Privacy Policy

1Who we are and what this policy covers

[Legal Entity Name, LLC] (“Tracktion,” “we,” “us” or “our”) is an organic influencer marketing agency that pairs ecommerce brands with creators on TikTok, Instagram and YouTube. This Privacy Policy explains what personal information we collect, why we collect it, who we share it with, and the choices you have.

It applies to https://tracktion.org and to the calls, text messages and emails we exchange with prospective and current clients. It does not cover:

• Creator platforms. TikTok, Instagram and YouTube each handle your data under their own policies. We have no control over them.
• Our clients’ own sites and stores. If you reached us from a brand’s store or a creator’s post, that business’s privacy policy governs what it collected.
• Content our clients or creators publish. Comments, DMs and public posts live on the platform that hosts them.

By using this site or contacting us, you agree to this policy. If you do not agree, please do not submit the booking form.

2Information we collect

Information you give us

• Booking details. The form on this site collects your first name, last name and mobile phone number, along with the checkbox recording your consent to be contacted. These are the only fields we ask for before a call.
• Business information. On the call and afterwards, we typically learn your company name, store URL, product catalogue, price points, current marketing channels, budget range and objectives.
• Contact and communication content. Your email address, the messages you send us, and notes we take about what you asked for and what we agreed.
• Campaign and billing information. For clients: the assets, briefs, approvals and feedback you send us, plus billing contact and payment details. Card numbers go directly to our payment processor; we do not store them.

Information collected automatically

• Device and connection data. IP address, browser and operating system, device type, screen size, language and referring URL.
• Usage data. Pages viewed, time on page, scroll depth, which videos and FAQ items you opened, and which buttons you clicked.
• Cookies and similar technologies. Described in section 6.

Information from other sources

• Advertising and analytics platforms. Aggregated campaign and audience reporting, and conversion data matched to ads you may have clicked.
• Public creator and brand data. Follower counts, engagement rates, audience demographics and past campaign performance, which we use to vet creators.
• Referrals. If an existing client or partner refers you, we may receive your name and contact details from them.

We do not intentionally collect sensitive personal information — government identifiers, financial account credentials, precise geolocation, health data, biometrics, or data revealing race, religion, union membership, sexual orientation or immigration status — and we ask that you not send it to us.

3How we use personal information

We use the information above to:

• Schedule, confirm, reschedule and follow up on your free growth strategy call.
• Answer your questions and send you proposals, pricing and campaign plans.
• Deliver our services: matching creators to your brand, running outreach and briefs, managing approvals and reporting on results.
• Invoice you and collect payment, and keep accounting records.
• Send service messages about a live campaign, and — with your consent — marketing messages about our services.
• Measure and improve the site and our marketing: which pages convert, which channels bring qualified brands, and where visitors drop off.
• Protect against fraud, spam, abuse and security incidents, and enforce our Terms of Service.
• Comply with law, respond to lawful requests, and establish or defend legal claims.

We may create aggregated or de-identified statistics (for example, average conversion rate across campaigns in a category) and use them without restriction, provided they cannot reasonably be used to identify you.

We do not sell your personal information for money, and we do not use artificial intelligence to make decisions about you that have legal or similarly significant effects.

4Phone calls and text messages

When you check the consent box and submit the booking form, you agree that Tracktion and the people working on its behalf may call and send text messages to the mobile number you provided, including messages sent with an automatic telephone dialing system or prerecorded voice, about scheduling your call and about our services.

• Consent is not a condition of purchase. You do not have to agree to marketing texts or calls in order to work with us — email johndemic@tracktion.org instead and we will reply that way.
• Message frequency. Expect up to 6 messages per month, varying with how far along your enquiry or campaign is.
• Message and data rates may apply, depending on your mobile plan. We do not charge for the messages themselves.
• To stop: reply STOP to any text and we will stop texting that number. Reply HELP for help, or contact us at johndemic@tracktion.org or 425-000-0000. Opting out of texts does not remove you from email, and does not end a campaign already underway.
• Carriers are not liable for delayed or undelivered messages.

We do not share mobile numbers or SMS consent with third parties or affiliates for their own marketing purposes. Numbers are shared only with the vendors that help us send messages on our behalf, and only for that purpose.

We do not record calls without telling you at the start of the call. If a call will be recorded we will say so and you can decline.

5Email marketing

If you give us your email address, we may send you campaign examples, case studies, pricing updates and other marketing about our services. Every marketing email includes an unsubscribe link, and you can also ask us to stop by emailing johndemic@tracktion.org.

Transactional and service emails — a proposal you asked for, a booking confirmation, an invoice, a change to these policies, or an update on a live campaign — are not marketing, and you will keep receiving them while we are working together even if you unsubscribe from marketing.

6Cookies, analytics and advertising technologies

We and our providers use cookies, pixels, tags, local storage and similar technologies for three purposes:

• Strictly necessary. Serving the site securely, load balancing, and remembering form state. The site does not work without these.
• Analytics. Understanding traffic and behaviour in aggregate — how many people reached the booking form, which sections they read, which devices they used.
• Advertising. Conversion pixels from advertising platforms (including Meta, TikTok and Google) that tell us which ad or creator post led to a booking, measure campaign performance, and allow us and our clients to show relevant ads to similar audiences. These technologies may set identifiers that let a platform recognise your browser across sites.

Embedded TikTok and Instagram videos on our homepage load from those platforms, which may set their own cookies when the embed loads. We browse-lock those embeds so playback only starts when you choose it, but the platforms’ own terms govern what they collect.

Your controls

• Your browser can block or delete cookies; blocking analytics and advertising cookies will not break the site.
• We honour the Global Privacy Control (GPC) signal where our providers support it. Because a browser-level signal is per-browser and per-device, send it from each browser you use.
• Industry opt-outs are available at optout.aboutads.info and optout.networkadvertising.org, and inside your account settings on each advertising platform.

7How we share personal information

We share personal information only as described here. We share categories of information with categories of recipients as follows:

• Service providers and processors, which handle data on our instructions and are contractually restricted from using it for their own purposes: website hosting and content delivery, form and lead capture, our customer relationship manager (CRM), calendar and scheduling tools, telephony and SMS delivery, email delivery, analytics, payment processing, cloud storage, e-signature, and support tooling.
• Advertising and analytics platforms, which may act as independent controllers for the identifiers their pixels set. See section 8.
• Creators. When a campaign starts we share what a creator needs to produce and ship the content — brand name, brief, product details, shipping address for samples, and a point of contact. We do not give creators your mobile number unless you ask us to.
• Clients. If you are a creator, we share your handle, public metrics and the deliverables you produce with the brand paying for the campaign.
• Professional advisors — lawyers, accountants, auditors and insurers — under confidentiality obligations.
• Corporate transactions. In a merger, acquisition, financing, reorganisation or sale of assets, information may pass to the counterparty and its advisors, subject to this policy or a successor policy.
• Legal and safety. When we believe disclosure is required by law, subpoena or court order, or is necessary to investigate fraud, enforce our Terms, or protect the rights, property or safety of any person.
• With your direction, to anyone else you ask us to share with.

8Targeted advertising, and what “sale” means here

We do not exchange personal information for money. However, several US state privacy laws define “sale” and “sharing” broadly enough to include the use of third-party advertising and analytics technologies described in section 6. Under those definitions, our use of advertising pixels may be treated as “sharing” or a “sale” of online identifiers and browsing activity for cross-context behavioural advertising.

You may opt out of that at any time by:

• sending a Global Privacy Control signal from your browser, or blocking advertising cookies in your browser settings; and
• emailing johndemic@tracktion.org with the subject line “Opt out of targeted advertising” so we can suppress your details in our own systems.

We do not knowingly sell or share the personal information of anyone under 16.

9How long we keep information

We keep personal information only as long as we have a reason to, then delete it or de-identify it:

• Enquiries that do not become clients: up to 24 months from your last contact with us, so we can pick a conversation back up where it left off.
• Client records, contracts and campaign files: for the life of the relationship and then as long as needed for legal claims — generally up to 7 years.
• Invoices and accounting records: as long as tax and corporate law require, generally 7 years.
• Opt-out and suppression records: indefinitely, because we need to remember that you asked us to stop.
• Analytics and advertising data: according to each platform’s retention settings, typically 14 to 26 months.

10How we protect information

We use administrative, technical and physical safeguards appropriate to the sensitivity of the data: encryption in transit (HTTPS), encryption at rest with our cloud providers, access limited to the people who need it, multi-factor authentication on business accounts, and vendor due diligence before we send data anywhere.

No method of transmission or storage is completely secure, so we cannot guarantee absolute security. If a breach affects your personal information we will notify you and any regulator as the law requires. Please tell us at johndemic@tracktion.org if you believe your interaction with us is no longer secure.

11Your privacy choices and rights

Everyone who contacts us can ask us to:

• Access the personal information we hold about you, and tell you where it came from and who we shared it with;
• Correct information that is inaccurate;
• Delete information we no longer need to keep;
• Port a copy to you in a portable, machine-readable format;
• Opt out of marketing calls, texts and emails, and of targeted advertising and profiling.

How to make a request

Email johndemic@tracktion.org or write to us at [Street Address, City, State ZIP]. Tell us what you want us to do and give us enough detail — the phone number, email address or brand name you used — to find your records. We will verify the request against information we already hold; if we cannot verify you, we will tell you why. Requests are free and answered within 45 days, extendable once by another 45 days if we tell you why. An authorised agent may act for you with written permission we can verify.

We will not discriminate against you for exercising these rights: no worse pricing, no worse service, no denial of a campaign.

If we say no

You may appeal by replying to our decision with the word “Appeal”. A person who was not involved in the original decision will review it and respond in writing within 45 days, and will tell you how to contact your state attorney general if you are still not satisfied.

12Additional US state disclosures

Residents of California, Colorado, Connecticut, Delaware, Iowa, Montana, Nebraska, Nevada, New Hampshire, New Jersey, Oregon, Texas, Utah, Virginia and other states with comprehensive privacy laws have the rights in section 11. This section adds the disclosures those laws require.

Categories of personal information we collect, using the California Consumer Privacy Act’s labels: identifiers (name, phone number, email address, IP address, online identifiers); commercial information (services enquired about and purchased); internet or network activity (browsing and interaction with this site); professional or employment-related information (your role and the brand you represent); and inferences drawn from the above (for example, that your store is a fit for a particular creator tier). We collect these from you, from your device automatically, and from the sources in section 2; we use them for the purposes in section 3; and we disclose them to the recipients in section 7.

Sensitive personal information. We do not collect or process sensitive personal information for the purpose of inferring characteristics about you.

Financial incentives. We do not offer financial incentives in exchange for personal information.

California “Shine the Light.” California residents may request the identity of third parties with whom we shared personal information for their own direct marketing in the prior calendar year. As stated above, we do not share personal information for third parties’ own direct marketing.

Nevada. Nevada residents may submit a verified do-not-sell request to johndemic@tracktion.org, although we do not sell covered information for money.

13Children

Our services are for businesses, and this site is not directed to children. We do not knowingly collect personal information from anyone under 18. If you believe a child has given us information, email johndemic@tracktion.org and we will delete it.

Creators we work with must be 18 or older. Where a campaign involves a minor creator, the creator’s parent or legal guardian must contract with us on their behalf and consent to the use of their content.

14Links, embeds and third-party platforms

Our site links to and embeds content from third-party platforms, including TikTok, Instagram and YouTube, and links to our clients’ stores. We are not responsible for those services’ privacy practices or content, and this policy does not apply to them. Read their policies before giving them information.

15Where your information is processed

We operate in the United States, and our providers store and process information there. If you contact us from outside the United States, you understand that your information will be transferred to and processed in the United States, where privacy laws may differ from those in your country. We do not target our services to individuals in the European Economic Area, the United Kingdom or Switzerland; if you are located there and would like us to delete your information, email johndemic@tracktion.org.

16Changes to this policy

We may update this policy as our practices, our tools or the law change. The date at the top always reflects the current version. If a change materially reduces your rights or expands how we use information you already gave us, we will give notice — by email, by text if that is how we have been talking, or by a prominent notice on this site — before it takes effect, and where the law requires it we will ask for your consent. Continuing to use the site after an update means you accept the revised policy.

17How to contact us

Questions, requests and complaints about privacy all go to the same place:

See also our Terms of Service.