Sodtrack Privacy Policy

1. Introduction

Sodtrack LLC, together with its affiliates and related entities, Sodtrack SpA and Sodtrack SAS (collectively, "Sodtrack"), is committed to protecting the privacy and security of the personal data processed in connection with its business activities.

This Privacy Policy describes how Sodtrack collects, uses, stores, and protects personal data when it acts as a data controller.

This Policy does not govern personal data that customers store or manage through the Sodtrack platform. With respect to that data, Sodtrack acts solely as a data processor, in accordance with each customer's instructions.

This Policy also describes the location data that Sodtrack's mobile applications collect, as detailed in Section 10.

This Policy is complemented by our Cookie Policy and our Data Processing Terms, which describe, respectively, our use of cookies on our sites and the terms under which Sodtrack processes personal data on behalf of its customers.

2. Personal Data We May Collect

We may collect the following categories of personal data:

• First and last name.
• Email address.
• Company or organization.
• Job title or role.
• Phone number.
• Information contained in contact requests, forms, or communications.
• Technical support records.
• Authentication and access data.
• IP address and technical logs associated with the use of our services.
• Location data collected through our mobile applications, as described in Section 10.

3. Purposes of Processing

We process personal data to:

• Respond to inquiries and requests for information.
• Manage requests for platform demonstrations.
• Administer business and contractual relationships.
• Provide technical support.
• Manage customer accounts.
• Maintain the security of our systems.
• Detect and prevent fraudulent or abusive activity.
• Comply with legal and regulatory obligations.

4. Legal Basis for Processing

We process personal data when necessary for:

• The performance of pre-contractual or contractual relationships.
• Compliance with legal obligations.
• Responding to requests made by data subjects themselves.
• Our legitimate interests relating to the security, continuity, and improvement of our services.

5. Data Sharing

We may share personal data with vendors that provide services necessary for the operation of our business, including:

• Amazon Web Services (AWS).
• Auth0.
• Zendesk.
• Amazon SES.
• Datadog.
• Google (Firebase and Google Maps Platform).
• Mapbox.

These vendors act under appropriate confidentiality and security obligations.

Sodtrack also shares personal data with its customers (the "Customer") and third parties, in accordance with our Data Processing Terms.

6. International Transfers

Sodtrack's primary infrastructure is hosted in the United States.

As a result, personal data may be stored, processed, or accessed from the United States, Canada, and countries in Latin America to the extent necessary to provide our services and technical support.

Sodtrack takes reasonable measures to protect personal data during such transfers.

7. Security

Sodtrack implements reasonable technical and organizational measures to protect personal data against unauthorized access, loss, alteration, or improper disclosure.

Among other measures, we maintain:

• Encryption in transit.
• Encryption at rest.
• Event and access logs.
• Segregation of test and production environments.
• Backup systems.
• Security incident management procedures.
• Access controls configurable by each Customer.

8. Retention

Personal data will be retained only for as long as necessary to fulfill the purposes described in this Policy or to comply with applicable legal obligations.

9. Rights of Data Subjects

Data subjects may exercise, in accordance with applicable law, their rights of access, rectification, erasure, objection, portability, restriction, and any other rights that may apply. To do so, they may write to privacy@sodtrack.com, providing their name, contact details, the right they wish to exercise, and sufficient information to verify their identity.

Sodtrack will review each request and respond in accordance with applicable law.

10. Location Data in Sodtrack Mobile Applications

This section applies to the Sodtrack Contractor mobile application and to the versions of it that Sodtrack publishes under the brands of its Customers (together, the "App"). The App is used by technicians and contractors ("Providers") to receive and carry out services assigned by a Customer.

11. Changes

Sodtrack may modify this Privacy Policy at any time. The current version will be available on its website.