Privacy Policy

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EFFECTIVE DATE: December 16, 2014

INTRODUCTION

This Privacy Policy explains the privacy practices that apply to this website or any related website, application, service or mobile application on or in which this Privacy Policy appears or is linked or referenced (collectively, the “XTRAC Digital Services”).  The XTRAC Digital Services are owned and/or operated by XTRAC LLC (d/b/a XTRAC Solutions) located at 245 Summer Street, Boston, MA 02110 USA, or its affiliates (“XTRAC,” “we” or “us”). 

XTRAC’s Privacy Policy was developed as an extension of our commitment to maintaining the highest level of integrity in dealing with our clients, customers and partners. This Privacy Policy describes:

  • The information we collect on or through the XTRAC Digital Services and how we collect it
  • How we use and disclose the information we collect
  • Your choices regarding the collection and processing of your Personal Information

Before submitting information to or through the XTRAC Digital Services, please review this Privacy Policy carefully. If you have not done so already, please also review our Terms of Use.  When you submit information to or through the XTRAC Digital Services, you hereby consent to the collection and processing of information as set forth in this Privacy Policy and our Terms of Use.

CHANGES TO PRIVACY POLICY 

The Effective Date of this Privacy Policy is set forth at the top of this webpage.  We will notify you in advance if we make any material change by posting notice on this webpage and, when possible, contacting you using the email address you have provided to us (if any).  We will not make retroactive changes that reduce your privacy rights unless we are legally required to do so.  Your continued use of the XTRAC Digital Services after the Effective Date constitutes your acceptance of the amended Privacy Policy. The amended Privacy Policy supersedes all previous versions. 

PERSONAL INFORMATION

Throughout this Privacy Policy, "Personal Information" means information associated with or used to identify a specific person.  Our definition of Personal Information does not include information that has been made anonymous or aggregated so that it can no longer be used, whether alone or in combination with other information, to identify a specific person.  For example, Personal Information does not include information that allows us to calculate how many users access the XTRAC Digital Services. 

INFORMATION XTRAC COLLECTS AND HOW IT IS COLLECTED

When you use the XTRAC Digital Services, we may collect certain information, including Personal Information, from or about you, such as your name and the contact details you provide when registering to use XTRAC Digital Services or when sending correspondence to us through the XTRAC Digital Services.

We also collect certain technical and navigational information from users of the XTRAC Digital Services as described below. This includes information such as your device type, browser type, Internet Protocol address, webpages visited and average time spent on the XTRAC Digital Services.

COOKIES AND OTHER DATA COLLECTION TOOLS

Cookies are small data files in web browsers that store information about your online activities, including your use of the XTRAC Digital Services.  Cookies placed in your web browser directory by XTRAC Digital Services are called "first party cookies".  Cookies placed in your web browser directory by third parties are called "third party cookies". Third party cookies enable third party features or functionality to be provided on or through the XTRAC Digital Services, such as advertising, videos and analytics.  A third-party cookie may recognize your computer or device both when it visits the XTRAC Digital Services and also when it visits other websites serviced by the same third party providing the cookie.

Cookies can remain on your computer or device for different periods of time. "Session cookies” are active only while your website browser is open and are deleted automatically once you close your browser.  "Persistent cookies" are stored in your web browser until you delete them and enable websites to recognize your computer when you later re-open your browser and browse the internet again.

We use cookies and similar data collection tools to support the operation of the XTRAC Digital Services.  XTRAC engages third-party services providers, such as advertising networks, that use cookies and similar data collection tools to help us provide the XTRAC Digital Services to you and to display advertising on or through other websites and digital services.  This Privacy Policy does not apply to those third parties or their data collection tools. We do not, however, permit these third-party services providers to use the information they collect on XTRAC’s behalf for any purpose other than to assist them with advertising XTRAC’s services. 

XTRAC and our third-party service providers also may use other data collection tools, such as web beacons, to support our online advertising campaigns and to measure the performance of our online advertising campaigns.  

If you wish to reject cookies or manage the cookies you accept, you may adjust your browser settings to reject Cookies or alert you when a Cookie is placed on your computer. The Help, Preferences or Tools settings (or similar menu option) on most major web browsers will tell you how to reject cookies, how your browser will notify you when you receive a new cookie or how to disable cookies.  Although you are not required to accept our cookies, if you set your browser to reject cookies, you may not be able to use all of the features and functionality of the XTRAC Digital Services.

Some web browsers also incorporate a “Do Not Track” feature that signals the websites that you visit that you do not want to have your online activity tracked.  The Help, Preferences or Tools settings (or similar menu option) on most major web browsers will explain how to enable or disable the Do Not Track signal.  How browsers communicate the Do Not Track signal is not yet uniform.  For this reason, many websites and applications, including the XTRAC Digital Services, are not set up to interpret Do Not Track signals.

HOW XTRAC USES AND PROCESSES INFORMATION

We use the information we collect from you, including Personal Information, to:

  • provide the XTRAC Digital Services you request;
  • personalize the types of information that you receive from us or our third-party service providers;
  • assess trends in your use of the XTRAC Digital Services;
  • customize, improve and develop content and functionality that helps us better serve your needs;
  • facilitate communication between XTRAC and you;
  • provide you with information that we think may interest you, such as company news, products or services;
  • enforce our agreements with you;
  • send you important administrative information regarding the XTRAC Digital Services, such as changes to this Privacy Policy, our Terms of Use or our other policies; and
  • prevent fraud and other prohibited or illegal activities.

We and our affiliates or third-party services providers working on our behalf also may combine different types of information collected from or about you through various sources, including Personal Information, and use the combined information for the purposes described in this Privacy Policy. 

HOW XTRAC DISCLOSES INFORMATION

 XTRAC may disclose the information it collects from or about you with its affiliates and with third-party service providers that perform services on XTRAC’s behalf for the purposes described in this Privacy Policy. All third-party service providers that XTRAC engages are required to implement appropriate technical and organizational measures to maintain the security of the information they process and only to process that information in accordance with instructions from XTRAC.

XTRAC may also disclose information it collects from or about you as we deem necessary, in our sole discretion and without your prior permission, to comply with a subpoena, regulation, binding order of a data protection agency, legal process, governmental request or other legal or regulatory process.  XTRAC reserves the right to disclose your Personal Information if we believe you have or are violating our Terms of Use or in order to protect or defend XTRAC’s rights or property, even without a subpoena, warrant or other court order.

If all or part of XTRAC (or any of its assets) is sold, merged or otherwise transferred to another entity, we will continue to process information consistent with this Privacy Policy and, when possible, will provide you with notice before Personal Information is transferred or becomes subject to a different privacy policy. 

CALIFORNIA CONSUMER RIGHTS INFORMATION

A business subject to California Civil Code section 1798.83 is required to disclose to its California customers, upon request, the identity of any third parties to whom the business has disclosed Personal Information within the previous calendar year, along with the type of Personal Information disclosed, for the third parties' direct marketing purposes.  XTRAC does disclose your Personal Information to any third party for its direct marketing purposes.

CHILDREN

We do not knowingly collect information from minors, including children under the age of thirteen (13). To use the XTRAC Digital Services, you must be the age of legal majority in your place of residence. By using the XTRAC Digital Services, you hereby represent that you are at least the age of legal majority in your place of residence. All information provided to us is treated as if provided by an adult.

If we learn that a minor has submitted information about himself/herself to us, we delete it as soon as possible. If you believe that we have collected Personal Information from a minor, please contact us via email at compliancextracsolutions@fmr.com.

SECURITY

For more information about how the steps we take to help secure information, please see our Security Notice.

GENERAL

Links To Other Websites, Applications or Services: Certain of the XTRAC Digital Services may include links to third-party websites, applications or services that XTRAC does not own or control.  We are not responsible for the information collection practices of any website, application or service that we do not own or control.  We encourage you to review and understand the privacy practices of third-party websites, applications or services before providing any information to or through them.

Dispute Resolution:  Please see our Terms of Use for important information about dispute resolution.

Information Transmission: The XTRAC Digital Services are hosted in the United States and other jurisdictions. If you are visiting the XTRAC Digital Services from outside the United States, your information may be transferred to, stored and processed in the United States. The data protection and other laws of the United States may not have the same requirements as those in your country.  By using the XTRAC Digital Services, you consent to transfer of your information to our facilities as described in this Privacy Policy and our Terms of Use.

QUESTIONS

If you have questions about this Privacy Policy, please contact us at compliancextracsolutions@fmr.com.