Privacy Policy
[Last Updated: August 7, 2024]
This Privacy Policy ("Privacy Policy") is an integral part of our Terms of Service together with any supplement agreement thereto (“Agreement”) and governs the processing of information collected by Baionic, LLC. (“Company”, “we”,“us”, or “our”) from you (“user” or “you”), as a user of the Trackification Application and our Services as defined under the Agreement (collectively, the “Services”).
Any capitalized terms not defined herein shall have the meaning ascribed to them in the Agreement.
The Company may update or revise this Privacy Policy from time to time. Such modifications will be posted on the Platform or addressed directly to where The Company, upon its sole discretion, finds it required.
This Privacy Policy explains how the data is collected, used, or shared with others, how it is safeguarded, and transfer in respect with our Services, all in accordance with the relevant data protection and privacy laws and regulations, including, if relevant to the user's jurisdiction, the EU General Data Protection Regulation (“GDPR”), and any other applicable privacy laws and regulations.
Please note that you are not required by law to provide us with Personal Information (as defined below). Providing Personal Information to us is entirely voluntary. However, not always we will be able to provide you with some or all of our services without obtaining your Personal Information.
The Company shall be entitled to (however not obligated), to retain and store Personal Data in its databases, as detailed under this Privacy Policy and the Agreement, and subject to applicable law.
1. CONTACT DETAILS
Baionic LLC., incorporated under the laws of Delaware, USA, is the Data Controller (as such term is defined under the GDPR or equivalent privacy legislation) of the Personal Information we collect from you. This Privacy Policy pertains to the data collected by us as a Data Controller. It does not pertain to any data collected by us as a processor on behalf of another Data Controller. The privacy and security practices applicable to such other data are regulated by separate agreements signed between us and the owner and Data Controller of such data.
For any question, inquiry or concern related to this Privacy Policy or the processing of your Personal Information, you may contact as follows:
Contact Email: privacy@t12n.io
By Post Mail: Broadway, 3rd Floor #3588, New York, NY 10001, United States
2. WHICH DATA DO WE COLLECT AND FOR WHAT PURPOSE?
“Non-Personal Data” or “Non-Personal Information”: means non-identifiable, aggregated data, that is mainly technical data which is transmitted to us by your device when you access and interact with our Platform, such as the type of browser, type of operating system, type of device used, the time and date you access the Platform, navigation, language preference, Usage Data (as defined under the Agreement), etc. Non-Personal data is used mainly for click stream analysis to provide, maintain, develop and enhance our Platform and the Services provided therein (if applicable) and is not used to identify individuals. Under this Privacy Policy, we can use any aggregated, statistical and de-identified data with no limitation. Such data may be included in our proprietary information and is not deemed personal data under the law.
“Personal Data” or “Personal Information”: means individually identifiable information which identifies or may identify, with reasonable effort, an individual, including online identifiers, such as your name, address, phone number, and online identifiers (such as IP address).
Please see below the table which specifies the Personal Data we collect and how we use it.
| DATA SET | PURPOSE AND OPERATIONS | LAWFUL BASIS UNDER THE GDPR (if applicable) |
| Registration and login data When you register and access the Platform, we use third parties identification methods, such as Google’s sign on services. In those cases, the identification process takes place separately and independently with such third party, while we merely receive some basic identification and authentication data. Such data is processed to allow you with access to the Platform, manage your Account and keep your Customer Data and preferences. | This information will be processed for the purpose of performing our contract with you, to set up your account with us and enable you to use our Services. Further, and in accordance with the relevant third party’s policies, we may use that data to send you news, updates and promotional information regarding our services, all in accordance with applicable law. | The registration information is processed to perform our contract with you. Promotional activities are subject to our legitimate interest. You can opt-out at any time through the "unsubscribe" link within the email or by contacting us directly. However certain operational content, such as alerts regarding your use of the Platform or invoices, will still be sent to you. |
| Platform Data Regarding any user, we keep and process data regarding the use of the Services. That’s includes any information provided by the user while interacting with the Platform, log information and usage recordings, actions performed, and any other record of the User’s activity and interaction with the Platform. | We will use the information to provide you with the Services and record your activities as a user of the Platform. | We process such data for the purpose of performing our contract with you and will enable you to use our Services. |
| Online Identifiers We use third-party cookies on the Platform. As further detailed below, these cookies provide us with analytics and marketing services. The Personal Information may collect includes online identifiers, such as cookie ID, Google ID, IP address, etc. ** for further explanation regarding cookies (and similar technologies) usage please see below. | We will use such information through our or third parties’ cookies and tracking technologies for analytic, optimization and monitoring purposes. In addition, we process such data for operation, security, and fraud prevention purposes. | Cookies that are used for the basic operation of the Platform and provision of the Services, including the monitoring and improvement of the Services per the Agreement are processed per the contract between us. Other strictly necessary cookies, such as for security purposes, will be processed per our legitimate interest. |
| Contact Us and Support If you voluntarily contact us in order to ask for information regarding our Services, get support or any other inquiry, you may be required to provide us with certain information such as your name, email address and any additional information you decide to share with us. | We will use such information to provide you with the information you requested, respond to your inquiry, or provide our Services. We may process the content of our correspondence with you to improve User service, and in the event, we believe it is required in order to provide you with any further assistance (if applicable). The correspondence and its contents with you may be processed and stored by us in order to improve our User service and in the event, we believe it is required to continue to store it, for example, in the event of any claims or in order to provide you with any further assistance (if applicable). | If you contact us for support purposes or as an active user of the Platform, we process such data to perform our contract with you. In other cases, we process such data and retain any inquiry records and history subject to our legitimate interests. |
Please note that the actual processing operation per each purpose of use and lawful basis detailed in the table above may differ. Such processing operation usually includes a set of operations, made by automated means, such as collection, storage, use, disclosure by transmission, erasure, or destruction. Transfer of personal data to third-party countries, as further detailed in the "Data Transfer" section, is based on the same lawful basis as stipulated in the table above.
In addition, we may use certain Personal Data to prevent potentially prohibited or illegal activities, fraud, misappropriation, infringements, identity thefts, and any other misuse of the Platform and to enforce the Agreement, as well as to protect the security or integrity of our databases, Platform and to take precautions against legal liability. Such processing is based on our legitimate interest.
3. COOKIES USAGE
We use cookies to improve your experience while you interact with our Platform and use the Services provided therein. We may use various types of cookies, as explained in the table above:
- Essential Cookies – which are necessary for the Platform to work properly;
- Functional Cookies – designated to save your settings on the Platform - your language preference or other view preferences;
- Session Cookies – used to support the Platform's functionality – such cookies are stored only temporarily during a browsing session and are deleted from your device when you close the browser;
- Targeting Cookies - these cookies are used to collect information from you to help us improve our Services and provide you with targeted advertisements that we believe will be relevant to you (e.g., Google's Cookies).
- Analytics Cookies - give us aggregated and statistical information to improve the Services and further developing it (e.g., Google analytics, etc.).
Please note that the data collected by the use of cookies may be linked to and combined with any other data, including Personal Data.
In addition, cookie's data is usually collected through the use of third-party services, like Google, Facebook, LinkedIn, etc. In those cases, your Personal Data might be transferred to those third parties, which might link it and use it together with other information they have on you from other sources. Such data is "owned" and processed separately by those third-parties under their terms and conditions and the direct accounts or subscriptions you have with those third parties.
4. HOW WE COLLECT INFORMATION
According to the nature of your interaction with the Platform, we may collect information as follows:
- Automatically – we may use cookies and similar tracking technologies (as elaborated in the Cookies Section below) to gather some information automatically when you interact with our Platform.
- Provided by you voluntarily – we will collect information if and when you choose to provide us with information, such as when you contact us in case of an inquiry or providing us with answers to a questionnaire part of the Services.
- Provided from third parties – for example, in case you choose to register to the Services with one of your social media accounts (e.g., Gmail), we will receive certain registration information from such third party services, subject to their independent terms and privacy practices.
5. DATA SHARING – CATEGORIES OF RECIPIENTS WE SHARE PERSONAL DATA WITH
We share your data with third parties, including trusted partners or service providers that help us provide our Services and improve the Platform:
- Legal Requirement: We will share your information in this situation only if we are required to do so to comply with any applicable law, regulation, legal process, or governmental request (e.g., to comply with a court injunction, comply with tax authorities, etc.);
- Third party AI engines and services (per your request) – as part of the Platform usage, and per your request and integration with third party services, we may transfer or interface with those services, including by identifying you as the user of such services. We will always do so upon your decision and it is your responsibility to validate and be familiar with such third party privacy practices;
- Policy Enforcement: We will share your information, solely to the extent required to (i) enforce our policies and agreements; or (ii) to investigate any potential violations thereof, including without limitations, detect, prevent, or take action regarding illegal activities or other wrongdoings, suspected fraud or security issues;
- Company's Rights: We will share your information to establish or exercise our rights, to prevent harm to our rights, property, or safety, and to defend ourselves against legal claims, when necessary, subject to applicable law;
- Third Party Rights: We will share your information, solely to the extent required to prevent harm to the rights of our Users, yourself, or any third party's rights, property, or safety;
- Service Providers: we share your information with third parties that perform services on our behalf (e.g., online and cloud computing services) these third parties may be located in different jurisdictions.
- Corporate Transaction: we may share your information in the event of a corporate transaction (e.g., sale of a substantial part of our business, merger, consolidation or asset sale). In the event of the above, our affiliated companies or acquiring Company will assume the rights and obligations as described in this Privacy Policy;
- Authorized Disclosures: we may disclose your information to third parties when you consent to a particular disclosure. Please note that once we share your information with another company, that information becomes subject to the other Company's privacy practices.
Where we share information with service providers and partners, we ensure they only have access to such information that is strictly necessary in order for us to provide the Services. These parties are required to secure the data they receive and to use the data for pre-agreed purposes only, while ensuring compliance with all applicable data protection regulations.
6. DATA TRANSFER
Any information you provide us may be transferred to and processed in countries other than the country from which you accessed the Platform. Any such transfer will be done in accordance with applicable law after ensuring that your privacy is well guarded. If you are a resident of the European Economic Area ("EEA") we will take appropriate measures to ensure that your Personal Data receives an adequate level of data protection upon its transfer outside of the EEA. If you are a resident of a jurisdiction where the transferring of your Personal Data requires your consent, then your consent to this Privacy Policy includes your express consent for such data transfer.
7. USER RIGHTS
We acknowledge that different people have different privacy concerns and preferences. Our goal is to be clear about what information we collect so that you can make meaningful choices about how it is used. We provide you with the ability to exercise certain choices, rights, and controls in connection with your information. The following principal rights regarding your Personal Data are principally apply to any User: The right to access your Personal Data that we process; The right to ensure your Personal Data is accurate, complete and up to date and have it Data amended; The right to withdraw consent to any use of your Data for promotional purposes.
Other rights, may apply in accordance with the specific country laws applicable to you, such as: The right to object to the processing of your Personal Data, to the extent applicable; The right to send or "port" your Personal Data; The right to file a complaint with a supervisory authority in your jurisdiction; The right to withdraw consent, subject to legal or contractual restrictions and reasonable notice; etc.
You may exercise any or all your above rights in relation to your Personal Data and subject to your jurisdiction by contacting us at: privacy@t12n.io.
Where we are not able to provide you with the information for which you have asked, we will endeavor to explain the reasoning for this and inform you of your rights, including the right to complain to the supervisor authority (in the event you are an EEA resident). We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any such information in accordance with applicable law.
8. RETENTION
We retain Personal Information we collect as long as it remains necessary for the purposes set forth above, all in accordance with applicable laws, or until an individual expresses a preference to opt-out.
Other circumstances in which we will retain your Personal Information for longer periods of time include: (i) where we are required to do so in accordance with legal, regulatory, tax, or accounting requirements; (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges; or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Information. Please note that except as required by applicable law, we may at our sole discretion, delete or amend information from our systems, without notice to you, once we deem it is no longer necessary for such purposes.
9. SECURITY
We implement extensive security measures to reduce the risks of damage, loss of information, and unauthorized access or misuse of Personal Information. We implement appropriate data collection, storage, and processing practices and security tools to protect Personal Information against unauthorized access, alteration, disclosure, or destruction. You should be aware that no security measures are completely fail-proof, and it is impossible to prevent any and all threats to the security of data and systems. Therefore, you should be aware that any processing of digital Personal Information holds certain inherent risks, and we cannot guarantee that our services and databases will be immune to any wrongdoings, malfunctions, unauthorized interceptions or access, malware attacks or other kinds of abuse and misuse.
10. CHILDREN
Our Services are not intended for use by children, and we do not knowingly collect or maintain information about anyone under the age of 12. Please contact us immediately at: privacy@t12n.io if you have reason to believe that a child has shared any information with us.