1. Introduction

This GDPR Privacy Addendum (the "GDPR Privacy Addendum") supplements the information contained in our Privacy Notice (our "Privacy Notice") and applies solely to the users of our Website who are located in the European Economic Area ("EEA"), the United Kingdom, or Switzerland. We adopt this GDPR Privacy Addendum to comply with the European Union's General Data Protection Regulation, and any laws implementing the foregoing by any member states of the European Economic Area, the United Kingdom (including the UK Data Protection Act and the UK-GDPR), and/or Switzerland (collectively, the "GDPR"). Unless otherwise defined in this GDPR Privacy Addendum, any terms defined in the GDPR or our Privacy Notice have the same meaning when used in this GDPR Privacy Addendum. When this GDPR Privacy Addendum is applicable to you, it takes precedence over anything contradictory in our Privacy Notice.

2. Data Controller and Representative

Tracer Labs UK Limited is the data controller of your Personal Data. Tracer has appointed a Data Protection Officer in both the European Union and the United Kingdom in compliance with the GDPR and the UK Data Protection Act and UK-GDPR. At this time, Tracer is not required to appoint representatives in either the European Union or the United Kingdom and has elected not to do so. Tracer or its Data Protection Officer may be contacted in any manner set forth below in the Contact Information Section of this GDPR Privacy Addendum.

3. Information We Collect About You and How We Collect It

The Personal Data we collect and the ways in which we collect it are described in our Privacy Notice.

We only place non-essential cookies on your device and use other interaction and/or performance monitoring tools with your affirmative consent. You may withdraw or change your consent at any time by accessing our cookie consent manager through the "Cookies Setting" link on our Website. You may also set your browser to refuse all or some browser cookies (which may include essential cookies), or to alert you when cookies are being sent. However, if you do not consent to our use of cookies or select this setting you may be unable to access certain parts of our Website.

4. Lawful Basis for Processing Your Personal Data

The processing of your Personal Data is lawful only if it is permitted under the GDPR. We have a lawful basis for each of our processing activities (except when an exception applies as described below):

  • Consent. By using our Website, you consent to our collection, use, and sharing of your Personal Data as described in our Privacy Notice and this GDPR Privacy Addendum. If you do not consent to the terms of our Privacy Notice and this GDPR Privacy Addendum, please do not use the Website;

  • Legitimate Interests. We will process your Personal Data as necessary for our legitimate interests. Our legitimate interests are balanced against your rights and freedoms and we do not process your Personal Data if your rights and freedoms outweigh our legitimate interests. We process your Personal Data only so far as is necessary to achieve the purpose outlined in our Privacy Notice. Our processing activities will not unreasonably intrude on your privacy and help us optimize the provision of our Website to you. Specifically, we rely on several legitimate interests for processing your Personal Data including, but not limited to: (i) facilitating communications between Tracer and you; (ii) managing our relationship with you; (iii) providing you information about your Tracer products or account; (iv) operating, administering, and protecting our business, Website, and IT infrastructure; (v) detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity; (vi) providing access to, as well as researching, developing, improving, and/or customizing our Website and product offerings; (vii) understanding how our customers interact with the Website to enhance user experience and functionality; (viii) providing quality customer support; (ix) growing our business; and (x) verifying your identity, and detecting and preventing fraud;

  • To Fulfill Our Obligations to You under our Contract. We process your Personal Data in order to fulfill our obligations to you pursuant to our contract with you to deliver our goods and services to you, where applicable; and

  • As Required by Law. We may also process your Personal Data when we are required or permitted to by law; to comply with government inspections, audits, and other valid requests from government or other public authorities; to respond to legal process such as subpoenas; or as necessary for us to protect our interests or otherwise pursue our legal rights and remedies (for instance, when necessary to prevent or detect fraud, attacks against our network, or other criminal and tortious activities), defend litigation, and manage complaints or claims.

5. Special Categories of Information

Tracer does not ask you to provide, and we do not knowingly collect, any special categories of Personal Data from you.

6. Automated Decision Making

Tracer does not use your Personal Data with any automated decision-making process, including profiling, which may produce a legal effect concerning you or similarly significantly affect you.

7. How We Use and Disclose Your Information

With the exception of certain cookies described below, we use your Personal Data in the same manner set out in our Privacy Notice and do not share or otherwise disclose your Personal Data other than to the entities and for the purposes discussed in our Privacy Notice.

  • Cookies: Except for those cookies that are strictly necessary for the operation of our Website, we will only use cookies if we have your explicit consent to use them in the UK and the EEA. Please bear in mind that if you have given your consent to a cookie, you may withdraw your consent at any time by adjusting the cookie settings on our Website.

8. Disclosure of Your Information

We do not share or otherwise disclose your Personal Data for purposes other than to the entities and for the purposes described in our Privacy Notice.

9. Your Rights Regarding Your Information and Accessing and Correcting Your Information

The GDPR provides you with certain rights with regards to our processing of your Personal Data. These rights replace the similar rights provided in our Privacy Notice or are supplemental to such rights.

  • Access and Update. You may notify us through the Contact Information below of any changes or errors in any Personal Data we have about you to ensure that it is complete, accurate, and as current as possible. We may not be able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect.

  • Restrictions. You have the right to restrict our processing of your Personal Data under certain circumstances. In particular, you can request we restrict our use of it if you contest its accuracy, if the processing of your Personal Data is determined to be unlawful, or if we no longer need your Personal Data for processing but we have retained it as permitted by law.

  • Withdrawal of Consent. To the extent that our processing of your Personal Data is based on your consent, you may withdraw your consent at any time by contacting us through the Contact Information below. Withdrawing your consent will not, however, affect the lawfulness of the processing based on your consent before its withdrawal, and will not affect the lawfulness of our continued processing that is based on any other lawful basis for processing your Personal Data.

  • Right to be Forgotten. You have the right to request that we delete all of your Personal Data. We may not accommodate a request to erase information if we believe the deletion would violate any law or legal requirement or cause the information to be incorrect. In all other cases, we will retain your Personal Data as set forth in this policy. In addition, we cannot completely delete your Personal Data as some data may rest in previous backups. These will be retained for the periods set forth in our disaster recovery policies. Proper access and use of information provided on the Website is governed by our Terms of Use.

  • Complaints. You have the right to lodge a complaint with the applicable supervisory authority in the country you live in, the country you work in, or the country where you believe your rights under applicable data protection laws have been violated. However, before doing so, we request that you contact us directly in order to give us an opportunity to work directly with you to resolve any concerns about your privacy.

  • How You May Exercise Your Rights. You may exercise any of the above rights by contacting us through any of the methods listed under Contact Information below. If you contact us to exercise any of the foregoing rights, we may ask you for additional information to verify your identity. We reserve the right to limit or deny your request if you have failed to provide sufficient information to verify your identity or to satisfy our legal and business requirements. Please note that if you make unfounded, repetitive, or excessive requests (as determined in our reasonable discretion) to access your Personal Data, you may be charged a fee subject to a maximum set by applicable law.

In order to provide our Website, we may send and store your Personal Data outside of the EEA or the United Kingdom, including to the United States. Accordingly, your Personal Data may be transferred outside the country where you reside or are located, including to countries that may not or do not provide an equivalent level of protection for your Personal Data. Your information may be processed and stored in the United States and United States federal, state, and local governments, courts, or law enforcement or regulatory agencies may be able to obtain disclosure of your information through the laws of the United States. By using our Website, you represent that you have read and understood the above and hereby consent to the storage and processing of Personal Data outside the country where you reside or are located, including in the United States.

Your Personal Data is transferred by Tracer to another country only if it is required or permitted under the GDPR and provided that there are appropriate safeguards in place to protect your Personal Data. To ensure your Personal Data is treated in accordance with our Privacy Notice and this GDPR Privacy Addendum when we transfer it to a third party, Tracer uses Data Protection Agreements between Tracer and all other recipients of your data that include, where applicable, the standard contractual clauses adopted by the European Commission and/or the Information Commissioner's Office in the United Kingdom (collectively, the "Standard Contractual Clauses") where required by law. The European Commission and the Information Commissioner's Office in the United Kingdom have determined that the transfer of Personal Data pursuant to the Standard Contractual Clauses provides for an adequate level of protection of your Personal Data, however, the Standard Contractual Clauses may need to be supplemented in some cases with additional measures on a case-by-case basis after an analysis that such supplemental measures can provide you with an essentially equivalent level of protection as afforded in the EEA and/or the UK. When, as a result of this analysis, we believe this to be appropriate and necessary, the Standard Contractual Clauses have been supplemented in this way. Under these Standard Contractual Clauses, you have the same rights as if your Personal Data was not transferred to such third country.

11. Data Retention Periods

We will retain your Personal Data for as long as is necessary for the purposes set out in this GDPR Privacy Addendum (e.g., for as long as you maintain an account with us) or you request us to delete your Personal Data (subject to above), unless a longer period is required by applicable law, or is necessary to resolve disputes, protect our legal rights, or comply with legal obligations.

Where we are processing Personal Data based on our legitimate interests, we generally will retain the data for a reasonable period of time based on the particular interest, taking into account the fundamental interests and the rights and freedoms of data subjects.

Where we are processing Personal Data based on your consent, we generally will retain the information for the period of time necessary to carry out the processing activities to which you consented, subject to your right, under certain circumstances, to have certain of your Personal Data erased (see Your Rights).

12. Changes to This GDPR Privacy Addendum

We may change this GDPR Privacy Addendum at any time. It is our policy to post any changes we make to our GDPR Privacy Addendum on this page. The date this GDPR Privacy Addendum was last updated is identified at the top of the page. You are responsible for periodically visiting our Website and this GDPR Privacy Addendum to check for any changes.

13. Contact Information

If you have any questions, concerns, complaints, or suggestions regarding our Privacy Notice or this GDPR Privacy Addendum, have any requests related to your Personal Data described in the Privacy Notice or this GDPR Privacy Addendum, or otherwise need to contact us, you may contact us at the contact information below.

To Contact Tracer (Controller)

Tracer Labs UK Limited
Knights Plc Majestic
City Square, Leeds
LS1 2EF
United Kingdom
Email: privacy@tracer.tech

To Contact Our Data Protection Officer

Andrew Johnston
Email: ajohnston@tracer.tech