Track-i Privacy Policy

1. Who is responsible?

Track-i is an online software service developed, managed and provided by SnoS.

Depending on the processing activity, SnoS may act as controller or processor within the meaning of the General Data Protection Regulation (GDPR).

2. When does SnoS act as controller?

SnoS is responsible for processing personal data required to provide, manage and invoice Track-i.

This may include:

• the Customer's name and contact details;
• Users' names and email addresses;
• practice and business information;
• account and authentication data;
• subscription information;
• payment and administrative information;
• contact and support requests;
• technical data required for security and operation of the service.

3. Client data within Track-i

Customers can enter data in Track-i concerning clients, programmes, sessions, appointments, tasks, documents and other information required for their professional services.

For this data, the Customer generally determines why and how the data is processed. The Customer therefore acts as controller.

To the extent that SnoS processes this personal data solely to provide Track-i on behalf of the Customer, SnoS acts as processor.

Further arrangements may be set out in a data processing agreement between SnoS and the Customer.

4. Special categories of personal data

Depending on how Track-i is used, Customers may enter information classified as special category personal data under the GDPR.

The Customer is responsible for determining whether such data may lawfully be processed and for having a valid legal basis and, where required, additional safeguards.

SnoS does not process such data for its own purposes where it is stored solely on behalf of the Customer within the Practice Environment.

5. Purposes of processing

For personal data for which SnoS acts as controller, processing may include the following purposes:

• entering into and performing a Track-i subscription;
• creating and managing accounts;
• providing and securing the Track-i service;
• processing payments;
• administration and invoicing;
• responding to questions and support requests;
• preventing and investigating misuse and security incidents;
• improving and technically managing Track-i;
• complying with legal obligations.

6. Legal bases

SnoS processes personal data only where there is a valid legal basis for doing so.

Depending on the processing activity, this may include:

• performance of a contract;
• compliance with a legal obligation;
• a legitimate interest;
• consent, where legally required.

7. Payments

Track-i uses an external payment service provider to process payments.

The payment service provider processes the information required to execute payments and may independently act as controller for certain processing activities.

Track-i does not unnecessarily receive or store complete payment card or bank details.

8. Service providers and subprocessors

SnoS may use external suppliers to provide Track-i, for example for hosting, email, payments, infrastructure, backups and security.

Where a supplier processes personal data on behalf of SnoS, appropriate data processing and security arrangements will be made where required.

9. Security

SnoS takes appropriate technical and organisational measures to protect personal data against loss, unauthorised access, unwanted disclosure, alteration and other unlawful processing.

Security is an ongoing process. Measures may be adapted when technological developments, risks or the service require this.

10. Retention periods

Personal data is not retained for longer than necessary for the purpose for which it was collected, unless a legal retention obligation requires a longer period.

For data processed by a Customer within its Practice Environment, retention periods may also be determined by the Customer and the arrangements in the data processing agreement.

11. Termination of a subscription

Following termination of a Track-i subscription, access to the Practice Environment may be terminated.

Data will subsequently be retained or deleted in accordance with the applicable data policy, data processing agreement and legal obligations.

12. Transfers outside the European Economic Area

If personal data is processed outside the European Economic Area, SnoS will, where required, ensure an appropriate legal basis and appropriate safeguards in accordance with the GDPR.

13. Rights of data subjects

Depending on the circumstances, data subjects have rights under the GDPR including:

• access to personal data;
• rectification of inaccurate data;
• erasure of data;
• restriction of processing;
• objection to certain processing activities;
• data portability;
• withdrawal of consent where processing is based on consent.

Where a request concerns client data entered by a Track-i Customer, the request should generally be submitted to that Customer. SnoS will assist the Customer where required under the GDPR.

14. Complaints

Questions or complaints regarding the processing of personal data can be submitted to info@track-i.com.

A data subject also has the right to lodge a complaint with the competent data protection authority.

15. Changes

This Privacy Policy may be amended when the service, applicable legislation or the manner in which personal data is processed changes.

The most recent version will be published on the Track-i website.