Privacy Policy

Last updated on 10th March 2025.

Introduction

Welcome to Track Zero Labs Ltd’s privacy policy.

This privacy policy applies to all individuals accessing TrackZero ("users"). When we refer to "TrackZero" we mean trackzero.eco and all services provided via TrackZero.

Our services enable businesses to measure and reduce their carbon footprint, track sustainability progress, and facilitate compliance with ESG (Environmental, Social, and Governance) standards.

TrackZero Labs Ltd ("we", "us" or "our") respects your privacy and we are committed to protecting your personal data and Company Data.

This policy covers:

1. Personal Data: Information that relates to an identified or identifiable individual.
2. Company Data: Business-related data provided by organisations, such as operational metrics and emissions data, that is not classified as personal data.

It is important that you read this privacy policy together with any other privacy policy or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements the other notices and is not intended to override them.

Who we are and important information

Controller & Contact Details

The controller of TrackZero is Track Zero Labs Ltd of X+Why, Unity Place, 200 Grafton Gate, Milton Keynes MK9 1UP. We have appointed a data protection officer ("DPO") who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO at . or write to the DPO at Track Zero Labs Ltd, X+Why, Unity Place, 200 Grafton Gate, Milton Keynes MK9 1UP.

You have the right to make a complaint at any time to the Information Commissioner's Office ("ICO"), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Your duty to inform us of changes

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

TrackZero may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave TrackZero, we encourage you to read the privacy notice of every website you visit.

The data we collect about your Company

Company Data is distinct from personal data and includes:

• Operational Data: Business operations-related data, such as energy consumption, business activities, emissions data, and ESG (Environmental, Social, and Governance) metrics.
• Performance Data: Metrics related to business performance, ESG (Environmental, Social, and Governance) metrics, and carbon reduction progress.
• Financial Data: Revenue, expenditure, and other relevant financial details provided for evidencing and reporting purposes.

Aggregated and anonymised data derived from Company Data is not considered personal data and may be used for research and benchmarking.

How is your Company Data collected?

Company Data is collected when users upload or submit business-related data to TrackZero. This may include manual entry, data integrations with third-party systems, or data imports by authorised users.

How we use your Company Data

We will use your Company Data in the following circumstances:

• where we need to perform the contract we are about to enter into or have entered into with you;
• where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; and
• where we need to comply with a legal obligation.

Your Company Data is used to:

• Deliver core services, such as carbon footprint calculations, ESG assessments, action planning, and reporting.
• Support sustainability and ESG reporting and compliance.
• Enable companies to share data with authorised collaborators for support, verification and reporting.
• Aggregate and anonymise data for benchmarking, research, and product improvement.

How we share your Company Data

Company Data may be shared with:

• Collaborators: Third parties you authorise for specific purposes such as supporting collection, measurement, verification and/or reporting of emissions. Collaborators must adhere to data protection standards and cannot use the data beyond agreed-upon purposes.
• Research Partners: Aggregated and anonymised data may be shared for reasearch purposes and benchmarking.

The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity & Contact Data includes name, username or similar identifier, email address, location and telephone number.
• Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access TrackZero.
• Transactional Data includes details about payments to and from you and other details of services you have purchased from us.
• Usage Data includes information about how you use TrackZero.
• Marketing Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
• Account Data includes information available on your account profile such as your job role or description, organisation, employer’s name, industry, and links.

We also collect and use aggregated data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific feature of TrackZero. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

How is your personal data collected?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity & Contact Data by opening an account, subscribing to our services or by corresponding with us as well as your Account Data when you set up your account.
• Indirect interactions. We will learn information about you from your use of the interactive functions on TrackZero.
• Automated technologies or interactions. As you interact with TrackZero, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies. Please see our Cookie Policy for further details.
• Third Parties. We will receive personal data about you from various third parties as set out below:
  • Identity & Contact Data. We may be provided with your Identity & Contact Data from your team for the purposes of inviting you to use TrackZero. We rely on those third parties to have the right to share your data with us. You should review their privacy policies for more information.
  • Technical Data from analytic providers (such as Google).
  • Identity & Contact Data and/or Account Data from other providers. This may also include other services that you agree to us integrating with for the purpose of populating your account.

How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• where we need to perform the contract we are about to enter into or have entered into with you;
• where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; and
• where we need to comply with a legal obligation.

Generally we do not rely on consent as a legal basis for processing your personal data. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.