PRIVACY STATEMENT

Last Updated: August 31, 2023

This Privacy Statement applies to MVTRAC, LLC. and each of its subsidiaries’ and affiliates’ (“MVTRAC”, “we”, “us”, or “our”) websites, including our mobile versions, personal data and the choices available to you regarding collection, use, access, disclosure and how to update and correct your personal data. This Statement is not, however, a contract and does not create any legal rights or obligations.

We may provide additional information on the collection or use of personal data provided prior to or at the time of data collection where this is required by applicable data protection laws. Certain MVTRAC websites and Solutions may have their own privacy documentation describing how we handle personal data for those websites or Solutions specifically.  To the extent a specific statement for a website or Solution conflicts with this Privacy Statement, such specific statement will control.

We will update this Statement from time to time. You can see when this Statement was last updated by checking the date displayed at the top of this Statement.

Our Role as a Processor or Service Provider

Data protection laws sometimes differentiate between “controllers” and “processors” of personal data. A “controller” determines the purposes and means (or the why and the how) of processing personal data. A “processor,” which is sometimes referred to as a “service provider,” processes personal data on behalf of a controller subject to the controller’s instructions.

When our customers use the products and services they purchase from us, we may  process personal data on behalf of our customers (the controllers)  in accordance with their instructions and, therefore, act as a “processor.” If you have questions about personal data that may be processed by MVTRAC as a “processor” in connection with the products or services used by one of our customers, or want to exercise any of your rights regarding such personal data, we recommend that you contact the applicable customer directly as it will be our obligation to redirect any inquiry you make to us back to that MVTRAC customer.

Personal Data Collected

What personal data is collected?

Product and Services

When you place an order with us, we may collect personal data about you, including name, title, company, address, email address, phone numbers and, in rare instances, other categories of personal data, such as payment card information, driver’s license numbers, social security numbers (or equivalent national identification numbers) and date of birth. If you contact us via email, phone, chat, or other communication channels, we may collect personal data you provide in connection with your communication (such as, name, title, company, address, email address, phone number, and products / services of interest) and may monitor or record our conversation (including through the use of automated tools by us or our third-party providers).

Marketing

We may ask you for and collect personal data at other times in connection with our marketing activities, including when you enter a sweepstakes or contest; participate in a promotion or marketing campaign sponsored by us or one of our business partners; when you want to find out about services offered in your area; when you complete surveys or other questionnaires; when you participate in a user forum or blog hosted by us or one of our business partners; when you send us an email.

We (and our Service Providers) may also collect information made publicly available through third-party platforms such as social media websites, online databases, or online directories.

If you do not wish to receive marketing communications you can opt out by following the link in the email you received. After you opt out, we will not send further promotional communications, but we may continue to contact you to the extent necessary for the purposes of any services that you have requested.

Recruitment

We collect personal data when you express interest in employment with MVTRAC, whether directly or via an agent or recruiter (speculatively or in response to any ad on the basis of our legitimate interest to recruit new employees or contractors), including names, contact information, CV or resume, date of birth, performance management information, compensation information, race and ethnic origin.

Cookies and Online Activities

When you interact with us online, including through our websites, we and our third-party providers may automatically collect certain information from your device and your browsing activities. For example, our web server logs collect IP addresses and other unique identifiers of visitors to our websites, as well as certain device characteristics and metrics relating to their visits including operating system, device type and version, browser type and version, the URL entered and the referring page/campaign, date/time of visit, other user agent string data, the time spent on our services, and any errors that may occur during the visit to our services.

We and our third-party providers may also collect information automatically about the electronic path you take to our websites, through our websites and when exiting our websites, as well as your usage and activity on our websites and other online services, such as the links and objects you view, click or otherwise interact with (also known as “clickstream data”). We and our third-party providers use log data and clickstream data to measure the use of our websites and online services, as well as to improve the content of our sites. We and our third-party providers may also use this data for purposes of determining which products and services may be of interest to you, and to market to you based on those interests.

In order to collect this data, we and our third-party providers may use (i) cookies or small data files that are stored on an individual’s computer or device and (ii) other, related technologies, such as web beacons, pixels, embedded scripts, location-identifying technologies and logging technologies (collectively, “cookies”). For more information about these practices, and any choices you may have in relation to the use of cookies, please refer to the Cookies section of this Statement.

Information for Channel Partners

If you represent a MVTRAC’ channel partner, you may visit our websites intended specifically for channel partners. We may use information provided on that site to administer and develop our business relationship with you, the channel partner you represent, and channel partners generally. For instance, this may involve using your information to send you details of channel partner programs, including product offerings or special opportunities. It may also include sharing certain information with other channel partners (subject to any confidentiality obligations that may exist), or MVTRAC’ customers or prospects. In connection with a particular transaction or program, we may also contact you as part of customer satisfaction surveys or for market research purposes. We will process your data on the basis of performance of a contract to which you (as a representative of a MVTRAC channel partner) are party or in order to take steps at your request prior to entering into a contract.


Information for Suppliers

If you represent a MVTRAC’ supplier, you may visit our websites intended specifically for use by MVTRAC’ suppliers. We may use the information provided on those sites in connection with entering into or performing purchases, contracts, or other transactions with you or related business partners (such as customers). For example, this may include sharing information with other parts of MVTRAC, MVTRAC’ channel partners, customers, shipping companies, financial institutions and postal or government authorities involved in fulfillment. It may also be used to administer and develop our relationship with you, the supplier you represent, and other MVTRAC’ suppliers generally.

Social Computing Tools

We also provide social computing tools on some of our websites to enable online sharing and collaboration among members who have registered to use them. These include forums, wikis, blogs and other social media platforms. For more information about these tools and our practices relating to them, please refer to the Social Computing Tools section of this Statement.

Third Party Websites

Who is collecting the information?

When you are on our websites and are asked for personal data, you are sharing that information with MVTRAC, Inc., its subsidiaries and related companies. Additionally, if you purchase a product or other device requiring service, your personal data may be collected by a third party company working with us. We may also contract with third party companies to perform services for us on our websites that require these companies to collect personal data (e.g. hosting a website sweepstakes, promotion or survey, conducting advertising activities, selling software, facilitating online job applications, or providing / monitoring communications and chat features).

In addition, our websites may be operated by third parties, or may allow third-party vendors to provide products and services directly to our customers. Such relationships are designated with a “Provided By” or “Powered By” company legend or logo, or other similarly worded designation. If you desire to purchase a product or service from such a third party, your personal data will be collected by the third-party company, and shared with us. You may review the privacy practices of the third party either by clicking the link on the bottom of the page, or by clicking on the “Provided by Company” logo, which will take you to their website. Additionally, when you purchase or download software applications from us or a third party, your personal data is shared with the software developer/licensor in order to register you as a licensed software user, and to permit them to provide you any required support. If you are concerned about the privacy statement of a certain developer or software company, you may contact them directly or visit their individual websites.

Our websites may also contain various links to third-party websites. These sites may provide additional information, goods, services and/or promotions. These sites are owned and operated independently of us, and have their own separate privacy and data collection practices. Any information you provide to these websites will be governed under the terms of their privacy statement, if any. We have no responsibility or liability whatsoever for the independent actions or policies of these independent sites, and we are not responsible for the content or privacy practices of such sites.

Use of Personal Data

How is my personal data used?

MVTRAC’s primary goal in collecting personal data is to facilitate order processing, to communicate regarding business matters, to enable us to contact you if a problem arises with your order, or if there is some other need to reach you. Additionally, if you purchase a product or other device requiring service, your personal data may be used to obtain a credit report if necessary. Such information is required to complete a purchase transaction. Certain information may also be used to provide you with a customized experience on our websites, which includes interactive communications and other services. Our websites may also contain optional registration, surveys and questionnaires asking for information, as well as several opportunities for visitors to ask questions. We use the information you provide to help us design and build better products, to customize your shopping experience, to work better with you as a channel partner, and to provide advice and purchase recommendations. If you do not provide information that we request, we may not be able to provide (or continue providing) relevant products or services.

We also use the information we collect to help with marketing and advertising offers customized for you. This kind of advertising may be done with banner ads as well as promotional emails sent by us, or by third parties under contract with us. We may also match user information with third-party data to help us better understand our customers.

We also conduct research on our users’ demographics, interests, and behavior based on the information provided to us when making a purchase, during a promotion, from surveys and from our server log files. We do this to better understand and serve our users. This research is compiled and analyzed on an aggregated basis so as to prevent identification of personal data relating to any one individual. We may share the aggregated data with our business partners.

Legal Basis

On what legal basis do we process personal data?

We process personal data:

  • When it is necessary for the performance of any contractual relationship we may have with you, such as payment information where it is necessary to conclude a transaction with you;
  • Where it is necessary for us to comply with our legal obligations, such as tax reporting or for anti-money laundering purposes; or
  • Where it is necessary for the purposes of the legitimate interests pursued by us, which are identified in the “Use of Personal Data” section, where those interests are not overridden by the interests or fundamental rights and freedoms of the data subject.

We may also process your personal data based on your explicit consent (i.e., your freely given, specific, informed and unambiguous consent). Where this is the case, we will clearly request your consent prior to collecting or processing your personal data. You should be aware that you have the right to withdraw your consent at any time.

Sharing of Personal Data

With whom does MVTRAC share my personal data?

We share personal data with our subsidiaries and related companies. If you or your company purchase a product or other device requiring service, your personal data is shared with the relevant service provider. Additionally, if you express an interest in a product requiring a particular type of service, we may share your personal data with your local service provider in order to determine whether such service is available in your area.

We may share your personal data with third-party service providers so that they may provide services to us that are consistent with the terms of this Privacy Statement (e.g., database management, providing / monitoring communications and chat features, sending personalized emails, software sales, and conducting sweepstakes and other promotions on our behalf). We may also, on occasion, provide personal data to third-party businesses as part of a specific product, service, or promotion.

We share website usage information about visitors to our websites, who have received a personalized promotional campaign, with third-party advertising companies for the purpose of personalizing future campaigns and upgrading visitor information used in reporting statistics. For this purpose, we and our third-party advertising companies note some of the pages you visit on our websites through the use of cookies, pixel tags (also called clear gifs) and related technologies. For more information about these practices, and any choices you may have in relation to the information being collected, please refer to the Cookies section of this Statement.

We may share your information with third parties, such as legal advisors and law enforcement, in connection with the establishment, exercise or defense of legal claims; to comply with laws and regulations or to respond to lawful requests and legal process; to protect our rights and property and the rights and property of our agents, customers, and others, including to enforce our agreement, policies, and Terms of Use; to detect, suppress, or prevent fraud; to reduce credit risk and collect debts owed to us; to protect the health and safety of us, our customers, or any person; as otherwise required by applicable law, court order, subpoena or other legal process; or as requested by a governmental or law enforcement authority. We may also disclose information about you to third parties with your consent.

What About Cookies?

What are Cookies and Related Technologies?

Cookies are small data files that are stored on your device that allow us and our third-party providers to collect certain information about your interactions with our websites and other online services. We and our third-party providers may also use other, related technologies to collect this information, such as web beacons, pixels, embedded scripts, location-identifying technologies and logging technologies (collectively, “cookies”).

What Do We Collect When Using Cookies?

When you interact with our websites and other online services, we and our third-party providers may use cookies to automatically collect certain types of information about your usage of our websites and other online services. For example, we may collect log data about your device and its software, such as your IP address, operating system, browser type, date/time of your visit, and other similar information. We may collect analytics or “clickstream” data or use third-party analytics tools such as Google Analytics to help us measure traffic, usage and activity trends for our websites and online services, and to better understand our user base.

Third-party providers may also collect personal data about your online activities over time and across different websites when you use our websites and online services. 

How Do We Use That Information?

We use or may use the data collected through cookies to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit our websites and online services; (b) provide and monitor the effectiveness and quality of our websites and online services; (c) monitor online usage and activities of our websites and online services; (d) diagnose errors and problems with our websites and online services; (e) otherwise plan for and enhance our websites and other online services; and (f) facilitate the purposes identified in our Privacy Statement. We and our third-party advertising providers also use the information we collect through cookies to understand your browsing activities, including across unaffiliated third-party sites, so that we can deliver personalized ads, content and information about products and services that may be of interest to you.

Please note that we may link some of the personal data we collect through cookies with the other personal data that we collect about you and for the purposes described in our Privacy Statement.

Your Choices About Cookies

If you would prefer not to accept cookies on the www.mvtrac.com site, you may adjust your Cookie Preferences.

Where available, you may adjust your cookie preferences on our other websites through similar cookie preference managers usually linked at the bottom of each website. Alternatively, most browsers allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies.  Please note that rejecting cookies may negatively impact your experience using our online services, as some features and services may not work properly.

Depending on your device and operating system, you may not be able to delete or block all cookies using your device or browser settings. In addition, if you want to reject cookies across all your browsers and devices, you will need to do so on each browser on each device you actively use.

You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and performed certain functions with it.

Many of our websites use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). For more information on the use of Google Analytics, please visit Google’s privacy policy here. You can also view Google’s currently available opt-out options here.

Your Choices About Online Ads

In addition to providing you the ability to adjust your Cookie Preferences as outlined above, we support the self-regulatory principles for online behavioral advertising (“Principles”) published by the Digital Advertising Alliance (“DAA”).

If you want to opt out of receiving online interest-based advertisements from advertisers and third parties that participate in the DAA program on mobile apps, please follow the instructions at http://www.aboutads.info/appchoices.

Please note that when you opt out of receiving interest-based advertisements, this does not mean you will no longer see advertisements from us or on our online services. It means that the online ads that you do see from DAA and NAI program participants should not be based on your interests. We are not responsible for the effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs. In addition, third parties may still use cookies to collect information about your use of our websites and online services, including for analytics and fraud prevention as well as any other purpose permitted under the DAA’s Principles and other program requirements.

Mergers or Acquisitions or Sale

We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, financing or sale of company assets. We may disclose, transfer or assign personal data to a third party during negotiation of, in connection with or as an asset in such a corporate business transaction.

Also, in the unlikely event of our bankruptcy, receivership or insolvency, your personal data may be disclosed, transferred or assigned to third parties in connection with the proceedings or disposition of our assets.

Your Choices

You may have certain choices in relation to your personal data. For more information about these choices, please refer to the Your Choices section of this Statement.

U.S. State Privacy Disclosures

If you are a resident of the State of California, Colorado, Connecticut, Nevada, Utah, or Virginia in the United States, please refer to the U.S. Residents section of this Statement for additional U.S. state-specific privacy disclosures.

Privacy Disclosures For U.S. Residents

Nevada Residents:  If you are a resident of the state of Nevada in the United States, please note Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of future sales of certain covered information that a website operator has collected or will collect about the resident. To submit such a request, please complete the form found here.

California, Colorado, Connecticut, Utah and Virginia Residents: The remainder of this section applies to individual residents of the state of California, Colorado, Connecticut, Utah, or Virginia in the United States and provides additional information about our personal data processing practices relating to such individuals. 

This section does not apply to information relating to our employees, contractors, applicants and other personnel. In addition, we often act as a “service provider” or “processor” as defined under applicable U.S. privacy law, processing personal data on behalf of our customers, and this section does not apply to the personal data processing we perform as a service provider or processor.

Collection and Use of Personal Data

Personal Data

As described in more detail in the Personal Data Collected section of our Privacy Statement, we collect the following categories of personal data:

  • Identifiers, such as full name, alias, account name and password, customer number, driver’s license number, social security number or equivalent national identification number, IP address and other unique personal identifiers;
  • Customer Records, such as address, telephone number, email address, date of birth and payment card information;
  • Protected Classification Characteristics, such as age;
  • Commercial Information, such as product or service interests and orders, credit information (if you purchased a product or other device requiring service) and investment information (if you are an investor in MVTRAC);
  • Internet/Network Information, such as log file data (including IP address, browser type) and clickstream data (including your usage and activity on our websites and online services);
  • Geolocation Data, such as general geographic location based on IP address or more precise location when accessing our services through a mobile device or using our services with geolocation capabilities;
  • Sensory Information, such as audio recordings, photographs and video footage an individual chooses to provide, or we otherwise record as permitted by law;
  • Professional/Employment Information, such as job title, company and industry;
  • Other Personal Data, such as entries to sweepstakes, contests and promotions, comments on our forums, wikis, blogs, social computing tools or in response to surveys and any other inquiries, requests or comments an individual chooses to send us;
  • Inferences, such as deriving purchase recommendations from other personal data we have collected.

We collect this personal data directly from you, from your browser or device when you interact with our websites and other online services, from third parties including our service providers, business partners, channel partners, and from public third-party platforms such as social media websites, online databases or online directories.

We collect personal data from and about you for a variety of purposes. For example, we use personal data to communicate with you; to facilitate, process and fulfill orders you place with us or the services you request; to conduct surveys, sweepstakes, contests and other promotions; to analyze and improve the use of our websites and other online services; to deliver marketing communications and personalized and non-personalized advertising; and to facilitate our customer and investor relations operations. For more information about our use of personal data, please refer to the Use of Personal Data section of our Privacy Statement.

Sensitive Information

The following personal data elements we collect may be classified as “sensitive” under certain privacy laws (“sensitive information”):

  • Account name and password;
  • Payment card information; and
  • Precise geolocation data.

As described in our Privacy Statement, we use account name and password, as well as payment card information, social security number or equivalent national identification number, to provide certain of our products and services. We also use precise geolocation data to provide our services with geolocation capabilities.

Depending on your state of residency and subject to certain legal limitations and exceptions, you may be able to limit, or withdraw your consent for, our processing of sensitive information (as described in the Your Privacy Choices section below).

Deidentified Information

We may at times receive, or process personal data to create, deidentified information that can no longer reasonably be used to infer information about, or otherwise be linked to, a particular individual or household. Where we maintain deidentified information, we will maintain and use the information in deidentified form and not attempt to reidentify the information except as required or permitted by law.

Personal Data Disclosure, Sale, and Use for Targeted Advertising

We may disclose the categories of personal data identified above to the following categories of third parties: our subsidiaries and related companies, service providers, business partners and channel partners, marketing and business strategy partners and providers, ad networks and advertising partners, analytics providers, sweepstakes and contest providers, order fulfillment and payment providers, and certain third parties where you have provided consent or where we are required by law.

Some of these disclosures of personal data may qualify as “sales” of personal data or the sharing or processing of personal data for the purpose of displaying advertisements that are selected based on personal data obtained or inferred over time from an individual’s activities across businesses or distinctly-branded websites, applications, or other services (otherwise known as “targeted advertising” or “cross-context behavioral advertising”). Depending on your state of residency and subject to certain legal limitations and exceptions, you may be able to limit or opt-out of the sale of personal data or the processing of personal data for purposes of targeted advertising (as described in the Your Privacy Choices section below).

However, we do not sell the personal data of individuals we know to be less than 16 years of age or share such information for targeted advertising purposes. In addition, we do not sell sensitive information, and we do not process or otherwise share sensitive information for the purpose of targeted advertising. Nonetheless, depending on your state of residency and subject to certain legal limitations and exceptions, you may be able to limit, or withdraw your consent for, our processing of sensitive information (as described in the Your Privacy Choices section below).

Your Privacy Choices

  • Right to Know: The right to confirm whether we are processing personal data about you and, under California law only, to obtain certain personalized details about the personal data we have collected about you, including:
    • The categories of personal data collected;
    • The categories of sources of the personal data;
    • The purposes for which the personal data were collected;
    • The categories of personal data disclosed to third parties (if any), and the categories of recipients to whom this personal data were disclosed;
    • The categories of personal data shared for targeted advertising purposes (if any), and the categories of recipients to whom the personal data were disclosed for these purposes; and
    • The categories of personal data sold (if any) and the categories of third parties to whom the personal data were sold.
  • The Right to Access & Portability: The right to obtain access to the personal data we have collected about you and, where required by law, the right to obtain a copy of the personal data in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance.
  • The Right to Correction: The right to correct inaccuracies in your personal data, taking into account the nature of the personal data and the purposes of the processing of the personal data.
  • The Right to Control Over Sensitive Information: The right to exercise control over our collection and processing of certain sensitive information.
  • The Right to Opt-Out of Targeted Advertising: The right to direct us not to use or share personal data for certain targeted advertising purposes.
  • The Right to Opt-Out of Sales: The right to direct us not to sell personal data we have collected about you to third parties.
  • The Right to Request Deletion: The right to have us delete the personal data we maintain about you.

Depending on your state of residency, you may also have the right not to receive retaliatory or discriminatory treatment in connection with a request to exercise the above rights. However, please note that the exercise of the rights described above may result in a different price, rate, or quality level of product or service where that difference is reasonably related to the impact the right has on our relationship or is otherwise permitted by law.

Submitting Privacy Rights Requests

To Exercise the Right to Know, Access, Portability, Correction, or Deletion,please submit a request specifying the right you wish to exercise by:

  • Completing our online form found here, or
  • Calling our toll-free U.S. phone number: 1-847-485-2300.

Before processing your request, we will need to verify your identity and confirm you are a resident of a state that offers the requested right(s). In order to verify your identity, we will generally either require the matching of sufficient information you provide us to the information we maintain about you in our systems, or the successful log-in to your account (if applicable). As a result, we require requests to include first and last name, email address, state of residency and data request. We may at times need to request additional personal data from you, taking into consideration our relationship with you and the sensitivity of your request.

In certain circumstances, we may decline or limit your request, particularly where we are unable to verify your identity or locate your information in our systems, or where you are not a resident of one of the eligible states.

To Exercise Opt-Out Rights in Relation to Sensitive Information, Targeted Advertising, or Personal Data Sales, please submit a request specifying the right you wish to exercise by:

  • For Non-Cookie-Based Opt-Outs:
  • Completing our online form found here, or
  • Calling our toll-free U.S. phone number: 1-847-485-2300.
  • For Cookie-Based Opt-Outs: To exercise your right to opt-out as it relates to the use of cookies and related technologies that involve the sale of personal data or the use of personal data for targeted advertising purposes on the www.mvtrac.com site, click here to open our homepage, scroll to the bottom of the page, click “Cookie Preferences” in the footer of the website, and adjust your preferences accordingly.  Where available, you may adjust your cookie preferences on our other websites through similar cookie preference managers. Please note these opt-out tools are device and browser specific, so you will need to change your preferences on each device and browser you use to interact with the specific website you are visiting. In addition, you can also opt-out of cookie-based sales by businesses that participate in the DAA’s CCPA Opt-Out Tool by visiting https://www.privacyrights.info/. Lastly, you may follow the other steps set forth in the Cookies ** section of our Privacy Statement to further exercise control over cookies and related technologies.

Where available, you may adjust your cookie preferences on our other websites through similar cookie preference managers usually linked at the bottom of each website.  Please note these opt-out tools are device and browser specific, so you will need to change your preferences on each device and browser you use to interact with the specific website you are visiting. In addition, you can also opt-out of cookie-based sales by businesses that participate in the DAA’s CCPA Opt-Out Tool by visiting https://www.privacyrights.info/. Lastly, you may follow the other steps set forth in the Cookies section of our Privacy Statement to further exercise control over cookies and related technologies.

Submitting Authorized Agent Requests

In certain circumstances, you are permitted to use an authorized agent to submit requests on your behalf through the designated methods set forth above where we can verify the authorized agent’s authority to act on your behalf. In order to verify the authorized agent’s authority, we generally require evidence of either (i) a valid power of attorney or (ii) a signed letter containing your name and contact information, the name and contact information of the authorized agent, and a statement of authorization for the request. Depending on the evidence provided and your state of residency, we may still need to separately reach out to you to confirm the authorized agent has permission to act on your behalf and to verify your identity in connection with the request.

Appealing Privacy Rights Decisions

Depending on your state of residency, you may be able to appeal a decision we have made in connection with your privacy rights request. All appeal requests should be submitted by replying to the communication resolving your original request or by calling 1-847-485-2300.

California Notice of Financial Incentives

The following disclosures only apply to residents of the State of California.

We may choose to provide programs and other offerings intended to provide benefits to eligible participants that qualify as financial incentives under certain privacy laws. For example, the financial incentives we may choose to make available to interested individuals may include promotional materials or opportunities to obtain sweepstakes and contest prizes.

To obtain access to certain of these programs and other offerings, we may ask to collect or share an interested individual’s personal data, including name, contact information, and purchase history. We have determined that the value of any of these programs and other offerings are reasonably related to the value of the personal data we would receive and otherwise process in connection with these programs and offerings, based on our reasonable but sole determination. We estimate the value of the personal data we would receive and otherwise process in connection with these programs and offerings by considering the expense we would incur in collecting and processing the personal data, as well as the expenses related to facilitating the program or offering.

The terms applicable to each program and other offering will be provided at the time an eligible individual is offered an opportunity to participate. Interested individuals can opt-in to these financial incentives by following the instructions presented at the time the offer is made. Participating individuals may withdraw from our programs and other offerings at any time by following the instructions provided in connection with each offering or emailing us at privacy1@motorolasolutions.com.

Social Computing Tools

We also provide social computing tools on some of our websites to enable online sharing and collaboration among members who have registered to use them. These include forums, wikis, blogs and other social media platforms.

When registering to use these social computing tools, you may be asked to provide certain personal data. Registration information will be subject to this Privacy Statement.

After completing your registration, any other content you voluntarily post, such as pictures, information, opinions, or any other type of personal data that you make available to other participants on these social platforms may be made available to others inside and outside MVTRAC.

If you do not wish this information to be made broadly available you can cancel your registration at any time. However, you may not be able to participate on these social platforms once you cancel your registration and any information already posted will continue to be made available through these platforms.

Information Security

What about information security?

When you place an order or provide personal data, we employ certain technical and organization security measures, such as encryption where appropriate. Encryption scrambles the information in your purchase, including your credit card number, so this information can only be viewed by MVTRAC. MVTRAC currently uses Secure Socket Layer (SSL) encryption technology, where appropriate, for Internet-based transactions.

However, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we have taken appropriate steps to protect your personal data, MVTRAC cannot ensure or otherwise warrant the security of any information you provide to us or from our website, and therefore you use our site at your own risk.

Retention

For how long will MVTRAC keep my personal data?

We apply a general rule of keeping personal data only for as long as is reasonably necessary to fulfill the purposes for which it was collected.

However, if necessary, we may retain personal data for longer periods of time, until set retention periods and deadlines expire, for instance where we are required to do so in accordance with legal, tax and accounting requirements, set by a legislator, regulator or supervisory authorities. In specific circumstances we may retain your personal data until the statutory limitation periods have expired (usually three years, but up to thirty years in some cases), when this is necessary for the establishment, exercise or defense of legal claims.

To determine the appropriate duration of the retention of personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of personal data and if we can attain our objectives by other means, as well as our legal, regulatory, tax, accounting and other applicable obligations.

When we have no ongoing legitimate business need to process your personal data, we will either delete, deidentify, or anonymize it or, if this is not possible (for example, because your personal data has been stored in backup archives), then we will securely store your personal data and isolate it from any further processing until deletion, deidentification, or anonymization is possible.

Children’s Privacy

What about my child’s privacy?

Websites and other online services operated by or on behalf of MVTRAC, Inc. and its world-wide affiliated companies and subsidiaries are not intended for use by persons under the age of 13. We do not seek to or knowingly collect or solicit information about children under the age of 13. No information should be submitted to or posted on our websites or other online services by users under 13 years of age. If a child under the age of 13 provides personal data to us, we encourage the child’s parent or guardian to contact us to request that we remove the personal data from our systems. If we learn that any personal data we collect has been provided by a child under the age of 13, we will promptly delete the information.

Updates to this Privacy Statement

We will update this Privacy Statement from time to time. When we make changes to this Privacy Statement, we will change the “Last Updated” date at the beginning of this Privacy Statement. If we make material changes to this Privacy Statement, we will notify you by prominent posting on our website or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided in the notification. 

How To Contact Us

If you have other questions, comments or concerns about our privacy practices please contact our Privacy Office at privacy1@motorolasolutions.com or at the address below. If you wish to issue a request to exercise your rights where applicable by law please complete the U.S. form found here.