Trackbook Privacy Policy

Last updated: December 5, 2024

Vectura Games OÜ (“Company”, “We”, “Us”, or “Our”) is the owner and operator of trackbook.online (“Website” or “Site”). Any reference to “You”, “Your” or “User” refers to the User who accesses, browses, visits or uses the Website. The Company is the data controller of all personal information you provide to us.

1. Acceptance of this Privacy Policy

Please read this Privacy Policy before you proceed to use the Website. This Privacy Policy informs you: what information we and the third-party services we use collect from you; and how we and these third-party services process and share the information we collect from you. If you do not expressly agree with our collection and use of your information as outlined in this Privacy Policy, please do not access our Website. By accessing our Website and you give us your full consent to the collection and use of your Information as outlined hereunder. If you have any questions about this Privacy Policy, please contact us at .

2. Definitions

“Controller,” “Data Subject,” “Personal Data,” “Processing,” “Processor,” and “Supervisory Authority” shall have the same meaning as defined in the General Data Protection Regulation 2016/679.

“Data Subject Request” means the exercise by a Data Subject of their privacy rights in accordance with the GDPR.

3. Amendments to this Privacy Policy

We may amend this Privacy Policy at any time at our sole discretion. When we make any amendments to this Privacy Policy, we will inform you of such amendments by changing the last updated date on the top of this web page. If we wish to process your personal data for a new purpose, we will only do so with your consent.

4. Personal Data Collection and Use

4.1. Types of personal data we collect

The personal data we may collect from our users includes:

4.1.1. Name;
4.1.2. Email address;
4.1.3. Your user generated content you voluntarily submit, such as images to your tracks and waypoints;
4.1.4. Content of any communication you have with our customer support team;
4.1.5. Information provided by you when you participate in surveys, contests, or other promotional activities on the Website.
4.1.6. Information about users’ interactions with the Website, including browser type, pages visited, visit times, and IP address.
4.2. Collection and Use of Personal Data
4.2.1. Account registration data

When you create an account for https://trackbook.online we will collect your email address.

Purpose of processing

We process this information to enable you to securely log into your account and to contact you if required.

Legal Basis for Processing

The legal basis for our collection and use of your personal information is legitimate interest as we are unable to create your account without the collection and processing of this information.

4.2.2. Collection of user-generated content data

The Website enables you to upload images to your tracks and waypoints. These images are visible only to the uploading user. If a user marks a track as public, the track will become publicly available to other users, but the images associated with that track will remain private and only visible to the uploading user.

Purpose of processing

We process this data to enable users to enhance their tracks and waypoints with images for personal use and share tracks that they wish to make publicly available.

Legal Basis for Processing

The legal basis for our collection and processing of this personal data is our legitimate interest, as this data is essential to provide the new feature's functionality and it does not override your privacy rights.

4.2.3. Collection of communication data

We collect your name, email address, and the content of your message when you contact us for any reason.

Purpose of processing

We process the data to respond to your requests, to keep record of your past communication with us, to provide support and other compatible purposes.

Legal Basis for Processing

The legal basis of our processing is legitimate interest which does not override your privacy rights.

4.2.4. Automatically collected usage data

We automatically collect certain usage data about you when you use our website such as browser type, operating system, pages visited on our website, the date and time of visit.

We also collect additional usage data such as:

Your location and pages viewed through the use of Matomo Analytics. Matamo Analytics does not collect any personal data from our users and the User’s IP address is anonymized for ensuring privacy. To learn more please visit Matomo Analytics’ Privacy Policy by visiting this link.

Crash reports, and device information, that helps us diagnose and address technical issues promptly through the use of Sentry. When errors or crashes occur, Sentry may also collect anonymised session replay data to help us understand the circumstances around an issue. Sentry’s session replay feature is designed to capture and reproduce user interactions leading up to a crash. This data is automatically scrubbed of any personal data to protect user privacy. To learn more about Sentry’s Privacy Policy please visit this link.

Purpose of processing

Your personal data is processed to analyse how you use our Website and to improve our user experience. We also process crash and error data to identify and resolve technical issues and improve our Website performance.

Legal Basis for Processing

The legal basis for processing additional usage data processed by Matomo Analytics is your express consent which is requested when you use our Website. You can opt-out of our collection of usage data by following the opt-out instructions provided in Section 7 of this Privacy Policy. The legal basis for processing additional usage data processed by Sentry is our legitimate interest in ensuring the security, stability, and functionality of our Website. This type of data collection is essential to maintaining and improving the website’s reliability.

You can opt-out of our collection of usage data by following the opt-out instructions provided below.

5. Disclosure of Personal Data

We do not sell or rent your personal information to any third-party. We may disclose your personal information in the following circumstances:

5.1. Third-party service providers

We may engage third-party service providers to perform some services on our behalf, including but not limited to Website hosting, crash monitoring/error tracking, marketing, and support services. During such services, your personal data may be disclosed to such third-party service providers only to the extent required for them to perform relevant functions on our behalf. In no event will these service providers use your personal data for any purpose other than those specified in this privacy policy.

5.2. Commercial Transactions

In the event we enter into any commercial transaction, such as a merger, acquisition, sale, or purchase, all your personal data may be disclosed or transferred to the other entity as part of such a commercial transaction.

5.3. Protection of Rights or Fulfilment of Legal Obligations

We will disclose your personal data to third parties in situations where we believe such disclosure is necessary to investigate or remedy any violations of our Agreement with you or to protect our rights and the rights of others. We will also disclose your personal data in situations where we are required to do so by applicable law/regulation or legal process, such as to comply with a subpoena.

5.4. With Your Consent

We may share your personal data with third parties with your express consent.

6. Transfer of Personal Data

Although the Company is located in Estonia, we may use third-party applications and services whose servers are located outside of the Eurpoean Economic Area (EEA) including the United States of America where the data protection laws are significantly less stringent than those within the EEA. When we use such third-party services, your personal data may be transferred and processed outside of the EEA. Whenever such data transfer takes place, we will ensure that it complies with the General Data Protection Regulation.

6.1. Merger or Acquisition

Mergers and acquisitions are part of business reality. In the event we undergo a merger or acquisition, your personal information will be transferred to the new acquirer who may be outside the EEA as part of our business asset. We assure you that any transfer of your personal data to a new entity will not limit your rights under this privacy policy and your personal information will be managed by the new entity on terms substantially the same as set out in this Privacy Policy.

7. Your Privacy Rights

You have the following rights relating to your personal data we process:

7.1. Right to access your personal data

You have the right to request access to your personal data or a copy of your personal data by contacting us. This right is only available to the extent that your request is not excessive or manifestly unfounded.

7.2. Right to rectification

If the personal data we process for you is incorrect, outdated, or incomplete, you have the right to rectify, update, or complete it by contacting us.

7.3. Right to withdraw consent

To the extent the lawful basis of our processing of your personal data is your consent, you have the right to withdraw your consent at any time as outlined in Clause 7 below.

7.4. Right to restrict processing

You may under certain circumstances request us to restrict processing your personal data.

7.5. Right to request erasure of personal data

You have the right to request the erasure of your personal data. You can exercise this right by deleting your account. To delete your account you will need to log into your account and access your "Account settings" and select the "Delete account" option. Once you delete your account all your tracks, waypoints, images and all data associated with your account will be permanently removed from our server and it won't be possible to recover them.

7.6. Your right to data portability

Where your personal data was collected automatically, you have the right to receive your data in a machine readable format. We will respond to your request within thirty days from the date of receipt of your request.

7.7. Right to file a complaint

If you believe that your personal data rights are breached, You have the right to lodge a complaint with your local supervisory authority.

The local supervisory authority in Estonia is:

Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon)
Väike-Ameerika 19
10129 Tallinn
Tel.: +372 6274 135
Fax: +372 6274 137
e-mail: info@aki.ee
Website: http://www.aki.ee/en

Please note that we may request that you provide proof of your identity before servicing your data subject requests.

If you wish to exercise any of your above data rights, please contact us at and we will respond to your request within thirty days.

8. Consent Management and Opt-Out Options

To withdraw your consent for data processing please contact .

If you wish to opt out of receiving marketing communications, click “unsubscribe” at the bottom of our marketing emails and we will immediately cease processing your personal data for direct marketing purposes.

If you wish to disable Matomo Analytics please enable “Do Not Track” in your browser.

9. Security of Personal Data

The security of your personal data is important to us. We take all reasonable and financially viable steps to safeguard your personal data from any unauthorised access, use, modification, destruction, or loss. We have integrated various security measures into the design of our Website and our day-to-day operations. Although we make our best effort to safeguard your personal data, You acknowledge that no mode of transmission over the Internet is one hundred percent secure; therefore, we cannot offer you any guarantees as to the absolute security of your personal data. By using the Website, you understand and accept that the transmission of data through the Website is carried out at your own risk.

10. Retention of data

We will retain your personal data only as long as we have a lawful basis. For personal data associated with your user accounts, we retain this personal data until you delete your account. All usage data is retained for a period of 24 months for analytics purposes, after which it is deleted or anonymized.

11. Disclaimer for third-party website links

Our Website may contain links to third party websites that are neither owned nor operated by us. Should you decide to click on any such third party links, you will be directed to such third party website. These third-party websites have their own Terms of Service and Privacy Policy and we encourage you to review their Terms and Privacy Policy prior to using their site or any services offered by them.

We disclaim all liability with regards to your use and access of such third-party sites. We cannot be held responsible for any content made available by these third-party sites or their practices. You access and use these sites solely at your own risk.

12. Children’s Privacy

Our Website is not for users under the age of eighteen (18) years. If you believe we have collected data from a child, contact us immediately, and we will delete it. We do not perform active age verification but will take steps to remove any data inadvertently collected from minors.

13. Data Controller

The Company is the data controller for all the personal data that we collect from you. You can contact us at:

Email:
Address: Sepapaja 6, Tallinn 15551, Estonia