TRKX, INC. PRIVACY NOTICE FOR CALIFORNIA RESIDENTS
Effective Date: 01/01/2020
Last Reviewed on: September 24, 2019
This Privacy Notice for California Residents supplements the information contained in TRKX, Inc.’s
www.trkx.com/privacy and applies solely to all visitors, users, and
others who reside in the State of California (”consumers” or “you”). We adopt this notice to comply with
the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same
meaning when used in this notice.
Information We Collect
Our Website collects information that identifies, relates to, describes, references, is capable of being
associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device
(”personal information”). In particular, TRKX, Inc.’s website, www.TRKX.com, has collected the
following categories of personal information from its consumers within the last twelve (12) months:
Category Examples Collected
A. Identifiers. A real name, alias, postal address, unique personal identifier,
online identifier, Internet Protocol address, email address,
account name, Social Security number, driver’s license
number, passport number, or other similar identifiers.
categories listed in
statute (Cal. Civ.
A name, signature, Social Security number, physical
characteristics or description, address, telephone number,
passport number, driver’s license or state identification card
number, insurance policy number, education, employment,
employment history, bank account number, credit card
number, debit card number, or any other financial
information, medical information, or health insurance
Some personal information included in this category may
overlap with other categories.
under California or
Age (40 years or older), race, color, ancestry, national origin,
citizenship, religion or creed, marital status, medical
condition, physical or mental disability, sex (including
gender, gender identity, gender expression, pregnancy or
childbirth and related medical conditions), sexual orientation,
veteran or military status, genetic information (including
familial genetic information).
Records of personal property, products or services purchased,
obtained, or considered, or other purchasing or consuming
histories or tendencies.
Genetic, physiological, behavioral, and biological
characteristics, or activity patterns used to extract a template
or other identifier or identifying information, such as,
fingerprints, faceprints, and voiceprints, iris or retina scans,
keystroke, gait, or other physical patterns, and sleep, health, or
F. Internet or other
Browsing history, search history, information on a
consumer’s interaction with a website, application, or
Physical location or movements. YES
H. Sensory data. Audio, electronic, visual, thermal, olfactory, or similar
I. Professional or
Current or past job history or performance evaluations. YES
and Privacy Act (20
1232g, 34 C.F.R.
Education records directly related to a student maintained by
an educational institution or party acting on its behalf, such as
grades, transcripts, class lists, student schedules, student
identification codes, student financial information, or student
drawn from other
Profile reflecting a person’s preferences, characteristics,
psychological trends, predispositions, behavior, attitudes,
intelligence, abilities, and aptitudes.
Personal information does not include:
• Publicly available information from government records.
• Deidentified or aggregated consumer information.
• Information excluded from the CCPA’s scope, like:
• health or medical information covered by the Health Insurance Portability and Accountability
Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or
clinical trial data;
• personal information covered by certain sector-specific privacy laws, including the Fair Credit
Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial
Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
TRKX, Inc. obtains the categories of personal information listed above from the following categories of
• Directly from you. For example, from forms you complete or products and services you purchase.
• Indirectly from you. For example, from observing your actions on our Website or App.
• Directly and indirectly from activity on our website (www.trkx.com). For example, from
submissions through our Website and App portal or Website and App usage details collected
• From third-parties that interact with us or provide services to us in connection with the services we
perform and provide for you. For example, from technology providers when we use them to process
payments for you and track user mileage or other information.
Use of Personal Information
We may use, sell, or disclose the personal information we collect for one or more of the following
• To fulfill or meet the reason you provided the information. For example, if you share your name and
contact information to request a price quote or ask a question about our products or services, we will
use that personal information to respond to your inquiry. If you provide your personal information to
purchase a product or service, we will use that information to process your payment and facilitate
delivery. We may also save your information to facilitate new product orders or process returns.
• To provide, support, personalize, and develop our Website, App, products, and services.
• To create, maintain, customize, and secure your account with us.
• To process your requests, purchases, transactions, and payments and prevent transactional fraud.
• To provide you with support and to respond to your inquiries, including to investigate and address
your concerns and monitor and improve our responses.
• To personalize your Website and/or App experience and to deliver content and product and service
offerings relevant to your interests, including targeted offers and ads through our Website, our App,
third-party sites, and via email or text message (with your consent, where required by law).
• To help maintain the safety, security, and integrity of our Website, our App, products and services,
databases and other technology assets, and business.
• For testing, research, analysis, and product development, including to develop and improve our
Website, our App, products, and services.
• To respond to law enforcement requests and as required by applicable law, court order, or
• As described to you when collecting your personal information or as otherwise set forth in the CCPA.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale
or transfer of some or all of TRKX, Inc.’s assets, whether as a going concern or as part of bankruptcy,
liquidation, or similar proceeding, in which personal information held by TRKX, Inc. about our
Website and/or App users is among the assets transferred.
TRKX, Inc. will not collect additional categories of personal information or use the personal information
we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information
TRKX, Inc. may disclose your personal information to a third party for a business purpose or sell your
personal information, subject to your right to opt-out of those sales (see Personal Information Sales
Opt-Out and Opt-In Rights). When we disclose personal information for a business purpose, we enter a
contract that describes the purpose and requires the recipient to both keep that personal information
confidential and not use it for any purpose except performing the contract. The CCPA prohibits third
parties who purchase the personal information we hold from reselling it unless you have received explicit
notice and an opportunity to opt-out of further sales.
We share your personal information with the following categories of third parties:
• Service providers.
• Data aggregators.
• Payment Processors.
• Other users of the Website and App.
Disclosures of Personal Information for a Business Purpose
In the preceding twelve (12) months, Company has not disclosed personal information for a business
We may in the future disclose your personal information for a business purpose to the following categories
of third parties:
• Service providers.
Sales of Personal Information
In the preceding twelve (12) months, Company had not sold personal information.
We may in the future sell your personal information to the following categories of third parties:
• Data aggregators.
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal
information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that TRKX, Inc. disclose certain information to you about our collection and
use of your personal information over the past 12 months. Once we receive and confirm your verifiable
consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:
• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability
• If we sold or disclosed your personal information for a business purpose, two separate lists
• sales, identifying the personal information categories that each category of recipient purchased;
• disclosures for a business purpose, identifying the personal information categories that each
category of recipient obtained.
Deletion Request Rights
You have the right to request that TRKX, Inc. delete any of your personal information that we collected
from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable
consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and
direct our service providers to delete) your personal information from our records, unless an exception
We may deny your deletion request if retaining the information is necessary for us or our service
• Complete the transaction for which we collected the personal information, provide a good or service
that you requested, take actions reasonably anticipated within the context of our ongoing business
relationship with you, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or
prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or
exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et.
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest
that adheres to all other applicable ethics and privacy laws, when the information’s deletion may
likely render impossible or seriously impair the research’s achievement, if you previously provided
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your
relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which
you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable
consumer request to us by either:
• Calling us at (800) 574-TRKX (8759)
• Visiting www.TRKX.com
• Emailing us at firstname.lastname@example.org
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request
related to your personal information. You may also make a verifiable consumer request on behalf of your
You may only make a verifiable consumer request for access or data portability twice within a 12-month
period. The verifiable consumer request must:
• Provide sufficient information that allows us to reasonably verify you are the person about whom we
collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and
respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your
identity or authority to make the request and confirm the personal information relates to you.
Making a verifiable consumer request does not require you to create an account with us. However, we do
consider requests made through your password protected account sufficiently verified when the request
relates to personal information associated with that specific account.
We will only use personal information provided in a verifiable consumer request to verify the requestor’s
identity or authority to make the request.
For instructions on exercising sale opt-out rights, see Personal Information Sales Opt-Out and Opt-In
Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we
require more time (up to 45 days), we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do not have an
account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer
request’s receipt. The response we provide will also explain the reasons we cannot comply with a request,
if applicable. For data portability requests, we will select a format to provide your personal information
that is readily useable and should allow you to transmit the information from one entity to another entity
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive,
repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why
we made that decision and provide you with a cost estimate before completing your request.
Personal Information Sales Opt-Out and Opt-In Rights
If you are 16 years of age or older, you have the right to direct us to not sell your personal information at
any time (the “right to opt-out”). We do not sell the personal information of consumers we actually know
are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either
the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13
years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time.
Although we do not currently sell personal information to third-parties, if we do in the future, we will
notify you and provide you with a link to a page where you can submit your opt-out notice.
Once you make an opt-out request, we will wait at least twelve (12) months before asking you to
reauthorize personal information sales.
You do not need to create an account with us to exercise your opt-out rights. We will only use personal
information provided in an opt-out request to review and comply with the request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the
CCPA, we will not:
• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or
other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or
quality of goods or services.
However, we may offer you certain financial incentives permitted by the CCPA that can result in
different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably
relate to your personal information’s value and contain written terms that describe the program’s material
aspects. Participation in a financial incentive program requires your prior opt in consent, which you may
revoke at any time.
Other California Privacy Rights
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are
California residents to request certain information regarding our disclosure of personal information to
third parties for their direct marketing purposes. To make such a request, please send an email to
info@TRKX.com or write us at: 11487 San Fernando Road, San Fernando, CA 91340.
Changes to Our Privacy Notice
TRKX, Inc. reserves the right to amend this privacy notice at our discretion and at any time. When we
make changes to this privacy notice, we will post the updated notice on the Website and update the
notice’s effective date. Your continued use of our Website following the posting of changes
constitutes your acceptance of such changes.
If you have any questions or comments about this notice, the ways in which TRKX, Inc. collects and uses
or wish to exercise your rights under California law, please do not hesitate to contact us at:
Phone: (800) 574-TRKX (8759)
11487 San Fernando Road
San Fernando, CA 91340
Attn: Ryan wong