Last updated: June 21, 2023

Please read these terms and conditions carefully before using Our Service.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of these Terms and Conditions:

Application means the software program provided by the Company downloaded by You on any electronic device, named 1000TRAX

Application Store means the digital distribution service operated and developed by Apple Inc. (Apple App Store) or Google Inc. (Google Play Store) in which the Application has been downloaded.

Affiliate means an entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.

Account means a unique account created for You to access our Service or parts of our Service.

Country refers to: United Kingdom

Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to 1000TRAX Operations Limited, 83 Roberts Road
Colchester, Essex, CO2 7FQ United Kingdom.

Content refers to content such as text, images, or other information that can be posted, uploaded, linked to or otherwise made available by You, regardless of the form of that content.

Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.

Feedback means feedback, innovations or suggestions sent by You regarding the attributes, performance or features of our Service.

Free Trial refers to a limited period of time that may be free when purchasing a Subscription.

Promotions refer to contests, sweepstakes or other promotions offered through the Service.

Service refers to the Application or the Website or both.

Subscriptions refer to the services or access to the Service offered on a subscription basis by the Company to You.

Terms and Conditions (also referred as "Terms") mean these Terms and Conditions that form the entire agreement between You and the Company regarding the use of the Service.

Third-party Social Media Service means any services or content (including data, information, products or services) provided by a third-party that may be displayed, included or made available by the Service.

Website refers to 1000TRAX, accessible from https://www.1000trax.com

You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Acknowledgment

These are the Terms and Conditions governing the use of this Service and the agreement that operates between You and the Company. These Terms and Conditions set out the rights and obligations of all users regarding the use of the Service.

Your access to and use of the Service is conditioned on Your acceptance of and compliance with these Terms and Conditions. These Terms and Conditions apply to all visitors, users and others who access or use the Service.

By accessing or using the Service You agree to be bound by these Terms and Conditions. If You disagree with any part of these Terms and Conditions then You may not access the Service.

You represent that you are over the age of 18. The Company does not permit those under 18 to use the Service.

Your access to and use of the Service is also conditioned on Your acceptance of and compliance with the Privacy Policy of the Company. Our Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your personal information when You use the Application or the Website and tells You about Your privacy rights and how the law protects You. Please read Our Privacy Policy carefully before using Our Service.

Subscriptions

Subscription period

The Service or some parts of the Service are available only with a paid Subscription. You will be billed in advance on a recurring and periodic basis (such as daily, weekly, monthly or annually), depending on the type of Subscription plan you select when purchasing the Subscription.

At the end of each period, Your Subscription will automatically renew under the exact same conditions unless You cancel it or the Company cancels it.

Subscription cancellations

You may cancel Your Subscription renewal either through Your Account settings page or by contacting the Company. You will not receive a refund for the fees You already paid for Your current Subscription period and You will be able to access the Service until the end of Your current Subscription period.

Billing

You shall provide the Company with accurate and complete billing information including full name, address, state, zip code, telephone number, and a valid payment method information.

Should automatic billing fail to occur for any reason, the Company will issue an electronic invoice indicating that you must proceed manually, within a certain deadline date, with the full payment corresponding to the billing period as indicated on the invoice.

Fee Changes

The Company, in its sole discretion and at any time, may modify the Subscription fees. Any Subscription fee change will become effective at the end of the then-current Subscription period.

The Company will provide You with reasonable prior notice of any change in Subscription fees to give You an opportunity to terminate Your Subscription before such change becomes effective.

Your continued use of the Service after the Subscription fee change comes into effect constitutes Your agreement to pay the modified Subscription fee amount.

Refunds

Except when required by law, paid Subscription fees are non-refundable.

Certain refund requests for Subscriptions may be considered by the Company on a case-by-case basis and granted at the sole discretion of the Company.

Free Trial

The Company may, at its sole discretion, offer a Subscription with a Free Trial for a limited period of time.

You may be required to enter Your billing information in order to sign up for the Free Trial.

If You do enter Your billing information when signing up for a Free Trial, You will not be charged by the Company until the Free Trial has expired. On the last day of the Free Trial period, unless You cancelled Your Subscription, You will be automatically charged the applicable Subscription fees for the type of Subscription You have selected.

At any time and without notice, the Company reserves the right to (i) modify the terms and conditions of the Free Trial offer, or (ii) cancel such Free Trial offer.

Promotions

Any Promotions made available through the Service may be governed by rules that are separate from these Terms.

If You participate in any Promotions, please review the applicable rules as well as our Privacy policy. If the rules for a Promotion conflict with these Terms, the Promotion rules will apply.

User Accounts

When You create an account with Us, You must provide Us information that is accurate, complete, and current at all times. Failure to do so constitutes a breach of the Terms, which may result in immediate termination of Your account on Our Service.

You are responsible for safeguarding the password that You use to access the Service and for any activities or actions under Your password, whether Your password is with Our Service or a Third-Party Social Media Service.

You agree not to disclose Your password to any third party. You must notify Us immediately upon becoming aware of any breach of security or unauthorized use of Your account.

You may not use as a username the name of another person or entity or that is not lawfully available for use, a name or trademark that is subject to any rights of another person or entity other than You without appropriate authorization, or a name that is otherwise offensive, vulgar or obscene.

Content

Your Right to Post Content

Our Service allows You to post Content. You are responsible for the Content that You post to the Service, including its legality, reliability, and appropriateness.

By posting Content to the Service, You grant Us the right and license to use, modify, publicly perform, publicly display, reproduce, and distribute such Content on and through the Service. You retain any and all of Your rights to any Content You submit, post or display on or through the Service and You are responsible for protecting those rights. You agree that this license includes the right for Us to make Your Content available to other users of the Service, who may also use Your Content subject to these Terms.

You represent and warrant that: (i) the Content is Yours (You own it) or You have the right to use it and grant Us the rights and license as provided in these Terms, and (ii) the posting of Your Content on or through the Service does not violate the privacy rights, publicity rights, copyrights, contract rights or any other rights of any person.

Content Restrictions

The Company is not responsible for the content of the Service's users. You expressly understand and agree that You are solely responsible for the Content and for all activity that occurs under your account, whether done so by You or any third person using Your account.

You may not transmit any Content that is unlawful, offensive, upsetting, intended to disgust, threatening, libelous, defamatory, obscene or otherwise objectionable. Examples of such objectionable Content include, but are not limited to, the following:

• Unlawful or promoting unlawful activity.
• Defamatory, discriminatory, or mean-spirited content, including references or commentary about religion, race, sexual orientation, gender, national/ethnic origin, or other targeted groups.
• Spam, machine – or randomly – generated, constituting unauthorized or unsolicited advertising, chain letters, any other form of unauthorized solicitation, or any form of lottery or gambling.
• Containing or installing any viruses, worms, malware, trojan horses, or other content that is designed or intended to disrupt, damage, or limit the functioning of any software, hardware or telecommunications equipment or to damage or obtain unauthorized access to any data or other information of a third person.
• Infringing on any proprietary rights of any party, including patent, trademark, trade secret, copyright, right of publicity or other rights.
• Impersonating any person or entity including the Company and its employees or representatives.
• Violating the privacy of any third person.
• False information and features.

The Company reserves the right, but not the obligation, to, in its sole discretion, determine whether or not any Content is appropriate and complies with this Terms, refuse or remove this Content. The Company further reserves the right to make formatting and edits and change the manner of any Content. The Company can also limit or revoke the use of the Service if You post such objectionable Content. As the Company cannot control all content posted by users and/or third parties on the Service, you agree to use the Service at your own risk. You understand that by using the Service You may be exposed to content that You may find offensive, indecent, incorrect or objectionable, and You agree that under no circumstances will the Company be liable in any way for any content, including any errors or omissions in any content, or any loss or damage of any kind incurred as a result of your use of any content.

Content Backups

Although regular backups of Content are performed, the Company does not guarantee there will be no loss or corruption of data.

Corrupt or invalid backup points may be caused by, without limitation, Content that is corrupted prior to being backed up or that changes during the time a backup is performed.

The Company will provide support and attempt to troubleshoot any known or discovered issues that may affect the backups of Content. But You acknowledge that the Company has no liability related to the integrity of Content or the failure to successfully restore Content to a usable state.

You agree to maintain a complete and accurate copy of any Content in a location independent of the Service.

Copyright Policy

Intellectual Property Infringement

We respect the intellectual property rights of others. It is Our policy to respond to any claim that Content posted on the Service infringes a copyright or other intellectual property infringement of any person.

If You are a copyright owner, or authorized on behalf of one, and You believe that the copyrighted work has been copied in a way that constitutes copyright infringement that is taking place through the Service, You must submit Your notice in writing to the attention of our copyright agent via email at info@1000trax.com and include in Your notice a detailed description of the alleged infringement.

You may be held accountable for damages (including costs and attorneys' fees) for misrepresenting that any Content is infringing Your copyright.

DMCA Notice and DMCA Procedure for Copyright Infringement Claims

You may submit a notification pursuant to the Digital Millennium Copyright Act (DMCA) by providing our Copyright Agent with the following information in writing (see 17 U.S.C 512(c)(3) for further detail):

• An electronic or physical signature of the person authorized to act on behalf of the owner of the copyright's interest.
• A description of the copyrighted work that You claim has been infringed, including the URL (i.e., web page address) of the location where the copyrighted work exists or a copy of the copyrighted work.
• Identification of the URL or other specific location on the Service where the material that You claim is infringing is located.
• Your address, telephone number, and email address.
• A statement by You that You have a good faith belief that the disputed use is not authorized by the copyright owner, its agent, or the law.
• A statement by You, made under penalty of perjury, that the above information in Your notice is accurate and that You are the copyright owner or authorized to act on the copyright owner's behalf.

You can contact our copyright agent via email at info@1000trax.com. Upon receipt of a notification, the Company will take whatever action, in its sole discretion, it deems appropriate, including removal of the challenged content from the Service.

Intellectual Property

The Service and its original content (excluding Content provided by You or other users), features and functionality are and will remain the exclusive property of the Company and its licensors.

The Service is protected by copyright, trademark, and other laws of both the Country and foreign countries.

Our trademarks and trade dress may not be used in connection with any product or service without the prior written consent of the Company.

Your Feedback to Us

You assign all rights, title and interest in any Feedback You provide the Company. If for any reason such assignment is ineffective, You agree to grant the Company a non-exclusive, perpetual, irrevocable, royalty free, worldwide right and license to use, reproduce, disclose, sub-license, distribute, modify and exploit such Feedback without restriction.

Links to Other Websites

Our Service may contain links to third-party web sites or services that are not owned or controlled by the Company.

The Company has no control over, and assumes no responsibility for, the content, privacy policies, or practices of any third party web sites or services. You further acknowledge and agree that the Company shall not be responsible or liable, directly or indirectly, for any damage or loss caused or alleged to be caused by or in connection with the use of or reliance on any such content, goods or services available on or through any such web sites or services.

We strongly advise You to read the terms and conditions and privacy policies of any third-party web sites or services that You visit.

Termination

We may terminate or suspend Your Account immediately, without prior notice or liability, for any reason whatsoever, including without limitation if You breach these Terms and Conditions.

Upon termination, Your right to use the Service will cease immediately. If You wish to terminate Your Account, You may simply discontinue using the Service.

Limitation of Liability

Notwithstanding any damages that You might incur, the entire liability of the Company and any of its suppliers under any provision of this Terms and Your exclusive remedy for all of the foregoing shall be limited to the amount actually paid by You through the Service or 100 USD if You haven't purchased anything through the Service.

To the maximum extent permitted by applicable law, in no event shall the Company or its suppliers be liable for any special, incidental, indirect, or consequential damages whatsoever (including, but not limited to, damages for loss of profits, loss of data or other information, for business interruption, for personal injury, loss of privacy arising out of or in any way related to the use of or inability to use the Service, third-party software and/or third-party hardware used with the Service, or otherwise in connection with any provision of this Terms), even if the Company or any supplier has been advised of the possibility of such damages and even if the remedy fails of its essential purpose.

Some states do not allow the exclusion of implied warranties or limitation of liability for incidental or consequential damages, which means that some of the above limitations may not apply. In these states, each party's liability will be limited to the greatest extent permitted by law.

"AS IS" and "AS AVAILABLE" Disclaimer

The Service is provided to You "AS IS" and "AS AVAILABLE" and with all faults and defects without warranty of any kind. To the maximum extent permitted under applicable law, the Company, on its own behalf and on behalf of its Affiliates and its and their respective licensors and service providers, expressly disclaims all warranties, whether express, implied, statutory or otherwise, with respect to the Service, including all implied warranties of merchantability, fitness for a particular purpose, title and non-infringement, and warranties that may arise out of course of dealing, course of performance, usage or trade practice. Without limitation to the foregoing, the Company provides no warranty or undertaking, and makes no representation of any kind that the Service will meet Your requirements, achieve any intended results, be compatible or work with any other software, applications, systems or services, operate without interruption, meet any performance or reliability standards or be error free or that any errors or defects can or will be corrected.

Without limiting the foregoing, neither the Company nor any of the company's provider makes any representation or warranty of any kind, express or implied: (i) as to the operation or availability of the Service, or the information, content, and materials or products included thereon; (ii) that the Service will be uninterrupted or error-free; (iii) as to the accuracy, reliability, or currency of any information or content provided through the Service; or (iv) that the Service, its servers, the content, or e-mails sent from or on behalf of the Company are free of viruses, scripts, trojan horses, worms, malware, timebombs or other harmful components.

Some jurisdictions do not allow the exclusion of certain types of warranties or limitations on applicable statutory rights of a consumer, so some or all of the above exclusions and limitations may not apply to You. But in such a case the exclusions and limitations set forth in this section shall be applied to the greatest extent enforceable under applicable law.

Governing Law

The laws of the Country, excluding its conflicts of law rules, shall govern this Terms and Your use of the Service. Your use of the Application may also be subject to other local, state, national, or international laws.

Disputes Resolution

If You have any concern or dispute about the Service, You agree to first try to resolve the dispute informally by contacting the Company.

For European Union (EU) Users

If You are a European Union consumer, you will benefit from any mandatory provisions of the law of the country in which you are resident in.

United States Federal Government End Use Provisions

If You are a U.S. federal government end user, our Service is a "Commercial Item" as that term is defined at 48 C.F.R. §2.101.

United States Legal Compliance

You represent and warrant that (i) You are not located in a country that is subject to the United States government embargo, or that has been designated by the United States government as a "terrorist supporting" country, and (ii) You are not listed on any United States government list of prohibited or restricted parties.

Severability and Waiver

Severability

If any provision of these Terms is held to be unenforceable or invalid, such provision will be changed and interpreted to accomplish the objectives of such provision to the greatest extent possible under applicable law and the remaining provisions will continue in full force and effect.

Waiver

Except as provided herein, the failure to exercise a right or to require performance of an obligation under these Terms shall not effect a party's ability to exercise such right or require such performance at any time thereafter nor shall the waiver of a breach constitute a waiver of any subsequent breach.

Translation Interpretation

These Terms and Conditions may have been translated if We have made them available to You on our Service. You agree that the original English text shall prevail in the case of a dispute.

Changes to These Terms and Conditions

We reserve the right, at Our sole discretion, to modify or replace these Terms at any time. If a revision is material We will make reasonable efforts to provide at least 30 days' notice prior to any new terms taking effect. What constitutes a material change will be determined at Our sole discretion.

By continuing to access or use Our Service after those revisions become effective, You agree to be bound by the revised terms. If You do not agree to the new terms, in whole or in part, please stop using the website and the Service.

Contact Us

If you have any questions about these Terms and Conditions, You can contact us:

• By email: info@1000trax.com

Privacy Policy and Privacy

1000TRAX respects your privacy. This Privacy Statement describes your privacy rights and our obligation to secure your personal data.
1000TRAX is a European company with legal entities, business processes, management structures and technical systems across borders. 1000TRAX provides software and services to private companies (Customers) in Europe. 1000TRAX's head office is located 83 Roberts Road
Colchester, Essex, CO2 7FQ in United Kingdom, and 1000TRAX is subject to European Personal Data Law, including the General Data Protection Regulation (GDPR).

Scope and acceptance

— When and in what context does this Privacy Policy apply?

This Privacy Statement applies to all business processes and to all 1000Trax websites, domains, mobile solutions, cloud services and communities, and 1000Trax branded websites. Service-specific supplements can be found in 1000TRAX Terms, Data Processing Agreements or equivalent information for that specific service.
The Privacy Statement provides information about the data processing carried out by 1000TRAX when 1000TRAX determines for what purpose and assistive means the processing is carried out (1000TRAX acts as controller). It also provides information about the data processing that 1000TRAX performs on behalf of our Customers based on their instructions (Customer as Data Controller and 1000TRAX as Data Processor).
Personal data is information that can identify you as a person, such as email address, postal address or telephone number, etc. It is necessary for us to process your personal data in order to serve our Customers. Please do not use 1000TRAX Pages or our Mobile App if you are unable to accept the way we process personal data under this Privacy Statement.

Who's data we process

— Who's personal data does 1000TRAX process?

1000TRAX processes personal information about contacts or software users associated with our Customers. We also process personal data about people who make up potential Customers (Leads) and who address us through 1000TRAX Pages or through other channels. Our statement in these respects can be found in the section '1000TRAX as data controllable'.
We also process data on behalf of our Customers, where the Customer controls the processing. Our statement in these respects can be found in the section '1000TRAX as data processor. '
In this Privacy Statement, data subjects may also be referred to as persons or you/you.

1000TRAX as a Data Controller

— How does 1000TRAX process personal data in its role as a data controller?

1000TRAX acts as a data controller in scenarios where 1000TRAX collects personal data, in the context of you being a representative of a Customer or a Level, or when you are a software user.

Why we process personal data

About Customer Contacts and Software Users

In order to generally manage our Customer Relations and to meet our Customer obligations, 1000TRAX needs information about you in your role as a Customer Contact or User of a Service. The purposes of processing this personal data are:
(a) to carry out the sales and contract process to Customers
(b) provide the requested offers of products and services to Customers
(c) to complete deliveries in accordance with agreements concluded with you or Customers
d) to offer support to users of our products and services
e) improve and develop the quality, functionality and user experience of our products, services and 1000TRAX Pages
(f) detect, limit and prevent security threats and carry out maintenance, troubleshooting and debugging
(g) prevent misuse of our products and services;
(h) process orders, invoicing, payments and other financial follow-up
(i) to create interest profiles to promote relevant products and services;
The legal basis for processing personal data according to the purposes stated above in letter (a) to (i) is primarily based on the fact that from a business perspective 1000TRAX has a legitimate interest in processing your personal data in a manner which, in our opinion, is not in conflict with your rights regarding privacy and self-determination.

About Leads

1000TRAX processes personal data on Leads for marketing purposes. In order to deliver targeted and relevant content to potential Customers, 1000TRAX builds an interest profile based on your activity and choices and actions on 1000TRAX Pages as well as your response to marketing content by email. The legal basis for such processing is primarily your consent.
In the sections below you can read how we form such profiles, how you can adjust the profile, as well as how to revoke your consent.

About Software User

You are a Software user when you, as a registered user, use 1000TRAX or 1000TRAX Mobile App. The legal basis for such processing is your consent.

How we collect your personal data

Generally, 1000TRAX collects personal data directly from you or other persons associated with our Customer. These individuals can be a manager or colleague.
We also use cookies and other tracking technologies when you use 1000TRAX Pages or 1000TRAX Mobile App and when you interact with us by email to optimize your experience of 1000TRAX and our sites. Please refer to the 'Automatic Data Collection Tools' section for more information on how these technologies work and your rights in this context.
In some cases, we may also collect information about you from other sources. These sources may be 1000TRAX's marketing partners, public sources or third-party social networks. 1000TRAX will be able to combine personal data about you collected from one source with information obtained from another source. This gives us a more complete picture of you, which also allows us to serve you in a more relevant way with a higher level of personalization.

Cookies

What personal data we process

The type of personal data 1000TRAX processes about you may be:
> Basic contact information, such as name, address, phone number and email
> Feedback, comments or questions regarding 1000TRAX or our products and services
> Usage Patterns in Listening Behavior.
> Unique user information, such as login ID, username, password and security questions
> Financial information, such as credit card information
> ClickStream behavior and activity on 1000TRAX Pages and in our products and services
> Email behavior, such as which emails from 1000TRAX you open when and how
> Other personal data contained in your profile that you have freely provided on third-party social networks, such as LinkedIn etc.
As a data controller, 1000TRAX does not process sensitive personal data about you.

How we share your personal data

1000TRAX may share your personal data with external third parties in the following contexts:

Business Partners

1000TRAX may share your personal information with our partners if this is legitimate from a business perspective and is in accordance with applicable data protection laws. For example, if you purchase, on behalf of your employer, a product or service that 1000TRAX provides through one of our certified partners. In this regard, 1000TRAX and our partner may share personal data in order to be able to provide the product or service to the Customer.

Public authorities

Police and other authorities may require personal information from 1000TRAX to be handed over. In these cases, 1000TRAX will only disclose the information if there is a court order, etc., bidding to do so.

Subcontractors

Your rights

What rights do you have?

The right to opt out of marketing communications.

You can unsubscribe from 1000TRAX news emails and marketing at any time with a click on our link in our newsletter or by writing to support@1000trax.com
Please note that even if you opt out of receiving marketing communications, you may still receive administrative notices from 1000TRAX, such as order confirmations and notifications necessary to manage your account or the services provided to our Customers.

Basic rights

You have the right to access your personal data by requesting an overview of personal data about you, and you may have a right to data portability. You also have the right to request 1000TRAX to correct inaccuracies in your personal data. If you have an account with 1000TRAX, this can usually be done through the appropriate “your settings” or “your profile” sections on the appropriate 1000TRAX Page or in the application.
You also have the right to request the deletion of personal data and to limit or object to our processing of your personal data under this Privacy Statement or other service-specific terms.
Please use support@1000trax.com to submit all requests as mentioned in this section. Finally, you also have the right to lodge a complaint with the Data Protection Authority regarding our processing of your personal data.

Data security and storage

— How does 1000TRAX secure and store your personal data?

How we secure your personal data

1000TRAX takes the trust you and our Customers show us very seriously. 1000TRAX undertakes to avoid unauthorized access, disclosure or other deviant processing of personal data. 1000TRAX must ensure the confidentiality of the personal data we process, maintain integrity of personal data and ensure its availability in accordance with applicable privacy laws.
As part of our obligations, we take reasonable and appropriate organizational, technical and physical procedures and precautions to protect the information we collect and process, taking into account the type of personal data and the risk you and our Customers are exposed to by As there is a high likelihood that the root causes of personal data breaches can be found internally, we believe that building a strong corporate culture where respect for and vigilance about data protection among our employees is fundamental to to ensure the lawful processing and protection of your information. The following precautions are of particular importance in this regard:

Organizational

> E-learning courses in data protection, which are mandatory for all employees.
> Data processing agreements with subcontractors that process data on behalf of 1000TRAX.

Technical

> Classification of personal data that ensures the implementation of security measures at the level of risk assessment.
> Assess the use of encryption and pseudonymization as risk mitigation measures.
> Restrict access to personal data to those persons who need it for the fulfillment of obligations arising from agreements or legislation concluded, etc.
> Use systems that detect, prevent and warn of any breach of personal data security.
> Use security reassessments to analyze whether existing technical and organizational measures are sufficient for the protection of personal data in the light of the requirements set out in applicable data protection legislation.

Physical

> Locations are protected by access control and video surveillance systems.

How long do we keep your personal data?

1000TRAX will retain your personal data only for as long as necessary for the purposes stated, while taking into account our need to respond to inquiries and resolve issues and comply with legal requirements under applicable law.
This means that 1000TRAX may retain your personal data for a reasonable period of time after your and our Customer's last interaction with us. When the personal data we have collected is no longer needed, we delete it. We may process data for statistical purposes, but in such cases the data will be pseudonymized or anonymized.

1000TRAX as a data processor

— How does 1000TRAX process personal data in its role as a data processor?

1000TRAX provides many different services to our Customers. Most of our services involve processing Customers' data, including their personal data. The purposes of processing are determined by our customers, not by 1000TRAX. This makes the Customer the controller. In such cases 1000TRAX acts as a data processor and processes the data on behalf of and in accordance with instructions given by the Customer. The relationship between the Customer as Data Controller and 1000TRAX as Data Processor shall be governed by a Data Processor Agreement.
Customer's and 1000Trax's liabilities
When the Customer acts as Data Controller, the Customer shall, in accordance with applicable data protection laws, ensure the legal basis for processing personal data. The customer must also assess and establish the ownership of the risks to which data subjects are exposed through the processing of their personal data. Another important aspect of Customer's obligations as data controller is to comply with the disclosure obligation in relation to data subjects.
1000TRAX is a natural part of Customer's obligations as Data Controller in the sense that 1000Trax's services constitute parts of the processing of personal data that the Customer must ensure is in compliance with applicable data protection laws. Thus, when 1000TRAX processes personal data on behalf of its Customers, we must do so in accordance with applicable data protection laws for data processors.
In short, the Customer and 1000TRAX are obliged to cooperate to ensure the privacy of data subjects. 1000TRAX provides the necessary information to the Customer so that it can act in accordance with applicable data protection laws.

Subcontractors and export of personal data

— To what extent does 1000TRAX use subcontractors?

1000TRAX uses subcontractors to process personal data and, in this regard, may export your or our Customers' data to a non-EU location. These subcontractors are typically vendors of cloud services or other IT hosting services.
When using subcontractors, 1000TRAX will enter into a data processing agreement (DPA) with subcontractors to secure your personal data rights and to fulfill our obligations to our Customers. When subcontractors are located outside the EU, 1000TRAX ensures the legal basis for such international transfers on behalf of you or our Customers, including by endorsing Privacy Shield (US) or by making use of EU Model Clauses.
1000TRAX supports some strategic external third parties that support our business processes and provide our cloud services.

Changes to this Statement

If we change our Privacy Statement, we will publish the revised statement here with an updated audit date. We encourage you to review the Statement regularly. If we make significant changes to our Statement that significantly alter our privacy practices, we may also communicate this to you in other ways, such as by sending an email or by posting a notice on our Group website and/or at social media before the changes take effect.
This Privacy Statement was updated on June 24, 2022.

How to contact

We value your opinion. If you have any comments or questions regarding our Privacy Statement, unresolved privacy and data usage issues, or a possible breach of your privacy, please send them to info@1000trax.com.
We will process your requests confidentially. Our representative will contact you to deal with your issues and outline the options for resolving these. It is our aim to ensure that complaints are resolved in a timely and appropriate manner.