uTRAC Privacy Policy

This section of our privacy policy refers specifically to the commercial website, utraconline.com, and not our privacy policy for use of the uTRAC Workforce Management Software. Please contact privacy@utraconline.com for more information on how to opt-out of visitor tracking on this website.

Visitor Information We May Collect

• Information that you provide by filling in forms on our site.
• Demographic Information eg. age, gender, interests.
• Device Information eg. operating system and browser type.
• If any person contacts us via our site, we may keep a record of that correspondence.
• We may also ask visitors to our site to complete surveys that we use for research purposes, although there is no obligation to complete those surveys.
• Details of transactions you carry out through our site.
• Details of your visits to our site including, but not limited to, traffic data, location data, content interactions, weblogs and other communication data.

IP Addresses

Website analytical tools used by uTRAC anonymize IP addresses allowing us to analyse relevant visitor data while masking the identity of the visitor.

Cookies

Our site uses cookies to distinguish you from other visitors to our site. This helps us to provide you with a good experience when you browse our site and also allows us to improve our site.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive. Visitors may deny the use of websites saving cookie information within their browser's security settings.

Third Party Cookie Tracking

You can find more information about the individual analytical services we use and the purposes for which we use them in the table below:

Service	Type	Purpose
Google Analytics	Visitor Information	We use Google Analytics to monitor visitor information, traffic levels, search queries and visits to this website. Google Analytics stores IP address anonymously on its servers in the US, and neither uTRAC or Google associate your IP address with any personally identifiable information. These cookies enable Google to determine whether you are a return visitor to the site, to track the pages that you visit during your session, and tailor search and display advertisements. Opt-Out of Google Analytics Tracking How to Opt-Out of Google Advertising
Mouseflow	Visitor Behaviour	We use Mouseflow to monitor visitor behavior on this website such as referrer URL, page visits, clicks, mouse movements, hovers and scrolling. Mouseflow stores IP address anonymously on its servers in the EU/EEA, and neither uTRAC or Mouseflow associate your IP address with any personally identifiable information. Mouseflow does not record any actions input into forms hosted on the uTRAC website. Opt-Out of Mouseflow Tracking
Wistia	Content Interaction	We use Wistia to monitor the interaction with video content embedded on our website, such as play duration, skips etc. Wistia stores IP address anonymously on its servers in the EU/EEA, and neither uTRAC or Wistia associate your IP address with any personally identifiable information. Wistia Privacy Policy

All visitor data is deleted every 6 months where there is no legitimate requirement to hold that data. Please contact privacy@utraconline.com for more information on how to opt-out of visitor tracking on this website.

Communications

Individuals that contact uTRAC via our proprietary domains (utraconline.com, utrac.online, utrac.email etc.) do so at their own discretion and any personal details are shared at their own risk. Every effort has been made, to keep personal data shared through electronic communications private and secure until a time it is no longer required and has no legitimate use, as detailed in the 2018 GDPR Legislation.

This website's owners, uTRAC, and their employees may use submitted information to provide assistance with queries about our products that may have been submitted. This includes forwarding any updates included in our newsletter program that visitors/users have opted-in to (read below).

Third Party Communication Services

uTRAC uses third party communication tools for the purposes of interacting with individuals that have contacted us via our proprietary domains. uTRAC's internal data policies ensure all third parties adhere to the strictest form of data privacy and can adequately provide regulatory compliance to our business.

Service	Type	Purpose
G Suite	Email	G Suite is part of the Google Cloud suite for businesses. We use G Suite to manage emails sent to/from uTRAC personnel. Google Cloud Privacy Details
Salesforce	CRM	We use Salesforce to capture personal data input into forms embedded throughout this website, such as contact requests and trial sign-ups. Salesforce stores this information within the EU/EEA and does not capture IP addresses with any form captures. uTRAC will not communicate with any individual that fills our forms without expressed consent and individuals may opt-out of any communications sent by uTRAC. Salesforce Privacy Details
Intercom	Instant Messaging	We use Intercom to communicate with visitors to our website and users of the uTRAC workforce management software. Individuals may choose to interact with our sales and support teams via the Intercom instant messaging widget located on various uTRAC websites. Visitors that provide email addresses will automatically receive email communications related to their queries and can opt-out of these communications should they wish. Intercom Privacy Details
Zendesk	Support	We use Zendesk to capture contact information, sent to our various helpdesk email accounts (support@utraconline.com, support@utrac.online etc.) and input into forms embedded throughout this website and the https://utraconline.zendesk.com Help site, such as contact requests and trial sign-ups. Zendesk stores IP address anonymously on its servers in the EU/EEA, and neither uTRAC or Intercom associate your IP address with any personally identifiable information that is provided. Zendesk Privacy Details
Mailchimp	Marketing	uTRAC uses Mailchimp to manage our newsletter program used to update subscribers about products and services supplied by our business. Only opted-in subscribers will receive newsletter communications and may easily opt-out of future communications. Mailchimp Privacy Details

Disclosure of Your Information

We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 155 of the Companies Acts, 1963.

uTRAC will only disclose your personal information to third parties in the event ...

• ... that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
• ... that Beretangia Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
• ... that are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of Beretangia Limited, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Access to Your Data

uTRAC will adhere to legitimate requests to disclose and erase your personal data. Requests can be made via privacy@utraconline.com.

Where We Store Your Data

uTRAC endeavours to store all data provided by website visitors from the EU/EEA region within the EU. Any third-party data processors used by uTRAC that transfer visitor data outside of the EU can do so lawfully by relying on binding corporate rules, Privacy Shield certifications, or standard contractual clauses.

Employee Data We Process

• Employee personal data - name, address, contact info.
• Employee sensitive data - social security, pps, health background, criminal convictions.

How We Process Employee Data

Keeping our customer’s data safe is the most important aspect of what we do and uTRAC’s security is fundamental to our business. Please read this article for more information.

Data Protection Officer	uTRAC have appointed Data Protection Officer. In this role, our DPO will be performing regular internal audits to ensure that uTRAC’s Privacy Policies is fully implemented and adhered to. Please contact compliance@utraconline.com if you have any queries.
Data Processing Agreement	uTRAC's standard data processing agreement for EU/EEA customers is applied through our software terms of service.
Security Policies, Training & Enforcement	uTRAC enforces strict data policies throughout its businesses with rigorous training and monitoring.
Risk Impact Assessments	uTRAC implements a 'privacy by design' approach to developing our platform which includes extensive risk assessment to each product change.
Data Separation	All personal data uploaded by EU/EEA clients is not transferred outside of uTRAC's EU based servers.
3rd Parties	uTRAC does not share any employee data uploaded by clients with any 3rd parties.
Encryption in Transit	All data transferred to/from uTRAC is encrypted using 256b enterprise level SSL encryption.
Encryption at Rest	Sensitive data remains hidden through pseudonymisation and asynchronous encryption when appropriate.
Testing	uTRAC regularly scans for endpoint vulnerabilities and runs penetration tests to maintain data integrity.
Breach Monitoring & Notifications	uTRAC utilize alarms and redundancies to monitor breaches. Customers will be notified the exact details of any data breach without delay, where feasible.
Consent, Transparency & 'Right to Be Forgotten'	Employees may review and amend their personal data through the uTRAC platform while uTRAC enables its clients to request privacy policy 'opt-ins' from employees. uTRAC can also quickly assist with any requests made by employees to our clients for data amendment, review, or erasure.

Information for Employees

What is uTRAC?

uTRAC is an online workforce management application used by businesses to store your personal data for legitimate HR purposes.

What Data Is Collected?

Information about you collected and stored in the uTRAC platform is controlled by your employers. Please contact your employers for more information about the personal data they host in uTRAC.

Where Is Your Data?

uTRAC stores all personal data belonging to employees of non-US companies, including EU companies, within the EU. Data belonging too employees of US companies is held in the United States.

What are Your Rights?

Data Access	If you wish to obtain a copy of your data, please contact your employer.
Data Correction	If you wish to amend your data, please contact your employer to request a change or access to a uTRAC portal where you may manually update your details.
Data Erasure	In some instances, you are entitled to request the erasure of your personal data. Please submit any data erasure requests to your employer, or former employer, who may comply where they do not have a legitimate requirement to hold that data.

If any request cannot be processed or is not responded to in a timely manner, please contact privacy@utraconline.com.