Privacy Policy
Trakaff provides solutions for performance marketers. Trakaff is the
leading performance marketing platform, used by the world’s top mobile and desktop networks to manage their
online advertising relationships. Clients use Trakaff to assess the effectiveness of their
Affiliate and Publisher relationships – by measuring User clicks and conversions.
This Privacy Policy is provided to help you understand how Trakaff processes end user data on
behalf of advertising networks who use the Trakaff platform. It does not state the use
practices or policies of our clients, of the websites or apps on which ads are shown, or of other parties.
We hold in high esteem the privacy of every Trakaff’s user/clients. We want you to understand
that we apply our long term commitment to protecting privacy to the online and internet activities. This Privacy
Policy contains the details about the information Trakaff will collect and how we will make use
of the said information in terms of the Information Technology Act 2000 and rules thereunder.
Trakaff and our clients care about how end-user data is collected, used, and shared. We are a
“data processor” that collects and analyzes end-user data at the specific request of our clients, the “data
controllers”. This Privacy Policy relates solely to our Trakaff product. For information
on Trakaff’s approach to and preparation for GDPR, please refer GDPR, which is applicable to
the users residing in the European Union.
Further, you agree and consent to the fact that Trakaff may collect, use and disclose your
Personal Information in accordance with this Policy. If you do not agree with these terms, you are requested not
to provide any personal information to us.
- Trakaff just being an Intermediary, our clients determine the data that they provide to and
collect through Trakaff. Clients’ use, collection, exportation, or any other use of end-user data, including
the use of Trakaff products and services, is governed by their own privacy policies and
applicable laws, rules, or regulations.
2. Client uses Trakaff to process information from end-users, with an aim of:
- measuring the performance of ad campaigns
- measuring the performance of Affiliates, Publishers and Networks
- creating customized performance reports (for example, how well a particular advertisement is performing in a
particular geographic region)
- determining when Users respond to ads
- ad serving – Trakaff uses data that does not personally identify users to target advertising for Clients.
End users can be targeted by device type (OS, Make, Model) and imprecise geographic location (state and
region).
- Types of information: At the direction of our clients, who act as data
controllers, Trakaff collects the following types of information from Users to help clients
optimize and measure their advertising network, affiliate and publisher relationships:
- Ad Identifiers
- IP address
- Cookies
- Pixel Tags
- Imprecise Geographic Location Data derived from IP address and/or wifi networks
Trakaff also collects this information from employees of Clients who access information using
their Trakaff accounts to maintain up-to-date contact information.
- Information at Sign Up At the time of signing up with Trakaff, we collect
contact details – including location, email address, phone, company name, skype ID and website URL. Clients
will also need to provide a username and password to set up a Trakaff account. Please note
that Trakaff treats all Client contact details as confidential business information that
will only be used to service Client accounts and respond to Client, Affiliate or Publisher inquiries in
accordance with a contractual agreement or applicable agreement by and between the parties.
- Sensitive Information: Trakaff collects and treats the sensitive information in terms of
the Information Technology Act, 2000 read with the rules thereunder. The disclosures as to sensitive
information which may reside with Trakaff is as follows:
- Login Password: The registration requires you to create a password for accessing
of Trakaff services, which is confidential and sensitive information, collected and
retained within Trakaff database. But the said sensitive information is just used by you as
a Trakaff user for gaining access to the services and is not used or accessed
by Trakaff or its affiliates/partners in any way.
- Financial Information: The Bank Details may be visible on the cheques couriered to us for payment of any
services, but the complete bank account details are never noted down or processed for any reasons
whatsoever, with us. Though we recommend direct deposit of payments in our Bank Account either electronic
transfer or by the drop of a cheque.
In case of payment made by a secured Payment Gateway at Trakaff, the information is processed at the Payment
Gateway, who are PCI Compliant and do not retain the sensitive information for the period more than required.
The said online payments are additionally subject to an independent agreement with the payment gateway provider.
- Sharing of Information: Trakaff uses the personal information (other than the sensitive
information) for fulfilling your need and requests for products and services, improve user experience,
sending transactional emails or notification you have opted for, for displaying relevant advertisement
according to your location, products/services rendered, etc. Trakaff do not rent, sell, or
share personal information (other than the sensitive information) about you with any third parties, except
when we have specifically obtained your consent at the time of collection of the information online
at Trakaff or otherwise offline, and/or to provide products or services you’ve requested,
or under the following circumstances:
- We provide the information, other than sensitive information, to trusted partners who work on our behalf of
or with us under confidentiality agreements for the purpose of creating / modifying / maintaining the site.
However, these companies do not have any independent right to share/use this information for any other
purpose, except for that specifically authorised by us.
The Credit Card Information is collected by the Payment Gateway for processing of the payment and deleted soon
thereafter, as declared above. Otherwise, no outside agency has been authorized for the use of any sensitive
information for now;
- Trakaff’s administrator may be required to login to the admin panel for troubleshooting, as
a result, can get access to the personal data, but which purely can only be for administration and
troubleshooting purposes.
- Trakaff believe it is necessary to share information in order to investigate, prevent, or
take action regarding illegal activities, suspected fraud, situations involving potential threats to the
physical safety of any person, violations of User Agreement, or as otherwise required by law;
- Trakaff responds to court orders, or legal process, or to establish or exercise our legal
rights or defend against legal claims;
- Trakaff we may transfer such data to a successor entity in connection with a corporate
merger, consolidation, sale of assets, bankruptcy, or other corporate change. In this event, we will notify
you before information about you are transferred and becomes subject to different privacy policy;
- Trakaff may disclose end-user data in the event we reasonably suspect fraudulent,
malicious, or unlawful activity, or invalid traffic, or believe that we are legally required to do so.
- Trakaff may also share anonymous aggregated data derived from
the Trakaff platform, including, for example, statistics
about Trakaff platform activity.
Trakaff never uses or share the personally identifiable information provided to us online, in
ways or for reasons unrelated to the ones described above.
- Third-Party Sources: Clients can also choose to view and measure information provided by
other third-party sources in the Trakaff platform. Those sources may include Advertisers,
Publishers, Affiliates, and other Networks and analytics partners. Affiliates may sign up with Advertisers
through the Trakaff platform or through their own client website. Affiliate information
provided to our Advertisers will be used by Trakaff for fraud prevention purposes and to
fulfil contractual requirements with our Advertisers.
- Ownership of Data: Clients own the data that they provide to and collect through
the Trakaff platform. When clients remove or export their data from
the Trakaff platform, their use of data is governed by their own privacy policies and
applicable laws, rules, or regulations. Trakaff serves as a data processor, acting at the
direction of our data controller clients. Specific fields that likely contain personal data, such as IP
address or device ID, maybe obfuscated or blanked, respectively, by the Trakaff client.
- Client-side Tracking: Clients use Trakaff for pixel or server postback
tracking to collect information about Users. Pixel tracking (also called “cookie-based tracking” and
“client-side tracking”) methods store a Trakaff session identifier in a user’s browser
cookie on click. In postback tracking (also called “server-side tracking”), Trakaff directly sends a session
identifier to the advertiser on click. On conversion, the advertiser then communicates that identifier to
Trakaff for validation. Trakaff also supports server-to-server measurement for some
clients. With any of the mentioned methods, when an end-user click on an advertisement, goes to a specific
web page or mobile app action that a Client chooses to monitor, Trakaff collects
information from the User’s computer or device, including but not limited to IP and Ad Identifiers.
- Cookies: User can disable cookies in most internet browsers. Disabling cookies will not,
however, stop receipt of all advertisements. If an end-user would like to opt-out of a particular ad
network, publisher, or advertiser’s ads, they will need to contact those companies directly to inquire
whether they have an opt-out option. End users can also disable the collection of Ad Identifiers for
targeted advertising by enabling the Limit Ad Tracking setting on their smartphone. End users can also reset
the Ad Identifier altogether using their smartphone’s privacy settings. End users should also note
that Trakaff collects information on behalf of its clients. To opt-out, please see
optoutmobile.com or contact the data controller directly. We will actively work with our clients to fulfil
such requests as reasonable and required by law.
- Tracking Technologies: We partner with third parties to display advertising on our website
or to manage our advertising on other sites. Our third party partner may use technologies such as cookies to
gather information about your activities on this site and other sites to provide you with advertising based
on your browsing activities and interests. You may opt-out by visiting the website of that specific partner
like Facebook, Google, LinkedIn, Twitter and Quora.
- Adherence to GDPR Policy: Trakaff serves as a data processor under the GDPR, and adheres to
the principles and rules of the GDPR. Specifically, Trakaff implements privacy by design
and default principles, ensures limited data retention protocols, adheres to incident response norms, allows
for appropriate third party audits, ensures data is only transferred internationally with a lawful basis,
only contracts with sub-processors with adequate written commitments to data processing, respects data
subject rights, does not process sensitive personal data, and provides data processing agreements to all
appropriate clients and partners.
- Communication: Trakaff reserve the right to send you certain communications relating to our
services or sponsored advertisements, administrative messages and the Newsletter, that are considered part
of your registered account, with an option for you to stop receiving them. We shall also send you emails
which shall contain information about our existing or new services or features.
- Security: Trakaff uses commercially reasonable efforts including a variety
of security technologies and procedures to secure client and end-user data from unauthorized access, use or
disclosure. Personal information, especially the sensitive information about users that is maintained on
Trakaff systems and is protected using industry-standard security measures. We maintain a variety of
physical, electronic, and procedural safeguards to guard your personal information. You should be aware that
Trakaff has no control over the security of other sites on the Internet you might visit, interact with, or
from which you buy products or services. You should keep your user name, password or other access
information safe and confidential to protect against unauthorized access to your account information and
services. And you must adopt passwords that others may not guess easily.
- Retention of Information: Trakaff holding sensitive/ personal data or information of
providers of information, shall not retain such information for longer than is required for the purposes for
which the information may lawfully be used or is otherwise required under the User Agreement or any other
law for the time being in force or unless ordered to the contrary by any order of court of law. The
information collected shall be used for the purpose for which it has been collected.
- Deletion of Information: You may also request that Trakaff may delete your Personal
Information from system and records. Additionally, you may delete your account anytime at your own free
will. However, due to technical constraints and the fact that we back up our systems at regular intervals.
Personal Information may continue to reside in our systems after deletion for some limited time.
- Location: The information is collected and retained by Trakaff on its server located in the
USA.
- Changes: Trakaff may find it necessary to update this Privacy Policy from time to time.
Please check this Privacy Policy, as any changes will be posted on this site.
Questions About This Privacy Policy?
If you have an unresolved privacy or data use concern that a Trakaff client or Trakaff has not addressed
satisfactorily, please use [email protected]
Contact Information
If you have any questions regarding this Privacy Policy or would like more information on our privacy practices,
please contact us at [email protected]