Privacy Policy

Last Updated: [October 15, 2015]

Trax Technology Solutions PTE Ltd. (“Trax“, “we“, “our” or “us“) develops and provides advanced computer vision and deep learning solutions for in-store optimization, shelf strategy and retail management (the “Platform“).

Our Platform, our website available at (the “Site“) and the Trax mobile application (the “App“, and together with the Site and Platform – the “Services“) allow manufacturers and retailers (each, our “Customer“) to easily photograph and upload in-store or in-venue images of product shelves, and analyze such images to optimize their product planning, marketing, distribution and sales.

We are strongly committed to making our Privacy practices more transparent and fair. This Privacy Notice describes how we collect, store, use and disclose personal data regarding individuals who visit our Site (“Visitors“), install our App or use our Platform on behalf of a Customer (“Users” or “you“), and our role as “Data Processor” of such Users’ data. It applies whenever you visit our Services or use our Platform, interact with us or otherwise access or use any of our Services.

Specifically, it describes our practices regarding –

  1. Data Collection
  2. Data Uses
  3. Data Location and Retention
  4. Data Sharing
  5. Cookies, Tracking and Advertising Uses
  6. Communications
  7. Data Security
  8. Data Subject Rights
  9. Children
  10. Data Controller/Processor
  11. Updates & How to contact us


Please read this Notice and make sure that you fully understand and agree to it.
If you do not agree to this Notice, please discontinue and avoid using our Services.

You are not legally required to provide us with any Personal Data (defined below), but without it we will not be able to provide you with the full range or with the best experience when using our Services.

Data Collection

We collect Personal Data regarding our Users as well as data regarding Visitors to our Site. Such data is typically collected and generated through the Visitor’s or User’s interaction with our Services, through automatic means or directly from our Customers or such Visitor or User.

Specifically, we collect the following main categories of data (which, if it could be used to identify a specific person, or is linked to such identifying data, we will deem it as “Personal Data“):


  1. Data automatically collected or generated: when one visits, interacts with or uses our Services, we may collect or generate certain technical data about him/her. We collect or generate such data either independently or with the help of third party services (as detailed in Section 4 below), including through the use of “cookies” and other tracking technologies (as further detailed in Section 5 below).

Such data mainly consists of connectivity, technical and aggregated usage data, such as IP addresses, non-identifying data regarding a device, operating system, browser version, locale and language settings used, the cookies and pixels installed on such device and the activity (clicks and other interactions) of Visitors and Users in connection with our Services. We do not use such data to learn a person’s true identity or contact details, but mostly to have a better understanding on how Users typically use our Services and how we could improve their user experience, to optimize our marketing campaigns and ad management, and the overall performance of our Services.


  1. Data received from you: you may provide us Personal Data such as your name, workplace and position, contact details (such as e-mail, phone and address), account login details (such as usernames and hashed passwords) (collectively, “Account Data“), as well as any other data you choose to provide when you use our Services, create a user account or contact us.
    Customers may provide us additional Account Data such as their billing details, business needs and preferences. To the extent that such Account Data concerns a non-human entity (e.g., the bank account of a company or business), we will not regard it as “Personal Data” and this Notice shall not apply to it.


  1. Data received from our Customers: Customers may also provide us with data concerning their Users, in order to enroll such Users to our Services. Such data usually refers to the Users’ first names/nicknames and work e-mails, however additional data may be provided at the Customer’s discretion.


  1. Data in Photographs: Users may use the App in order to photograph and upload images, namely images of in-store or in-venue shelves holding stock and products. All Users are instructed to only submit to us photogrpahs which do not in any way contain any Personal Data of any individuals whatsoever.

Data Uses

We use Personal Data as necessary for the performance of our Services; for complying with applicable law; and based on our legitimate interests in maintaining and improving our Services and offerings, understanding how our Services are used, optimizing our marketing, customer service and support operations, and protecting and securing our Users, ourselves and our Services.

Specifically, we use Personal Data for the following purposes:

  1. To facilitate, operate, and provide our Services;
  2. To authenticate the identity of our Users, and to allow them access to our Services;
  3. To provide our Visitors and Users with assistance and support;
  4. To further develop, customize and improve the Services and your user experience, based on common or personal preferences, experiences and difficulties;
  5. To contact our Visitors, our Users, with general or personalized service-related messages (such as password-retrieval or billing); to contact our Visitors, Users with promotional messages (such as newsletters, webinars, new features etc.); and to facilitate, sponsor and offer certain events and promotions;
  6. To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal or prohibited activity;
  7. To create aggregated statistical data, inferred non-personal data or anonymized or pseudonymized data (rendered non-personal), which we or our business partners may use to provide and improve our respective services; and
  8. To comply with any applicable laws and regulations.

Data Location & Retention

Data Location: Your Personal Data may be maintained, processed and stored by Trax and our authorized affiliates and Service Providers in the United States of America and other jurisdictions, as necessary for the proper delivery of our Services, or as may be required by law.

Trax is based in a jurisdiction which is considered by the European Commission to be offering an adequate level of protection for the Personal Data of EU Member State residents.

Trax’s U.S. subsidiary materially adheres to the principles of the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks, and is currently in the process of self-certifying its U.S. entity with such Frameworks. All Personal data received from European Union (EU) member countries and Switzerland will be processed in reliance on the applicable Privacy Shield Framework and in accordance with the Framework’s applicable principles. To learn more about the Privacy Shield Framework, please visit

While privacy laws may vary between jurisdictions, Trax, its affiliates and Service Providers are each committed to protect Personal Data in accordance with this Notice and industry standards, regardless of any lesser legal requirements that may apply in their jurisdiction.

Data Retention: We keep Users’ Personal Data for as long as their Customer’s agreement with us is in effect, or for as long as their account is active or we consider necessary for the purposes described in this Notice.
We keep Visitor Personal Data for as long as we reasonably need it in order to maintain and expand our relationship further and to provide them with our Services.

We will also keep and use such Personal Data for as long as is required in order to comply with our legal and contractual obligations, or to protect ourselves from any potential disputes (i.e., as required by laws applicable to records and bookkeeping, as necessary for allowing the Users you engaged with via our Services to meet their own obligations or legitimate needs, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), in accordance with our data retention policy. If you have any questions about our data retention policy, please contact us at


Legal Compliance: We may disclose or allow government and law enforcement officials access to Personal Data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations. Such disclosure or access may occur if we believe in good faith that we are legally compelled to do so, or that disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing.

Service Providers: We may engage selected third party companies and individuals to perform services complementary to our own (e.g. hosting services, data analytics services, marketing and advertising services, data and cyber security services, payment processing services, user engagement services, e-mail distribution and monitoring services, session recording, and our business, legal and financial advisors) (collectively, “Service Providers“). These Service Providers may have access to your Personal Data, depending on each of their specific roles and purposes in facilitating and enhancing our Services, and may only use it for such purposes.

Sharing Users Personal Data with our Customer: We may share the Personal Data of Users with their Customer organization (including data and communications concerning their Services user account). In such cases, sharing such data means that other individuals from your organization may receive it on its behalf, and will be able to monitor, process and analyze your Personal Data and associated content. Please note that Trax is not responsible for and does not control any further disclosure, use or monitoring by or on behalf of your organization, who is the “Data Controller” of such data (as further described in Section 10 below).

Protecting Rights and Safety: We may share your Personal Data with others if we believe in good faith that this will help protect the rights, property or personal safety of Trax, any of our Users or any members of the general public.

Trax Subsidiaries and Affiliated Companies: We may share Personal Data internally within our group for the purposes described in this Notice. In addition, should Trax or any of its affiliates undergo any change in control, including by means of merger, acquisition or purchase of substantially all of its assets, your Personal Data may be shared with the parties involved in such event. If we believe that such change in control might materially affect your Personal Data then stored with us, we will notify you of this event and the choices you may have via e-mail or prominent notice on our Services.

For the avoidance of doubt, Trax may share your Personal Data in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so, or if we have successfully rendered such data non-personal and anonymous. We may transfer, share or otherwise use non-personal data at our sole discretion and without the need for further approval.

Cookies and Tracking Technology

Our Services and some of our Service Providers utilize “cookies”, anonymous identifiers and other tracking technologies which help us provide, secure and improve our Services, personalize your experience and monitor the performance of our activities and campaigns. A “cookie” is a small text file that is used, for example, to collect data about activity on our Site. Some cookies and other technologies serve to recall Personal Data, such as an IP address, previously indicated by the User.

A list of the cookies we use can be found here.

__utma – Google Analytics – – Website Analytics
__utmb – Google Analytics – – Website Analytics
__utmc – Google Analytics – – Website Analytics
__utmt – Google Analytics – – Website Analytics
__utmz – Google Analytics – – Website Analytics
_ga – Google Analytics – – Website Analytics
_vwo_uuid_v2 – Wingify – – A/B Testing and Conversion Optimization
wordpress_test_cookie – Trax – Inhouse
__cfduid – Cloudflare – – Website Caching

How to adjust your preferences regarding cookies and interest-based advertising

While we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser, most browsers allow you to control cookies, including whether or not to accept them and to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser.

If you wish to prevent the use of your mobile device’s advertising ID, you may change your device settings to reset such advertising ID (typically, this is available under the “Privacy” or “Ads” section in your device settings). You may also change your browser settings to reset or block cookies (typically, this is available under the “Settings” or “Help” section in your browser menu).


Service Communications: we may contact you with important information regarding our Services. For example, we may notify you (through any of the means available to us) of changes or updates to our Services, billing issues, service changes, password-retrieval notices, etc. You will not be able to opt-out of receiving such service communications.

Notifications and Promotional Communications: we may send you notifications concerning messages and other updates in your user account. We may also send you notifications about new features, offerings, events and special opportunities or any other information we think our Users will find valuable. We may provide such notices through any of the contact means available to us (e.g. phone, mobile or e-mail), through the Services, or through our marketing campaigns on any other sites or platforms.

If you wish not to receive such promotional communications, you may notify Trax at any time by e-mailing us at or by following the “unsubscribe”, “stop” or “change e-mail preferences” instructions contained in the promotional communications you receive.

Data Security

In order to protect your Personal Data held with us and our Service Providers, we are using industry-standard physical, procedural and electronic security measures. However, please be aware that regardless of any security measures used, we cannot and do not guarantee the absolute protection and security of any Personal Data stored with us or with any third parties as described in Section 4 above.

Data Subject Rights

If you wish to exercise your rights under applicable law (e.g. the EU GDPR) to request access to and rectification or erasure of your Personal Data held with Trax, or to port such Personal Data – please contact us at

Please note that once you contact us by e-mail, we may require additional information and documents, including certain Personal Data, in order to authenticate and validate your identity and to process your request. Such additional data will be then retained by us for legal purposes (e.g. so we have proof of the identity of the person submitting the request), in accordance with Section 3 above.


Our Services are not designed to attract children under the age of 16. We do not knowingly collect Personal Data from children and do not wish to do so. If we learn that a child is using the Services, we will prohibit and block such use and will make all efforts to promptly delete any Personal Data stored with us with regard to such child.

If you believe that we might have any such data, please contact us at

Data Controller/Processor

Certain data protection laws and regulations, such as the EU General Data Protection Regulation (GDPR), typically distinguish between two main roles for parties processing Personal Data: the “Data Controller”, which determines the purposes and means of processing, and the “Data Processor”, which processes the data on behalf of the Data Controller. Below we explain how these roles apply to our Services, to the extent that such laws and regulations apply.

Trax is the “Data Controller” of its Visitors’ Personal Data, and with respect to which assumes the responsibilities of Data Controller (solely to the extent applicable under law), as set forth under this Notice.

If a Customer submits any Personal Data concerning any of its Users, or otherwise has any of its Users submit or upload Personal Data in connection with our Services, such Customer shall be deemed the “Data Controller” of its Users’ data, and we will only process such data on our Customer’s behalf, as its “Data Processor”. This means that in such cases, we will only process such Users’ data on behalf of our Customer and in accordance with its reasonable instructions, subject to our Terms of Service and other commercial agreements. The Customer will be solely responsible for meeting any legal requirements applicable to Data Controllers (such as establishing a legal basis for processing and responding to Data Subject Rights requests concerning the data they control).

If you are a User of any of our Customers, please note that Trax only processes your data solely on such Customer’s behalf. If a User would like to make any requests or queries regarding their Personal Data, he/she should contact such Customer directly. For example, if you are a User who wishes to access, correct, or delete data processed by Trax on behalf of its Customer, please direct your request to the relevant Customer (who is the “Data Controller” of such data). If requested to remove any User’s Personal Data, we will respond to such request within thirty (30) days. Unless otherwise instructed by our Customer, we will retain their Users’ Personal Data for the period set forth in Section 3 above.

Additional Notes

Updates and Amendments: We may update and amend this Notice from time to time by posting an amended version on our Site and App. The amended version will be effective as of the date it is so published. We will provide a 10-day prior notice if any substantial changes are involved via any of the communication means available to us or via the Services. After such notice period, all amendments shall be deemed accepted by you.

External links: While our Services may contain links to other websites or services, we are not responsible for their privacy practices, and encourage you to pay attention when you leave our Services and to read the privacy notices of each and every website and service you visit. This Notice applies only to our Services.

Questions, Concerns or Complaints: If you have any comments or questions about this Notice or if you have any concerns regarding your privacy, please contact us at Trax’s appointed Data Protection Officer may be reached at

Trax Retail Ltd. has been designated as Trax’s representative in the European Union for data protection matters, pursuant to Article 27 of the GDPR. Trax Retail Ltd. can be contacted only on matters related to the processing of Personal Data. To make such an inquiry, please contact If you are a GDPR-protected individual, you also have the right to lodge a complaint with an EU supervisory authority.