plugin.

2.5 Analytics.
We use Google Analytics, Google AdWords, Mixpanel, Intercom, HotJar, Optimizely and Facebook Pixel to measure and evaluate access to and traffic on the Public Area of the Site, and create user navigation reports for our Site administrators. Each of these systems operates independently from us and has its own privacy policy, which we strongly suggest you review.

(i) Google Privacy and Data Sharing;
(ii) Mixpanel Privacy Policy;
(iii) Intercom Terms & Policies;
(iv) Hotjar Privacy Policy;
(v) Optimizely Privacy Policy; and
(vi) Facebook Privacy & Consent.

We take measures to protect the technical information collected by our use of these systems. The data collected will only be used on a need to know basis to resolve technical issues, administer the Site and identify visitor preferences. 

3. To Whom We Disclose Information
Except as described in this Policy, we do not disclose the Personal Data of a User or User’s Client Data that we collect or store on the Service to third parties without the consent of the applicable Visitor or User. We may disclose information to third parties if you consent to us doing so, as well as in the following circumstances:

3.1 Unrestricted Information.
Any information that you voluntarily choose to include in a Public Area of the Service, such as a public profile page, will be available to any Visitor or User who has access to that content.

3.2 Service Providers.
We work with third party service providers who provide website, application development, hosting, maintenance, and other services for us. These third parties may have access to, or process Personal Data or User’s Client Data as part of providing those services for us. We limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions, and our contracts with them require them to maintain the confidentiality of such information.

3.3 Law Enforcement, Legal Process, and Compliance.
We may disclose Personal Data or other information if required to do so by law or in the good-faith belief that such action is necessary to comply with applicable laws, in response to a facially valid court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement or other governmental agencies.We also reserve the right to disclose Personal Data or other information that we believe, in good faith, is appropriate or necessary to:
(i) take precautions against liability;
(ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activity;
(iii) investigate and defend ourselves against any third-party claims or allegations;
(iv) protect the security or integrity of the Service and any facilities or equipment used to make the Service available; or
(v) protect our property or other legal rights, enforce our contracts, or protect the rights, property, or safety of others. 

4. Your Choices

4.1 Access, Correction, Deletion.
We respect your privacy rights and provide you with reasonable access to the Personal Data that you may have provided through your use of the Services. If you wish to access or amend any other Personal Data we hold about you, or to request that we delete or transfer any information about you, you may contact us at hello@traktion.ai. At your request, we will have any reference to you deleted or blocked in our database.You may update, correct, or cancel your Account information and preferences at any time by accessing your Account settings page in the upper-right hand corner of the Platform.

Please note that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain all information you submit for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.You may decline to share certain Personal Data with us, in which case we may not be able to provide to you some of the features and functionality of the Service.This provision does not apply to Personal Data that is part of User’s Client Data.

In this case, the management of the User’s Client Data is subject to the User’s own Privacy Policy, and any request for access, correction or deletion should be made to the User responsible for the connection of such data into the Service.

4.2 Navigation Information.
You may opt out from the collection of navigation information about your visit to the Site by Google Analytics by using the Google Analytics Opt-out feature.

4.3 Opting out from Commercial Communications.
If you receive commercial emails from us, you may unsubscribe at any time by following the instructions contained within the email or by sending an email to hello@traktion.ai.Users are able to view and modify settings relating to the promotional communications that they receive from us by accessing the “Mailing List Subscription” tab in the Account settings section of the Platform.Please be aware that if you opt-out of receiving commercial emails from us or otherwise modify the nature or frequency of promotional communications you receive from us, you will continue to receive administrative messages from us regarding the Service.Traktion has no direct relationship with the User’s Clients or third party whose Personal Data it may process on behalf of a User. An individual who seeks access, or who seeks to correct, amend, delete inaccurate data or withdraw consent for further contact should direct his or her query to the User they deal with directly. If the User requests Traktion remove the data, we will respond to its request within thirty (30) days.

We will delete, amend, or block access to any Personal Data that we are storing or connecting to only if we receive a written request to do so from the User who is responsible for such Personal Data, unless we have a legal right to retain such Personal Data. We reserve the right to retain a copy of such data for archiving purposes, or to defend our rights in litigation. 

5. Third-Party Services
The Service may contain features or links to web sites and services provided by third parties. Any information you provide on third-party sites or services is provided directly to the operators of such services and is subject to those operators’ policies, if any, governing privacy and security, even if accessed through the Service. We are not responsible for the content or privacy and security practices and policies of third-party sites or services to which links or access are provided through the Service. We encourage you to learn about third parties’ privacy and security policies before providing them with information. 

6. Data Security
We maintain administrative, physical, and technical safeguards for protection of the security, confidentiality and integrity of Personal Data. This includes, for example, firewalls, password protection, and other access and authentication controls. We use SSL technology to encrypt data during transmission through public internet.

Those safeguards will include, but will not be limited to, measures for preventing access, use, modification or disclosure of Personal Data by our personnel except:
(i) to provide the Traktion Audit Service and prevent or address service or technical problems;
(ii) as compelled by law; or
(iii) as a User expressly permits in writing.If you believe your Personal Data has been compromised, please contact us at hello@traktion.ai.If we learn of a security systems breach, we will inform you and the authorities of the occurrence of the breach in accordance with applicable law.

6.1 Personal Data collection and storage.
Personal Data is collected and stored at the following times/places, and for the following purposes:
(i) User’s email address. Collected when Account is first established with User. This Data serves as User’s account sign-in access, and allows us to communicate with you regarding your Account. This Data is stored on Bubble.io’s secure server.
(ii) User’s first and last name. Collected at the User’s discretion. This Data can be shared by the user in the Profile section of the Platform. It is optional, but can be used to enhance the experience and communications with the Traktion Service. This Data is stored on Bubble.io’s secure server. 

6.2 User Data and User’s Client Data collection and storage.
We store aggregate User Data. This is to increase the Services’ performance only, in order to prevent the Platform from calling third-party platform APIs every time a User views or edits a dashboard. User Data connected from third-party platforms is usually read-only; therefore, there is no way we can add, update, or delete it. In a case where third-party platforms grant edit capabilities to the Service, we do not edit, update, or delete User Data account information under any circumstance.User Data and User’s Client Data is stored in the following places in order to provide the Traktion Audit Service and prevent or address service or technical problems:(i) Bubble.io Server(ii) Auth0(iii) SendgridFor more information or to address any concerns, please contact hello@traktion.ai 

7. Data Retention
We only retain the Personal Data collected from a User for as long as the User’s account is active or otherwise for a limited period of time as long as we need it to fulfill the purposes for which we have initially collected it, unless otherwise required by law.

We will retain and use information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements as follows:
(i) the contents of closed (cancelled) accounts are stored indefinitely, unless a Delete is requested by User;
(ii) backups and billing information are kept indefinitely, unless a Delete is requested by User.

8. Changes and Updates to this Policy
Please revisit this page periodically to stay aware of any changes to this Policy, which we may update from time to time. If we modify the Policy, we will make it available through the Service, and indicate the date of the latest revision, and will comply with applicable law. Your continued use of the Service after the revised Policy has become effective indicates that you have read, understood and agreed to the current version of the Policy.