Privacy Policy

Version: September 29, 2022 | You may contact us for previous versions of the Privacy Policy.

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Track160 Ltd. (“Track”, “we”, “our” or “us”), offers its users (“User”, “you”, or “your”) an online application (“App”) enabling You to receive Your performance video recording and statistical information as gathered by Track160 in accordance with the agreement between Track160 and the club to which you are registered or assigned (the “Club”, and “Agreement” respectively). This privacy policy (“Privacy Policy”) governs and is intended to describe our practices regarding the information (including Personal Information as defined below) that we may collect from you when You use or access our App and/or our website(s) available at https://www.track160.com/ and any other website that we operate (each, together with its sub-domains, content and services, a “Site”), the ways in which we may use such information, and the choices and rights available to You.

This Privacy Policy supplements and shall be read in conjunction with our End-User Terms and Conditions (collectively referred to herein as the “Terms”) available at https://www.track160.com/terms-and-conditions, which you accepted prior to accessing and using the App. This Privacy Policy may be supplemented by additional privacy statements, terms or notices provided to you. Capitalized terms which are not defined herein, shall have the meaning ascribed to them in our Terms.

If you have any question regarding your Personal Information collected and/or processed by Track160 as part of the Agreement (“Club Data”) - please approach the Club, who can assist you with the question and rights you might have with respect to such Personal Information.

 

​1. Consent and Modification. You are not legally obligated to provide us Personal Information while using the App and/or the Site, and you hereby confirm that providing us with such Personal Information is at your own free will. By using the App and/or the Site, you consent to the terms of this Privacy Policy and to our collection, processing and sharing of Personal Information for the purposes set forth herein. If you do not agree to this Privacy Policy, please do not access or otherwise use the App and/or the Site. We reserve the right, at our discretion, to change this Privacy Policy at any time. Such change will be effective ten (10) days following posting of the revised Privacy Policy on the App and/or the Site, and your continued use of the App and/or the Site thereafter means that you accept those changes.

1. Non-Personal Information: “Non-Personal Information” is un-identified and non-identifiable information pertaining to You, which may be made available to us, or collected automatically via your use of the App and/or the Site which does not enable us to identify the person from whom it was collected. This mainly consists of technical and aggregated non-identifiable, such as the type of operating system you use, type of browser you use, your screen resolution, your browser and keyboard language. In addition, we may collect certain behavioural non personal information regarding your use of the App and/ the Site, which may include your session recordings, “click stream” activity, etc.

2. Personal Information: “Personal Information” is information that identifies an individual or may with reasonable efforts or together with additional information we have access to, enable the identification of an individual, or may be of a private or sensitive nature relating to an identified or identifiable natural person. Identification of an individual also includes the association of such individual with a persistent identifier such as a name, an identification number, persistent cookie identifier etc. Over the course of your use of the App and/or Site Personal Information we collect about You may include the following: your full name, IP address, phone number, email address, addresses, phone number, your Club name, organization name, Candidates Information (as defined below), your password, and certain information you may share with us in your own volition when contacting us via the App and/or Site. Personal Information does not include information that has been anonymized or aggregated and can no longer be used to identify a specific natural person.

 

2. How We Collect Information from You. We receive and/or collect information from You in the following ways:

1. Information we receive when you use the App and/or the Site. When you use the App and/or the Site, we may collect the certain Personal Information about You.

2. Account. In order to use our App, the Club will create for You, or you will be required to create an account (“Account”). If you create an Account, you will be required to provide us with certain information, such as your name, email address, Club name, phone number as well as a password that you will use for your Account. In addition, following the setup of your Account, we may collect information regarding your use of the Account and the App. 

3. “Request a demo” Information. If you send us a “Request a demo” request, whether by submitting an online form that we make available or by sending an email to an email address that we display, you may be required to provide us with certain information such as your name, organization name and email address.

4. Through integrations with certain third-party services. We may collect Personal Information through integrations with third party service providers.

5. Log Files. We may make use of log files. The information inside the log files includes internet protocol (IP) addresses, type of browser, Internet Service Provider (ISP), date/time stamp, referring/exit pages, clicked pages and any other information your browser may send to us. We may use such information to analyze trends, administer the App and/or the Site, track users’ movement around the App and/or the Site, and gather demographic information.

6. Candidates. We may use a Candidate’s (as defined below) Candidate Information (as defined below) solely for our internal recruitment purposes (including for identifying Candidates, evaluating their applications, making hiring and employment decisions, and contacting Candidates by phone or in writing).

7. Usage Data. We may store certain data and analytics information in connection with the routine operation of the App and/or Site, including, language information, connectivity information, configuration information and usage data, and/or technical, statistical and aggregated data resulting from the use of the App and/or Site.

8. Personal information collected from other sources. We may collect personal information concerning you, from third parties who have assured us that they have obtained your consent for such provision of information (including without limitation the Club).

We do not collect any Personal Information from you or related to you without your approval which is obtained, inter alia, through your active acceptance of this Privacy Policy or pursuant to the approvals provided to us by your Club (including on your behalf). We may also obtain, process and/or have access to personal information which is made available to us by the Club as part of the Club’s use of our products and/or services, who have assured us it has the rights to do so. Our access and use of any such Personal Information is governed by the Agreement between us and the Club

3. Why do we collect and process your Information.

1. To provide and operate the App and/or Site and related services (including under the Agreement).

2. To allow users to access to certain components or features of our Site and/or App or related services.

3. To be able to deliver and enhance the App and/or Site, and to provide You with technical assistance and support.

4. To respond to a “Contact Us” or an administrative request (for example, to change your password).

5. To send you updates, notices, notifications, newsletters, and additional information related to the App and/or Site.

6. To create cumulative statistical data and other cumulative information that is non-personal, with which we and/or our business partners might make use in order to operate and improve the App and/or Site and offer related products.

7. To identify and authenticate your access to the App and/or Site (or any part thereof) which you are authorized to access.

8. To comply with any applicable rule or regulation and/or response or defend against legal proceedings versus us or our affiliates.

 

4. What are our legal grounds for collecting and processing your Personal Information?

1. With your Consent. We ask for you consent, (which may be given directly to Company or through consent obtained from the Club), to collect and process your information for the purposes stated in this Privacy Policy.

2. Providing the Requested Services. We collect Personal Information to provide our users and customers with the App and/or the Site and the access to the services available through our App and/or the Site.

3. Legitimate Interests. We process your information for our legitimate interests while applying appropriate safeguards that protect your privacy. This means that we process your information for purposes like detecting, preventing or otherwise addressing fraud, abuse, security, usability, functionality or technical issues with our App and/or Site; protecting against harm to the rights, property or safety of our App and/or Site, our users or the public as required or permitted by law; enforcing legal claims, including investigation of potential violations of this Privacy Policy; and in order to comply and/or fulfil our obligations under applicable laws, regulation, guidelines, industry standards and contractual requirements, legal process, subpoena or governmental request.

 

5. The Way We Share Personal Information. We may share and/or transfer your Personal Information in the following ways and for the following purposes (please note that for the purpose of this Section ‎5, any transfer of Personal Information facilitated by the user shall not be deemed a transfer to third parties by Track and such transfer is made on the users sole volition and consent):

1. Internally – We may share information with our family companies, as well as our employees, for the purposes described in this Privacy Policy and in accordance with Section ‎2 above. In addition, should We or any of our affiliates undergo any change in control, including by means of merger, acquisition or purchase of substantially all of its assets, your information may be shared with the parties involved in such event under strict security conditions, for the purpose of evaluating such event and in accordance with the terms of this Privacy Policy. If we believe that such change in control might materially affect your Personal Information then stored with us, we will notify you of this event and the choices you may have, through prominent notice on the App and/or Site.

2. Protecting Our Rights and Safety – We may share your information to enforce this Privacy Policy and/or the End-User Terms and Conditions, including investigation of potential violations thereof; to detect, prevent, or otherwise address fraud, security or technical issues; or otherwise, if we believe in good faith that this will help protect the rights, property or personal safety of any of our users, customers, or any member of the general public.

3. Third Parties & Business Partners – We may share your information with a number of selected service providers, whose services and solutions are required or otherwise facilitate achievement of the purposes of processing set forth under Section ‎1 above. These third parties serve in facilitating and enhancing our Site and/or App and related services, namely, to allow cloud hosting of the App and/or Site (e.g. AWS, Dropbox), for analytics purposes (e.g., Google Analytics and Prometheus), for website technology facilitation (such as Wix,  and Cloudflare), for development Services (e.g., ThinkSys) and for communication and support services (such as Mandrill, Mailchimp, HubSpot, Anydesk and Babcom). Our third-party service providers act as our sub-processors and may only process your information according to our instructions (which are given in accordance with the terms hereof). We remain responsible for any processing of your information done by such third-party service providers on our behalf not in accordance with the terms hereof, except for events outside of such service providers’ reasonable control.

4. Law Enforcement – We may cooperate with government and law enforcement officials to enforce and comply with the law. We may therefore disclose any information to government or law enforcement officials as we believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect our or a third party’s property and legal rights, to protect the safety of the public or any person, or to prevent or stop any activity we may consider to be, or to pose a risk of being, illegal, unethical, inappropriate or legally actionable.

Specifically, each of our service providers which store or process your Personal Information either: (i) assured us that they provide adequate safeguards to protect your rights to privacy including where applicable, by undertaking to comply with the EU Standard Contractual Clauses; (ii) where applicable, hold and process such information on our behalf in jurisdictions which have been determined to ensure an adequate level protection by the EU Commission; (iii) perform such processing pursuant to your consent and acceptance of their privacy policy as further detailed in this Privacy Policy.  

For avoidance of doubt, we may share anonymized/de-identified information with any other third party, at our sole discretion.

 

6. Where do we store your Personal Information.

Your information may be transferred to, maintained, processed and stored by us and our authorized affiliates and service providers in Europe, US and/or Australia in secured cloud storage, provided by our third-party service provider. While the data protection laws in the above jurisdictions may be different than the laws of your residence or location, please know that we, our affiliates and our service providers that store or process your Personal Information on our behalf are each committed to keep it protected and secured, pursuant to this Privacy Policy and industry standards, regardless of any lesser legal requirements that may apply in their jurisdiction.

You hereby accept the place of storage and the transfer of information as described above.

GDPR (EEA Users): This section applies only to natural persons residing in the European Economic Area (for the purpose of this section only, "you" or "your" shall be limited accordingly). It is our policy to comply with the EEA's General Data Protection Regulation (“GDPR”). In accordance with the GDPR, we may transfer your Personal Information from your home country to Israel, the U.S. and/or other countries, provided that the transferee has provided appropriate safeguards, and on condition that enforceable data subject rights and effective legal remedies for data subjects are available. Specifically, we may cause such transfer if we ensured that at least one of the following applies:

• The country to which Personal Information has been transferred, has been determined by the EU Commission to be a country providing adequate protection to the privacy rights of EU residents.

• Application of Standard Contractual Clauses (also known as "Model Clauses") where appropriate.

You have additional rights regarding your personal data under the GDPR, please refer to Section 8 below.

 

7. Your Rights.

If applicable to you under your country’s jurisdiction, you may have certain rights in connection with your Personal Information and how we handle it. You can exercise your rights at any time by contacting us via any of the methods set out below. Those rights may include, but are not limited to, the following:

1. Right of access. You may have a right to know what information we hold about you and, in some cases, to have the information communicated to you. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any information.

2. Right to correct Personal Information. We endeavour to keep the information that we hold about you accurate and up to date. Should you realize that any of the information that we hold about you is incorrect, please let us know and we will correct it as soon as we can.

3. Data deletion. In some circumstances you may have a right to request that some portions of the Personal Information that we hold about you be deleted or otherwise anonymized.

4. Data portability. In some circumstances, you may have the right to request that data which you have provided to us is provided to you, so you can transfer this to another data controller.

5. Restriction of processing. In some cases, you may have the right to request a restriction of the processing of your Personal Information, such as when you are disputing the accuracy of your information held by us.

Please Note: Company is merely acting as a processor of your certain Personal Information on behalf of the Club (pursuant to the Agreement between Company and the Club). As such, if you are using of our App and/or any related services, you should contact your Club in order to enforce any of the rights listed in this section ‎7 above with respect to your Personal Information that has been made available to us as part of Club Data.

To find out whether these rights apply to you and on any other privacy related matter, you can contact your local data protection authority if you have concerns regarding your rights under local law.

 

8. Use of Anonymous Information. We may use Anonymous Information (as defined below) or disclose it to third party service providers in order to improve our App and/or Site and enhance your experience with such. We may also disclose Anonymous Information (with or without compensation) to third parties, including advertisers and partners. “Anonymous Information” means information which does not enable identification of an individual user, such as aggregated information about the use of our App and/or Site.

 

9. Cookies and Other Tracking Technologies.

1. What are cookies and similar technologies?

   1. Cookies are small text files that are stored on your device to help websites and mobile apps remember things about you. Session-based cookies last only while your browser is open and are automatically deleted when you close your browser. Persistent cookies last until you or your browser delete them or until they expire. To learn more about cookies, visit http://www.allaboutcookies.org/.

   2. Pixel Tags (also known as web beacons or clear GIFs) are transparent images, iFrames, or JavaScript placed on a website or in marketing emails that are used in order to understand how you interact with such websites or emails.

   3. Social Media Features, such as the Facebook “like” button, may collect your IP address and which page you are visiting on a website, and may set a cookie to enable the feature to function properly. Your interactions with these features are governed by the privacy policy of the company providing the relevant Social Media Features.

   4. Single Sign-on allows you to log in to certain websites or mobile applications using sign-in services provided by third parties, such as Facebook or Google. These services will authenticate your identity and provide you the option to share certain personal information with us such as your name and email address to pre-populate our sign-up form.

   5. Ad ID is a unique number issued to you by an entity which received your permission to serve you with advertisements. The Ad ID allows persons or entities with whom you interact to gather and store information they learn about you in connection with your Ad ID. Most entities that have assigned you with an Ad ID allow you to delete or change such Ad ID and thereby prevent third parties from collecting information concerning your behaviour across multiple sessions. To learn more about Ad ID and how change or delete it on Android and Apple, please refer to https://www.androidguys.com/tips-tools/how-to-disable-personalized-ads-on-android/ and https://support.apple.com/en-il/HT205223.

2. Our Site may utilize “cookies”, anonymous identifiers and other tracking technologies in order to for us to provide our Site and related services and present you with information that is customized for you. A “cookie” is a small text file that may be used, for example, to collect information about activity on the Site. Certain cookies and other technologies may serve to recall Personal Information, such as an IP address, previously indicated by a user. Most browsers allow you to control cookies, including whether or not to accept them and how 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.

3. Such cookies are placed on our Site and/or App or our advertisements and emails, that are used to understand how you interact with the Site and/or App, with such advertisements and emails. It is important to note that some of these tracking technologies are provided to us by our services providers who collect and process personal information in the scope of the services that they provide us.

4. How we use Cookies? The cookies we use can be classified in one of the following categories:

   1. Strictly necessary cookies - We use these cookies to enable you to use our Site’s and/or App’s features, such as enabling movement between pages and remembering information you enter on forms. Without these necessary cookies, services and functions on our Site and/or App will not be possible and our Site and/or App will not perform as it should.

   2. Security cookies - We use these cookies to help identity and prevent security risks.

   3. Performance and Analytics cookies - We use these cookies to collect information about Users’ use of our Site and/or App to help improve the way it works.

   4. Functionality and Preference cookies - We use these cookies to remember the choices you make such as which language you prefer and to provide you with personalized features.

5. What cookies we use? We use the following First and Third-Party Cookies:

Cookie Name: Google - Analytics

          Type: 3rd P.

          Purpose / Functionality / Policies & Links: Google provides anonymized data about the visits made to our Site and/or App. https://policies.google.com/privacy?hl=en&gl=uk

          Cookie Name: Hubspot

          Type: 3rd P.
          Purpose / Functionality / Policies & Links: Hubspot provides data about the visits made to our site: https://legal.hubspot.com/cookie-policy

​

          Cookie Name: Wix

          Type: 3rd P.

          Purpose / Functionality / Policies & Links: Wix provides us with certain data regarding our Site its use.

https://www.wix.com/about/privacy

6. Your choices.

1. Strictly Necessary Cookies - Because these cookies are essential to operate our Site and/or App, there is no option to opt out of these cookies.

2. Other Cookies - You can follow the instructions provided by your web browser or mobile browser (usually located within the "Help", "Tools" or "Edit" facility) to modify your cookie and Ad ID settings.

3. You can opt out of third-party tracking technologies by following the instructions provided by each third-party service provider in its privacy policy.

7. Deletion of Cookie history. You can choose to delete your cookie history and to opt-out from future usage of cookies by Track, by emailing us at info@track160.com. Your request to delete your cookies shall take effect within a reasonable timeframe from receipt of your request.

8. Do Not Track. We cannot currently ensure responding to your browsers’ ‘Do Not Track’ signals with respect to our Site and/or App, in part, because no common industry standard for ‘Do Not Track’ has been adopted by regulators, including no consistent standard of interpreting a user’s intent. We are committed to monitoring the developments around ‘Do Not Track’ and the implementation of a standard.

9. The Site may use a tool called “Google Analytics” to collect information about use of the Site. Google Analytics collects information such as how often users visit the Site, what pages they visit when they do so, and what other sites they used prior to coming to the Site and/or App. We use the information we get from Google Analytics to maintain and improve the Site and our services or products. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to and use of the Site is restricted by the Google Analytics Terms of Services, available at: http://www.google.com/analytics/terms/us.html, and the Google Privacy Policy, available at http://www.google.com/policies/privacy/. You may learn more about how Google collects and processes data specifically in connection with Google Analytics at http://www.google.com/policies/privacy/partners/. You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/.Please note – in certain cases such services providers may collect and process personal information, in a scope which is broader than the scope of collection and processing required for the purposes set forth above. This means that sometimes these services providers have access to more of your personal information than we do. In such cases, all such excess collections and processing are performed pursuant to and under a direct contractual relationship you have with such service providers, as detailed below and any rights you may have with respect to such information, collected by such services providers, shall be governed by such contractual relationship. Otherwise, the terms of this Privacy Policy shall fully apply

 

10. Opting Out. You may choose not to receive future promotional, advertising, or other App and/or Site - related emails from us by not subscribing or later by selecting an unsubscribe link at the bottom of each email that we send. Please note that even if you opt out of receiving the foregoing emails, we may still send you a response to your requests (such as, without limitation “Request a Demo”) as well as administrative emails (for example, in connection with a password reset request) that are necessary to facilitate your use of the App and/or Site.

 

11. Data Retention. We will retain your Personal Information only for as long as necessary to achieve the purposes for collection and processing set forth above. Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time. If you withdraw your consent to our processing your Personal Information, we will delete your Personal Information from our systems (except to the extent retaining such data in whole or in part is necessary to comply with any applicable rule or regulation and/or to respond to or defend against legal proceedings brought against us or our affiliates).

Please Note: If your Personal Information has been made available to us as part of Club Data on behalf of your Club (anyd of such pursuant to the Agreement), the retention of your Personal Information will be in accordance with the terms stated in the Agreement and you should contact your Club in order to request the deletion of your Personal Information and/or any part thereof.

 

12. Choice. At all times, you may choose whether or not to directly provide or disclose Personal Information to us. If you choose not to provide mandatory Personal Information, you may still visit parts of the Site, but you may be unable to access the App and/or other certain options, programs, offers, and services that involve our interaction with you.

 

13. Access/Accuracy. To the extent that you do provide us with Personal Information, we wish to maintain accurate Personal Information. If you would like to delete or correct any of your other Personal Information that we may be storing, you may use the tools that we make available on the App and/or Site or submit an access request by sending an email to info@track160.com. Your email should include adequate details of your request.

Please Note: If your Personal Information has been made available to us as part of Club Data on behalf of your Club (any of such pursuant to the Agreement), you should contact your Club in order to request to delete or correct your Personal Information and/or any part thereof.

 

14. Links to and Interaction with Third Party Products. The App and/or Site may enable you to interact with or contain links to third party websites, mobile software applications and services that are not owned or controlled by us (each, a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third-Party Services. Please be aware that Third-Party Services may collect Personal Information from you. Accordingly, we encourage you to read the terms and conditions and privacy policy of each Third-Party Service that you choose to use or interact with.

 

15. Minors.

1. The Site is not intended for users under the age of 18 years. If we learn that we have collected Personal Information from a user under 18 years, we will delete that information as quickly as possible. If you believe that we might have any such information, please contact us at info@track160.com.

To use the App, you must be over the age of thirteen (13). Company does not knowingly collect Personal Information from minors under the age of thirteen (13) and does not wish to do so. If you are between the ages of thirteen (13) and eighteen (18) (or between 13 and the age of legal majority in Your jurisdiction of residence), You must review this Policy with a parent or legal guardian to ensure the parent or legal guardian acknowledge and agree to this Policy. Should Your parent or legal guardian not acknowledge and agree to this Policy, You must immediately uninstall this App and discontinue its use. The Company assumes no responsibility or liability for any misrepresentation of your age.

 

16. Candidates. We welcome qualified candidates (“Candidate(s)”) to apply to any of the open positions posted at our Site or via our dedicated third-party social media pages (e.g. LinkedIn) by sending us your CV or Resume and any other information you may choose to share with us (“Candidate Information”). Since privacy and discreetness are very important to our Candidates, we are committed to keep Candidate Information private and will use it solely for our internal recruitment purposes.

Please note that we may retain Candidate Information submitted to us even after the applied position has been filled or closed. This is done so we could re-consider Candidates for other suitable positions and opportunities at Track160 and use the Candidate Information as a reference for future applications; and in case the Candidate is hired, for additional employment and business purposes related to their employment with us. If you previously submitted your Candidate Information to us, and now wish to access it, update it or have it deleted from our systems, please contact us at info@track160.com.

 

17. Security. The security of Personal Information is important to us. We follow generally accepted industry standards, including the use of appropriate administrative, physical and technical safeguards, to protect the Personal Information submitted to us. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use reasonable acceptable means to protect your Personal Information, we cannot guarantee its absolute security or confidentiality. If you have any questions about security of the App and/or Site, you can contact us at info@track160.com.

 

18. General Information.

1. This Privacy Policy, its interpretation, and any claims and disputes related hereto, shall be governed by the laws of of the State of Israel, without respect to its criminal law principles. Any and all such claims and disputes shall be brought in, and you hereby consent to them being litigated in and decided exclusively by a court of competent jurisdiction located in Tel Aviv, Israel.

2. This Privacy Policy was written in English and may be translated into other languages for your convenience. If a translated (non-English) version of this Privacy Policy conflicts in any way with the English version, the provisions of the English version shall prevail.

 

19. Have any Questions? If you have any comments or questions regarding our Privacy Policy, or your Personal Information that we may be storing and using, please contact us at  info@track160.com.