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This Privacy Policy explains how TraceLoom, Inc. ("TraceLoom", "we", "us", or "our") collects, uses, discloses, and safeguards your information when you use our supply chain intelligence platform. This policy is written with the EU General Data Protection Regulation (GDPR) and other applicable privacy laws in mind.
1. What data we collect
Account and identity data: When you create an account, we collect your name, work email address, company name, job title, and password (handled by our authentication provider and stored as a salted hash, so we never see your plaintext password). This information is necessary to provide you with access to the Platform.
Operational data: We collect the supply chain data you submit through the Platform, including facility information, production metrics, emissions data, worker welfare indicators, product traceability records, and compliance documentation. This data is submitted voluntarily and belongs to you.
Usage data: Our hosting providers keep logs of the requests made to our website and the Platform, and those logs can contain IP addresses and, for logged-in users, account identifiers. Separately, if you click Accept on the cookie banner of our public website, we record how you use that website: the pages you view, where you came from, a coarse location taken from your IP address, your browser and device, a random identifier for your browser tab, and your clicks and scrolling. Section 8 lists exactly what is stored. The visitor counter and Vercel Web Analytics do not run inside the logged-in product, on the sign-in pages, on shared passport pages or in the demo sandbox. We use this to improve the website and diagnose technical issues.
Website enquiries: If you contact us, request a demo, claim a Founding Mill place, book a call, join a waitlist, or send us a security report, we collect what you enter (name, work email, company, role, a phone or WhatsApp number where the form asks for one, and your message) and store it so we can respond.
Communications: If you contact our support team or respond to our emails, we retain records of those communications to resolve issues and improve our service.
Cookies and similar technologies: We use essential cookies to keep you signed in and to remember your cookie choice. Nothing else starts on our public website until you click Accept on the banner. If you do, we also start the visitor counter, web analytics, product analytics and advertising-measurement tools described in section 8.
2. How we use your data
Providing the service: We use your data to operate, maintain, and improve the TraceLoom Platform, to authenticate you, to process your supply chain data as instructed, and to generate reports and analytics you request. Features that read documents you upload, write the daily brief, or answer questions in Ask send the relevant content to our AI provider, Anthropic, to produce the result.
Communications: We use your email address to send you product updates, security alerts, billing notices, and responses to your support requests. You can opt out of non-essential communications at any time.
Legal and compliance: We may use and retain your data as necessary to comply with legal obligations, resolve disputes, enforce our agreements, or respond to lawful requests from public authorities.
Improvement and research: We may use aggregated, anonymised usage data (with no ability to identify individuals or organisations) to improve the Platform and develop new features.
We do not sell or rent your personal data. If you accept marketing cookies, our advertising-measurement tool sends visit and conversion events to Meta, as described in section 8.
3. Legal basis for processing (GDPR)
For users in the European Economic Area (EEA) and UK, our legal bases for processing personal data are:
Contract performance: Processing necessary to deliver the services you have contracted for, including account management and operational data processing.
Legitimate interests: Processing for the purpose of improving the Platform, ensuring security, and preventing fraud, where these interests are not overridden by your rights.
Legal obligation: Processing required to comply with applicable laws and regulations.
Consent: Where we rely on consent (for example, for analytics and advertising-measurement cookies, or marketing communications), you have the right to withdraw consent at any time.
4. Data retention
Your account: We keep your account data while your account is active. If you ask us to delete your account, a 30-day window starts in which you can cancel. After it, we permanently delete your sign-in record, and your name is removed from the records you created, which stay with your organisation without your name on them.
Your organisation's data: When an organisation's subscription ends, we make its data available for export for 30 days, and then delete it within a further 30 days, unless the law requires us to keep it. Section 9 of our DPA sets out the same schedule.
Backups: Backup copies of the database that we hold are kept for no more than 30 days and then expire, so deleted data can persist in a backup for up to 30 days after deletion.
Enquiries: We keep website enquiries for as long as we need to respond and to keep a record of the conversation.
Anonymised, aggregated usage data may be retained indefinitely for product improvement purposes.
6. Your rights
Under GDPR and applicable privacy laws, you have the following rights regarding your personal data:
- Right of access: Request a copy of the personal data we hold about you.
- Right to rectification: Request correction of inaccurate or incomplete personal data.
- Right to erasure ("right to be forgotten"): Request deletion of your personal data, subject to legal retention obligations.
- Right to data portability: Request your personal data in a structured, machine-readable format (JSON or CSV).
- Right to restriction: Request that we restrict processing of your data in certain circumstances.
- Right to object: Object to processing based on legitimate interests.
- Right to withdraw consent: Withdraw consent at any time where processing is based on consent.
Users of the factory (mill and garments) portal can download their personal data as a JSON file and request deletion of their account from Settings. Everyone else, and anyone who prefers, can exercise any of these rights by email to privacy@traceloom.co. We will respond within 30 days. You also have the right to lodge a complaint with your local data protection supervisory authority.
7. Security
We protect your data with the measures described on our Security page: encryption in transit and at rest provided by our infrastructure providers, row-level security that separates each organisation's data, role-based access, and an audit log of changes to key records. Staff access to customer data is protected by authentication and logging. The Security page lists what we have not yet added, including separation-of-duty controls on that access.
In the event of a data breach that affects your personal data, we will notify you and, where required, the relevant supervisory authority, within 72 hours of becoming aware of the breach, in accordance with GDPR requirements.
No method of transmission over the internet is completely secure. While we strive to protect your data, we cannot guarantee absolute security, and we encourage you to use a strong, unique password.
9. Children's privacy
The Platform is intended for use by businesses and their employees. It is not directed at children under the age of 16. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact us immediately and we will delete it.
10. Changes to this policy
We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. We will notify you of material changes by email or by posting a notice on the Platform at least 30 days before the changes take effect. Your continued use of the Platform after the effective date constitutes acceptance of the revised policy.
11. Controller and contact
For privacy-related enquiries, requests to exercise your rights, or concerns about our data practices, contact the controller:
ControllerTraceLoom, Inc., a Delaware corporation.
Registered office: 8 The Green, Suite A, Dover, Delaware 19901, United States.
For privacy inquiries and to exercise your GDPR rights, email privacy@traceloom.co.