November 1, 2018
When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.
“Personal Information” is information that identifies you as an individual or relates to an identifiable individual, including:
- Postal address (including billing and shipping addresses)
- Mobile phone number
- Email address
- Credit or debit card number
- Profile picture (Optional)
- Social media account ID
- Luggage pictures
- Tracking device ID
LugTrack (“we,” “us,” “our,” and “LugTrack”) is a global provider of luggage tracking solutions (the “Services”) that includes the Track&Go tracking device (the “Device”) and the Track&Go apps for mobile devices (the “Apps”). We are headquartered at 225 US Highway 35, Suite #201, Red Bank, New Jersey 07701, United States.
Collection of Personal Information
We collect Personal Information in a variety of ways, including:
i.) Information you provide to us: In the course of engaging with our Services, you may provide Personal Information about you. Personal Information is often, but not exclusively, provided to us when you sign up for and use the Services, consult with our customer service team, send us an email, or communicate with us in any other way.
- Registration information: You need a LugTrack account to use the app Services. When you register for an account, you will be asked to provide certain basic information, such as your name, email address, sex, username, password, and phone number.
ii.) Information we collect automatically: When you use the Services, we will automatically collect certain information about your Device and usage of the Services. This information may include:
- Device information: We collect information about the Device and Apps you use to access the Services, such as your IP address, your operating system, your mobile device ID, and other information about your Device and connection. We collect the physical location of your Device by, for example, using satellite, cell phone tower or WiFi signals. We use your device’s physical location to provide you with personalized location-based services and content.
- Log data: Our web servers keep log files that record data each time a Device accesses those servers and those log files contain data about the nature of each access, including originating IP addresses and locations.
- Product usage data: We collect usage data about you whenever you interact with our Services, which may include the dates and times you access the Services, your Device’s data (location, movement, speed), and your location. We also collect information regarding the performance of the Services, including metrics related to the timely deliverability of emails and other communications your Devices send through the Services. This information allows us to improve the content and operation of the Services and facilitate research and analysis of the Services.
iii.) Information we collect from other sources: From time to time, we may obtain information about you from third-party sources, such as public databases, social media platforms, third-party data providers and our joint marketing partners. We take steps to ensure that such third parties are legally or contractually permitted to disclose such information to us.
Examples of the information we may receive from other sources include demographic information (such as age and gender), geographic mapping data, and online behavioral data (such as information about use of social media websites, page view information and search results and links). We use this information, alone or in combination with other information (including Personal Information) we collect, to enhance our ability to provide relevant content to you and to develop and provide you with more relevant products, features, and services.
- Device information: We may collect information about the type of device, operating system you use, and any location-based information from your mobile device while using our mobile Apps or Services.
- Product usage data: We may collect information about how often you use the application and other performance data.
Amazon Web Services, Inc. – 410 Terry Avenue North, Seattle, WA 98109-5210, USA. ATTN: AWS Legal.
Nexmo Limited – 5 New Street Square, London, England, EC4A 3TW.
AirFi Networks – Mindspace Aldgate, 114 Whitechapel High Street, London, E1 7PT, United Kingdom.
Children’s Personal Information
We don’t provide Services for purchase by children. If you are under 18 years of age, you may use our Services only with the consent of a parent or guardian.
How We Use Personal Information
We list below the specific purposes for which we collect your information, and how we and our service providers may use Personal Information:
- To deliver our Services to our customers. This includes delivering your communications to the intended service providers, authenticating you when you log into our Services, and operating and maintaining our Services.
- To communicate with you about the Services, including registration confirmations, purchase confirmations, expiration or renewal reminders, responding to your requests, and sending you notices, updates, security alerts, administrative messages, and other communications necessary to usage of the services.
- To respond to your inquiries and fulfill your requests, such as to complete your transactions and provide you with related customer service.
- To send administrative information to you, such as changes to our terms, conditions and policies, as well as marketing communications that we believe may be of interest.
- To personalize your experience on the Services by presenting products and offers tailored to you and to facilitate social sharing functionality.
- To engage in important supporting activities, such as billing and collections, including maintenance of records in the event of a subsequent billing dispute, data analysis, audits, fraud monitoring and prevention, violations of our acceptable use policies, developing new products, enhancing, improving or modifying our Services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities.
- To improve our services, to make them more reliable, secure, and useful to you and our users. We use data regarding the communications on our platform to understand how our services are performing and where they are being used in order to identify areas where we can do better. For instance, we may use message delivery and your Device’s physical location information to gauge the effectiveness of our Services and to ensure that our notifications delivery is timely and accurate.
- To comply with legal requirements. Applicable laws or regulations may require our processing of your data, such as laws mandating retention of communications data.
- To protect our legitimate business interests and legal rights. Where we believe it is necessary to protect our legal rights, interests and the interests of others, we use information about you in connection with legal claims, compliance, regulatory, and audit functions, and disclosures in connection with the acquisition, merger or sale of a business.
Legal Basis for Processing Personal Information of European Economic Area Persons
If you are from the EEA, our lawful basis to collect and use your Personal Information include;
- Our legitimate interest to improve, maintain, provide, and enhance our technology, and Services.
- Our need to comply with a legal obligation.
- You give us your consent to do so for a specific purpose.
Where required by law, we will collect Personal Information only where we have your consent to do so.
Disclosure of Personal Information
Your Personal Information may be disclosed to our third-party service providers who help us to deliver the Services (such as data storage and analysis, payment processing, communication technology and related Device provisioning, customer service, email and text messages delivery).
Other Uses and Disclosures
We also may use and disclose your Personal Information as we believe to be necessary or appropriate:
a.) To comply with applicable law, which may include laws outside your country of residence, to respond to requests from public and government authorities, which may include such authorities outside your country of residence, to cooperate with law enforcement, or for other legal reasons;
b.) To enforce our terms and conditions; and (c) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.
We may furthermore use, disclose or transfer your information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).
We may also use and disclose Personal Information collected through the Services in other ways, with your consent.
We take appropriate and reasonable technical, organizational and administrative measures to protect Personal Information from loss, misuse, unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in the processing and the nature of the Personal Information. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contacting Us” section below.
Choices and Access
If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.
To request deletion of your Personal Information, please contact us on the address provided in the “Contacting Us” section below. You should know that deletion of your Personal Information will result in you permanently losing access to your account and all Services data to which you previously had access through your account. Please note that certain data associated with that account may nonetheless remain on our servers in an aggregated or anonymized form that does not specifically identify you. Similarly, data associated with your account that we are required by law to maintain will also not be deleted. If you are an end user of our Apps, you should use the App to access and/or delete your Personal Information.
Consistent with applicable laws and data security requirements, we will reasonably honor written requests from you to access or amend your account information, such as name, address, and billing information. You are responsible for ensuring that the information on file with LugTrack is current and accurate. You may access and update your information by logging into your App account or contacting us as described in the “Contacting Us” section below.
If you are from the European Economic Area, you may have broader or additional rights, including:
- to be provided with a copy of your Personal Information held by us;
- to request the rectification or erasure of your Personal Information held by us;
- to request that we restrict the processing of your Personal Information (while we verify or investigate your concerns with this information, for example);
- to object to the further processing of your Personal Information,
- to request that your provided Personal Information be moved to a third party.
Where the processing of your Personal Information by us is based on consent, you have the right to withdraw that consent without detriment at any time by contacting us.
In your request, please make clear what Personal Information you would like to have changed, whether you would like to have your Personal Information suppressed from our database or otherwise let us know what limitations you would like to put on our use of your Personal Information. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.
Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion (e.g., when you make a purchase, you may not be able to change or delete the Personal Information provided until after the completion of such purchase).
The location history data that is associated with a Device, will be retained by Lugtrack for up to two (2) years. After that time, some of the information we have (such as anonymous location logs) may be aggregated and anonymized for statistical purposes and stored indefinitely. Other anonymous location data that is not associated with any unique identifier, Device ID or any other personally identifiable information may be stored indefinitely and used for purposes of improving and maintaining our service.
We ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Services or otherwise to us.
Cross Border Data Transfers
If you are located in the European Economic Area (“EEA”), AWS has certified to the EU-U.S. Privacy Shield Framework for the transfer of Personal Information from the EEA to the United States, as described in their Privacy Shield Notice. To learn more about the EU-U.S. Privacy Shield Framework and to view the certification, please visit https://aws.amazon.com/compliance/eu-us-privacy-shield-faq/
Because email communications are not always secure, please do not include credit card or other sensitive information in your emails to us.