Last updated: 16 May 2024

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This Privacy and Cookie Policy describes Our policies and procedures on the collection, use and disclosure of Your Personal Data when You use the Service and tells You about Your privacy rights and how the law protects You.

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We use Your Personal Data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy and Cookie Policy.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalised 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 this Privacy and Cookie Policy:

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

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.

Application refers to KeepTrackMed, the software program provided by the Company.

Company (referred to as either "the Company", "We", "Us" or "Our" in these Terms and Conditions) refers to Keep Track Solutions Ltd, a company registered in Scotland under company number SC742035 with its registered office at Clyde Offices, 2nd Floor, 48 West George Street, Glasgow, Scotland, G2 1BP. For the purpose of the Data Protection Legislation, the Company is the Data Controller.

Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.

Data Controller, for the purposes of the Data Protection Legislation (General Data Protection Regulation), refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.

Data Protection Legislation is the UK GDPR, the Data Protection Act 2018 and the Privacy and Electronic Communications (EC Directives) Regulations 2023.

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

Personal Data is any information that relates to an identified or identifiable individual. For the purposes of the Data Protection Legislation, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.

Service refers to the Application or the Website or both.

Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analysing how the Service is used. For the purpose of the Data Protection Legislation, Service Providers are considered Data Processors.

UK GDPR refers to the EU law retained version of the General Data Protection Regulation ((EU) (2016/679).

Website refers to KeepTrackMed, accessible from www.keeptrackmed.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. Under the Data Protection Legislation, You can be referred to as the Data Subject or as the User as You are the individual using the Service.

Collecting and Using Your Personal Data

Types of Data Collected

Identity Data

While using Our Service, You will be required to provide Us with a personal identifier, such as Your first name or Your initials, and We strongly advise against using any personally identifiable information, such as Your date of birth or national insurance number. We do not collect any other Identity Data about You through use of the Service. If You choose to input Your full name or other identifying data into the Service, this will be considered Identity Data. In cases where a surname is entered into the Service, we reserve the right to remove the surname and retain only the first name for privacy purposes. The Service has a feature whereby You can upload photos or files, which may include Your image of the image of those in Your family or group of users. These images are considered Identity Data. We do not collect any other Identity Data about You through use of the Service.

Contact Data

We will require that You provide Us with Contact Data so that We can provide You with the Service, contact You about Your Account, or deliver Your subscription. You may also provide Contact Data if You contact Us in respect of the Service.

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Contact Data includes phone numbers and email addresses.

Financial Data

As Our Service is available via a paid subscription, You will be required to provide Your Financial Data to the Service Provider responsible for collecting and processing payments.

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Financial Data includes bank account and payment card details.

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Please note that We do not ever have access to Your Financial Data – this is processed by the Service Provider responsible for collecting and processing payments.

Profile Data

This is information relating to Your Account with the Company, and includes Your username and password, purchases or orders made by You, Your interests, preferences, feedback, and survey responses. 

Usage Data

Usage Data is collected automatically when using the Service.

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Usage Data may include information such as Your Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of Our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

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When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

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We may also collect information that Your browser sends whenever You visit Our Service or when You access the Service by or through a mobile device.

Technical Data

Technical Data is collected automatically when using the Service.

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Technical Data may include internet protocol (IP) address, Your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the Devices You use to access the Service.

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Marketing and Communication Data

Marketing and Communication Data includes Your preferences in receiving marketing from us and Our third parties and Your communication preferences.

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You may receive marketing communications from Us if You have requested information from us or purchased goods or services from Us and You have not opted out of receiving that marketing. We will obtain Your express opt-in consent before We share Your Personal Data with any third party for marketing purposes.

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You can ask Us or third parties to stop sending You marketing messages at any time by following the opt-out links on any marketing message sent to You or by contacting Us at any time.

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Where You opt out of receiving these marketing messages, this will not apply to Personal Data provided to Us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

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Aggregated Data such as statistical or demographic data for any purpose, is not considered Personal Data in law as this data will not directly or indirectly reveal Your identity to Us. We may aggregate Your Usage Data to calculate the percentage of users accessing a specific Service feature.

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Health Data such as information directly inputted into the Service or represented in photos or files uploaded to the Service relating to Yourself or relating to those in Your family or group of users, relating to health, including without limitation information on medical conditions, prescriptions, medications, medical tests, vaccinations and symptoms. Health Data is considered a special category of Personal Data and is treated differently to other types of Personal Data, such that We must have your express consent to process it. By uploading the Health Data to the Service, whether in text or photo or other format, You are giving Your express consent to the processing of that Health Data and accordingly. We rely on consent and the performance of a contract when we process that Health Data. Please note, however, that We have no access to, nor can We see any Health Data of any kind that it uploaded to the Service, although it is still stored on our servers.

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Besides Health Data, We do not collect any other Special Categories of Personal Data about You (this includes details about Your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, and genetic and biometric data). It is however possible that You will upload to the Service Personal Data relating to health. We also do not collect any information about criminal convictions and offences.

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How is Your Personal Data Collected

We may use different methods to collect data from and about You including through:

Direct interactions. You may give us Your Identity and Contact by filling in forms, by corresponding or engaging with us by post, phone, email, social media or otherwise.

Your use of the Service. You may give us Your Identity and Contact and Health Data, or that of those in Your family or group of users, through use of the Service.

Automated technologies or interactions. As You interact with the Service, We will automatically collect Technical Data about Your equipment, browsing actions and patterns. We collect this Personal Data by using cookies, server logs and other similar technologies. We may also receive Technical Data about You if You visit other websites employing Our cookies. This is explained in this Privacy and Cookie Policy.

Third parties or publicly available sources. We may receive Personal Data about You from various third parties and public sources, such as Google, Companies House, or the electoral register.

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The lawful bases under which We use Your Personal Data

We will only process your Personal Data when We can rely on a legitimate (lawful) basis, such as:

Contract: Where We need to perform the contract, We are about to enter into or have entered into with You.

Legitimate Interests: Where it is necessary for Our legitimate interests (or those of a third party) and Your interests and fundamental rights do not override those interests.

Legal Obligation: Where We need to comply with a legal obligation.

Consent: Where You have provided Your express informed consent to the processing of Your personal data or the personal data belonging to a member of Your family or group that access the Service via Your account, which You can withdraw at any time as explained in this Privacy and Cookie Policy.

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Information Collected while Using the Application

While using Our Application, in order to provide features of Our Application, We may collect, with Your prior permission:

• Information regarding Your location

 

We use this information to provide features of Our Service, to improve and customise Our Service. The information may be uploaded to the Company’s servers and/or a Service Provider’s server or it may be simply stored on Your Device.

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You can enable or disable access to this information at any time, through Your Device settings.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information in accordance with the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 and the Data Protection Legislation to distinguish You from other users of Our Service. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyse Our Service. The technologies We use may include:

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• Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of Our Service. Unless You have adjusted Your browser setting so that it will refuse Cookies, Our Service may use Cookies.

• Web Beacons. Certain sections of Our Service and Our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

 

Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser.

We use both Session and Persistent Cookies for the purposes set out below:

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Necessary / Essential Cookies

Type: Session Cookies

Administered by: Us

Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.

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Cookies Policy / Notice Acceptance Cookies

Type: Persistent Cookies

Administered by: Us

Purpose: These Cookies identify if users have accepted the use of cookies on the Website.

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Functionality Cookies

Type: Persistent Cookies

Administered by: Us

Purpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering Your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter Your preferences every time You use the Website.

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For more information about the cookies We use and Your choices regarding cookies, please visit the Cookies section of Our Privacy and Cookie Policy.

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Use of Your Personal Data

The Company may use Personal Data for the following purposes:

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To provide and maintain Our Service, including to monitor the usage of Our Service. This includes Identity, Contact, Financial, Transaction, Marketing and Communications, Technical, Usage and Health Data. The lawful bases We rely on are contract and legitimate interests and, in the case of Health Data, consent.

To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user. This includes Identity, Contact, Financial, Transaction and Marketing and Communications Data.

For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.

To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation. This includes Identity, Contact, Profile, Usage and Technical Data. The lawful bases We rely on are contract and legitimate interests.

To provide You with news, special offers and general information about other goods, services and events which We offer that are similar to those that You have already purchased or enquired about unless You have opted not to receive such information. This includes Identity, Contact, Profile, Usage and Marketing and Communications Data. The lawful basis We rely on is legitimate interests.

To manage Your requests: To attend and manage Your requests to Us. This includes Identity, Contact and Profile Data. The lawful bases We rely on are contract and legitimate interests.

For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganisation, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about Our Service users is among the assets transferred.

For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of Our promotional campaigns and to evaluate and improve Our Service, products, services, marketing and Your experience. This includes Technical and Usage Data. The lawful basis We rely on is legitimate interests.

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We may share Your personal information in the following situations:

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• With Service Providers: We may share Your personal information with Service Providers to monitor and analyse the use of Our Service, for payment processing, to contact You.

• For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.

• With Affiliates: We may share Your information with Our Affiliates, in which case We will require those affiliates to honour this Privacy and Cookie Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.

• With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.

• With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.

• With Your consent: We may disclose Your personal information for any other purpose with Your consent.
   

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy and Cookie Policy. We will retain and use Your Personal Data to the extent necessary to comply with Our legal obligations (for example, if We are required to retain Your Personal Data to comply with applicable laws), resolve disputes, and enforce Our legal agreements and policies. To determine the appropriate retention period for Personal Data, We consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of Your Personal Data, the purposes for which We process Your Personal Data and whether We can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

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The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

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Transfer of Your Personal Data

We may transfer Your Personal Data outside of the UK or the European Economic Area (EEA) where We engage third parties to provide services on Our behalf, such as to receive services or deal with payment. Whenever We transfer Your Personal Data out of the UK or the EEA, We ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

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• We will only transfer Your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data

• Where We use certain service providers, We may use specific contracts approved for use in the UK which give Personal Data the same protection it has in the UK.

 

Please contact Us if You want further information on the specific mechanism used by Us when transferring Your Personal Data out of the EEA or the UK.

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Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy and Cookie Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

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• Comply with a legal obligation

• Protect and defend the rights or property of the Company

• Prevent or investigate possible wrongdoing in connection with the Service

• Protect the personal safety of Users of the Service or the public

• Protect against legal liability
   

Security of Your Personal Data

Data security is of great importance to Us, and to protect Your Personal Data We have put in place suitable physical, electronic, and managerial procedures to safeguard and secure Personal Data We collect. In addition, We limit access to Your Personal Data to those employees, agents, contractors and other third parties who have a business to know. They will only process Your Personal Data on Our instructions, and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected Personal Data breach and will notify You and any applicable regulator of a breach where We are legally required to do so.

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If there is an incident where We become aware that there has been a data breach, We will let You know without undue delay. We will then take all necessary steps, including informing the ICO, to limit the extent of the breach and to prevent a further reoccurrence.

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The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.
 

Detailed Information on the Processing of Your Personal Data

The Service Providers We use may have access to Your Personal Data. These third-party vendors collect, store, use, process and transfer information about Your activity on Our Service in accordance with their Privacy Policies.
 

Payments

We may provide paid products and/or services within the Service. In that case, We may use third-party services for payment processing (e.g. payment processors).

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We will not store or collect Your payment card details. That information is provided directly to Our third-party payment processors whose use of Your personal information is governed by their privacy policies. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

Google

Their privacy policy can be viewed at https://payments.google.com/payments/apis-secure/u/0/get_legal_document?ldo=0&ldt=privacynotice&ldl=en-GB

Apple

Their privacy policy can be viewed at https://www.apple.com/legal/privacy/en-ww/
 

Your Rights under the Data Protection Legislation

The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights.

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You have the right under this Privacy and Cookie Policy to:

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• Request access to Your Personal Data. The right to access, update or delete the information We have on You. Whenever made possible, You can access, update or request deletion of Your Personal Data directly within Your account settings section. If You are unable to perform these actions Yourself, please contact Us to assist You. This also enables You to receive a copy of the Personal Data We hold about You.

• Request correction of the Personal Data that We hold about You. You have the right to have any incomplete or inaccurate information We hold about You corrected.

• Object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation, which makes You want to object to Our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes.

• Request erasure of Your Personal Data. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.

• Request the transfer of Your Personal Data. We will provide to You, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.

• Withdraw Your consent. You have the right to withdraw Your consent on using Your Personal Data. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Service.
   

Exercising Your Rights

You may exercise Your rights of access, rectification, cancellation and opposition by contacting Us. Please note that We may ask You to verify Your identity before responding to such requests. If You make a request, We will try Our best to respond to You as soon as possible. You will not have to pay a fee to access Your Personal Data (or to exercise any of the other rights), but We can charge a reasonable fee if Your request is clearly unfounded, repetitive, or excessive, or We can refuse to comply in these circumstances.

 

We try to respond to all legitimate requests within one month, but it could take longer than a month if Your request is particularly complex or You have made a number of requests. In this case, We will notify You and keep You updated.
 

Information Commissioner’s Office

We are registered with the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (ico.org.uk), and Our registration number is C1311309. If You have any concerns about data protection, We would appreciate if You contacted us first so We can discuss these with You before You approach the ICO. You can reach us by email at info@keeptrackmed.com.
 

Notice for California Residents of Privacy Practices and Rights

If You are a California resident, California law may provide You with additional rights regarding Your Personal Data. The California Consumer Privacy Act (the "CCPA") as amended by the California Privacy Rights Act of 2020 (the "CPRA") gives You the following rights:

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• Right to know about the personal information We collect and share:

  • The CCPA gives You the right to request that We disclose the specific pieces of Personal Data We have collected about You;

  • Please see above for information on the Personal Data We collect on You, and how We process it; and

  • We do not sell Your Personal Data. However, We do disclose Your Personal Data to limited third parties, as described above.

• Right of deletion:

  • You have the right to request that We delete Your personal information, subject to certain exceptions

• If You wish to delete Your Personal Data that you have inputted into the Service, You can delete in by accessing the settings in the Subscription area of the Service. If You wish for Us to delete Your Personal Data that We hold about You, please contact Us at support@keeptrackmed.com  Please note that We may require certain information from You in order to verify Your identity before proceeding with Your request.

 

We collect the categories of personal information from You in connection with Your use of Our Service as described above. We will not discriminate against You for exercising any of Your CCPA rights.

Children's Privacy

Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13, however a parent or guardian may input Personal Data relating to children under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.

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If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the privacy policy of every site You visit.

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We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy and Cookie Policy

We may update Our Privacy and Cookie Policy from time to time. We will notify You of any changes by posting the new Privacy and Cookie Policy on this page.

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We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy and Cookie Policy.

 

You are advised to review this Privacy and Cookie Policy periodically for any changes. Changes to this Privacy and Cookie Policy are effective when they are posted on this page.

Contact Us

If You have any questions about this Privacy and Cookie Policy, You can contact Us:

• By email: info@keeptrackmed.com