PRIVACY POLICY

Effective Date: [01/01/2026]

Last Updated: [03/03/2026]

Version: v1.0

1. Introduction

PTRACKLY CO., LTD (“Company”, “we”, “our”, “us”) is committed to protecting personal data and ensuring transparency in how data is collected, processed, and safeguarded.

This Privacy Policy applies to all users of our services, website, and platform (“Services”).

2. Scope

This policy applies to:

  • Customers and end users
  • Website visitors
  • Business partners interacting with our platform

3. Categories of Personal Data Collected

We collect and process the following categories of personal data:

3.1 Identity Data

  • Full name
  • Email address
  • Phone number

3.2 Technical Data

  • IP address
  • Browser type and version
  • Device identifiers
  • Log data (access logs, system activity)

3.3 Usage Data

  • User interactions with the platform
  • Feature usage and behavior analytics

3.4 Communication Data

  • Support requests
  • Feedback and inquiries

4. Lawful Basis for Processing (GDPR)

We process personal data under the following legal bases:

  • Consent: When users explicitly provide consent
  • Contractual Necessity: To provide our services
  • Legal Obligation: Compliance with applicable laws
  • Legitimate Interests: Security, fraud prevention, service improvement

5. Purpose of Data Processing

We process personal data for the following purposes:

  • Service delivery and account management
  • Customer support and communication
  • Platform security and monitoring
  • Compliance with regulatory and audit requirements
  • Internal analytics and product improvement

6. Data Sharing & Disclosure

We may share personal data with:

  • Service Providers: Hosting, cloud infrastructure, analytics tools
  • Auditors & Compliance Partners: For certification and compliance verification
  • Regulatory Authorities: When required by law

We do not sell personal data.

7. Data Retention Policy

We retain personal data based on:

  • Duration of service usage
  • Legal and regulatory requirements
  • Audit and security needs

Retention examples:

  • User account data: retained while account is active
  • Logs & audit trails: retained for [6–12 months]
  • Compliance evidence: retained per audit requirements

8. Data Subject Rights (GDPR)

Users have the right to:

  • Access personal data
  • Correct inaccurate data
  • Request deletion (Right to Erasure)
  • Restrict processing
  • Object to processing
  • Data portability
  • [Data Request Form Link]

9. Data Request Handling Process (Audit Critical)

We maintain a structured process for handling data requests:

9.1 Submission

  • Requests are submitted via web form
  • Identity verification is required

9.2 Logging

  • Each request is assigned a unique ticket ID
  • Requests are logged in a tracking system

9.3 Processing

  • Requests are reviewed and processed within [X days]
  • Actions are documented (approved, rejected, completed)

9.4 Audit Trail

  • All requests and actions are logged
  • Logs are retained for compliance verification

10. Security Measures

We implement appropriate technical and organizational measures:

  • Access control and role-based permissions
  • Encryption (in transit and at rest where applicable)
  • Continuous monitoring and logging
  • Regular security reviews

11. Data Deletion & Retention Controls

We ensure:

  • Secure deletion upon valid request
  • Removal from active systems and backups (where feasible)
  • Logging of deletion actions

12. International Data Transfers

If personal data is transferred across borders, we implement safeguards such as:

  • Standard Contractual Clauses (SCCs)
  • Secure cloud infrastructure providers

13. Stakeholder & Regulatory Compliance (ISO 42001 Alignment)

We ensure:

  • Protection of customer data rights
  • Compliance with applicable regulations (GDPR, PCI DSS, etc.)
  • Consideration of societal and ethical impacts of data processing

14. Policy Review & Updates

  • This policy is reviewed quarterly
  • Updates follow internal change management procedures
  • Versioning is maintained for audit purposes

15. Contact Information

For any privacy-related inquiries:

Company Name: [PTRACKLY CO., LTD]

Email: [[email protected]]

Address: [Lot 9, An Thuong 40 Street, Ngu Hanh Son Ward, Da Nang City, Vietnam]


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