Privacy policy

As updated on: August 04, 2025

Welcome to the website of Clootrack Software Labs Inc. (hereinafter referred to as the “Platform”), and to all other related services provided through the Platform (“Services”). This Privacy Policy (“Privacy Policy”) delineates the Personal Information (as defined below) that we collect through the Platform, the methods by which we use and share that data, and the options you have regarding our data practices. Please thoroughly review this Privacy Policy before using the Platform or submitting any Personal Data to Clootrack and get in touch with us if you have any questions.

The Platform is owned and hosted by Clootrack Software Labs Inc. having its registered office at Suite 350, 2093A Philadelphia Pike, Claymont Delaware 19703, USA, (hereinafter referred to as “Clootrack” or “Company” or “We” or “Our” or “Us” where such expression shall, unless repugnant to the context thereof, be deemed to include its respective legal heirs, representatives, administrators, permitted successors and assigns). The Company ensures steady commitment to Your (defined below) privacy with regard to the protection of Your invaluable Information (defined below).

By visiting Our Platform and/or using the Services, You accept the terms relating to privacy of Information shared/communicated by You via written or oral means through the Platform or by using the Services.

This Privacy Policy (“Policy”) is incorporated into, and forms part of our Terms of Use, which You shall be subject to, by virtue of You visiting Our Platform or using the Services. In order to provide You with Our uninterrupted use of Services, We may collect and, in some circumstances, disclose Information about You, with Your permission. To ensure better protection of Your privacy, We provide this intimation explaining Our Information collection and disclosure policies, and the choices You make about the way Your Information is collected and used.

This Policy is in compliance with the General Data Protection Regulation (“GDPR”), the California Privacy Rights Act, 2020, the Digital Personal Data Protection Act, 2023 (“DPDP Act”) and any and all provisions that may read to the contrary shall be deemed to be void and unenforceable as of that date. If you do not agree with the terms and conditions of this Policy, including in relation to the manner of collection or use of Your Information, please do not use the Services or access the Platform.

ANY CAPITALIZED WORDS USED HENCEFORTH SHALL HAVE THE MEANING ACCORDED TO THEM UNDER THIS POLICY. FURTHER, ALL HEADINGS USED HEREIN ARE ONLY FOR THE PURPOSE OF ARRANGING THE VARIOUS PROVISIONS OF THE POLICY. NEITHER THE USER NOR THE COMPANY MAY USE THE HEADINGS TO INTERPRET THE PROVISIONS CONTAINED WITHIN IT, IN ANY MANNER.

1. DEFINITION

1.1 “You”, “Your”, “Yourself” and “User” shall mean and refer to natural and legal individuals who use the Platform.

1.2 “Information" shall mean any information You provide to Us, including without limitation information provided by You, in the registration process, in the feedback area, during call center calls, User complaints, bulletin board and messages or through any e-mail feature including Your Personal Information.

1.3 “Personal Information” shall mean and refer to any Information collected by Us which identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular User who is a natural person.

1.4 “Third Parties” refer to any other website or platform, company or individual apart from the User and the Company.

1.5 “Lawful Purpose” means any purpose which is not expressly forbidden by law.

2. INFORMATION WE COLLECT

2.1 We are committed to respecting Your online privacy and recognize Your need for appropriate protection and management of any Personal Information You share with Us. We may collect and store different kinds of Personal Information about You, when you access or submit information to us through the Website or when you visit, use and interact with the Website, which may include but not be limited to the following Information:

  • Identity data such as, but not limited to name, location, date of birth, gender, identification number;

  • Username and password, when you register with Us;

  • Contact details including email address, mobile number, postal address etc.

  • Tracking Information such as, but not limited to the IP address of Your device and device ID when connected to the internet. [This information may include the URL that You just came from (whether this URL is on the Platform or not), which URL You next go to (whether this URL is on the Platform or not), Your computer browser information, and other information associated with Your interaction with the Platform.]

2.2 Company shall also collect from Users, browsing behaviour, pages viewed etc.

2.3 We also collect and store Personal Information provided by You from time to time during the course of using Our Services and/or while registering with Us.

2.4 We may automatically track certain Information about You based upon Your behavior, acts, subscriptions, transactions and preferences on the Platform.

2.5 We collect and store Your search details on the Platform, including Your search history, the usage of the Platform and the features and the duration for which You have used the Platform.

2.6 Company may also collect payment related financial Information (credit card, debit card, bank account details, billing address etc.) as provided by the Users on the Platform.

2.7 We shall collect and store all such Information in our internal Company servers for a finite period of time, as long as You are a User of the Platform, and shall immediately delete all such Information upon expiry of your User status.

2.8 To the extent possible, We provide You the option of not divulging any specific Information that You wish for Us not to collect, store or use. You may also choose not to use a particular service or feature on the Platform, and opt out of any non-essential communications from the Platform.

2.9 At every stage prior to, during or after Information collection, You have the right to access all Personal Information provided, rectify or alter all Personal Information provided, withdraw the consent or restrict the level of Personal Information to be retained as per Your sole discretion and object to the retention, use and potential disclosure of the Personal Information.

3. OUR USE OF YOUR INFORMATION

3.1 The Information provided by You shall be used to:

  • Contact You when necessary and is also used for targeted marketing campaigns i.e. email marketing, remarketing, look alike campaigns etc., to conduct surveys, learn more about You by linking Your Information with additional data through Third-Party data providers or analyzing the data with the help of analytics service providers;

  • Improve and develop new products, services, and features;

  • Analyze purchase, usage and traffic data.

For more details about the nature of such communications, please refer to our Terms of Service.

3.2 Personal Information collected from You shall be used only for Lawful Purposes that We consider necessary for achieving a seamless, efficient and safe experience, customized to Your needs including:

  • To provide and facilitate your engagement with the Platform and the Services opted for, by You;

  • To provide you with administrative information, such as updates to our terms, conditions, and policies, or information about the Platform or the Services;

  • To communicate necessary account, and Service related information from time to time;

  • To personalize Your experience on the Platform by presenting advertising, products and offers tailored for You;

  • To allow You to receive quality customer care Services and for proper administration and protection of the integrity of the Platform;

  • To prevent fraud, criminal activity, or misuses of the Platform, and to ensure the security of our IT systems, architecture and networks;

  • To comply with legal obligations and legal process and to protect Our rights, privacy, safety or property, and/or that of Our affiliates, You or other Third Parties;

  • For internal record keeping.

3.3 We will not sell, license or trade Your Personal Information. We will not share your Personal Information with others unless they are acting under Our instructions as consented by You or We are required to do so by law.

3.4 We use Your tracking Information such as IP addresses, and or device ID to help identify You and to gather broad demographic information.

3.5 Information collected via Our server logs include users’ IP addresses and the pages visited; this will be used to manage the web system and troubleshoot problems.

3.6 We also use third-party analytics, tracking, optimization and targeting tools to understand how Users engage with Our Platform so that We can improve it and cater personalized content/ads according to their preferences.

3.7 Where any Service requested by You involves Third Parties, such Information including but not limited to cookies, log files, and device identifiers and location data as is reasonably necessary by the Company to carry out Your Service request may be shared with such Third Parties.

3.8 We also use Your contact Information to send You offers based on Your interests and prior activity. The Company may also use contact Information internally to direct its efforts for service improvement, but shall immediately delete all such Information upon withdrawal of Your consent for the same through our ‘unsubscribe’ button or through an email sent to contactus@clootrack.com.

3.9 The Company shall use the financial Information collected from the Users to complete the transaction/payment and shall keep all such Personal Information safe at all times and ensure that such Personal Information is only transacted over secured and approved payment gateways which are digitally encrypted, and provide the commercially reasonable degree of care. 

3.10 Transacting over the internet has inherent risks which can only be avoided by You following security practices, such as not revealing account/login related Information to any other person and informing Our customer care team about any suspicious activity where Your account has/may has been compromised.

3.11 We may share any Information with Our other affiliates to help detect and prevent identity theft, fraud and other potentially illegal acts; correlate related or multiple accounts to prevent abuse of Our Platform and/or Services; and to facilitate joint or co-branded Services that You request where such Services are provided by more than one corporate entity.

3.12 If We sell or otherwise transfer part or the whole of Our assets to another organization (e.g., in the course of a transaction like a merger, acquisition, bankruptcy, dissolution, liquidation), Your Information may be among the items sold or transferred for the sole purpose of continuing the operation of the Services, and only if the recipient of the Personal Information commits to a privacy policy that has terms substantially consistent with this Policy.

3.13 We may disclose Your Information to the extent such disclosure is reasonably necessary to enforce Our Terms of Use or Our other policies and in order to respond to claims of any other user or Third Parties.

4. HOW INFORMATION IS COLLECTED

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

  • Direct interactions – We collect Information when You create an account and log into and interact with, the Platform or provide Information to Us while registering with Us or through any other means including but not limited to sending email.

  • Third party – We may receive Information from Third Parties who may register Your details with Us or if any of our existing users refer to You.

  • Automated technologies or interactions. As You interact with Our Platform, We will automatically collect technical data about Your equipment, browsing actions and patterns. We collect this Personal Data by using cookies, add-in and other similar technologies. Please see Our cookie policy for further details.

  • Third parties or publicly available sources. We will receive technical data from analytics providers such as google as We may deem appropriate.

4.2 Before or at the time of collecting Personal Information, We will inform you the purposes for which such Personal Information is being collected. If the same is not informed to You, You have the right to request the Company to elucidate the purpose of collection of said Personal Information, pending fulfilment of which You shall not be mandated to disclose any Information, whatsoever.

4.3 We will collect and use Your Personal Information solely with the objective of fulfilling those purposes specified by Us, within the scope of consent of the User concerned or as required by law. We will only retain Personal Information as long as necessary for the fulfilment of those purposes subject to Clause 7 of this Policy. We will collect Personal Information by lawful and fair means and with the knowledge and consent of the User concerned.

4.4 Personal Information should be relevant to the purposes for which it is to be used, and, to the extent necessary for those purposes, should be accurate, complete, and up-to-date.

5. COOKIES, WEB BEACONS AND OTHER TRACKING TOOLS

5.1 We use data collection devices such as “cookies”, clear gifs (i.e. web beacons/web bugs hereinafter “Web Beacons”) on certain pages of our Platform and other tracking tools (collectively “Tracking Tools”). Tracking Tools collect information such as:

  • computer or device operating system type;

  • IP address;

  • browser type;

  • browser language;

  • mobile device ID;

  • device hardware type;

  • the website or application visited or used before or after accessing our Platform;

  • the parts of the Platform accessed;

  • the length of time spent on a page or using a feature; and

  • access times for a webpage or feature.

5.2 These Tracking Tools help Us learn more about Our Users and analyse howUsers use the Platform and Services, such as how often Users visit our Platform, what features they use, what pages they visit, what emails they open, and what other sites or applications they used prior to and after visiting the Platform.

5.3 “Cookies” are small files sited on Your hard drive that assist Us in providing customized Services on certain pages of Our Platform. We also offer certain features that are only available through the use of a “Cookie”. Cookies can also help Us provide information, which is targeted to Your interests. Cookies may be used to identify logged in or registered Users. Our Platform uses session Cookies to ensure that You have a good experience. These Cookies contain a unique number, Your ‘session ID’, which allows Our server to recognise Your computer and ‘remember’ what You’ve done on the Platform. The benefits of this are:

  • You only need to log in once if You’re navigating secure areas of the Platform; and

  • Our server can distinguish between Your computer and other Users, so You can see the Information that You have requested.

5.4 We also use various third-party Cookies for usage, behavioural, analytics and preferences data. The following are the different types of Cookies used on the Platform:

  • Authentication Cookies: To identify the User and share the content that he or she requested for.

  • Functionality Cookies: For customized User experience and resuming past course progress.

  • Tracking, optimization and targeting Cookies: To capture usage metric on device, operating system, browser etc. To capture behavioral metrics for better content delivery. To cater and suggest most suited products and Services.

5.5  Cookies table: The Platform uses the following Cookies:

Purpose

Cookie Name

Host

Authentication

Clootrack

clootrack.com
app.clootrack.com
api.clootrack.com
login.clootrack.com

Tracking, optimization and targeting cookies

Google

Facebook

google.com

facebook.com

5.6 Web Beacons: Web Beacons help Us better manage content on Our Platform by informing Us what content is effective. Web Beacons are embedded in, or otherwise associated with, certain emails or other communications that You may receive from Us. Web Beacons help Us track Your responses and interests and deliver relevant content and Services to You. Forexample, they may let Us know when You take actions based on the emails We send.

6. OPTING OUT

6.1 Web Browser Controls: You can prevent the use of certain Tracking Tools, such as Cookies, on a device-by-device basis using the controls in Your web browser. These controls can be found in the Tools > Internet Options (or similar) menu for Your browser, or as otherwise directed by Your browser’s support feature. Through Your web browser, You may be able to: (i) delete existing Tracking Tools, (ii) Disable future Tracking Tools and (iii) Set your browser to provide you with a warning each time a cookie or certain other Tracking Tools are being set.

6.2 Do Not Track ("DNT"): DNT is a privacy preference that Users can set in certain web browsers. DNT is a way for Users to inform websites and services that they donot want certain information about their webpage visits collected over time andacross websites or online services.

6.3  Emails: You can opt-out of non-essential emails such as marketing emails by clicking on the unsubscribe link at the bottom of each such email. Note that You cannot opt-out of emails that are essential to providing Clootrack Services relating to customer service, security, billing, or pursuant to legal/contractual obligations.

6.4 Withdrawing consent: Where You have consented to Clootrack’s processing of Yourpersonal data, You may withdraw that consent at any time and opt out of furtherprocessing by contacting Us  in the manner set out in the Contact Us section.

7. INTERNATIONAL TRANSFERS

7.1 Where We transfer Personal Information out of the United Kingdom/European Economic Area, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented: (i) We will only transfer Your Personal Information to countries that have been deemed to provide an adequate level of protection for Personal Information by the European Commission. (ii) Where We use certain service providers, We may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see our data processing agreement.

8. DURATION OF MAINTAINING AND USING YOUR INFORMATION

8.1 Following completion of the Service, We may retain certain Information (including Your Personal Information) for Lawful Purposes subject to the applicable laws, such as for backup, archival, tax and/or audit purposes. We will remove Your public posts from view and/or dissociate them from Your user profile, but We may retain Information about You for the purposes authorized under this Policy, unless expressly prohibited by law.

8.2 We may, at Our discretion, either delete Your Personal Information or de-identify it so that it is anonymous and not attributed to Your identity. For example, We may retain Information to prevent, investigate, or identify possible wrongdoing in connection with Our services or to comply with legal obligations.

9. GOOGLE ANALYTICS

9.1 We use Google analytics to help Us to understand how You make use of Our content and work out how We can make things better. These Cookies follow Your progress through Our Platform, collecting anonymous data on where You have come from, which pages You visit, and how long You spend on the Platform. This data is then stored by Google in order to create reports. These Cookies do not store your Personal Information.

9.2 The Information generated by the Cookie about Your use of the Platform, including Your IP address, may be transmitted to and stored by Google on servers in the United States. Google may use this Information for the purpose of evaluating Your use of the Platform, compiling reports on Platform activity for Us and providing other Services relating to Platform activity and internet usage. Google may also transfer this Information to Third Parties where required to do so by law, or where such Third Parties process the Information on google’s behalf. Google will not associate Your IP address with any other data held by google. By using this Platform, You consent to the processing of Information about You by Google in the manner and for the purposes set out above.

9.3 The Google website contains further information about analytics and a copy of Google’s privacy policy pages.

4. HOW INFORMATION IS COLLECTED

4.4 Personal Information should be relevant to the purposes for which it is to be used, and, to the extent necessary for those purposes, should be accurate, complete, and up-to-date.

4.4 Personal Information should be relevant to the purposes for which it is to be used, and, to the extent necessary for those purposes, should be accurate, complete, and up-to-date.

10. EXTERNAL LINKS ON THE PLATFORM

10.1 The Platform may include advertisements, hyperlinks to other websites, applications, content or resources. We have no control over any such websites or resources, which are provided by companies or persons other than Us. You acknowledge and agree that We are not responsible for any such external sites or resources, and do not endorse any advertising, services/products or other materials on or available from such websites or resources. You acknowledge and agree that We shall not be liable for any loss or damage which may be incurred by you as a result of the availability of those external sites or resources, or as a result of any reliance placed by You on the completeness, accuracy or existence of any advertising, products or other materials on, or available from, such websites or resources. These external websites and resource providers may have their own privacy policies governing the collection, storage, retention and disclosure of Your Personal Information that You may be subject to. We recommend that You enter the external website and review their privacy policy. If you require a list of third-party links on our Platform, please write to Us at contactus@clootrack.com and We will provide You with the same.

11. YOUR RIGHTS

11.1 Unless subject to an exemption, You have the following rights with respect to Your Personal Information:

  • The right to request a copy of your Personal Information which We hold about You;

  • The right to request for any correction, updation or deletion of Personal Information for which consent was given, if it is found to be inaccurate, incomplete or not updated;

  • The right to object to, restrict or withdraw Your consent to the processing of Personal Information at any time;

  • You shall have the right to have readily available means of grievance redressal and the right to lodge a complaint with a supervisory authority;

  • The right to obtain information as to whether Personal Information are transferred to a third country or to an international organization.

11.2 These rights may be enforced by connecting to Us at contactus@clootrack.com. You will not have to pay a fee to access Your Personal Information (or to exercise any of Your other rights). However, We may charge a reasonable fee if Your request is clearly unfounded, repetitive or excessive. Alternatively, We may refuse to comply with Your request in these circumstances.

12. CHILDREN

12.1 The Platform is not intended for use by User below the age of 18. Clootrack does not knowingly collect Personal Information from children under 18. If You believe that a child under 18 has submitted Personal Information to Us through the Platform, please get in touch with us through the contact details given in the Contact Us section of this Policy, and We will take prompt steps to delete such information from Our records.

​​​​​​​13. CONFIDENTIALITY

13.1 You further acknowledge that the Platform may contain Information which is designated confidential by Us and that You shall not disclose such Information without Our prior written consent. Your Information is regarded as confidential and therefore will not be divulged to Third Parties, unless legally required to do so, to the appropriate authorities, subject to the provisions of this Policy. We will not sell, share, or rent Your Personal Information to Third Parties or use Your e-mail address for unsolicited mail. Any emails sent by Us will only be in connection with the provision of agreed Services, and You retain the sole discretion to seek for discontinuation of such communications at any point of time.

​​​​​​​14. OTHER INFORMATION COLLECTORS

14.1 Except as otherwise expressly included in this Privacy Policy, this document only addresses the use and disclosure of Information We collect from You. To the extent that You disclose Your Information to other parties, whether they are on Our Platform, or on other sites throughout the internet, different rules may apply to their use or disclosure of the Information You disclose to them. To the extent that We use third party advertisers, they adhere to their own privacy policies. Since We do not control the privacy policies of the Third Parties, You are advised to ask questions from the said Third Parties before You disclose Your Personal Information to them.

15. OUR DISCLOSURE OF YOUR INFORMATION AND DATA SECURITY

15.1 Due to the existing regulatory environment, We cannot ensure that all of Your private communications and other Personal Information will never be disclosed in ways not otherwise described in this Privacy Policy. By way of example (without limiting and foregoing), We may be forced to disclose Information to the government, law enforcement agencies or Third Parties. We treat Information as an asset that must be protected against loss and unauthorized access and thus, We employ many different security techniques to protect such Information from unauthorized access by members inside and outside the Company. Although We use industry standard practices to protect Your privacy, no method of transmission over the internet, or method of electronic storage, is hundred percent secure. We do not promise, and You should not expect, that Your Personal Information or private communications would always remain private. We do, however assure You that any and all disclosure of Your Personal Information shall be personally intimated to You through an email sent to Your provided email address. If You believe your Personal Information has been compromised, please contact Us at the details set forth in the Contact Us section in this Policy. If we learn of a security system breach, We will inform You and the authorities of the occurrence of the breach in accordance with applicable law.

15.2 As a matter of policy, We do not sell or rent Your Personal Information to any third party. However, the following describes some of the ways that Your Personal Information may be disclosed:

  • External Service Providers: There may be a number of services offered by external service providers that help You use Our Platform. If You choose to use these optional services, and in the course of doing so, disclose Information to the external service providers, and/or grant them permission to collect Information about You, then their use of Your Information is governed by their privacy policy.

  • Law and Order: We cooperate with law enforcement inquiries, as well as other Third Parties to enforce laws, such as: intellectual property rights, fraud and other rights. We can (and You authorize Us to) disclose any Information about You to law enforcement and other government officials as We, in Our sole discretion, believe necessary or appropriate, in connection with an investigation of fraud, intellectual property infringements, or other activity that is illegal or may expose Us or You to legal liability.

​​​​​​​16. ACCESSING, REVIEWING AND CHANGING YOUR PROFILE

16.1 Following registration, You can review and change the Information You submitted at the stage of registration, except registered email ID. An option for facilitating such change shall be present on the Platform and such change shall be facilitated by the User. If You change any Information, We may or may not keep track of Your old Information. We will not retain in our files, Information You have requested Us to remove for certain circumstances, such as to resolve disputes, troubleshoot problems and enforce Our terms and conditions. Such prior Information shall be completely removed from Our databases, including stored ‘back up’ systems. If You believe that any Information we are holding on You is incorrect or incomplete, or wish to remove Your profile so that others cannot view it, the User needs to remediate, and promptly correct any such incorrect Information, either Yourself through the Platform or by getting in touch with Us through the contact given in the Contact Us section.

17. CONTROL OF YOUR PASSWORD

17.1 When You sign up to become a registered User, You will also be asked to choose a password. You are entirely responsible for maintaining the confidentiality of Your password. It is important that You protect it against unauthorized access of Your account and Information by choosing Your password carefully, and keeping Your password and computer secure by signing out after using Our Services.

17.2 You agree not to use the account, username, email address or password of another User at any time or to disclose Your password to any third party. You are responsible for all actions taken with Your login information and password, including making of payments on the Platform. If You lose control of Your password, You may lose substantial control over Your Personal Information and may be subject to legally binding actions taken on Your behalf. Therefore, if Your password has been compromised for any reason, You should immediately change Your password. You agree to notify Us promptly if You suspect any unauthorized use of Your account or access to Your password even after changing it.

18. SEVERABILITY

18.1  Each paragraph of this Policy is and shall remain separate from and independent of and severable from all and any other paragraphs herein except where otherwise expressly indicated or indicated by the context of this Policy. The decision or declaration that one or more of the sections are null and void shall have no effect on the remaining paragraphs of this Policy.

19. AMENDMENT

19.1  We reserve the rights to revise the Policy from time to time to suit various legal, business and customer requirement. Please revisit this page periodically to stay aware of any changes to this Policy, which We may update from time to time. If We modify the Policy, We will make it available through the Platform, and indicate the date of the latest revision. Your continued use of the Platform/Services after the revised Policy has become effective, indicates that You have read, understood and agreed to the current version of the Policy. This Policy is to be read concurrently with Our Terms of Use, and other policies of the Company.

20. AUTOMATED DECISION MAKING

20.1 As a responsible company, We do not use automatic decision-making or profiling.

21. CONSENT WITHDRAWAL, DATA DOWNLOAD & DATA REMOVAL REQUESTS

21.1 To withdraw Your consent, or to request the download or deletion of Your Information with Us for any or all our products & Services at any time, please email to contactus@clootrack.com from Your registered email address.

22. CONTACT US

If You have any questions or concerns regarding this Policy, You can get in touch with Us by sending an e-mail to contactus@clootrack.com.

We try to respond to all legitimate requests within one month, or such shorter period as required under applicable law. Occasionally it may take Us longer than a month if Your request is particularly complex or You have made a number of requests. In this case, We will notify You and keep You updated.

23. USAGE OF DATA RETRIEVED FROM DATA CONNECTORS

Company does not use the google workspace APIs to develop, improve, or train generalized/non-personalized AI and/or ML models.