GDPR Policy

1. GDPR Overview

The General Data Protection Regulation (GDPR) establishes consistent standards across the European Union for the protection of personal data and the privacy rights of individuals. It applies not only to organizations established in the EU, but also to organizations that process personal data relating to people in the EU in connection with offering services or monitoring activity.

Tech Face LLC is committed to privacy, security, and transparency. Where A-TRACK processes personal data on behalf of customers, Tech Face LLC generally acts as a processor or service provider and seeks to provide customers with practical tools and documentation that support their own GDPR compliance programs.

2. GDPR Basics

Under the GDPR, personal data should be processed lawfully, fairly, and transparently. It should be collected for specific and legitimate purposes, limited to what is necessary, kept accurate where appropriate, retained only as long as needed, and protected through appropriate security measures.

Individuals may also have rights of access, rectification, erasure, restriction, objection, portability, and the right to lodge a complaint with a supervisory authority, depending on the circumstances and applicable law.

3. What Data A-TRACK May Process

A-TRACK may process the following categories of information depending on how customers configure the service and what they choose to send:

• Account and business contact data, such as names, work email addresses, and billing or support contacts.
• Technical and request data, such as IP addresses, timestamps, session identifiers, API request metadata, and server access logs.
• Traffic source and attribution data, such as URL parameters, UTM tags, click identifiers, referrer fields, campaign IDs, ad metadata, and landing page context.
• Browser and device context, such as user agent strings, platform data, locale, timezone, screen and viewport dimensions, connection hints, and similar client-side signals.
• Customer-defined custom attributes or event properties that are submitted through the SDKs or APIs.

4. How Data May Be Collected

Tech Face LLC may receive personal data directly from customers or indirectly through the use of the Services. Data may be collected when a customer creates an account, configures an integration, sends events or session payloads to A-TRACK, contacts support, visits the website, or uses hosted product features.

Where customers deploy A-TRACK SDKs or APIs in their own products, they are responsible for determining what data is sent to the Services and for establishing an appropriate legal basis for doing so.

5. How Data May Be Used

Tech Face LLC may use personal data to provide and secure the Services, manage customer accounts, process transactions, operate APIs and SDKs, enrich attribution and session data, generate analytics and diagnostics, send usage or operational notices, respond to support requests, and meet legal or contractual obligations.

Tech Face LLC does not use Customer Data for purposes materially inconsistent with the applicable agreement or this policy.

6. Data Processing Addendum

A-TRACK provides a Data Processing Addendum that addresses processor obligations, security, subprocessors, international transfers, and related compliance matters.

See DPA.

7. Related Policies

Additional policy information may be provided in the following documents:

• Privacy Policy
• Cookie Policy
• Terms of Use

8. Data Subject Requests

Where Tech Face LLC processes personal data on behalf of a customer, that customer generally acts as the controller and is responsible for responding to data subject requests. Tech Face LLC will provide reasonable assistance to customers where required under applicable law and under the terms of the governing agreement or DPA.

9. International Transfers

Where Customer Data is transferred internationally, Tech Face LLC may rely on appropriate safeguards such as Standard Contractual Clauses, the UK Addendum, or other lawful transfer mechanisms, as described in the applicable Data Processing Addendum or customer agreement.

10. Subprocessors

Tech Face LLC may engage subprocessors to support hosting, infrastructure, analytics, security, monitoring, communications, payment operations, customer support, and related functions required to operate the Services. Subprocessors are contractually bound to protect personal data in a manner consistent with applicable law and the commitments made by Tech Face LLC to customers.

A detailed subprocessor list may be published separately or provided through customer documentation.

11. Security

Tech Face LLC maintains technical and organizational measures designed to protect personal data, including appropriate access controls, logging, monitoring, encryption in transit where applicable, internal process controls, and incident response procedures.