Standards Against Child Sexual Abuse and Exploitation (CSAE)

We are committed to creating and maintaining a safe environment for all users of our application. The safety and well-being of children is a top priority, and we have zero tolerance for any form of child sexual abuse and exploitation.

Our Commitments

1. Zero Tolerance Policy — Strictly prohibiting CSAM with immediate suspension and reporting to authorities.
2. Reporting and Removal — In-app reporting via the three-dot menu; prompt review and permanent bans.
3. Collaboration with Authorities — Full compliance with child safety laws and cooperation with law enforcement.
4. Proactive Safeguards — Moderation and detection measures to prevent CSAM and exploitation.
5. Child Safety Contact — contact@trekrecord.com
6. Ongoing Compliance — Following industry best practices including Tech Coalition guidelines.

CSAE policy last updated: 8 September 2025

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Terms and Conditions of Use

Please read these Terms of Use (collectively with the TREKRECORD Privacy Policy the "Terms of Use") fully and carefully before using the TREKRECORD application (the "App") and the services, features, content or applications offered by "TREKRECORD LTD" in connection with the App ("Company," "we", "us" or "our") (together with the App, the "Services"). These Terms of Use set forth the legally binding terms and conditions for your use of the App and the Services.

• Acceptance of Terms of Use.

• By signing up for, installing and/or using the App in any manner, you agree to these Terms of Use and all other operating rules, policies and procedures that may be published from time to time through the App by us, each of which may be updated from time to time without notice to you.
• Certain of the Services may be subject to additional terms and conditions specified by us from time to time; your use of such Services is subject to those additional terms and conditions, which are incorporated into these Terms of Use by this reference.
• These Terms of Use apply to all users of the Services, including, without limitation, users who are contributors of content, information, and other materials or services, registered or otherwise.

• Eligibility. You represent and warrant that you are an individual person at least 16 years of age. If you are under age 16, you may not, under any circumstances or for any reason, use the Services. We may, in our sole discretion, refuse to offer the Services to any person or entity and change its eligibility criteria at any time. Further, the Services are offered only for your use, and not for the use or benefit of any third party. You are not eligible for participation in the App if you violate any provision of these Terms of Use, as determined in our sole discretion.
• Registration. To sign up for the Services, we may require you to register for an account on the Services (an "Account"). You must provide accurate and complete information and keep your Account information updated. If you provide any information that is inaccurate, not current or incomplete, or Company has reasonable grounds to suspect that such information is inaccurate, not current or incomplete, Company may deny you access the App, areas requiring registration, and/or terminate your Account, at its sole discretion.

You shall not: (i) select or use as a username a name of another person with the intent to impersonate that person; (ii) use as a username a name subject to any rights of a person other than you without appropriate authorization; or (iii) use, as a username, a name that is otherwise offensive, vulgar or obscene. You are solely responsible for the activity that occurs on your Account, and for keeping your Account password and login credentials secure. You may never use another person's user Account or registration information for the Services without permission. You must notify us immediately of any change in your eligibility to use the Services (including any changes to or revocation of any licenses from state authorities), breach of security or unauthorized use of your Account. You should never publish, distribute or post login information for your Account. You shall have the ability to delete your Account, either directly or through a request made to one of our employees or affiliates.

You may establish, maintain, use and control only one Account. Each Account may only be owned, maintained, used and controlled by one individual. For avoidance of doubt, users shall not "co-own" accounts. In the event Company determines that you have opened, maintained, used or controlled more than one Account, in addition to any other rights that Company may have, Company reserves the right to suspend or terminate any or all of your accounts.

• Content.

• Definition. For purposes of these Terms of Use, the term "Content" includes, without limitation, information, data, text, photographs, videos, audio clips, written posts and comments, software, scripts, graphics, and interactive features generated, provided, or otherwise made accessible on or through the Services. For the purposes of the present, "Content" also includes all User Content (as defined below).
• User Content. In order for Trekrecord to provide the intended level of quality information on travelling and destinations, you must always observe the basic principles of Trekrecord, namely:
• Don't add countries that you've been to for less than 12 hours. Add a country if you have actually spent some time in it, not if you have just travelled through it to go to another country, or if you have just spent time in the airport waiting for a connecting flight;
• Don't upload photos from places you haven't been to;
• Don't upload photos you don't own;
• Don't write Treknotes - tips from places you haven't been to.
• In case a user reports the content of another user, we will review that content to see if it is offensive or inappropriate or content that does not meet the App's standards/terms and if deemed necesssary we will block the author of this content from using the App.

All Content added, created, uploaded, submitted, distributed, or posted to the Αpp by users (collectively "User Content"), whether publicly posted or privately transmitted, is the sole responsibility of the person who originated such User Content. You represent that all User Content provided by you is accurate, complete, up-to-date, and in compliance with all applicable laws, rules and regulations. You retain ownership of any and all User Content created and/or uploaded by you. You acknowledge that all Content, including User Content, accessed by you using the Services is at your own risk and you will be solely responsible for any damage or loss to you or any other party resulting therefrom. We do not guarantee that any Content you access on or through the Services is or will continue to be accurate.

Trekrecord is not responsible for, and does not endorse, Content posted within the Service. Trekrecord does not have any obligation to prescreen, monitor, edit, or remove any Content. Trekrecord reserves the right to request proof of trekrecords or to ban a user if it's found out that the user violates the above-mentioned principles.

• Notices and Restrictions. The Services may contain Content specifically provided by us, our partners or our users and such Content is protected by copyrights, trademarks, service marks, patents, trade secrets or other proprietary rights and laws. You shall abide by and maintain all copyright notices, information, and restrictions contained in any Content accessed through the Services.
• Use License. Subject to these Terms of Use, we grant each user of the Services a non-exclusive, non-sublicensable and non-transferable license to use (i.e., to download and display locally) Content solely for purposes of using the Services. Use, reproduction, modification, distribution or storage of any Content (other than your User Content) for other than purposes of using the Services is expressly prohibited without prior written permission from us. You shall not sell, license, rent, or otherwise use or exploit any Content (other than your User Content) for commercial use or in any way that violates any third party right.
• Availability of Content. We do not guarantee that any Content will be made available on the App or through the Services. We reserve the right to, but do not have any obligation to, (i) remove, edit, block, modify or otherwise manipulate any Content in our sole discretion, at any time, without notice to you and for any reason (including, but not limited to, upon receipt of claims or allegations from third parties or authorities relating to such Content or if we are concerned that you may have violated these Terms of Use), or for no reason at all.

• Rules of Conduct.

• As a condition of use, you promise not to use the Services for any purpose that is prohibited by these Terms of Use. You are responsible for all of your activity in connection with the Services. Violation of our rules may result in the termination and cancellation of your Account. You acknowledge and agree that we may terminate any TREKRECORD Account at any time for any reason (including, but not limited to, our independent assessment or the receipt of claims or allegations from third parties or authorities).
• By way of example, and not as a limitation, you shall not (and shall not permit any third party to) either (a) take any action or (b) upload, download, post, submit or otherwise distribute or facilitate distribution of any Content on or through the Service, including without limitation any User Content, that:
• infringes any patent, trademark, trade secret, copyright, right of publicity or other right of any other person or entity or violates any law or contractual duty, including but not limited to, facilitating the rebroadcast of the TREKRECORD Services;
• uses the Services for any unauthorized purpose, or in violation of any applicable law, including intellectual property laws;

iii. you know is false, misleading, untruthful or inaccurate, including, but not limited to, providing inaccurate contact or Account information;

• is unauthorized commercial communications, hate speech, threatening, or pornographic, incites violence, or contains nudity or graphic or gratuitous violence;
• results in the creation or operation of multiple user accounts;
• enters you into TREKRECORD App for which you are not eligible, whether by multi-accounting, providing misleading information, masking or altering your IP address, or other means;

vii. results in the sale or transfer of your Account;

viii. is unlawful, threatening, abusive, harassing, defamatory, libelous, deceptive, fraudulent, invasive of another's privacy, tortious, obscene, vulgar, pornographic, offensive, profane, contains or depicts nudity, contains or depicts sexual activity, otherwise violates any law or right of any third party, or is otherwise inappropriate as determined by us in our sole discretion;

• constitutes unauthorized or unsolicited advertising, junk or bulk email ("spamming");
• contains software viruses or any other computer codes, files, content, or programs that are designed or intended to disrupt, damage, limit or interfere with the proper function of any software, hardware, or telecommunications equipment or to damage or obtain unauthorized access to any system, data, password or other information of ours or of any third party;

xii. is designed or intended to obtain password, Account, or private information from any TREKRECORD user;

xiii. impersonates any person or entity, including any of our employees, representatives, or users;

xiv. includes anyone's identification documents, sensitive financial information or any kind of sensitive personal information of a third party.

• You shall not: (i) take any action that imposes or may impose (as determined by us in our sole discretion) an unreasonable or disproportionately large load on our (or our third party providers') infrastructure; (ii) interfere or attempt to interfere with the proper working of the Services or any activities conducted on the Services; (iii) bypass, circumvent or attempt to bypass or circumvent any measures we may use to prevent or restrict access to the Services (or other accounts, computer systems or networks connected to the Services); (iv) run any form of auto-responder or "spam" on the Services; (v) use manual or automated software, devices, or other processes to "crawl" or "spider" any page of the App without our express written permission; (vi) harvest or scrape any Content from the Services; or (vii) otherwise take any action in violation of these Terms and our guidelines and policies.
• You shall not (directly or indirectly): (i) decipher, decompile, disassemble or otherwise attempt to derive any source code or underlying ideas or algorithms of any part of the Services (including without limitation any application); (ii) modify, translate, or otherwise create derivative works of any part of the Services; or (iii) copy, rent, lease, distribute, or otherwise transfer any of the rights that you receive hereunder. You shall abide by all applicable local, state, national and international laws and regulations.
• You shall not: (i) collect other users' content or information, with any means, including automatic ones, without our prior explicit written consent; (ii) solicit login information or access an account belonging to someone else; (iii) use Trekrecord to do anything unlawful, misleading, malicious, or discriminatory. By accessing or using Trekrecord you represent and warrant that your activities are lawful in every jurisdiction where you access or use the service; (iv) provide any false personal information in order to create an account for anyone other than yourself without permission; (v) create more than one personal account; (vi) share your password let anyone else access your account
• We also reserve the right to access, read, preserve and disclose any information as we reasonably believe is necessary to (i) satisfy any applicable law, regulation, legal process or governmental request, (ii) enforce these Terms of Use, including investigation of potential violations hereof, (iii) detect, prevent, or otherwise address fraud, security or technical issues, (iv) respond to user support requests, or (v) protect the rights, property or safety of us, our users and the public.
• If for any reason the Service is not running as originally planned (e.g. if it becomes corrupted or does not allow the proper usage and processing of entries in accordance with the rules, or if infection by a computer virus, bugs, tampering, unauthorized intervention, actions by entrants, fraud, technical failures, or any other causes of any kind, in the sole opinion of Company corrupts or affects the administration, security, fairness, integrity or proper conduct of the Service), Company reserves the right, in its sole discretion, to disqualify any individual implicated in or relating to the cause and/or to cancel, terminate, extend, modify or suspend the Service.

• Third-Party Services. The Services may permit you to link to or otherwise access other websites, services or resources on your device and the Internet, and other websites, services or resources may contain links to or be accessed by the Services or the App (including, without limitation, sites and services to synchronize video to music). These other resources are not under our control, and you acknowledge that we are not responsible or liable for the content, functions, accuracy, legality, appropriateness or any other aspect of such websites or resources. The inclusion of any such link or access does not imply our endorsement or any association between us and their operators. You further acknowledge and agree that we shall not be responsible or liable, directly or indirectly, for any damage or loss caused or alleged to be caused by or in connection with the use of or reliance on any such content, goods or services available on or through any such website or resource.
• Location-Based Services. We may offer features that are based on the location of users and which may report on the locations of those users as they use the Services (the "Location-Based Services"). You may partake in using these Location-Based Services solely at your own discretion, and may opt out of providing such information by turning off those features. Should you use Location-Based Services, you are consenting to our collection and dissemination of your location information through the Services. Under no circumstances shall we be liable for claims or damages therefrom arising out of your informed decision to disseminate your location information through the Service.
• Termination. We may terminate your access to all or any part of the Services at any time, with or without cause, with or without notice, effective immediately, which may result in the forfeiture and destruction of all information associated with your use of the Services. If you wish to terminate your Account, you may do so by removing the App from your device and following the instructions on the App or through the Services. All provisions of these Terms of Use which by their nature should survive termination shall survive termination, including, without limitation, licenses of User Content, ownership provisions, warranty disclaimers, indemnity and limitations of liability.
• Warranty Disclaimer.

• We have no special relationship with or fiduciary duty to you. You acknowledge that we have no duty to take any action regarding:
• which users gain access to the Services;
• what Content you access via the Services; or

iii. how you may interpret or use the Content.

• You release us from all liability and fully indemnify us to the greatest extent provided under applicable laws for you having acquired or not acquired Content through the Services. We make no representations concerning any Content contained in or accessed through the Services, and we will not be responsible or liable for the accuracy, copyright compliance, or legality of material or Content contained in or accessed through the Services.
• The views and opinions of our hosts are their own and not necessarily representative of the views and opinions of the Company or its employees, and the Company assumes no responsibility for the Content, accuracy, or views of or opinions expressed by such hosts.
• NO WARRANTY OF ANY KIND, EXPRESS OR IMPLIED, IS BEING PROVIDED BY THE COMPANY IN RESPECT TO THE SERVICES. WE, AND OUR DIRECTORS, EMPLOYEES, AGENTS, SUPPLIERS, PARTNERS AND CONTENT PROVIDERS DO NOT WARRANT THAT: (I) THE SERVICES WILL BE SECURE OR AVAILABLE AT ANY PARTICULAR TIME OR LOCATION; (II) ANY DEFECTS OR ERRORS WILL BE CORRECTED; (III) ANY CONTENT OR SOFTWARE AVAILABLE AT OR THROUGH THE SERVICES IS FREE OF VIRUSES OR OTHER HARMFUL COMPONENTS; OR (IV) THE RESULTS OF USING THE SERVICES WILL MEET YOUR REQUIREMENTS. YOUR USE OF THE SERVICES IS SOLELY AT YOUR OWN RISK.

• Indemnification. You guarantee that you shall defend, indemnify, and hold harmless us, our affiliates and each of our and their respective employees, contractors, directors, suppliers and representatives from all liabilities, claims, and expenses, including reasonable attorneys' fees, that arise from or relate to your use or misuse of, or access to, the Services, Content, or otherwise from your User Content, violation of these Terms of Use, or infringement by you, or any third party using your Account or identity in the Services, of any intellectual property or other right of any person or entity.
• Limitation of Liability. IN NO EVENT SHALL WE, NOR OUR DIRECTORS, EMPLOYEES, AGENTS, PARTNERS, SUPPLIERS OR CONTENT PROVIDERS, BE LIABLE UNDER CONTRACT WITH RESPECT TO THE SERVICES (I) FOR ANY LOST PROFITS, DATA LOSS, COST OF PROCUREMENT OF SUBSTITUTE GOODS OR SERVICES, OR SPECIAL, INDIRECT, INCIDENTAL, PUNITIVE, COMPENSATORY OR CONSEQUENTIAL DAMAGES OF ANY KIND WHATSOEVER (HOWEVER ARISING), (II) FOR ANY BUGS, VIRUSES, TROJAN HORSES, OR THE LIKE (REGARDLESS OF THE SOURCE OF ORIGINATION), OR (III) FOR ANY DIRECT DAMAGES IN EXCESS OF (IN THE AGGREGATE) €250.
• Governing Law and Jurisdiction. These Terms of Use shall be governed by and construed in accordance with the laws of Cyprus. You agree that any dispute arising from or relating to the subject matter of these Terms of Use shall be governed by the exclusive jurisdiction of the courts of Nicosia, Cyprus.
• Modification. We reserve the right, in our sole discretion, to modify or replace any of these Terms of Use, or change, suspend, or discontinue the Services (including without limitation, the availability of any feature, database, or content) at any time by posting a notice on the App or by sending you notice through the Services, via email or by another appropriate means of electronic communication. We may also impose limits on certain features and services or restrict your access to parts or all of the Services without notice or liability. While we will timely provide notice of modifications, it is also your responsibility to check these Terms of Use periodically for changes. Your continued use of the Services following notification of any changes to these Terms of Use constitutes acceptance of those changes, which will apply to your use of the Services going forward. Your use of the Services is subject to the Terms of Use in effect at the time of such use.
• Intellectual Property Policy.

• The Company has adopted the following general policy toward copyright infringement in accordance with the applicable laws.
• Procedure for Reporting Copyright Infringement. If you believe that material or content residing on or accessible through the Services infringes a copyright, please send a notice of copyright infringement containing the following information to the Designated Agent listed below

• • A physical or electronic signature of a person authorized to act on behalf of the owner of the copyright that has been allegedly infringed;
  • Identification of works or materials being infringed;
  • Identification of the material that is claimed to be infringing including information regarding the location of the infringing with sufficient detail so that Company is capable of finding and verifying its existence;
  • Contact information about the notifier including address, telephone number and, if available, email address;
  • A statement that the notifier has a good faith belief that the material is not authorized by the copyright owner, its agent, or the law; and
  • A statement made under penalty of perjury that the information provided is accurate and the notifying party is authorized to make the complaint on behalf of the copyright owner.

• Please contact the Designated Agent to Receive Notification of Claimed Infringement for the Company at info@trekrecord.com.

• Apple Device and Application Terms.

In the event you are accessing the Services via an application on a device provided by Apple, Inc. ("Apple") or an application obtained through the Apple App Store (in either case, an "Apple Application"), the following shall apply:

• Both you and the Company acknowledge that these Terms of Use are concluded between you and the Company only, and not with Apple, and that Apple is not responsible for the Apple Application or the Content;
• The Apple Application is licensed to you on a limited, non-exclusive, non-transferable, non-sublicensable basis, solely to be used in connection with the Services for your private, personal, non-commercial use, subject to all the terms and conditions of these Terms of Use;
• You will only use the Apple Application in connection with an Apple device that you own or control;
• You acknowledge and agree that Apple has no obligation whatsoever to furnish any maintenance and support services with respect to the Apple Application;
• In the event of any failure of the Apple Application to conform to any applicable warranty, including those implied by law, you may notify Apple of such failure; upon notification, Apple's sole warranty obligation to you will be to refund to you the purchase price, if any, of the Apple Application;
• You acknowledge and agree that the Company, and not Apple, is responsible for addressing any claims you or any third party may have in relation to the Apple Application;
• You acknowledge and agree that, in the event of any third party claim that the Apple Application or your possession and use of the Apple Application infringes that third party's intellectual property rights, the Company, and not Apple, will be responsible for the investigation, defense, settlement and discharge of any such infringement claim;
• Both you and the Company acknowledge and agree that Apple and Apple's subsidiaries are third party beneficiaries of these terms, and that upon your acceptance of these terms, Apple will have the right (and will be deemed to have accepted the right) to enforce these terms against you as the third-party beneficiary hereof.

The abovementioned terms and conditions apply (to the extent applicable) when the App is downloaded through Google Play of the company Google LLC.

• Miscellaneous.

• Entire Agreement and Severability. These Terms of Use are the entire Agreement between you and us with respect to the Services, including use of the App, and supersede all prior or contemporaneous agreements, communications and proposals (whether oral, written or electronic) between you and us with respect to the Services. If any provision of these Terms of Use is found to be unenforceable or invalid, that provision will be limited or eliminated to the minimum extent necessary so that these Terms of Use will otherwise remain in full force and effect. The failure of either party to exercise in any respect any right provided for herein shall not be deemed a waiver of any further rights hereunder. You acknowledge that you fully understand the English language and the meaning of the full terms and conditions set out in this Agreement.
• Force Majeure. We shall not be liable for any failure to perform our obligations hereunder where such failure results from any cause beyond our reasonable control, including, without limitation, mechanical, electronic or communications failure or degradation.
• Assignment. These Terms of Use are personal to you, and are not assignable, transferable or sublicensable by you except with our prior written consent. We may assign, transfer or delegate any of our rights and obligations hereunder without your consent.
• Agency. No agency, partnership, joint venture, or employment relationship is created as a result of these Terms of Use and neither party has any authority of any kind to bind the other in any respect.
• Notices. Unless otherwise specified in these Term of Service, all notices under these Terms of Use will be in writing and will be deemed to have been duly given when received, if personally delivered or sent by mail, when receipt of such mail by the other party may be proved by any way. Electronic notices addressed to the Company should be sent to info@trekrecord.com.
• Relationships. The App is not sponsored, endorsed, administered by, or associated with Apple Inc or Google LLC or their subsidiaries or affiliates.
• Contact. You may contact us at the following address: TREKRECORD LTD, Tortola Pier Park, Building 1, Second Floor, Wickhams Cay I, Road Town, Tortola, British Virgin Islands and by email at info@trekrecord.com.

Date of Last Revision: 1 September 2022

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Privacy Policy

1. OUR APPROACH TO PRIVACY
   TREKRECORD LTD ("TREKRECORD", "Company", "we", "our" or "us"), a company incorporated in the British Virgin Islands with registered office at Tortola Pier Park, Building 1, Second Floor, Wickhams Cay I, Road Town, Tortola, British Virgin Islands, is committed to protecting and respecting your personal data. This privacy policy sets out how we collect, store, process, transfer, share and use data that identifies or is associated with you ("personal information" or "personal data" as those are defined in the applicable laws, including but not limited to the EU General Data Protection Regulation, and information regarding our use of cookies and similar technologies.

• TREKRECORD operates an application that allows you to track the number of countries you have visited and keeps your travel experience live and shareable with friends by using our app, which it can be downloaded to your mobile phone (the "Service").

• By using our Service, you understand and agree that we are providing a platform for you to post content, including photos, posts, comments and other materials and to share them publicly. This means that other users may search for, see, use, or share any of your content that you make publicly available through the application, consistent with the terms and conditions of this Privacy Policy and our Terms of Use.

• This privacy policy applies to our Service. Before accessing or using our Service, please ensure that you have read and understood how we collect, store, use and disclose your personal data as described in this privacy policy. By using our mobile application or by providing us your personal data, you agree and consent to the collection, use and disclosure of your personal information as outlined in this Policy.

• "Personal Data" means any information or set of information that relates to an individual such as name, address, email, telephone number etc. which can be either direct or indirect and can be collected by or on behalf of the Company.

• TREKRECORD is the data controller of the personal data we hold about you.

2. PERSONAL DATA WE COLLECT ABOUT YOU
   We collect and process the following personal data that you voluntarily submit directly to us when you use our Service, including but not limited to:

• Account Information. If you create an account, we will collect certain personal information that can be used to identify you, such as your name, postal and/or email address, phone number and date of birth. If you create an account using your login credentials from one of your social network accounts, we'll be able to access and collect your name and email address and other information that your privacy settings on such social network account permit us to access. If you create an account through our mobile application, we may also collect your gender and other personal information as well as non-personal information relating to you.
• Profile information, such as your username, profile picture and the details of other users you have invited to use our Service.

• Note about "Invite Friends" feature: You can choose to invite someone from the contact list on your device to our Service through the "Invite friends" feature by sending an email from your personal account. You understand and agree that you are responsible for any charges applied to communications sent from your device. As this invitation is coming directly from your personal account, TREKRECORD does not have access to or control this communication.

• User content, such as your photos, posts, comments, notes and other materials you provide when you use our Service;
• Identification data, such as your registration/identification information (for example, identity card numbers) insofar as required by the Company and permitted by law;

• Your Communications with Us. We collect personal information from you such as email address, phone number, or mailing address when you request information about our Service, request customer or technical support or otherwise communicate with us.
• Surveys. We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include personal information.

• In addition to the information you may provide us directly, we receive information about you from others, including:

• Users may provide information about you as they use our Services, for instance as they interact with you. Any person sharing personal data of other people should have granted their consent proof of which may be requested at any time during the use of Services.
• Other Partners. We may receive information about you from our sources, including through partners where TREKRECORD ads are published on a partner's service (in which case they may pass along details on a campaign's success), third party services and organizations or other social networks to supplement information provided by you. Where legally allowed, we can also receive information about suspected or convicted bad actors from third parties as part of our efforts to ensure our members' safety and security. If you connect a social network to our Service, or interact with our Service through a social network, we may receive information from the social network such as your name, profile information, and any other information you permit the social network to share with third parties. The data we receive is dependent on your privacy settings with the social network.
• Publicly available information.

• We will indicate to you where the provision of certain personal data is required in order for us to provide you certain features of the Service. If you choose not to provide such personal data, we may not be able to provide the Service to you or respond to your other requests.

• We also automatically collect digital personal data indirectly about how you access and use the Service and information about the device you use to access the Service. This information may include the following:

• Information about how you access and use the Service. For example, the website from which you came and the website to which you are going when you leave our website, how frequently you access the Service, the time you access our Service and how long you use it for, the approximate location that you access the Service from, whether you access the Service from multiple devices, the types of content you view or engage with or the frequency and duration of your activities and other actions you take on the Service.
• Log files and information about your device. We also collect information about the computer, tablet, smartphone or other electronic device you use to connect to our Service. This information can include details about the type of device, unique device identifying numbers, operating systems, browsers and applications connected to our Service through the device, your Internet service provider or mobile network, your IP address and your device's telephone number (if it has one).
• Approximate location information. Other than information you choose to provide to us, we do not collect information about your precise location. Your device's IP address may help us determine an approximate location.

• We may link or combine the personal data we collect about you and the information we collect automatically. This allows us to provide you with a personalised experience regardless of how you interact with us.

• We may anonymise any of the personal data we collect (so that it does not directly identify you). We may use anonymised information for purposes that include testing our IT systems, research, data analysis, improving our Service and developing new products and features. We may also share such anonymised information with others.

3. PURPOSES OF PROCESSING PERSONAL DATA

• 3.1 The Company will process your personal data only for purposes permitted by applicable laws, which may vary depending on where you live, and where the Company operates, and on the terms set forth in this Policy. The purposes of the data processing activities may include:

• Our primary purpose for collecting personal information from you is to provide and improve our Services, to administer your use of the Services (including your account, if you are an account holder), and to enable you to enjoy and navigate our Service.
• Fulfill our contract with you and provide you with our Service, such as:
• Managing your information and accounts;
• Providing access to certain areas, functionalities, and features of our Service;
• Communicating with you about your account, activities on our Service and policy changes.
• Analyze and improve our Service pursuant to our legitimate interest, such as:
• Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
• Measuring interest and engagement in our Service and short-term, transient use, such as contextual customization of ads;
• Researching and developing products, services, marketing or security procedures to improve their performance, resilience, reliability or efficiency;
• Improving, upgrading or enhancing our Service;
• Developing new products and Services;
• Ensuring internal quality control;
• Verifying your identity and preventing fraud;
• Enforcing our terms and policies; and
• Protecting your vital interest, or as may be required for the public good.
• Managing our relationships/communications with individuals: for example, responding to questions and comments or inquiries, inviting individuals to the Company's events, making proposals for future service needs.
• For collaboration and research purposes: for example, to enable Company to make more informed and objective decisions when identifying, engaging with individuals interested about our Service.
• Market research: processing data about individuals for lawful market research purposes. We collect data to help us improve our products and services.
• Direct marketing: to provide promotional material and engage in marketing and promotional activities with individuals in accordance with applicable laws.
• Website functions: to ensure that content from our website is presented in the most effective manner for you and for your device.
• Legal or regulatory obligations and the directions of law enforcement agencies and court orders: to comply with our legal or regulatory requirements (reporting for the safety of information and product quality complaints) or to fulfil transparency requirements.
• Sending you newsletters and other marketing material related to our project provided that you consent on these.
• Ensuring that the content of our mobile application is presented in the most effective way for you and your device.

• 3.2 The Company will process personal data for further purposes, where lawful to do so or when legally obliged to do so.

4. LEGAL BASIS OF PROCESSING

The Company processes personal data based on one or more of the following conditions:

• Consent: If you choose to provide us with information that may be considered "special" or "sensitive" in certain jurisdictions you're consenting to our processing of that information in accordance with this Privacy Policy. From time to time, we may ask for your consent to collect specific information or use your information for certain specific reasons. In some cases, you may withdraw your consent by deleting your content (for instance where you entered information in your profile that may be considered "special" or "sensitive"). In any case, you may withdraw your consent at any time by contacting us at the address provided at the end of this Privacy Policy.
• Provide our Service to you: The reason we process your information is to perform the contract that you have with us. For instance, as you go about using our Service to build meaningful connections, we use your information to maintain your account and your profile and to otherwise provide our features to you and other users.
• Comply with applicable laws and regulations: We process your information where it is necessary for us to comply with applicable laws and regulations and evidence our compliance with applicable laws and regulations. For example, we retain traffic data and data about transactions in line with our accounting, tax and other statutory data retention obligations and to be able to respond to valid access requests from law enforcement. We also keep data evidencing consents members give us and decisions they may have taken to opt-out of a given feature or processing.
• Legitimate interests: We process your information based on our legitimate interest. For example, the Company processes data for the improvement of our products and services, to provide security measures, to protect the Company's employees, contractors, information and other assets and to prevent crime (such as fraud, financial crime and theft of intellectual and industry property and to ensure the integrity of its manufacturing and other operations), for statistical purposes or in other ways strictly necessary to carry out our business.
• Individual interest: We process your information where it is necessary to protect the vital interests of an individual.
• Public Interest: We process your information where it is necessary in the public interest or for a public task.

5. RECIPIENTS OF PERSONAL DATA

• Personal data are not disseminated to unspecified recipients. The Company discloses your personal data to third party recipients on a need-to-know basis where this is reasonably permitted to pursue its legitimate business aims and as required by applicable law. Your personal data will be disclosed only in accordance with applicable laws, and appropriate safeguards through contractual agreements will be established to protect your personal data.

• We may share your personal data with the following:

• Employees of our Company: Access to your personal data is provided to the absolutely necessary staff of the Company, which has committed to maintain confidentiality.
• Affiliated Companies: we may share your personal data within the companies of the TREKRECORD's group for limited legitimate purposes. We may share information with other TREKRECORD companies to make the mobile application safer and enable us to address (e.g., ban) bad actors found or to assist us in data processing operations, as service providers, upon our instructions and on our behalf. Their assistance may include technical processing operations, such as data hosting and maintenance, customer care, marketing and targeted advertising, analytics, finance and accounting assistance, improving our service, securing our data and systems and fighting against spam, abuse, fraud, infringement and other wrongdoings. We may also share information with other TREKRECORD companies for other legitimate business purposes including corporate audit, analysis and consolidated reporting, where and as allowed under applicable law.
• Service providers and partners:we may share your personal data with third party vendors and other third party service providers who process personal data on behalf of the Company, for example (indicatively mentioned) advice / outsourcing, banks and other providers of support and provision of administrative services that provide support services to us, business associates and associates for the management and maintenance of, email distribution, research and analysis, brand and service promotion, Google, Facebook, and management of certain services and data under agreements that have been made. We also share information with partners who distribute and assist us in advertising our services. For instance, we may share limited information on you in hashed, non-human readable form to advertising partners.
• Other Third Parties when you have provided us with your consent: when you share content or any information using our Service, you choose the audience who can see what you share. Public information is any information or content you share with a public audience. Public information is available to all users of our Service, even those who aren't your friends. When you choose to share something with public, it's considered public information and other users may download or re-share this content on and off our Services. You can control who you share with when you post to our mobile application in your profile settings.
• Purchasers and third parties in connection with a business transaction: your personal data may be disclosed to third parties in connection with a transaction, such as a merger, sale of assets or shares, reorganisation, financing, change of control or acquisition of all or a portion of our business.
• Law enforcement, regulators and other parties for legal reasons: we may share your personal data with third parties as required by law or if we reasonably believe that such action is necessary to (i) comply with the law and the reasonable requests of law enforcement; (ii) detect and investigate illegal activities and breaches of agreements, including our Terms of Service; and/or (iii) exercise or protect the rights, property, or personal safety of TREKRECORD, its users or others.
• With your consent or at your request: We may ask for your consent to share your information with third parties. In any such case, we will make it clear why we want to share the information.

• The following is the policy we apply to those with whom we share your personal data:

• We only provide the information needed to perform their specific services;
• They may use your personal data only for the exact purposes set out in our contract with them;
• We work closely with them to ensure that your personal data are respected and protected at all times;
• If we stop using their services, any of the data they hold will be deleted or

• The third parties processing your personal data on our behalf have agreed and committed contractually with the Company:

• to maintain confidentiality;
• not to send to third parties your personal data without the consent of the Company;
• take appropriate security measures;
• comply with the legal framework for the protection of personal data and in particular Regulation 979/2016 / EU (otherwise GDPR).

6. STORING AND TRANSFERRING YOUR PERSONAL DATA

• Security. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy, applicable data protection laws and regulations as well as international security standards. All data you provide to us is stored on secure servers and accessed and used subject to our security policies and standards. The Company has implemented reasonable physical, technical and managerial controls and safeguards to keep your personal data protected from unauthorised access, disclosure, alteration, and destruction. Access to your personal data is limited to a restricted number of the Company's employees whose duties reasonably require such information and third parties with whom the Company contracts to carry out business activities related to the provision of Services. All electronic transactions entered into via our website or mobile application will be protected by encryption technology. We will never send you unsolicited emails or contact you by phone requesting your account details, password, credit or debit card information or national identification numbers.

• International Transfers of your Personal Data. Your personal data may be accessed by staff or suppliers or service providers in, transferred to and stored at, a location outside the EU or the EEA. Where the Company processes personal information in countries that may not provide the same level of data protection as in the EU/EEA or in your own country, where you are resident, the Company will implement reasonable and appropriate legal and technical and organizational security measures with the aim to ensure the security of the processing and in particular to protect your personal data from unauthorized access, use or disclosure. In particular, for residents of EEA – whenever we transfer your information outside of the EEA, we will take all reasonable steps to ensure that adequate safeguards are put in place to protect your information (unless we are permitted under applicable data protection law to make such transfers without additional formalities e.g. where the recipient country is considered an adequate destination). Such safeguards include the use of European Commission approved standard contractual clauses as mentioned above. Where appropriate we may also ask for your explicit consent.

• We will store and retain your personal data for the time strictly necessary to achieve the purposes for which the personal data were collected and any other permitted associated purpose. Personal data may be retained for longer duration where applicable laws or regulations require or where you allow the Company to do so. When your personal data is no longer needed it will be either irreversibly anonymised (and the anonymised information may be retained by the Company) or securely destroyed.

7. YOUR RIGHTS IN RESPECT OF YOUR PERSONAL DATA

• In accordance with applicable law on the protection of personal data, you have the following rights in respect of your personal data that our Company holds:

• Right of access. You have the right to obtain:

1. confirmation of whether, and where, we are processing your personal data;
2. information about the categories of personal data we are processing, the purposes for which we process your personal data and information as to how we determine applicable retention periods according to applicable laws and internal policies;
3. information about the categories of recipients with whom we may share your personal data; and
4. a copy of the personal data we hold about you.

• Right of portability. You have the right, in certain circumstances, to receive a copy of the personal data you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal data to another person.

• Right to rectification. You have the right to request rectification of any inaccurate or incomplete personal data we hold about you without undue delay.

• Right to erasure. You have the right, in some circumstances, to require us to erase your personal data without undue delay if the continued processing of that personal data is not justified.

• Right to restriction. You have the right, in some circumstances, to require us to limit the purposes for which we process your personal data if the continued processing of the personal data in this way is not justified, such as where the accuracy of the personal data is contested by you.

• Right to object. You have a right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your personal data, and we will assess and inform you if that is the case. You can object to marketing activities for any reason.

• If you wish to exercise one of the abovementioned rights, please contact us using the contact details at the end of this privacy policy. You may also review and edit the personal data you have submitted to us by logging into your account on the app.

• If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Service you have requested. We may also send you certain non-promotional communications regarding us and our Service, and you will not be able to opt out of those communications (e.g., communications regarding the Service or updates to our Terms or this Privacy Policy).

• You also have the right to lodge a complaint to your national data protection authority. Further information about how to contact your local data protection authority is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

8. LINKS TO THIRD PARTY SITES

• Our Service may, from time to time, contain links to and from third party websites, including those of other users, our partner networks, advertisers, partner merchants, news publications and affiliates. The Company does not endorse or recommend these sites' content or services and assumes no responsibility regarding the processing activities of personal data or any activity by or content on third-party sites to which our website provides links. We encourage you to read and be aware of the privacy policy, and all other policies, of each site you visit. Τhe statements in this Policy apply solely to information collected by the Company.

9. OUR POLICY TOWARDS CHILDREN

• Our Service is not directed at persons under 16 and we do not knowingly collect personal information from children under 16. If you become aware that your child has provided us with personal data, without your consent, then please contact us using the details below so that we can take steps to remove such data and terminate any account your child has created with us.

10. CHOICES ABOUT MARKETING

• If we intend to use your data for marketing purposes or if we intend to disclose your data to any third party for such purposes, we will inform you respectively. You have the right to object to personal data being used for the purposes of direct marketing and newsletters. You can also exercise the right at any time by contacting us as set out below.

11. CHANGES TO THIS POLICY

• The Company reserves the right to amend this Policy from time to time to reflect technological advancements, legal and regulatory changes, and the Company's business practices, subject to applicable laws. If the Company changes its privacy practices, an updated version of this Policy will reflect those changes by posting any revisions on with the respective update of the effective date listed on the bottom of this Policy. If there are significant changes in our Policy, we will make reasonable efforts to inform you (by any appropriate means) before the changes take effect. We therefore encourage you to periodically visit this page to stay informed of how we are using your personal data.

12. NOTICES

• If we need to provide you with information about something, whether for legal, marketing or other purposes related to TREKRECORD, we will select what we believe is the best way to get in contact with you. We will usually do this through email or by placing a notice on our Service. The fact that we may send notices to you will not stop you from being able to opt out of the certain type of contact.

13. CONTACTING US

• Please contact info@trekrecord.com if you have any questions, comments and requests regarding this Privacy Policy.

This privacy policy was last modified on 1 September 2022.