Privacy Policy

1. ABOUT THIS POLICY

At WorkTrek, we take data protection seriously.
This Privacy Policy has been put together to provide our customers (“Customers”)
with transparent information and guidelines about the privacy and data protection
aspects of our WorkTrek service.

This Privacy Policy has been divided into two sections
Customer as Data controller
First of all, we wish to remind our Customers of their data protection responsibilities
when collecting personal data via the WorkTrek service. These provisions can be
found under the section “Customer as Data controller – What to keep in mind”.
Under this section we have also gathered some general recommendations and best
practices.
WorkTrek as Data controller
Secondly, this Privacy Policy is intended to serve as our own legal information
document regarding the personal data we process about our Customers and users
for our own purposes. These provisions can be found under the section “WorkTrek as
Data controller.”

Updates to this policy
This Privacy Policy may be updated from time to time. The current version can be
found on our website (http://www.worktrek.com/privacy-policy/). We will not make
substantial changes or reduce the rights of Customers under this Privacy Policy
without providing a notice thereof.

 

2. OUR CONTACT INFORMATION

WorkTrek
Address: Vukovarska 284, Zagreb, Croatia
E-mail address: support@worktrek.com
Phone: +385 98 853 488
Website: http://www.worktrek.com/

3. CUSTOMER AS DATA CONTROLLER – WHAT TO KEEP IN MIND.

How does WorkTrek work?
The WorkTrek service is provided using our Asset, Maintenance and Field Work
Management Software that enables customers to manage their technicians and field
workers – plan and schedule maintenance work orders and tasks, manage
maintenance of the assets, monitor the work in the field and analyze the field workers
performance. Our Customers may then use the data and analytics collected from the
software for various purposes, including monitoring and optimizing the performance
of their employees and processes. WorkTrek does not actively monitor the type of
data being collected. We also do not control the purposes for which the collected
data is used.
Key definitions; Data subject, Data controller and Data processor
In EU data protection legislation, the Data subject is the individual whose personal
data is subject to processing. For example, any identifiable users such as technicians
are Data subjects. The Data controller is the one determining the purpose and
measures of processing personal data; what information is collected and how it is
used. The Data processor handles the data on behalf of the Data controller. In regard
to the data regarding the technicians and other users, the Customer is therefore the
Data controller, whereas WorkTrek acts as their Data processor.
Data processing agreement
The EU General Data Protection Agreement requires a data processing agreement to
be made between the Data controller and Data processor. These provisions have
been incorporated into Section 5 of our Terms of Service
(http://www.worktrek.com/terms-of-service).
Definition of personal data
Personal data is any piece of information from which an individual can be identified
either directly or indirectly. Typical examples of personal data include names,
addresses, phone numbers and identifiable photographs. Exact location data can
also be classified as personal data.
Please note that a combination of information may also result in identifiable
information, even if the pieces of information individually are not.
Informing users
You are responsible for including your own privacy policy or other form of information
document clarifying what personal data is collected and how it is handled.

You may do this by adding a link to an external privacy policy of your organization or
otherwise inserting your own privacy policy.
Data subject rights
The Data subject has certain rights in regard to their personal data, such as the right
to access it and the right to have it corrected and in some cases deleted. The Data
subject also has the right to withdraw any consent they have previously given.
As a Data controller you are responsible for ensuring data subjects can exercise their
legal rights. Your privacy policy should include clear contact details for Data subjects
to contact.
Sensitive data and consents
Personal data revealing or concerning health, political opinions, religious or
philosophical beliefs, trade union membership, a person’s sex life or sexual
orientation or race are considered to be categories of sensitive personal data.
The collection, processing and publication of this type of information generally
requires an explicit consent from the individual.
Please exercise special care when collecting these categories of data.
Publishing data results
In order to respect the privacy of the Data subjects it is recommended to get their
consent for publishing any data which may identify them. Any possible publication of
personal data should also be mentioned in your own privacy policy.
If no consent has been acquired, it is recommended to anonymize or pseudonymize
the publication material.
Natural persons as Data controllers
Most of our Customers are companies, organizations or public entities; however
sometimes natural persons may also independently use our service. Please note that
the Data controller responsibilities listed in this section apply regardless of the legal
status of the Data controller.

 

4. WORKTREK AS A DATA CONTROLLER

The following sections of the Privacy Policy describe how we process the personal
data of our Customers and their representatives for our own purposes.
Please note that this part of the privacy policy only applies to processing of personal
data carried out by WorkTrek as a Data controller. It does not apply to the data our

Customers collect. In regard to such data, please see section “Customer as Data
controller.”

 

5. INFORMATION WE COLLECT

Account Information and Correspondence If you sign up for an account with us,
we may collect information that you provide to us, such as your username and email
address. Further, in the course of using our services, you may provide us with
additional information through your communications with us (for example company
name/organization, title, phone number etc.).
Website Logs and Cookies: Whenever you visit or interact with our website, we
automatically collect certain information about your browser and your interaction with
our website, including (a) IP address, (b) browser and device type, (c) operating
system, (d) referring web page, (e) the date and time of page visits, (f) the pages
accessed on our websites, and (g) keyword/campaign information for marketing
campaigns. We also use cookies and similar technologies to recognize and improve
your use of our websites, and you will not be able to access certain parts of our
websites, including those that require a login, unless your device accepts cookies
from us.
Mobile Information: When using WorkTrek mobile applications and services, we
may collect information from you such as mobile device type, device info and IP
address. If you use location-enabled products and services, you may be sending us
location information. This information may or may not reveal your actual location. You
may opt-out of location-based services at any time by editing the setting at the device
level. The Mobile Information is used for the purpose of providing our services. We
also use the Mobile Information for support, to develop new features, and to improve
the overall quality of WorkTrek’s products and services. We may also use the
information to show a history of your activity, to provide you with statistics about you
or your use of our product or service, or to provide you with a better user experience.
Hosted Data: While using the WorkTrek web application or integration API you might
upload data concerning users, assets, requests, work orders, tasks and contracts.
We delete Hosted Data upon your request.
Feedback: You and/or your end users may provide us with feedback regarding our
Services (e.g., in the form of email, suggestions for how to improve our service,
reviews on services such as Capterra or G2 Crowd, etc.). We do not delete this
information.

 

6. PURPOSES AND LEGITIMATE GROUNDS FOR PROCESSING OF PERSONAL DATA

Purposes of processing
To provide our Services and carry out our contractual obligations
We process personal data in the first place to be able to offer the Services to our
Customers and to run, maintain and develop our business. Personal data may be
processed in order to carry out our contractual obligations towards the Customer. We
may use the data, for example, to offer essential functionalities of the Services and to
provide access to the Services. If Customer contacts our customer service, we will
use the provided information for answering questions and solving possible issues,
and supporting our Customers with their Customer service requests.
For Customer communication and marketing
We may process personal data for the purpose of contacting Customers regarding
our Services as part of our sales process, to inform Customers of changes in our
Services as well as to conduct marketing activities.
For quality improvement and trend analysis
We may process information regarding the use of our services to improve our service
quality e.g. by analyzing any trends in the use of our Services. When possible, we will
do this using only aggregated, non-personally identifiable data.

Legitimate grounds for processing
We process personal data to perform our contractual obligations towards Customers
and to comply with legal obligations. Furthermore, we process personal data to
pursue our legitimate interest to run, maintain and develop our business and to
create and maintain Customer relationships. When choosing to use your data on the
basis of our legitimate interests, we weigh our own interests against your right to
privacy.

 

7. COOKIES

We use various technologies to collect and store Analytics Data and other
information when Customers use our Services, including cookies.
Cookies are small text files sent and saved on your device that allows us to identify
visitors of our websites and facilitate the use of our Services and to create aggregate
information of our visitors. This helps us to improve our Services and better serve our
Customers. The cookies will not harm your device or files. We use cookies to tailor
our Services and the information we provide in accordance with the individual
interests of our Customers.

Customers may choose to set their web browser to refuse cookies, or to alert when
cookies are being sent.
Please note that some parts of our Services may not function properly if use of
cookies is refused.

 

8. INTERNATIONAL DATA TRANSFERS

European Customers
WorkTrek stores the Customer’s personal data within European Union.

USA Customers
WorkTrek stores the Customers’ personal data within the United States of America.

Other International Transfers
If you are located outside the U.S., the EU, the UK, and Switzerland, and you choose
to provide Personal Information to us, we may transfer your Personal Information to
the U.S. and process it there (or any other country where we operate or may have
co-locations). When you provide Personal Information, it may be sent to servers
located in the U.S. and other countries around the world. If you reside or are located
within the EU, the UK, or Switzerland and such transfers occur, we take appropriate
steps in an effort to provide the same level of protection for the processing carried out
in any such countries as you would have within the EU, the UK, or Switzerland to the
extent feasible under applicable law.
More information regarding the transfers of personal data may be obtained by
contacting us.

 

9. PERSONAL DATA RECIPIENTS

We do not share personal data with third parties outside of WorkTrek’s organization
unless one of the following circumstances applies:
It is necessary for the purposes set out in this Privacy Policy
To the extent that third parties need access to personal data to perform the Services,
WorkTrek has taken appropriate contractual and organizational measures to ensure

that personal data are processed exclusively for the purposes specified in this
Privacy Policy and in accordance with all applicable laws and regulations.
For legal reasons
We may share personal data with third parties outside WorkTrek’s organization if we
have a good-faith belief that access to and use of the personal data is reasonably
necessary to: (i) meet any applicable law, regulation, and/or court order; (ii) detect,
prevent, or otherwise address fraud, security or technical issues; and/or (iii) protect
the interests, properties or safety of WorkTrek, our Customers or the public in
accordance with the law. When possible, we will inform Customers about such
transfer and processing.
To authorized service providers
We may share personal data to authorized service providers who perform services
for us (including data storage, sales, marketing and Customer support services). Our
agreements with our service providers include commitments that the service
providers agree to limit their use of personal data and to comply with privacy and
security standards at least as stringent as the terms of this Privacy Policy. Please
bear in mind that if you provide personal data directly to a third party, such as through
a link on our website, the processing is typically based on their policies and
standards.
For other legitimate reasons
If WorkTrek is involved in a merger, acquisition or asset sale, we may transfer
personal data to the third party involved. However, we will continue to ensure the
confidentiality of all personal data. We will give notice to all Customers concerned
when the personal data are transferred or become subject to a different privacy policy
as soon as reasonably possible.
With explicit consent
We may share personal data with third parties outside WorkTrek’s organization for
other reasons than the ones mentioned above, when we have the Customer’s explicit
consent to do so. The Customer has the right to withdraw this consent at all times.

 

10. DATA RETENTION

WorkTrek does not store personal data longer than is legally permitted and
necessary for the purposes of providing the Services or the relevant parts thereof.
The storage period depends on the nature of the information and the purposes of
processing. The maximum period may therefore vary per use.
Customer Data relating to your use of the Services are typically deleted within
reasonable time after you no longer use the Services. We will store Customer’s

personal data for as long as the Customer is a registered user of our Services and,
thereafter, for no longer than is required by law or reasonably necessary for our
legitimate interests for example for claims handling, internal reporting, marketing and
reconciliation purposes.

 

11. CUSTOMERS’ RIGHTS

Right to access
You have the right to access your personal data processed by us. Customers may
contact us and we will inform them of what personal data we have collected and
processed regarding the said Customer.
Right to withdraw consent
In case the processing is based on a consent granted by Customer, Customer may
withdraw the consent at any time. Withdrawing a consent may lead to fewer
possibilities to use our Services. The withdrawal of consent does not affect the
lawfulness of processing based on consent before its withdrawal.
Right to rectify
Customers have the right to have incorrect or incomplete personal data we have
stored about the Customer corrected or completed. You can correct or update some
of your personal data through your user account in the Services.
Right to erasure
Customers may also ask us to erase the Customer’s personal data from our systems.
We will comply with such request unless we have a legitimate grounds to not delete
the data.
Right to object
Customers may object to the processing of personal data if such data are processed
for other purposes than purposes necessary for the performance of our Services to
the Customer or for compliance with a legal obligation. In case we do not have
legitimate grounds to continue processing such personal data, we shall no longer
process the personal data after your objection.
Right to restriction of processing
Customers may request us to restrict processing of personal data for example when
your data erasure, rectification or objection requests are pending and/or when we do
not have legitimate grounds to process your data. This may however lead to fewer
possibilities to use our Services.

Right to data portability
Customers have the right to receive their personal data from us in a structured and
commonly used format and to independently transmit those data to a third party.
How to use the rights
The above-mentioned rights may be used by sending a letter or an e-mail to us on
the addresses set out above, including the following information: the full name,
company name, address, e-mail address and a phone number. We may request the
provision of additional information necessary to confirm the identity of the Customer.
We may reject requests that are unreasonably repetitive, excessive or manifestly
unfounded.

 

12. DIRECT MARKETING

Notwithstanding any consent granted beforehand for the purposes of direct
marketing, Customer has the right to prohibit us from using their personal data for
direct marketing purposes by contacting us or by using the unsubscribe option
offered in connection with our newsletter.

 

13. INFORMATION SECURITY

We use administrative, organizational, technical, and physical safeguards to protect
the personal data we collect and process. Measures may include, for example, where
appropriate, encryption, firewalls, virtual private networks (VPN), secure facilities and
access right systems. Our security controls are designed to maintain an appropriate
level of data confidentiality, integrity, availability, resilience and ability restore the
data. We regularly test our Services, systems, and other assets for security
vulnerabilities.
Should despite of the security measures, a security breach occur that is likely to have
negative effects to the privacy of Customers, we will inform the relevant Customers
and other affected parties, as well as relevant authorities when required by applicable
data protection laws, about the breach as soon as possible.

 

14. LODGING A COMPLAINT

In case Customer considers our processing of personal data to be inconsistent with
the applicable data protection laws, a complaint may be lodged with the local
supervisory authority for data protection.