Privacy Policy

1. OUR APPROACH TO PRIVACY
   TREKRECORD LTD ("TREKRECORD", "Company", "we", "our" or "us"), a company incorporated in the British Virgin Islands with registered office at Tortola Pier Park, Building 1, Second Floor, Wickhams Cay I, Road Town, Tortola, British Virgin Islands, is committed to protecting and respecting your personal data. This privacy policy sets out how we collect, store, process, transfer, share and use data that identifies or is associated with you ("personal information" or "personal data" as those are defined in the applicable laws, including but not limited to the EU General Data Protection Regulation, and information regarding our use of cookies and similar technologies.

• TREKRECORD operates an application that allows you to track the number of countries you have visited and keeps your travel experience live and shareable with friends by using our app, which it can be downloaded to your mobile phone (the "Service").

• By using our Service, you understand and agree that we are providing a platform for you to post content, including photos, posts, comments and other materials and to share them publicly. This means that other users may search for, see, use, or share any of your content that you make publicly available through the application, consistent with the terms and conditions of this Privacy Policy and our Terms of Use.

• This privacy policy applies to our Service. Before accessing or using our Service, please ensure that you have read and understood how we collect, store, use and disclose your personal data as described in this privacy policy. By using our mobile application or by providing us your personal data, you agree and consent to the collection, use and disclosure of your personal information as outlined in this Policy.

• "Personal Data" means any information or set of information that relates to an individual such as name, address, email, telephone number etc. which can be either direct or indirect and can be collected by or on behalf of the Company.

• TREKRECORD is the data controller of the personal data we hold about you.

2. PERSONAL DATA WE COLLECT ABOUT YOU
   We collect and process the following personal data that you voluntarily submit directly to us when you use our Service, including but not limited to:

• Account Information. If you create an account, we will collect certain personal information that can be used to identify you, such as your name, postal and/or email address, phone number and date of birth. If you create an account using your login credentials from one of your social network accounts, we'll be able to access and collect your name and email address and other information that your privacy settings on such social network account permit us to access. If you create an account through our mobile application, we may also collect your gender and other personal information as well as non-personal information relating to you.
• Profile information, such as your username, profile picture and the details of other users you have invited to use our Service.

• Note about "Invite Friends" feature: You can choose to invite someone from the contact list on your device to our Service through the "Invite friends" feature by sending an email from your personal account. You understand and agree that you are responsible for any charges applied to communications sent from your device. As this invitation is coming directly from your personal account, TREKRECORD does not have access to or control this communication.

• User content, such as your photos, posts, comments, notes and other materials you provide when you use our Service;
• Identification data, such as your registration/identification information (for example, identity card numbers) insofar as required by the Company and permitted by law;

• Your Communications with Us. We collect personal information from you such as email address, phone number, or mailing address when you request information about our Service, request customer or technical support or otherwise communicate with us.
• Surveys. We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include personal information.

• In addition to the information you may provide us directly, we receive information about you from others, including:

• Users may provide information about you as they use our Services, for instance as they interact with you. Any person sharing personal data of other people should have granted their consent proof of which may be requested at any time during the use of Services.
• Other Partners. We may receive information about you from our sources, including through partners where TREKRECORD ads are published on a partner's service (in which case they may pass along details on a campaign's success), third party services and organizations or other social networks to supplement information provided by you. Where legally allowed, we can also receive information about suspected or convicted bad actors from third parties as part of our efforts to ensure our members' safety and security. If you connect a social network to our Service, or interact with our Service through a social network, we may receive information from the social network such as your name, profile information, and any other information you permit the social network to share with third parties. The data we receive is dependent on your privacy settings with the social network.
• Publicly available information.

• We will indicate to you where the provision of certain personal data is required in order for us to provide you certain features of the Service. If you choose not to provide such personal data, we may not be able to provide the Service to you or respond to your other requests.

• We also automatically collect digital personal data indirectly about how you access and use the Service and information about the device you use to access the Service. This information may include the following:

• Information about how you access and use the Service. For example, the website from which you came and the website to which you are going when you leave our website, how frequently you access the Service, the time you access our Service and how long you use it for, the approximate location that you access the Service from, whether you access the Service from multiple devices, the types of content you view or engage with or the frequency and duration of your activities and other actions you take on the Service.
• Log files and information about your device. We also collect information about the computer, tablet, smartphone or other electronic device you use to connect to our Service. This information can include details about the type of device, unique device identifying numbers, operating systems, browsers and applications connected to our Service through the device, your Internet service provider or mobile network, your IP address and your device's telephone number (if it has one).
• Approximate location information. Other than information you choose to provide to us, we do not collect information about your precise location. Your device's IP address may help us determine an approximate location.

• We may link or combine the personal data we collect about you and the information we collect automatically. This allows us to provide you with a personalised experience regardless of how you interact with us.

• We may anonymise any of the personal data we collect (so that it does not directly identify you). We may use anonymised information for purposes that include testing our IT systems, research, data analysis, improving our Service and developing new products and features. We may also share such anonymised information with others.

3. PURPOSES OF PROCESSING PERSONAL DATA

• 3.1 The Company will process your personal data only for purposes permitted by applicable laws, which may vary depending on where you live, and where the Company operates, and on the terms set forth in this Policy. The purposes of the data processing activities may include:

• Our primary purpose for collecting personal information from you is to provide and improve our Services, to administer your use of the Services (including your account, if you are an account holder), and to enable you to enjoy and navigate our Service.
• Fulfill our contract with you and provide you with our Service, such as:
• Managing your information and accounts;
• Providing access to certain areas, functionalities, and features of our Service;
• Communicating with you about your account, activities on our Service and policy changes.
• Analyze and improve our Service pursuant to our legitimate interest, such as:
• Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
• Measuring interest and engagement in our Service and short-term, transient use, such as contextual customization of ads;
• Researching and developing products, services, marketing or security procedures to improve their performance, resilience, reliability or efficiency;
• Improving, upgrading or enhancing our Service;
• Developing new products and Services;
• Ensuring internal quality control;
• Verifying your identity and preventing fraud;
• Enforcing our terms and policies; and
• Protecting your vital interest, or as may be required for the public good.
• Managing our relationships/communications with individuals: for example, responding to questions and comments or inquiries, inviting individuals to the Company's events, making proposals for future service needs.
• For collaboration and research purposes: for example, to enable Company to make more informed and objective decisions when identifying, engaging with individuals interested about our Service.
• Market research: processing data about individuals for lawful market research purposes. We collect data to help us improve our products and services.
• Direct marketing: to provide promotional material and engage in marketing and promotional activities with individuals in accordance with applicable laws.
• Website functions: to ensure that content from our website is presented in the most effective manner for you and for your device.
• Legal or regulatory obligations and the directions of law enforcement agencies and court orders: to comply with our legal or regulatory requirements (reporting for the safety of information and product quality complaints) or to fulfil transparency requirements.
• Sending you newsletters and other marketing material related to our project provided that you consent on these.
• Ensuring that the content of our mobile application is presented in the most effective way for you and your device.

• 3.2 The Company will process personal data for further purposes, where lawful to do so or when legally obliged to do so.

4. LEGAL BASIS OF PROCESSING

The Company processes personal data based on one or more of the following conditions:

• Consent: If you choose to provide us with information that may be considered "special" or "sensitive" in certain jurisdictions you're consenting to our processing of that information in accordance with this Privacy Policy. From time to time, we may ask for your consent to collect specific information or use your information for certain specific reasons. In some cases, you may withdraw your consent by deleting your content (for instance where you entered information in your profile that may be considered "special" or "sensitive"). In any case, you may withdraw your consent at any time by contacting us at the address provided at the end of this Privacy Policy.
• Provide our Service to you: The reason we process your information is to perform the contract that you have with us. For instance, as you go about using our Service to build meaningful connections, we use your information to maintain your account and your profile and to otherwise provide our features to you and other users.
• Comply with applicable laws and regulations: We process your information where it is necessary for us to comply with applicable laws and regulations and evidence our compliance with applicable laws and regulations. For example, we retain traffic data and data about transactions in line with our accounting, tax and other statutory data retention obligations and to be able to respond to valid access requests from law enforcement. We also keep data evidencing consents members give us and decisions they may have taken to opt-out of a given feature or processing.
• Legitimate interests: We process your information based on our legitimate interest. For example, the Company processes data for the improvement of our products and services, to provide security measures, to protect the Company's employees, contractors, information and other assets and to prevent crime (such as fraud, financial crime and theft of intellectual and industry property and to ensure the integrity of its manufacturing and other operations), for statistical purposes or in other ways strictly necessary to carry out our business.
• Individual interest: We process your information where it is necessary to protect the vital interests of an individual.
• Public Interest: We process your information where it is necessary in the public interest or for a public task.

5. RECIPIENTS OF PERSONAL DATA

• Personal data are not disseminated to unspecified recipients. The Company discloses your personal data to third party recipients on a need-to-know basis where this is reasonably permitted to pursue its legitimate business aims and as required by applicable law. Your personal data will be disclosed only in accordance with applicable laws, and appropriate safeguards through contractual agreements will be established to protect your personal data.

• We may share your personal data with the following:

• Employees of our Company: Access to your personal data is provided to the absolutely necessary staff of the Company, which has committed to maintain confidentiality.
• Affiliated Companies: we may share your personal data within the companies of the TREKRECORD's group for limited legitimate purposes. We may share information with other TREKRECORD companies to make the mobile application safer and enable us to address (e.g., ban) bad actors found or to assist us in data processing operations, as service providers, upon our instructions and on our behalf. Their assistance may include technical processing operations, such as data hosting and maintenance, customer care, marketing and targeted advertising, analytics, finance and accounting assistance, improving our service, securing our data and systems and fighting against spam, abuse, fraud, infringement and other wrongdoings. We may also share information with other TREKRECORD companies for other legitimate business purposes including corporate audit, analysis and consolidated reporting, where and as allowed under applicable law.
• Service providers and partners:we may share your personal data with third party vendors and other third party service providers who process personal data on behalf of the Company, for example (indicatively mentioned) advice / outsourcing, banks and other providers of support and provision of administrative services that provide support services to us, business associates and associates for the management and maintenance of, email distribution, research and analysis, brand and service promotion, Google, Facebook, and management of certain services and data under agreements that have been made. We also share information with partners who distribute and assist us in advertising our services. For instance, we may share limited information on you in hashed, non-human readable form to advertising partners.
• Other Third Parties when you have provided us with your consent: when you share content or any information using our Service, you choose the audience who can see what you share. Public information is any information or content you share with a public audience. Public information is available to all users of our Service, even those who aren't your friends. When you choose to share something with public, it's considered public information and other users may download or re-share this content on and off our Services. You can control who you share with when you post to our mobile application in your profile settings.
• Purchasers and third parties in connection with a business transaction: your personal data may be disclosed to third parties in connection with a transaction, such as a merger, sale of assets or shares, reorganisation, financing, change of control or acquisition of all or a portion of our business.
• Law enforcement, regulators and other parties for legal reasons: we may share your personal data with third parties as required by law or if we reasonably believe that such action is necessary to (i) comply with the law and the reasonable requests of law enforcement; (ii) detect and investigate illegal activities and breaches of agreements, including our Terms of Service; and/or (iii) exercise or protect the rights, property, or personal safety of TREKRECORD, its users or others.
• With your consent or at your request: We may ask for your consent to share your information with third parties. In any such case, we will make it clear why we want to share the information.

• The following is the policy we apply to those with whom we share your personal data:

• We only provide the information needed to perform their specific services;
• They may use your personal data only for the exact purposes set out in our contract with them;
• We work closely with them to ensure that your personal data are respected and protected at all times;
• If we stop using their services, any of the data they hold will be deleted or

• The third parties processing your personal data on our behalf have agreed and committed contractually with the Company:

• to maintain confidentiality;
• not to send to third parties your personal data without the consent of the Company;
• take appropriate security measures;
• comply with the legal framework for the protection of personal data and in particular Regulation 979/2016 / EU (otherwise GDPR).

6. STORING AND TRANSFERRING YOUR PERSONAL DATA

• Security. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy, applicable data protection laws and regulations as well as international security standards. All data you provide to us is stored on secure servers and accessed and used subject to our security policies and standards. The Company has implemented reasonable physical, technical and managerial controls and safeguards to keep your personal data protected from unauthorised access, disclosure, alteration, and destruction. Access to your personal data is limited to a restricted number of the Company's employees whose duties reasonably require such information and third parties with whom the Company contracts to carry out business activities related to the provision of Services. All electronic transactions entered into via our website or mobile application will be protected by encryption technology. We will never send you unsolicited emails or contact you by phone requesting your account details, password, credit or debit card information or national identification numbers.

• International Transfers of your Personal Data. Your personal data may be accessed by staff or suppliers or service providers in, transferred to and stored at, a location outside the EU or the EEA. Where the Company processes personal information in countries that may not provide the same level of data protection as in the EU/EEA or in your own country, where you are resident, the Company will implement reasonable and appropriate legal and technical and organizational security measures with the aim to ensure the security of the processing and in particular to protect your personal data from unauthorized access, use or disclosure. In particular, for residents of EEA – whenever we transfer your information outside of the EEA, we will take all reasonable steps to ensure that adequate safeguards are put in place to protect your information (unless we are permitted under applicable data protection law to make such transfers without additional formalities e.g. where the recipient country is considered an adequate destination). Such safeguards include the use of European Commission approved standard contractual clauses as mentioned above. Where appropriate we may also ask for your explicit consent.

• We will store and retain your personal data for the time strictly necessary to achieve the purposes for which the personal data were collected and any other permitted associated purpose. Personal data may be retained for longer duration where applicable laws or regulations require or where you allow the Company to do so. When your personal data is no longer needed it will be either irreversibly anonymised (and the anonymised information may be retained by the Company) or securely destroyed.

7. YOUR RIGHTS IN RESPECT OF YOUR PERSONAL DATA

• In accordance with applicable law on the protection of personal data, you have the following rights in respect of your personal data that our Company holds:

• Right of access. You have the right to obtain:

1. confirmation of whether, and where, we are processing your personal data;
2. information about the categories of personal data we are processing, the purposes for which we process your personal data and information as to how we determine applicable retention periods according to applicable laws and internal policies;
3. information about the categories of recipients with whom we may share your personal data; and
4. a copy of the personal data we hold about you.

• Right of portability. You have the right, in certain circumstances, to receive a copy of the personal data you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal data to another person.

• Right to rectification. You have the right to request rectification of any inaccurate or incomplete personal data we hold about you without undue delay.

• Right to erasure. You have the right, in some circumstances, to require us to erase your personal data without undue delay if the continued processing of that personal data is not justified.

• Right to restriction. You have the right, in some circumstances, to require us to limit the purposes for which we process your personal data if the continued processing of the personal data in this way is not justified, such as where the accuracy of the personal data is contested by you.

• Right to object. You have a right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your personal data, and we will assess and inform you if that is the case. You can object to marketing activities for any reason.

• If you wish to exercise one of the abovementioned rights, please contact us using the contact details at the end of this privacy policy. You may also review and edit the personal data you have submitted to us by logging into your account on the app.

• If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Service you have requested. We may also send you certain non-promotional communications regarding us and our Service, and you will not be able to opt out of those communications (e.g., communications regarding the Service or updates to our Terms or this Privacy Policy).

• You also have the right to lodge a complaint to your national data protection authority. Further information about how to contact your local data protection authority is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

8. LINKS TO THIRD PARTY SITES

• Our Service may, from time to time, contain links to and from third party websites, including those of other users, our partner networks, advertisers, partner merchants, news publications and affiliates. The Company does not endorse or recommend these sites' content or services and assumes no responsibility regarding the processing activities of personal data or any activity by or content on third-party sites to which our website provides links. We encourage you to read and be aware of the privacy policy, and all other policies, of each site you visit. Τhe statements in this Policy apply solely to information collected by the Company.

9. OUR POLICY TOWARDS CHILDREN

• Our Service is not directed at persons under 16 and we do not knowingly collect personal information from children under 16. If you become aware that your child has provided us with personal data, without your consent, then please contact us using the details below so that we can take steps to remove such data and terminate any account your child has created with us.

10. CHOICES ABOUT MARKETING

• If we intend to use your data for marketing purposes or if we intend to disclose your data to any third party for such purposes, we will inform you respectively. You have the right to object to personal data being used for the purposes of direct marketing and newsletters. You can also exercise the right at any time by contacting us as set out below.

11. CHANGES TO THIS POLICY

• The Company reserves the right to amend this Policy from time to time to reflect technological advancements, legal and regulatory changes, and the Company's business practices, subject to applicable laws. If the Company changes its privacy practices, an updated version of this Policy will reflect those changes by posting any revisions on with the respective update of the effective date listed on the bottom of this Policy. If there are significant changes in our Policy, we will make reasonable efforts to inform you (by any appropriate means) before the changes take effect. We therefore encourage you to periodically visit this page to stay informed of how we are using your personal data.

12. NOTICES

• If we need to provide you with information about something, whether for legal, marketing or other purposes related to TREKRECORD, we will select what we believe is the best way to get in contact with you. We will usually do this through email or by placing a notice on our Service. The fact that we may send notices to you will not stop you from being able to opt out of the certain type of contact.

13. CONTACTING US

• Please contact info@trekrecord.com if you have any questions, comments and requests regarding this Privacy Policy.

• This privacy policy was last modified on 1 September 2022.