TRACT PRIVACY NOTICE

We are committed to safeguarding and respecting your privacy and providing you with the information, options and choices necessary for you to control how we use your information. That is why in this privacy and cookie notice (“Notice”) we describe how we, as a data controller, collect and use your personal data. This Notice applies to all personal data we process about you when you visit our website www.tract.eco , use our platform or otherwise interact with us. We process and protect your personal data (“Personal Data”) with the utmost care. By “you” we refer to any natural person within the scope of this Notice, particularly our registered users. While processing your Personal Data, we comply with requirements imposed by laws and regulations, such as the General Data Protection Regulation (“GDPR”) and the Dutch GDPR Implementation Act.

1. Who we are

   TRACT B.V. is a Dutch private company with limited liability, based at Teleportboulevard 124-130, Unit B2.06, 1043 EJ, Amsterdam, The Netherlands, (hereafter: “TRACT BV” or “TRACT”), “we” and “our”). Here in The Netherlands, the main decisions are made by TRACT about the purposes and means with regard to the processing of Personal Data and we are responsible for the collection and use of your Personal Data as described in this Notice.

   If you want to exercise your rights, such as your right to access, correct, erase, restrict, object or port Personal Data or to withdraw you consent, or if you have any questions about the processing of your Personal Data, you can contact us in accordance with this Notice.

2. Information we collect and process about you

   The Personal Data we collect and process, as well as the purpose, will depend on the services provided to you. The legal meaning of the term 'processing' is very broad and includes, among other things: the collection, storage, consultation, use and deletion of personal data.

   We will collect and process Personal Data about you from the following sources:

   • Information you give us: this is information about you that you give us directly when you interact with us. This includes your profile information, login details, and other details required to register with us. You are free to share your Personal Data with us. However, if you fail to provide necessary data to us, we may not be able to provide you with our services.

   • Information we collect about you when you visit our website www.tract.eco

   • If you apply directly for a job with us, or if you have been engaged with us via an external recruitment agency we will process the following Personal Data of you that we receive directly from you or extract from your CV that is shared with us: your first and your last name, your date of birth, your address, your phone number, your email address, your LinkedIn URL, your banking account number.

   The main purposes for which we process your Personal Data are as follows:

   • To provide our services to you and to communicate with you;

   • Direct marketing purposes, based on your communication preference;

   • For administrative and statistical purposes;

   • For record keeping and to comply with statutory legal and fiscal obligations;

   • For recruitment process (internships, employment) to hold a job interview, to conclude an internship or employment agreement, to pay out rewards/ salary.

   We mainly process the following Personal Data categories: name and address, telephone number, email address, login details, IP address. Depending on the services we may incidentally process additional categories of Personal Data.

3. Legal basis

   We process your Personal Data on the basis of consent, performance of a contract with you, to comply with legal obligations or if it is in our legitimate interests.

   When we process your Personal Data for our legitimate interest, we will also take you into account and ensure that the further processing of your Personal Data is performed in accordance with the legal requirements. As such we will also look into ensuring that processing for this new purpose is compatible with the purpose for which the Personal Data were initially collected. This does not apply when such processing is performed due to a legal obligation. Our legitimate interests are for example: improving our product and services, reducing our costs, improving our newsletters and website or securing our services and facilities.

4. Information sharing

   It is possible that your Personal Data is shared with trusted third parties for the execution of the agreement, or with trusted third parties that perform business functions or provide services to us for the execution and only for the purposes listed in this Notice. All such third parties will be required to adequately safeguard your Personal Data, subject to agreements that correspond to the requirements of applicable laws. We conclude a processing agreement with companies that process your Personal Data on our behalf to ensure the same level of security and confidentiality of your Personal Data. TRACT remains responsible for these processing operations.

   Our website may contain hyperlinks to third party websites. TRACT is not responsible for the content of any third party website.

   Tract engages the following third parties that are qualified as our sub-processors to provide (parts of) services on its behalf: