OnTrak Software believes in the importance of thoughtfully handling personal information and is committed to privacy practices that are transparent and compliant. This Privacy Statement sets out how OnTrak Software uses the personal information we collect and receive about you.
Categories of Personal Information Collected
OnTrak Software collects personal information in support of its mission to help alcohol beverage distributors. This personal information is collected through a variety of ways. You provide some information directly to us; and we receive some information when you use our products and services.
The categories of information we collect will depend on your interactions with OnTrak Software:
Contact information. Name, employer, title, email address, physical address, phone number, and similar contact info, user names and passwords.
Transaction and registration information. Information which is generated in the course of your transaction with OnTrak Software, including account information, logins, passwords, and purchase history. Product registration information, product interest information, transaction information, and in some cases, student verification information.
Usage and geographic data. OnTrak Software collects information related to your use of our products, services and websites. Usage data includes online and technical information about your computer's or mobile device's operating system and browser type; your device type; details about how you are using our products (including natural language queries); your Internet Protocol (IP) address, and geographic areas derived from your IP address; networking connection data; OnTrak Software cookie information; file information; metadata; time stamped logs regarding access times and duration of visits; the web pages you visited before coming to OnTrak Software websites (referring URL); and other usage data relating to your activities on our Sites, including the pages you request. We may link this information to the personal information we have collected about you and use it for the purposes described in this Privacy Statement, and we may deliver targeted marketing and product information back to you based on your usage data.
If you decline to provide your personal information or ask us to delete it, we may be unable to continue to provide or support our products or services.
Ways We Use Personal Information
We use the personal information we collect for the purposes described in this Privacy Statement, as covered in any agreement that incorporates this Policy, or as disclosed to you in connection with our websites. For example, we will use your information to:
- Provide and deliver products or services, including software updates;
- Operate and improve our operations, systems, products, and services;
- Understand you and your preferences to enhance your experience;
- Respond to your comments and questions and provide customer service;
- Provide service and support, such as sending confirmations, invoices, technical notices, updates, security alerts, and administrative messages and providing customer support and troubleshooting;
- Communicate with you and your referrals about promotions, upcoming events, and news about products and services offered by OnTrak Software and our selected partners;
- Link or combine information about you with other personal information we get from third parties, to help understand your needs and provide you with better and more personalized service;
- Enforce our terms and conditions or protect our business, partners, or users;
- Protect against, investigate, and deter fraudulent, unauthorized, or illegal activity; and
- Keep our products, facilities, and services secure.
Reasons for Using Your Information
When we process your personal information we will only do so where at least one of the following applies:
- We need to use your personal information to perform our responsibilities under our contract with you and to provide you with tools and services.
- We have a legitimate reason to collect and use your personal information. For example, it is in our legitimate interests to use usage data including your personal information to improve our products and services; to tell you about changes to this Privacy Statement and other policies; to tell you about new products, services and events or changes to our products, services or websites; for business reasons (for example to develop and expand our business); and to tell you about offers or promotions we are running.
- You have given consent to use your personal information. You may withdraw consent by opting out where we give you the opportunity to do so, or by contacting us using the contact details below.
- If it is necessary for us to use your personal information in order to comply with a legal obligation.
- You have chosen to make the information public. You should not share any personal information which you wish to keep confidential or private.
Sharing of Personal Information
OnTrak Software works to keep your personal information confidential and secure. In some circumstances OnTrak Software may share your information with third parties, for example:
- We may share your personal information when we have your permission, including when you choose to share information using OnTrak Software Public websites;
- If you connect to your third party accounts through our products, we will use that information to authenticate you, enumerate the data sources available to you, download any data you request us to, and download and refresh authentication tokens or persist authentication information such as user names and passwords as necessary to continue to connect to these data;
- We may share your contact and transactional information with our current or future affiliates, which may include parent and subsidiary companies, joint ventures, or other companies under common control, in which case we will require our affiliates to honor this Privacy Statement;
- We will disclose your personal information to comply with legal requirements, such as in response to a court order or a subpoena. We also may disclose your personal information in response to a law enforcement agency's request, or where we believe it is necessary to investigate, verify, prevent, enforce compliance with, or take action regarding illegal or suspected illegal activities; suspected fraud; situations involving potential threats to the physical safety of any person; protection of the rights and property of OnTrak Software, our agents, customers, or others; violations or suspected violations of our agreements and policies; or as otherwise required or permitted by law or consistent with legal requirements;
- We transfer or disclose your personal information for corporate reasons. For example, to third parties in connection with or during negotiation of any merger, financing, acquisition, bankruptcy or similar transaction. We may also share personal information with our auditors, attorneys or other advisors in the connection with corporate functions; and
- Finally, we also share aggregated, anonymized or statistical information about you, including demographics data, with others for a variety of purposes, for example, for improving products and services for OnTrak Software and others.
We may facilitate third party services or ways to share data through third parties, including social media platforms, websites, applications, and services through plug-ins, widgets, buttons, and other third party features on and connected with our websites, communications or products. Third parties whose services you use in connection with OnTrak Software, such as our training and certification partners, or third parties whose websites we link to, may have information practices that are different from ours. This Privacy Statement does not apply to the activities of third parties when they are collecting or using data for their own purpose or on behalf of others. We are not responsible for the activities of these third parties. We encourage you to review their privacy policies to understand how they use your information.
Storage and Security of Your Personal Information
We have reasonable and appropriate physical, electronic, and managerial procedures in place to help safeguard your personal information. However, you should know that no company, including OnTrak Software, can fully eliminate security risks associated with personal information. To help protect yourself, use a strong password, do not use the same passwords to access your OnTrak Software accounts that you use with other accounts or services, and protect your user names and passwords to help prevent others from accessing your accounts and services.
Information collected by OnTrak Software or on our behalf may be stored on your computers, on your mobile devices, or on our servers, and may be transferred to, accessed from, or stored and processed in, the United States and other countries where OnTrak Software or its service providers maintain facilities or support centers. However, we will protect all personal information we obtain in accordance with this Privacy Statement and take reasonable steps to ensure that it is treated lawfully.
In certain circumstances we may retain your personal information after you have closed your account or are no longer actively engaged with OnTrak Software. For example:
- We may retain your personal information after you have closed your account so that we can send you information about products, services and publications we think you may be interested in. You can "unsubscribe" from receiving such messages or tell us you are no longer interested;
- We may retain your personal information in order to protect our legal rights, or those of third parties, or to comply with the law;
- We may retain personal information about how you have used our products and services in order to improve and develop our business;
- If you purchase products or services from us, we may retain your personal information for as long as we need to in order to provide you with customer service, or for compliance purposes, for example, in order to comply with our record keeping requirements;
- OnTrak Software may also use and share aggregated, non-personally identifiable data for research, external training and marketing purposes.
Controlling your Personal Information
Our marketing emails permit you to opt-out of receiving further marketing emails. You may also contact us at email@example.com at any time to let us know that you no longer wish to receive marketing emails. If you opt out but are a current customer, we will still send you transactional emails. Transactional emails are necessary communications about your accounts and our business dealings with you, such as renewals and updates, and, as allowed by applicable law, requests for your participation in surveys.
You have certain rights in your personal information, subject to local data protection laws.
Cookies and Web Beacons
Our websites use various software technologies including cookies, web beacons and pixel tags. Cookies are small text files that we and others may place in visitors' computer browsers to store their preferences. We use web beacons or pixel tags - small pieces of code placed on a web page or within the body of an email - to monitor the behavior and collect data about the visitors viewing a web page or viewing or opening an email. Web beacons can be used to count the users who visit a web page or to deliver a cookie to the browser of a visitor viewing that page, and we use them from time to time for this and advertising purposes.
We partner with third parties, including analytics companies who may place cookies on your browser when you visit our websites, may send their own cookies to your cookie file, and may use those cookies to track and collect information about you and your online activities over time and across different websites, devices, and applications and to provide targeted advertising based on your interests and previous browsing history.
Questions regarding this Statement or the practices of this Site should be directed to OnTrakSoftware.com's Security Administrator by e-mailing such questions to support@OnTrakSoftware.com or by regular mail addressed to:
Attn: OnTrak Software Security Administrator
4050 Executive Park Drive -Suite 430
Cincinnati, OH 45241
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Various trademarks held by their respective owners.