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Tracky Solutions privacy policy

The applications ("apps") that Tracky Solutions publishes for the web and mobile devices, or "we", in this privacy policy means Tracky Solutions S.A.R.L, located c/o ste A and A Khadamat N 1525 Bur 05 CITE SALAM, Agadir, Morocco.

For the purposes of data protection laws, Tracky Solutions is the "controller" of your personal information. In most cases, the apps are free apps (with optional in-app purchases), and to maintain high quality and a great user experience, we process information about you, in particular to improve the overall experience in the apps and to support our internal operations.

This Privacy Policy applies when you download and use our apps or otherwise access any of our other services, content, websites (www.tracky.ma, among others) or other domains provided by Tracky Solutions, collectively referred to as the "Services". By using any of the Services, including when you use or access our Services through social networks or mobile devices, you agree to the collection and use of your information in accordance with this Privacy Policy and our Terms of Use (please note that depending on the Service, a customized version of the Terms of Use may apply to it, as indicated on that Service's website).

If you do not want Tracky Solutions to collect, store, use or share your information in the ways described in this Privacy Policy, you should not use the Tracky Solutions apps or Services.

This Policy:

  • Covers the personal data we collect through our websites or mobile apps (Information we collect and how we collect it);
  • Explains how the information gathered through our websites is used and protected (How we use that information);
  • Provides information about your rights to access, correct, delete or object to the use of your personal data.

By using a Site and/or a Service and providing us with your personal data, you consent to the processing of your personal data as described in this privacy policy.

I. Information we collect and how we collect it

The information about you that we collect falls into two categories: information you provide to us directly and information we collect automatically.

1. Information you share directly with us

When you use our Services, you may provide information to us directly. We will store the information you provide directly on our systems and use it for the purposes described in this Privacy Policy.

a. Account and profile information

Some apps or parts of the Services may let you provide us with certain profile information, including:

  • Your first and last name;
  • Your age or date of birth;
  • Your gender;
  • Your email address;
  • Other information that allows us to authenticate you or improve our Services.

We may also let you create a user profile, separate from your site profile, that other Tracky Solutions users can see. Your user profile will include the following information that you provide to us:

  • A profile picture;
  • One or more usernames;
  • Biographical details (such as your age range);
  • The approximate location you provide;
  • If you sign in through your social network profile, the information associated with your profile on that social network;
  • Details about the apps you use;
  • A Tracky Solutions user ID number created by Tracky Solutions and used to identify your profile.

Some apps make certain information from your Tracky Solutions user profile publicly available, including:

  • Your Tracky Solutions user ID;
  • Your first and last name;
  • Your profile picture.

b. Information about your contacts

Some of our Services let you import contacts from your address book, including names, email addresses and social network usernames where available, or enter them manually, so you can find your contacts on Tracky Solutions and invite them to use another of our Services. You are responsible for getting your contacts' permission when you choose to give us their contact details. We may receive information about you from other Tracky Solutions users who import or manually share their contacts. We use and may store some or all of those contact details so that you and your contacts can connect through any of our Services. If you want to remove the contacts stored in our apps or Services, follow the instructions provided in the app or Service concerned. If you have given us your contacts in several apps or Services and want to remove them from all apps and Services, you need to do this in each app or Service. If you have to enter a password to let us access your address book, we will not store that password.

c. Information you generate using our communication features

Some of our Services let you communicate or share information with Tracky Solutions and other Tracky Solutions users. These features include:

  • User forums, newsletters and chat features;
  • Private messaging;
  • The ability to send invitations to other users, directly on our websites or to their email account;
  • Sharing photos or drawings.

We may ask for your approval to access your audio, and it may be used only to let you communicate with other users. It will not be used for advertising or to improve or personalize our services. We can only access audio transmissions temporarily during chat features and will not record or store them on our servers.

You expressly acknowledge and agree that we may access in real time, record or store those communications, comments, photos and drawings on our servers. We will use those communications to protect the safety and well-being of our users and the rights and property of Tracky Solutions in connection with our Services; to conduct research; to operate, improve and personalize our Services and our users' experiences, including through analytics; and to manage and serve contextual ads.

d. Payment information

If you make purchases on our Services, our third-party payment processor will collect billing and financial information to process your charges. Tracky Solutions does not collect or store your financial information. However, Tracky Solutions' payment processors may share non-financial information with us related to your purchases, such as your transaction details, transaction IDs, the items purchased and the value of those purchases, in order to process your order. Please note that purchases of third-party credits or currencies may also be subject to those third parties' policies.

e. Correspondence with Customer Support

When you contact our Customer Support team, we will collect and store the contact details you give them (usually your name and email address), information about your sessions or activity on our Services, and your user ID or social network ID number. We will also store the communications you have with the Customer Support team and any information in those communications in order to provide support.

2. Information we collect automatically

a. Information from social networks

If you use Tracky Solutions apps or access another of our Services using a social network ID (such as Facebook), we will automatically receive certain information about you from the social network, depending on the Tracky Solutions app you use, the social network, and the privacy settings of you and your friends on that social network. For example, Tracky Solutions will automatically collect and store some or all of the following information provided by the social network:

  • Your first and last name;
  • Your profile picture or its URL;
  • Your social network ID number, which is linked to publicly available information such as your name and profile picture;
  • Public data about your friends (including their social network ID numbers);
  • Information about friends who have also linked their social network account to our App;
  • The sign-in email you gave that social network when you registered;
  • The location of the devices you use to access our Services;
  • Your gender;
  • Your exact age or age range;
  • Other publicly available information on the social network;
  • Any other information that you or the social network share with us.

If you access our Services through a social network, you should also read that social network's Terms of Use and Privacy Policy. If you have questions about the information a social network shares with us, please go to the social networks where you use our apps to learn more about their privacy settings.

b. Tracking technologies

We, along with service providers acting on our behalf such as Google Analytics, store log files and use tracking technologies such as:

  • Device identifiers such as IDFA (the identifier for advertisers on iOS devices) and AAID (Google's advertising ID for Android devices);
  • Cookies on our websites, which are small pieces of data transferred to your mobile device or computer that let us (i) recognize your computer; (ii) store your preferences and settings; (iii) understand which Services web pages you have visited; (iv) improve your user experience by delivering content and ads tailored to your interests and measuring how well they work; (v) carry out research and analytics; and (vi) support security and administrative functions.

We and our service providers use these technologies to collect and analyze certain types of technical information, such as:

  • IP addresses;
  • The type of computer or mobile device you use;
  • Your operating system version and platform type;
  • Your mobile device identifiers, such as your MAC address, IDFA and International Mobile Equipment Identity (IMEI);
  • Your browser type and language;
  • App activity, including records of your interactions with the app only;
  • App status and the date and time of activity on our websites or app.

We may link this information to your social network ID (if available) or your Tracky Solutions user ID.

Please note that companies that serve ads on our Services may also use cookies or other technologies, and those practices are subject to those companies' policies.

c. Information from your mobile device

If you use Tracky Solutions apps or access our other Services on your mobile device, in addition to your device identifiers, we may also automatically collect:

  • The name you have given your device;
  • Your country.

With your permission, we may also automatically collect your precise GPS location information.

d. Information across devices and apps

Sometimes we (or our service providers) may use the information we collect, such as usernames, IP addresses, unique mobile device identifiers or other IDs (such as a social network ID), to locate or try to locate the same unique users across multiple browsers or devices (such as smartphones or tablets), or work with providers that do this, in order to better personalize content and features and give you a smooth experience across devices.

If you want to opt out of cross-device tracking for interest-based advertising, you can do so from your Android or Apple device settings.

II. How we use the information we collect

We, or our service providers, mainly use the information we collect and store to analyze and improve our Services in line with a legitimate business interest, to fulfill our contract with you and provide our Services, and for other purposes, including:

  • To operate, improve and optimize our Services and our users' experiences;
  • To create user accounts or user profiles and let you use our apps;
  • To find and recommend other Tracky Solutions users to you;
  • To personalize our Services for you;
  • To let users communicate with each other;
  • To provide technical support and respond to user requests;
  • To process transactions;
  • To do research and develop new products and Services;
  • To protect the safety and well-being of our users;
  • To protect the rights and property of Tracky Solutions in connection with our Services;
  • To verify your identity and prevent fraud or potentially illegal activity;
  • To enforce our Terms of Use;
  • To manage and serve contextual and behavioral ads;
  • To inform users of in-app updates, new products or promotional offers;
  • To run rewards, surveys, sweepstakes, contests or any other promotional activity or event sponsored or managed by us or our business partners;
  • To debug, identify and fix errors that impair the intended existing functionality of the Services;
  • To meet our legal obligations, resolve any dispute we may have with you or other users, and enforce our agreements with third parties;
  • To carry out audits related to interactions, transactions and other compliance activities; and
  • For other purposes that you consent to, are notified of, or that are disclosed to you when you provide personal information.

a. Email and SMS communications

If you give your email address to Tracky Solutions, we will use it to respond to your customer support requests, notify you of in-app activity, including friends' comments, status updates and in-app upgrades, invite you to take part in anonymous surveys, and invite you to events organized by Tracky Solutions. Some messages, such as invitations to friends to use an app, may include your name and profile picture. We may also send promotional emails and promotional SMS messages ("Promotional Communications") directly or in partnership with other parties, in line with your marketing preferences. Each Promotional Communication will give you choices about receiving further messages and a way to opt out of future communications.

b. Use of de-identified and aggregated information

For the purposes described in this Privacy Policy, we may combine the information we collect through the Services with information we receive from other sources, both online and offline, and use that combined information in accordance with this Privacy Policy.

c. How we use automatic collection technologies

We, along with third parties that provide content, advertising or other features on the Services, may use cookies, web beacons, local storage and other technologies ("Technologies") to automatically collect information through the Services. Our uses of these Technologies fall into the following general categories:

  • Strictly necessary: This includes technologies that let you access our services, apps and tools, that are needed to identify irregular site behavior, prevent fraudulent activity and improve security, or that let you use our features;
  • Performance-related: We may use the Technologies to assess the performance of our Services, including as part of our analytics practices to help us understand how our visitors use the Services;
  • Functionality-related: We may use Technologies that let us offer you enhanced functionality when you access or use our Services. This may include identifying you when you sign in to our Services or keeping track of your specified preferences, interests or previously viewed items;
  • Advertising or targeting-related: We may use first-party or third-party Technologies to deliver content, including ads that match your interests, on our Services or on third-party sites.

III. Data subject rights and your choices

You have certain rights regarding your information, as described in this section.

1. Legal bases for processing personal data

Our legal basis for collecting and using personal data will depend on the personal data concerned and the specific context in which we collect it.

However, we only collect your personal data when you expressly consent to its processing (for marketing communications, for example), or when processing is necessary to perform the contract between us, to meet our legal obligations, to protect your vital interests or those of another person, or to serve our legitimate interest.

For more information, please contact us by email at the address given in the "Contact" section.

2. Your rights

  • The right to access the personal information we hold about you;
  • The right to ask us to update or correct any personal information about you;
  • The right to request a copy of your data. A fee may be charged for these copies;
  • The right to withdraw your consent to the processing of your personal data at any time, where that processing is based on your consent;
  • The right to object to receiving commercial and marketing communications;
  • The right to erasure, only to the extent that the data is no longer needed for the Services purchased or required for our legal or contractual obligations (note that some data is mandatory to provide certain services);
  • The right to restrict processing. Here, the restriction will depend on the nature of the service we provide to you;
  • The right to data portability;
  • The right to object to the processing of your personal data;
  • The right to lodge a complaint with a supervisory authority, which in Morocco is the CNDP.

You can exercise these rights at any time by emailing us at the address given in the "Contact" section.

3. Sharing and disclosure of your personal data

We may share your personal data with internal and/or external recipients, solely so that we can serve you when you use our Services.

Internal recipients: this means all internal staff involved in providing you with Tracky Solutions Services or managing your account, such as the technical, sales, and administrative and finance departments.

External recipients: these include:

  • Our service providers for payment processing and fraud prevention, marketing, web analytics, web hosting, messaging and anti-spam;
  • Our SSL certificate providers;
  • Any national administrative or judicial authority requesting disclosure of your personal data where required by law. This type of disclosure may be required in connection with any lawsuit, request or investigation, government request, court order, enforcement of legal rights, etc.;
  • WIPO, where required by applicable regulations;
  • Any other person with your consent to the disclosure.

In line with our instructions, our suppliers and service providers may process or store personal data as part of their duties.

Note that whenever we share personal data, we take all reasonable steps to make sure it is handled securely and in accordance with this Privacy Policy.

a. Our policies on children

Protecting children's privacy online is very important to us. Most of our services are intended for users of all ages, and we do not knowingly collect personal information from children under 13.

If we offer Services intended for children, or when users identify themselves as children when we ask about age, we may provide additional privacy information about those Services, limit the collection of personal information to comply with the law, and/or ask for parental consent.

If you are a parent or guardian and believe your child has given us personal information through the Services, please contact us by sending a request through our web form or an email to privacy@tracky.ma.

b. How long we keep your information

We do not keep your information longer than necessary for the purposes for which it is processed. How long we keep information depends on the purposes for which we collected and use it, or on what applicable laws require. For example, we may keep some information for a few years after you close your account with us if this is needed to meet legal obligations or to assert, defend or establish legal rights.

c. Security of your information

We implement appropriate security measures to protect your information. If you access our Services through a social network and your social network account is hacked, someone could gain access to your Tracky Solutions apps without your permission. Be sure to also protect your social network account details, including your social network account password. We encourage you to sign out of your Tracky Solutions account and any social network account you used to access our Services once you are done using them.

When you sign in to your Tracky Solutions account or enter payment information, we or our third-party payment processor use secure socket layer ("SSL") technology to encrypt the transmission of that information. Although we take reasonable precautions against possible security breaches of our Services, customer databases and records, no website or Internet transmission is completely secure. Although we work to protect your personal information, we cannot guarantee that unauthorized access, hacking, data loss or other breaches will never occur, and we cannot guarantee the security of your information while it is being transmitted to our Service. Any transmission is at your own risk. If you have questions about the security of our websites, please contact us through our website at www.tracky.ma.

d. User account deletion

As a Tracky Solutions user, you have the right to delete your account at any time. To do so, go to your account settings in the app. By selecting the account deletion option, you start the process of removing your personal data from our databases.

We take the privacy of your data seriously. Once the deletion request is made, your data will be permanently erased from our servers in a secure and irreversible way, in accordance with our data protection policies and applicable regulations.

Please note that this process cannot be undone. After deletion, you will not be able to recover your account or the associated data.