Privacy Policy

Welcome to Tracup Privacy Policy!

Tracup is owned and operated by the company TRACUP PTE LTD. TRACUP PTE LTD acts as a data controller in regard to the interactions on Tracup, as well as in relation to the use of Services, which means that we have the responsibility for collecting and processing your Personal Data.

This Privacy Policy has been created to clarify the processing of the Personal Data on Tracup, and in order to make all the related issues understandable and transparent in a user-friendly way. Therefore, here you can read more on how we collect, share, and use Personal Data, as well as on how you can exercise the rights you have as a data subject. This is due to the fact that we take the privacy of our Users very seriously and hence approach Personal Data processing as a significantly important matter.

This Privacy Policy is a part of the Agreement you conclude with TRACUP PTE LTD once you enter this Website or the Services, which means that the provisions hereof are legally binding and applicable to you. In addition to this Privacy Policy, the aforementioned Agreement includes our Terms of Use and Cookie Policy. In order to get familiar with your rights and obligations regarding the use of Tracup, please read the entire Agreement carefully.

Unless they are explicitly defined herein, all the terms written in capital letters have meaning in accordance with our Terms of Use.

All the questions you may have with regard to this Privacy Policy you may raise by sending an email to the email address designated in the section "Get in touch".

1. Defined terms

When we say…

We mean…


Your explicit consent on the processing of your Personal Data. Only persons age 15 or more may give their free consent to the processing of their Personal Data.


Pieces of data stored on the device you use (computer or mobile device) that is being used to track your use of Tracup, as well as to compile the statistical records on Website activity. You can read an explanation about the use of cookies and managing them in our Cookie Policy.

Data processor

Any natural or legal subject processing Personal Data on our behalf. To process your Personal Data more effectively, we may use the services of various service providers.

Data Subject or you

A natural person sharing their Personal Data with us by using Tracup, or Services, or otherwise.

Personal data

Any information relating to an identified or identifiable natural person - Data Subject.
An identifiable natural person is a person who can be identified (directly or indirectly) by reference to an identifier such as name, ID number, location data, online identifier, or to one or multiple factors specific to its physical, physiological, genetic, mental, economic, cultural, or social identity.
Generally, data about a legal entity does not classify under Personal Data, but registration on Tracup on behalf of a legal entity may anyhow result in sharing Personal Data. For instance, if it enables the identification of a natural person, any information on one-person companies may constitute Personal Data.
The same rules apply to the Personal Data in relation to a natural person in the course of the professional activity, such as the fact of employment in the particular company, employee's business phone number, a business email address including such employee's name, for example
However, the Privacy Policy is not applicable to information that cannot reasonably lead to the identification of an individual (known as anonymized information).

Tracup or Website

This website, available on or any subdomain.


Activity (or more of them) performed on Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.


Any service we provide via Website, excluding any other services which we may provide without the use of Website.

2. Data controller or data processor

Concerning Personal Data processed by TRACUP PTE LTD through Tracup, TRACUP PTE LTD may act in the role of a data controller or a data processor.

Data controller

In cases we act in the capacity of a data controller, we determine the purpose and the means of your Personal Data processing. We process your Personal Data with a specified purpose of data processing, further explained in the section "Why do we collect Personal Data?" along with the legal grounds for the processing of Personal Data. When we have a role of a data controller, we are responsible for your Personal Data.

This Privacy Policy primarily concerns the data processing by TRACUP PTE LTD when we act as a data controller, whereas exceptionally we process your Personal Data as a data processor, as explained in the following sub-section.

You may address any concerns you have regarding the processing of your Personal Data when we are the data controller, by contacting us in accordance with the section "Get in touch".

Data processor

In regards to any content including Personal Data you share via Workspace within a team on Tracup, the Admin is a data controller, which means that such person (including Enterprise) is responsible for your Personal Data. In such an event, TRACUP PTE LTD acts in the capacity of a data processor and does not take part in analyzing, disclosing, or accessing the shared Personal Data, but solely conducts the particular activities regarding the Personal Data in accordance with the request of the Admin.

If you wish to send an inquiry or exercise any of the rights you have as a Data subject in accordance with the section "Your rights", please contact the Admin as a data controller.

As we aim to achieve the greatest level of transparency of your Personal Data processing, despite being a processor in the described case, we have made an additional effort to explain how your Personal Data generally is being processed via Tracup and Service. Please, read the sub-section "TRACUP PTE LTD as a data processor" within the section "Data we collect".

In case you fall under the scope of application of the GDPR or similar data protection legislation, you may sign the Data Protection Addendum to these Terms of Use ("DPA"), with TRACUP PTE LTD as a data processor based outside the EEA. The DPA includes the Standard Contractual Clauses adopted by the European Commission, as applicable, and reflects the agreement between you and TRACUP PTE LTD in regard to the terms governing the processing of your Personal Data under the Terms of Use. Once signed, such DPA will be considered as an amendment to the Agreement, and will be considered to form a part of the Agreement.

If you consider signing a DPA with us, contact us for more information, by following the instructions in the section "Get in touch".

3. Data we collect

We collect information with regard to you in several different ways:

from you, voluntarily,
through the use of cookies, which is further explained in our Cookie Policy.
Voluntarily provided data

Some information you share with us voluntarily. Note that any Personal Data you decide to provide must at all times be true, complete, and accurate. Therefore, please inform us as soon as possible in case of any changes to any Personal Data we have collected in relation to you.

Voluntarily shared data include:

1. Personal Data related to your account

In order to create an account on Tracup, we ask you to share certain information such as the name of your organization, your name, email address and password. Besides these mandatory data, you may choose to share some additional Personal Data voluntarily, as explained in detail in the section "Why do we collect Personal Data?".

In case you decide to access Tracup through your Google account, we may process any Personal Data available on your Google account which is necessary for providing Service to you.

2. Personal Data for the subscription to get early access

When you decide to get early access to Tracup, we will collect your email address.

3. Additional Personal Data you share with us when reaching out to us

In cases you wish to contact us via any email address available on our Website, you choose which Personal Data you will share with us through your inquiry.

Automatically collected data

1. Technical data

When you access Tracup, we automatically collect your IP address, your device type and unique identification number, browser, broad geographical location such as your country or city, as well as other similar information. This type of information is typically collected through the use of cookies and other similar tracking technologies, which are further explained in Cookie Policy. For instance, we automatically collect the information on the time zone you are in at the moment of registering at Tracup and the language of your choice in your operating system, in order to display Tracup to you in your language and in the exact time zone you are in. Also, we collect the information on the date you joined Tracup, as well as on the date you were last online.

Also, in order to improve the performance of our Website, we collect certain information from your device, including the date and time stamps of your use of Tracup.

2. Data on your usage of Tracup

As we always aim to improve our Services, we follow and measure the traffic and usage trends on Tracup. With that goal, we use analytic tools to collect information that is sent from your device to Tracup. For example, we may analyze the web pages you visit, add-ons you use, and any other information that helps us improve our Website. However, please have in mind that such analytics information is collected and processed along with identical information from other users of Tracup, so it cannot reasonably be used to identify any particular individual. Therefore, such data does not classify under Personal Data.

4. Why do we collect Personal Data?

TRACUP PTE LTD as a data controller

The following table explains which Personal Data we collect for which purpose, as well as the legal ground for each of them. Have in mind that no Personal Data is processed outside the specific purposes. TRACUP PTE LTD does not sell any kind of Personal Data, disclose Personal Data to marketers, nor do we provide your Personal Data to any third party unless we are strictly compelled to do so by law or unless otherwise stipulated in the Privacy Policy and Cookie Policy.

Data we collect

Purpose of collecting

Legal ground

Your name, email, password, and the name of your organization.
In case you decide to log in to Tracup through your Google account, we may collect any Personal Data included in that account that is necessary for the functionality of your Tracup account.

Creating an account Personal Data is collected in order to create your account on Tracup and conclude an Agreement between you and Tracup.

Undertaking steps necessary for entering into Agreement and the provision of Service, as well as your explicit consent.

Technical data and data on your usage of Tracup, as described in the section "Data we collect".

Managing Tracup performance, analysing the use of Tracup and improving our Service
We collect some data in order to:
- manage and operate Tracup,
- improve the Services, as well as the performance and usability of Website, by keeping it up-to-date,
- analyze the use of Tracup and measure the interests of our visitors,
- ensuring the most effective presentation of the Tracup content to you, in accordance with the device you use.

Entering into Agreement and the provision of Service, legitimate interest of third parties (Admins), as well as your consent, provided via a cookie banner that appears on a web page the first time you visit Tracup. You can withdraw your consent at any moment in accordance with our Cookie Policy, but that will not affect the lawfulness of the processing based on your consent provided prior to such withdrawal.

TRACUP PTE LTD as a data processor

As explained above, TRACUP PTE LTD acts in the capacity of a data processor with regard to your Personal Data processed on or via Service, due to the fact that we process such data in accordance with the instructions provided by the Admin - the data controller. The purpose of such processing is to enable the efficient manner of managing projects, teams, as well as all types of work.

As a Personal Data processor, we are permitted to collect, use, disclose and/or otherwise process Personal Data solely in accordance with the instructions the data controller provides us with.

1. Processing Personal Data prior to the use of Service

Once the Admin or an Owner of the Workspace invites you to become a member of the team, you will be asked to share your name and password. For any questions regarding the legal basis for the processing of such Personal Data, please reach out to the Admin who has invited you to join the team.

2. Processing Personal Data while using the Service

Your acceptance of the previously described invitation results in you creating an account on Tracup.

You may choose to share some additional Personal Data within the option "My profile" available once you log in, such as your title in the company, phone and mobile phone number, skype number, location, birthday, work anniversary. This is not Personal Data necessary for the use of Service in relation to TRACUP PTE LTD. The controller decides on Personal Data required for their use of Service and determines the legal basis for processing such data.

In order to provide the Service to you, we may collect technical data and data on your usage of Tracup, as described in the section "Data we collect".

Tracup is not intended to be used for the processing of the special categories of Personal Data, and we do not analyze any such Personal Data. Special categories include the information on your racial or ethnic origin, religious and/or philosophical beliefs, health data, sex life or sexual orientation data, information on your political opinions, trade union membership, and genetic or biometric data. You may choose to share such Personal Data with the data controller, but please note that in such case you will be deemed to have provided your explicit consent to the processing of such Personal Data.

5. Underaged persons on Tracup

Tracup is not intended for persons under the age of 18. In case you fall under this category, please do not provide any personal information about yourself to us. If it comes to our knowledge that we have collected personal information concerning a person under 18 years of age, we will erase such information without delay.

If you believe we have collected Personal Data of a person under the age of 18, please contact us immediately at

6. How do we use collected Personal Data?

Personal Data we collect about you is used solely within the purposes it is collected for, and always under the condition that we have a reasonable and lawful legal basis to do so. TRACUP PTE LTD does not use any of the collected Personal Data without your consent, or other legally permitted reason, all in accordance with the section "Why do we collect Personal Data" above.

Our staff is legally bound by the professional secret rules, in order for TRACUP PTE LTD to achieve the highest level of Personal Data security. Additionally, we have implemented the appropriate legal, technical, and organizational measures to prevent the disclosure of any Personal Data beyond the legal purpose it was collected for.

7. How long do we keep Personal Data?

In accordance with the applicable legal regulation, we keep your Personal Data until the purpose of its collection is fulfilled. For example, where your consent is a legal ground for the processing, we will keep your Personal Data as long as we have your consent.

Upon the legal ground for the processing ceases to exist, we retain your Personal Data within the periods which are in compliance with the applicable laws, contractual obligations, and the expectations and requirements of our users and clients.

Once we no longer need your Personal Data, or upon your valid request for the erasure of such information, we will securely erase or destroy it, in accordance with the applicable law and our internal policies.

8. Sharing of Personal Data

As previously briefly explained, we sometimes engage third parties – external processors for the provision of certain services. In such cases, we use information audits to identify, categorize and make records of all Personal Data collected by us that is being processed outside of TRACUP PTE LTD. That way, all the Personal Data, information on particular processing activities, processors, and legal grounds are recorded, reviewed, and easily accessible.

9. International transfer

It may happen that we transfer your Personal Data to countries other than the one you reside in.

In such cases, we transfer your personal data only to the countries:

located within the EEA;
ensuring an adequate level of protection;
which do not belong to those specified under items 1 and 2, but only by applying the appropriate safeguard measures.

10. Your rights

Having in mind that we hold your Personal Data, as a Data Subject you have the following rights:

right to be informed about how we collect and use your Personal Data;
right to access your Personal Data we have collected;
right to the rectification of your Personal Data in case any of them is inaccurate or incomplete;
right to be forgotten by requesting us to erase or dispose of any of your Personal Data we have collected;
right to the restriction of processing of your Personal Data;
right to data portability regarding the Personal Data you have provided us with, and which is processed using automated means. In this case, you have the right to request a copy of such Personal Data, as well as to have such Personal Data transmitted to a third-party data controller;
right to object to the use of your Personal Data in case processing is based on our legitimate interest, as well as if the processing is conducted for the purposes of direct marketing, including profiling.
To exercise any of the listed rights, please contact us at

11. Security of the Personal Data

We use our best effort to maintain the safety of the Personal Data we collect. In order to achieve this goal, we use appropriate technical and organizational measures aimed at providing such a level of security that is proportional to the risk of processing your Personal Data.

Regardless, no method of electronic storage or method of transmission over the internet may be absolutely secure. With that in mind, we cannot guarantee 100% security or confidentiality regarding the collected Personal Data.

12. Changes to Privacy Policy

TRACUP PTE LTD holds the right to update and modify this Privacy Policy from time to time, as we consider appropriate. When we do so, any changes shall enter into force upon being published on Tracup, so we suggest you regularly review our Privacy Policy in order to remain up to date. Additionally, if you have shared your email address with us, we may send you a notice of these changes.

If you do not agree with any changes made to our Privacy Policy, please stop using Tracup immediately.

13. Get in touch

In case you have any questions regarding our Privacy Policy or you wish to exercise any of the rights described in the section "Your rights", please reach out to us by sending an inquiry to

Last updated on 10/02/2022