PRIVACY POLICY

Last Updated: [DATE]

Trackore (“Trackore”, the “Company”, “we”, “our”, or “us”) is committed to protecting the privacy of individuals whose personal information we collect, use, or disclose.

This Privacy Policy explains how we collect, use, disclose, and safeguard personal information through:

  • our website located at www.trackore.com

  • our logistics tracking and supply chain visibility platform (the “Platform”)

  • related communications and services.

This Privacy Policy is designed to comply with the Personal Information Protection and Electronic Documents Act (PIPEDA) and other applicable Canadian privacy laws.


1. Accountability

Trackore is responsible for personal information under its control.

We have designated a Privacy Officer who is responsible for overseeing compliance with this Privacy Policy and applicable privacy legislation.

Privacy inquiries may be directed to:

Privacy Officer
Trackore Inc.
1 Yonge St., Suite 1903
Toronto, Ontario, Canada

M5E 1E5

privacy@trackore.com


2. Personal Information We Collect

“Personal information” means information about an identifiable individual.

Trackore may collect the following categories of personal information.

Contact Information

When users contact us, request a call, or subscribe to communications, we may collect:

  • name

  • email address

  • phone number

  • job title

  • company name

  • country or location.

Account Information

If users create an account for the Platform, we may collect:

  • name

  • business email address

  • username and password

  • organization affiliation

  • role or permission level within the Platform.

Technical Information

When users visit the Website, we may collect:

  • IP address

  • browser type

  • operating system

  • referring URLs

  • pages viewed

  • time spent on the Website.

This information may be collected using cookies or analytics technologies.

Platform Operational Data

When organizations use the Platform, it may process operational data relating to logistics workflows such as:

  • shipment identifiers

  • product tracking information

  • operational timestamps

  • user actions within the platform.

This information is typically associated with business activities rather than individuals, but may occasionally include personal information where shipment or operational records reference identifiable persons.

Communications

If users communicate with us, we may retain records of communications, including:

  • emails

  • support requests

  • feedback submissions.


3. Purposes for Collecting Personal Information

We collect personal information for the following purposes:

Providing Services

To:

  • operate the Platform

  • authenticate users

  • administer user accounts

  • provide logistics tracking services.

Website Operations

To:

  • maintain and improve the Website

  • analyze website performance

  • understand user engagement.

Customer Support

To:

  • respond to inquiries

  • provide technical assistance

  • resolve service issues.

Business Communications

We collect and use personal information to:

  • provide information about our products and services;

  • respond to demonstration requests and follow-up inquiries; and

  • send service updates and relevant business communications.

As per Section 22 of the Website T&Cs, where we send commercial electronic messages, we do so in accordance with Canada's Anti-Spam Legislation (CASL), S.C. 2010, c. 23. You have the right to withdraw your consent to receive marketing communications from us at any time, at no cost, by:

  • clicking the unsubscribe link included in any commercial electronic message we send you; or

  • contacting our Privacy Officer directly at the details set out in Section 1 of this Privacy Policy.

We will process unsubscribe requests promptly and in any event within 10 business days, as required by CASL. Withdrawal of consent to marketing communications will not affect your ability to receive transactional or service-related communications that are necessary for the operation of your account or the Platform.


Security and Fraud Prevention

To:

  • monitor for suspicious activity

  • detect unauthorized access

  • maintain system security.

Legal Compliance

To comply with legal obligations or enforce our contractual rights.


4. Consent

Trackore collects, uses, and discloses personal information with the knowledge and consent of the individual, except where otherwise permitted or required by law.

Express consent is obtained through deliberate actions such as submitting a contact form or demo request, creating a Platform account, or opting in to marketing communications.

Implied consent is relied upon where the purpose of collection is obvious and an individual would reasonably expect their information to be used in the manner described. In a B2B context this includes:

  • a business representative providing contact details in the course of a professional inquiry, where follow-up would be reasonably anticipated; and

  • passive collection of technical information — including IP addresses, browser type, operating system, and session data — which is an inherent and reasonably expected aspect of operating any internet-based service.

Trackore does not rely on implied consent for sensitive personal information or for purposes beyond those described in this Privacy Policy.

Withdrawing consent — Individuals may withdraw consent at any time by contacting our Privacy Officer at the details in Section 1. Withdrawal will not affect the lawfulness of prior processing, but may limit our ability to provide certain services.

Where consent is not required — Trackore may collect or disclose personal information without consent in limited circumstances permitted by PIPEDA, including for legal proceedings, investigation of a breach of agreement, or as otherwise required by law.


5. Cookies and Tracking Technologies

The Website may use cookies or similar technologies to:

  • enable website functionality

  • analyze site usage

  • improve user experience 

Users may control cookies through their browser settings.

Disabling cookies may affect certain Website functionality.

Along with cookies and similar tracking technologies, this Website uses web analytics tools and third-party tracking pixels. This includes the LinkedIn Insight Tag, which is operated by LinkedIn and tracks visitor interactions for analytics and advertising purposes. LinkedIn's privacy policy is available at www.linkedin.com/legal/privacy-policy.


6. Disclosure of Personal Information

Trackore does not sell personal information.

We may disclose personal information in the following circumstances.

Service Providers

We may disclose information to trusted service providers that assist in operating our business, including:

  • cloud hosting providers

  • analytics providers

  • customer support tools

  • email communication platforms.

These providers are contractually required to protect personal information.

Business Customers

Where the Platform is used by organizations, certain personal information may be accessible to the customer organization that administers the account.

Legal Requirements

We may disclose personal information where required to:

  • comply with applicable law

  • respond to lawful requests by authorities

  • protect the rights or safety of Trackore or others.


Business Transactions

Personal information may be transferred in connection with:

  • mergers

  • acquisitions

  • corporate restructuring

  • sale of company assets.


7. Cross-Border Transfers

Personal information may be stored or processed outside Canada, including in jurisdictions where Trackore or its service providers maintain facilities including the United States of America.

Where information is transferred internationally, it may be subject to the laws of those jurisdictions.

Trackore takes reasonable steps to ensure that personal information remains protected and safeguards are in place in accordance with this Privacy Policy including contractual protections with service providers and internal mechanisms. 


8. Safeguards

Trackore implements reasonable administrative, technical, and physical safeguards to protect personal information against:

  • loss

  • theft

  • unauthorized access

  • disclosure

  • alteration.

Safeguards may include:

  • encryption

  • access controls

  • secure hosting infrastructure

  • employee confidentiality obligations.

However, no method of transmission or storage is completely secure.


9. Data Retention

Trackore retains personal information only as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce agreements. The following indicative retention periods apply:

Category

Retention Period

Contact form and demo inquiry data

24 months from date of submission, or until the individual requests deletion

Account information (active users)

For the duration of the account

Account information (closed accounts)

3 years following account closure

Platform operational data

For the duration of the applicable Platform Agreement, plus 3 years following termination

Technical and analytics data (IP addresses, browser data)

12 months from collection

Communications and support records

3 years from the date of the communication

Financial and billing records

7 years from the date of the transaction, in accordance with applicable tax and accounting requirements

Legal compliance records

As required by applicable law, which may exceed the periods above


Where personal information is no longer required for any of the above purposes, it will be securely deleted or anonymized in accordance with Trackore's internal data retention procedures.

Individuals may request deletion of their personal information at any time, subject to Trackore's legal obligations to retain certain records. Requests should be directed to the Privacy Officer using the contact details in Section 1.


10. Accuracy

Trackore takes reasonable steps to ensure that personal information is accurate, complete, and up to date for the purposes for which it is used.

Users may request corrections to their personal information.


11. Access and Correction Rights

Individuals may request access to personal information held by Trackore.

Requests may include:

  • confirmation of whether personal information is held

  • access to that information

  • correction of inaccurate information.

Requests may be submitted to the Privacy Officer.

Trackore may require identity verification before responding to requests. We will respond access requests within 30 days or notify the individual if an extension is required.


12. Complaints

Individuals who have concerns about Trackore’s privacy practices may contact our Privacy Officer.

If concerns cannot be resolved, individuals may file a complaint with the:

Office of the Privacy Commissioner of Canada


13. Children’s Privacy

The Website and Platform are intended for use by business users and are not directed toward individuals under the age of 16.

Trackore does not knowingly collect personal information from children.


14. Third-Party Links

The Website may contain links to third-party websites as per Section 5.

Trackore is not responsible for the privacy practices of those websites.

Users should review the privacy policies of those third parties.


15. Additional Rights for Individuals in the EEA, UK, and Switzerland

If you are located in the European Economic Area ("EEA"), the United Kingdom ("UK"), or Switzerland, the General Data Protection Regulation ("GDPR") or equivalent legislation may apply to the processing of your personal information.

Data Controller

Trackore Inc. is the data controller in respect of personal information collected through the Website and Platform. Contact details are set out in Section 1 of this Privacy Policy.

Legal Basis for Processing

Trackore relies on the following legal bases for processing personal information where GDPR applies:

  • Contract — to respond to demo requests, administer accounts, and provide requested services;

  • Legitimate interests — to operate and improve the Website, monitor security, prevent fraud, and conduct business-to-business marketing;

  • Legal obligation — to comply with applicable legal requirements; and

  • Consent — for non-essential cookies and tracking technologies. Consent may be withdrawn at any time without affecting the lawfulness of prior processing.

Your Additional Rights

In addition to the rights described in Section 11, individuals in the EEA, UK, and Switzerland have the right to:

  • request erasure of their personal information;

  • request restriction of processing in certain circumstances;

  • receive their personal information in a portable, machine-readable format (data portability);

  • object to processing based on legitimate interests, including for direct marketing purposes;

  • not be subject to solely automated decision-making that produces significant legal effects (Trackore does not currently engage in such processing); and

  • lodge a complaint with their local supervisory authority. In the UK, this is the Information Commissioner's Office at www.ico.org.uk.

To exercise any of these rights, contact our Privacy Officer at the details in Section 1. We will respond within one month, with a possible extension of up to two additional months for complex requests. Identity verification may be required.

International Transfers

Canada holds an adequacy decision from the European Commission, permitting transfers of personal information from the EEA to Canada without additional safeguards. Where Trackore transfers data to third-party service providers outside Canada or the EEA, including in the United States, appropriate safeguards are applied, such as Standard Contractual Clauses or equivalent data processing agreements. Contact our Privacy Officer for further details.


16. Changes to This Privacy Policy

Trackore may update this Privacy Policy from time to time.

Updated versions will be posted on the Website with the revised “Last Updated” date.  For material changes, the Company will provide reasonable notice prior to the changes taking effect.


17. Breach Notification 

In the event of a breach of security involving personal information that creates a real risk of significant harm to an individual, Trackore will notify affected individuals and the Office of the Privacy Commissioner of Canada as required by applicable law, including PIPEDA's breach of security safeguards provisions. Trackore maintains a record of all security breaches involving personal information regardless of whether notification is required.