Privacy policy

Effective date: 03/18/2026

The following Privacy Policy covers all the websites/webpages owned, affiliated or operated by TRAKTRAIN ("TRAKTRAIN", "Traktrain", "us", "we", or "our"). It is our goal to allow you to showcase your music but, at the same time, protect your privacy. Please read the following to learn more about our Privacy Policy. By continuing to use traktrain.com you are accepting this policy. Some personal data information is essential to traktrain.com functioning and our supplying a service to you. If you do not wish to allow us to process your data then you will not be able to use our services.

Thank you for visiting TRAKTRAIN. This Privacy Policy is written to better explain how we collect and use your information. This Privacy Policy is a binding contract and you must agree to it to the same extent as our Terms and Conditions in order to use our Services. We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. We will let you know via email and/or a prominent notice on our Services, prior to the change becoming effective. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Please see our cookie banner or settings for information relating to our use of cookies and similar tracking technologies. If you are a California resident, you can learn about your additional consumer privacy rights under the California Consumer Privacy Act by reviewing our Notice for California Residents (https://traktrain.com/california-privacy). In the EEA/UK, where applicable, we rely on consent for non-essential cookies (e.g., advertising/analytics); you can manage or withdraw consent at any time in the cookie banner or settings. If you are a resident of Canada, Brazil, or certain U.S. states (such as Virginia, Colorado, Connecticut, Utah, or Texas), please see the additional disclosures in Section 4 below.

If you are a customer with a visual impairment or other disability or a customer who seeks support in another language, you may access the TRAKTRAIN Privacy Policy by emailing [email protected].

This Privacy Policy applies to any Site and Service that links to this Privacy Policy. This Policy does not apply to third-party websites, products, or services, even if they link to our Site or Services. We recommend you review the privacy practices of those third parties before connecting your TRAKTRAIN account or sharing any personal data. We also encourage you to read this Privacy Policy, along with our Terms and Conditions (https://traktrain.com/terms), to understand how your personal data will be treated as you make full use of our Services. Unless otherwise defined in this Privacy Policy, capitalized terms used in this Privacy Policy have the same meanings as in our Terms and Conditions.

By using the Services, you agree to the collection and use of information in accordance with this Privacy Policy. We ask that you do not use the Services if you do not agree to any of the provisions in this Privacy Policy. For more information about our privacy practices, please contact us by emailing us at [email protected].

Who is the controller? TRAKTRAIN USA Inc. ("Traktrain", "we", "us") is the controller of personal data processed in connection with operation of the Platform and our Traktrain-operated subscriptions and services. Contact: [email protected] Mailing address: 1445 Ross Avenue, Dallas, Texas 75202, USA.

Creators as independent controllers. For Creator Memberships where the Creator is merchant of record, the relevant Creator acts as an independent controller of subscriber information they receive for their memberships (e.g., to fulfill benefits, communicate about the membership, and handle refunds/disputes as MoR). Traktrain is not a party to that contract and is not the seller of Creator Memberships.

Processors. We use service providers (e.g., hosting, analytics, payments) who process data under our instructions.

We gather data from:

• Non-registered viewers of our website where our services are described ("Viewers");
• Producers registering in order to sell beats;
• Customers registering to purchase beats either as producers from our beat store or as customers purchasing from our marketplace;
• Individuals registering to use other services such as posting comments on traktrain.com ("Registrants").
• Where you are merely a Viewer we will normally only gather data indirectly but might also do so directly if you i) request further information from us ii) engage with us on social media as examples.

Where you are our Producers, Customers or other Registrants we will gather data indirectly and directly.

We are required to process your personal data in a lawful, fair and transparent manner.

Personal Data means any information that relates to an identified or identifiable individual.

Usage Data is data collected automatically either generated by the use of the Services or from the Services infrastructure itself (for example, the duration of a page visit).

Cookies are text files placed on your computer to collect standard Internet log information and visitor behavior information.

Data Controller means a person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed.

For the purpose of this Privacy Policy, we are a Data Controller of your data.

Data Processor (or Service Provider) means any person (other than an employee of the Data Controller) who processes the data on behalf of the Data Controller.

We may use the services of various Service Providers in order to process your data more effectively.

Data Subject is any living individual who is the subject of Personal Data.

The User is the individual using our Services. The User corresponds to the Data Subject, who is the subject of Personal Data.

"Paid Subscriptions" means (i) Creator Memberships (auto-renewing paid subscriptions offered by independent Creators; merchant of record = the Creator) and (ii) Traktrain-Operated Paid Subscriptions (auto-renewing paid services offered by Traktrain; merchant of record = Traktrain).

The website generally collects personally identifying information with your specific knowledge and consent for various purposes to provide and improve our Services to you. We process this information pursuant to our legitimate interest in providing you the Services and the best user experience on our Sites, as well as where necessary to perform any contract between you and us. This includes but is not limited to when you register or complete a survey. You can choose not to provide us with certain information, but you may not be able to take advantage of our Services.

Registration: In order to use specific parts of our websites such as uploading and allowing others to listen to the music you have produced, you must complete a registration form. As part of this registration process, we require your email address. Optional information such as your referrer or time zone may also be requested.

Personal Data we collect will be apparent by the context of the page, and may include, but is not limited to the following:

House Party Submissions – display name, link or uploaded audio file, optional note to the Host, Donation amount, and Stripe transaction ID;

Membership Subscriptions – information about your participation in the Creator Membership feature. If you subscribe to a Creator, we collect the Creator's identity, your subscription tier, the amount and timing of payments, and associated transaction IDs. If you are a Creator, we collect information about your tiers and your Subscribers (for example, subscriber display names, the tier purchased, subscription status, and payment history) to enable billing, access control, and fulfillment of membership benefits.

When you register for an account, we collect your first and last name, email address, telephone number and your password. We may also collect your payment and financial information such as your PayPal email address or billing address.

You may choose to add information to your profile on TRAKTRAIN, which may be made public. Such information may include your username, the city or country you live in, profile photo, links to your music recordings and social media profiles.

When you communicate with us or other Users through the Sites and Services or otherwise communicate with us by email, we collect information about the communication and any other information you provide in your response.

In addition to the uses described below, we may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us.

Marketing emails (for example, product announcements or promotions) require your consent where applicable and include an unsubscribe link. Service or operational emails (for example, subscription confirmations, renewal reminders, payment issues, or price-change notices) are necessary to provide the Service and may be sent even if you opt out of marketing emails. You can manage marketing preferences at any time in your account settings.

We send service or operational notices related to the Creator Membership feature, such as purchase confirmations, renewal reminders (where required), payment failure notices, and advance notices of price or material changes to a membership tier. These messages are necessary to operate your subscription and are not marketing. While you cannot opt out of strictly service or operational emails, you can manage your preferences for marketing communications at any time. For Creator-as-Merchant memberships, refund and dispute handling occurs directly between the Subscriber and the Creator; Traktrain may facilitate communications but does not process refunds. Our legal bases for these operational messages include performance of a contract and our legitimate interests in operating the Service and preventing fraud, without prejudice to your rights under applicable law.

We may also collect information that your browser sends whenever you visit our Services or when you access the Services by or through a mobile device ("Usage Data").

This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Services that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When you access the Services by or through a mobile device, this Usage Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data. Usage Data helps us recognize you as well as provide personalized content and advertising across all of your devices.

We may use and store information about your location if you give us permission to do so ("Location Data"). We use this data to provide features of our Services, to improve and customize our Services.

You can enable or disable location services when you use our Services at any time, through your device settings.

When you visit our websites, we may collect information from you automatically, such as the activity on our Services, through cookies or similar tracking technologies.

Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Services. We may also allow our business partners to use cookies and similar tracking technologies on the Services or work with third parties to track your behavior on our behalf.

When you visit a website that has integrated a TRAKTRAIN Widget, we may receive certain information about you, such as the website you visited. The website containing the widget may also receive this information about you. The widget may be used to stream music and purchase music licenses.

We may receive Personal Data about you from our Service Providers and business partners, such as those that conduct payment processing, analytics, advertising, hosting, marketing, customer and technical support, and other services.

TRAKTRAIN aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

Whenever made possible, you can update your Personal Data directly within your account settings section. If you are unable to change your Personal Data, please contact us to make the required changes.

If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.

To provide the Creator Membership feature, we share the minimum necessary subscriber information with the relevant Creator (independent controller) so they can deliver membership content and perks, manage tiers, and address support issues (e.g., your display name, subscription tier, status; and, where needed to deliver a specific benefit, your contact details). Where the Creator is a merchant of record, the Creator and Stripe may process payment-related data as independent controllers under their own privacy notices (see "Who is the controller?" above). Traktrain is not the seller of Creator Memberships and does not operate an escrow. Data subject requests for Creator-held subscriber information (e.g., access, correction, deletion) should be directed to the relevant Creator as an independent controller. If you submit such a request to Traktrain, we may forward it to the Creator or advise you how to contact them.

In order for you to place an order with us, you must provide us with your first name, last name, e-mail address, and PayPal or other supported payment service billing information. We will not disclose any information that you provide to us except in accordance with the provisions of this Privacy Policy.

When you visit our websites, we may collect information from you automatically through cookies or similar technologies. TRAKTRAIN does not sell, rent, or trade your personal information with unaffiliated third parties. We share your Personal Data with the entities listed below. We also rely on partners to provide many features of our Sites and Services using data about your use of the Sites and Services. We use your Personal Data (and, where applicable, cookies or similar technologies) for the following purposes:

• To enhance or improve user experience, the website, or Services;
• To process transactions and share limited information with our processors and service providers for fraud prevention, security, taxation, and compliance purposes. We do not sell your personal information. For cross-context behavioral advertising, see "Third Party Platform Advertising" and "Your privacy choices" below;
• To prioritize, transmit, and publicly display your House Party Submission, to process related Donations, and, where applicable, to issue refunds;
• To send e-mails about the site or respond to inquiries;
• To send e-mails about the website and other products, news, or updates for TRAKTRAIN;
• To send e-mails about third parties' products or Services.

When one or more of our business partners co-sponsor a service, promotion and/or contest, we may share some or all of the information collected in connection with such service, promotion or contest with the co-sponsor(s). If you do not want your information to be shared, you will be able to choose not to allow the transfer by not using or signing up for that particular service, promotion or contest.

We may employ third party companies and individuals to facilitate our Services ("Service Providers"), to provide the Services on our behalf, to perform Service-related services or to assist us in analyzing how our Services are used. For example, when you make a purchase through our online store, or sign up to receive promotional items from us, we may share some of your personal information with third parties helping us to complete your transaction or send you the items you signed up to receive. When we share your information with such third parties, we will work to ensure that only the information necessary to complete your transaction is disclosed. This Privacy Policy does not apply to such third parties. These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Any information in your profile will be accessible by other Users of the Sites and Services. If you listen to any music recordings uploaded by another User, the fact that you have listened to those recordings will be shared with that User. Similarly, if you comment on a user's profile, all Users will be able to see your comment. Your display name and the text of your House Party Submission may appear publicly in the queue or on the stream overlay. If you subscribe to a Creator's membership, limited subscriber information may be shared with that Creator to deliver your benefits. See "Sharing with Creators for Membership fulfillment" below for details. House Party streams may be recorded or restreamed by the Host on third-party platforms. Hosts are independent controllers for content on their channels and may retain overlays/queue snapshots in accordance with their own policies. Public profile elements and certain public interactions (e.g., comments, playlists) may be indexed by search engines and cached by third-party services.

If you subscribe to a Creator's membership, that Creator will be able to see that you are a subscriber, along with your display name and other profile information you choose to share. We may also provide the Creator with additional info strictly necessary to fulfill membership benefits (for example, contact details to schedule an off-platform one-on-one session if such benefit is included in your tier). Creators must handle subscriber information in accordance with applicable privacy laws and this Policy, and may use it only to fulfill membership offerings and communicate about the membership.

If you share our content through social media, for example by liking us on Facebook, following or tweeting about us on Twitter, or giving us a '+1' via Google Plus, those social networks will record that you have done so and may set a cookie for this purpose.

In some cases, where a page on our website includes content from a social network, such as a Twitter feed, or Facebook comments box, those services may set a cookie even when you do not click a button. As is the case for all cookies, we cannot access those set by social networks, just as those social networks cannot access cookies we set ourselves.

We may share your information with third party platform providers who assist us in serving advertising regarding the Services to others who may be interested in the Services. For the House Party feature, we share your Submission details with the selected Host solely to fulfill your request. We also partner with third parties (such as Facebook, Google and Twitter) who use cookies and similar tracking technologies to serve targeted advertising/content to you via the relevant third-party platform based on your profile/interests (also known as "interest-based advertising"). Your information is used by the third-party platform provider to identify your account and serve advertisements to you. While we will not share information that identifies you by name with unaffiliated third parties for their own use, such third parties may be able to identify you with sufficient data from other sources. You can control what advertisements you receive via the privacy settings on the relevant provider's platform and you should consult the third party's help/support center for more information. CPRA "share" and Global Privacy Control (GPC). We do not sell your personal information. We may "share" limited identifiers and internet/electronic activity for cross-context behavioral advertising as defined by California law. You may opt out via the "Do Not Sell or Share My Personal Information" link in the footer or your account settings. We honor browser-based Global Privacy Control (GPC) signals as an opt-out request for such "sharing."

Our website utilizes the Conversion Tracking Pixel service of Facebook. This tool allows us to follow the actions of users after they are redirected to a provider's website by clicking on a Facebook advertisement. We are thus able to record the efficiency of Facebook advertisements for statistical and market research purposes. The collected data remain anonymous and we cannot see the personal data of any individual user, however the collected data is saved and processed by Facebook. Facebook is able to connect this data with your Facebook account and the data is used for their own advertising purposes in accordance with their policy found under: https://www.facebook.com/about/privacy Please click here if you would like to revoke your permission: https://www.facebook.com/ads/website_custom_audiences/

We may analyze aggregated, de-identified data and share these analytics, including to marketing agencies, media agencies and analytics providers. We may also combine information from the Services with other information we obtain. Additionally, information collected about you from a particular browser or device may be linked to information collected from another computer or device that may relate to you.

We may use third-party Service Providers to monitor and analyze the use of our Services: Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Services. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: http://www.google.com/intl/en/policies/privacy/

Our website now offers the convenience of signing in using Google Single Sign-On (SSO), allowing users to access our services with their Google account credentials. This feature is implemented to streamline the login process and enhance user experience by minimizing the need for multiple passwords.

By opting for Google SSO, we collect the following information from your Google account with your consent:

• Email Address;
• Full Name;
• Profile Picture.

This information is used to:

• Create and manage your user account on our platform;
• Personalize your experience on our website;
• Communicate with you about updates, services, and offers, subject to your communication preferences.

We are committed to protecting your privacy. The information collected through Google SSO is not shared with any third parties except as required to provide our services or as required by law. We implement robust security measures to safeguard your personal information against unauthorized access and use.

By using Google SSO to sign into our website, you consent to the collection and use of your information as described in this policy. You retain the right to access, update, or delete your personal information at any time through your account settings or by contacting us directly.

Our platform uses YouTube API Services to provide certain features. By using these features, you agree to be bound by the YouTube Terms of Service (Terms of Service) and Google Privacy Policy (Privacy Policy – Privacy & Terms – Google). We collect and use information in accordance with our Privacy Policy, and any data obtained from YouTube API Services will be handled in compliance with YouTube's API Services Terms of Service, which can be reviewed here (YouTube API Services Terms of Service Google for Developers).

Limited Use & Deletion. Data obtained via YouTube API Services is used only to provide/maintain the features you request, is not transferred to third parties except as necessary to provide those features or comply with law, and is handled in accordance with YouTube's API Services User Data Policy (including the Limited Use requirements). You may revoke our access via your Google account permissions and may request deletion of YouTube-sourced data we hold by contacting [email protected].

We use Google Ads Enhanced Conversions to improve the measurement of our advertising campaigns and provide more relevant ads to our users. This feature involves sharing hashed versions of user data (such as email addresses) with Google Ads. The data is securely hashed and encrypted before transmission to protect your privacy. In the EEA/UK, we deploy Enhanced Conversions only with your consent for advertising cookies/trackers. You can withdraw consent at any time via our cookie banner or settings; withdrawal does not affect prior processing.

• Data Shared: We may collect and share hashed versions of first-party customer data such as email addresses, names, home addresses, and phone numbers. This data is captured in our conversion tracking tags, securely hashed, and sent to Google. Google uses this hashed data to match it with Google accounts that were signed in when interacting with one of our ads, helping us track conversions more effectively;
• Purpose: This data helps us match conversions to ad interactions, enhancing the effectiveness of our advertising efforts;
• Data Security: All data shared with Google is hashed using industry-standard encryption methods.

For more information on how Google handles this data, please visit the Google Privacy Policy: Privacy Policy – Privacy & Terms – Google

Your Choices:

• Consent: By using our services, you consent to the processing of your data as described;
• Opt-Out: You can opt out of this data sharing at any time by adjusting your account settings or visiting Google's Ad Settings: Ads Settings

We also partner with Microsoft Clarity and Microsoft Advertising to capture how you use and interact with our website through behavioral metrics, heatmaps, and session replay to improve and market our products/services. Website usage data is captured using first and third-party cookies and other tracking technologies to determine the popularity of products/services and online activity. Additionally, we use this information for site optimization, fraud/security purposes, and advertising. For more information about how Microsoft collects and uses your data, visit the Microsoft Privacy Statement (https://privacy.microsoft.com/privacystatement). In the EEA/UK, Clarity is activated only after you provide consent in our cookie banner or settings, which you can withdraw at any time.

We may update this privacy policy to reflect changes to our information practices. If we make any material changes, we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this website prior to the change becoming effective.

If TRAKTRAIN is involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.

You can modify your browser settings to decline or accept cookies. However, in a few cases, some of our Site features may not function as designed.

Your information, including Personal Data, may be transferred to - and maintained on - computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those from your jurisdiction.

If you are located outside the United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to the United States and other countries and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

TRAKTRAIN will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information. Where applicable, we rely on appropriate safeguards such as the EU Standard Contractual Clauses (SCCs) and the UK International Data Transfer Agreement/Addendum (IDTA), supplemented by transfer risk assessments, to legitimize transfers.

We rely on the following legal bases to process your information: (1) as necessary to perform any contract between you and us to provide the Services; (2) as necessary for our legitimate interests in providing the Services where those interests do not override your fundamental rights and freedoms related to data protection; and (3) with your consent.

Users that reside in the European Economic Area (EEA) and Switzerland have the right to lodge a complaint about our data collection and processing actions with the appropriate supervisory authority. You can view the contact information for data protection authorities here (https://edpb.europa.eu/about-edpb/board/members_en). UK residents may contact the ICO: (https://ico.org.uk).

In certain circumstances, residents of the EEA or Switzerland are entitled to the following data protection rights:

• Right to access. You have the right to request TRAKTRAIN for copies of your Personal Data;
• Right to rectification. You have the right to request that TRAKTRAIN correct any information you believe is inaccurate. You also have the right to request TRAKTRAIN to complete the information you believe is incomplete;
• Right to erasure. You have the right to request that TRAKTRAIN erase your Personal Data, under certain conditions;
• Right to restrict processing. You have the right to request that TRAKTRAIN restrict the processing of your Personal Data, under certain conditions;
• Right to object to processing. You have the right to object to TRAKTRAIN's processing of your Personal Data, under certain conditions;
• Right to data portability. You have the right to request that TRAKTRAIN transfer the data that we have collected to another organization, or directly to you, under certain conditions.

If you would like to exercise any of these rights, please contact us by emailing us at [email protected].

Where required, we process personal data for membership subscriptions under the legal bases of: (i) performance of a contract (to provide the membership, billing, access control, and fulfillment of benefits), and (ii) legitimate interests (to send operational notices about renewals, price changes, or payment issues, and to prevent fraud), without prejudice to your rights under applicable law.

We do not sell your personal information. We may "share" limited identifiers and internet/electronic activity with advertising partners for cross-context behavioral advertising as defined by California law. You can opt out of such "sharing" by using the "Do Not Sell or Share My Personal Information" link in the footer or via your account settings.

EEA/UK residents can object to processing for direct marketing at any time and manage consent for advertising cookies via our cookie banner or settings. These choices do not affect service or operational emails (for example, subscription confirmations, renewal reminders, payment issues, or price-change notices). If you are a resident of other U.S. states (such as Virginia, Colorado, Connecticut, Utah, or Texas), Canada, or Brazil, please refer to the applicable sections above for information about your privacy rights.

If you are a California resident, you can visit our Notice for California Residents (https://traktrain.com/california-privacy) to learn more about the personal information we collect and disclose about you as well as your privacy rights related to your personal information under the California Consumer Privacy Act.

If you are a resident of Virginia (under the Virginia Consumer Data Protection Act), Colorado (Colorado Privacy Act), Connecticut (Connecticut Data Privacy Act), Utah (Utah Consumer Privacy Act), Texas (Texas Data Privacy and Security Act), or other states that have enacted comprehensive privacy laws, you have the following rights, subject to certain exceptions:

• The right to confirm whether we are processing your personal information and to access that information;
• The right to correct inaccuracies in your personal information;
• The right to delete your personal information;
• The right to obtain a copy of your personal information in a portable format;
• The right to opt out of the processing of your personal information for purposes of (i) targeted advertising, (ii) the sale of personal information, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects.

To exercise any of these rights, please contact us at [email protected] or use the "Do Not Sell or Share My Personal Information" link in our footer. We will respond in accordance with applicable law. If we decline your request, you may appeal our decision by contacting us at the same email address.

If you are a resident of Canada, you have the right to access and request the correction of your personal information held by us. Under Canada's Personal Information Protection and Electronic Documents Act (PIPEDA) and substantially similar provincial laws (including those of Alberta, British Columbia, and Quebec), we rely on your consent to collect, use, and disclose your personal information, subject to legal and contractual restrictions. You may withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice. To exercise your rights or if you have any questions about our privacy practices in Canada, please contact us at [email protected].

If you are a resident of Brazil, this section applies to you. We process your personal data in accordance with the Brazilian General Data Protection Law (Lei Geral de Proteção de Dados – LGPD). You have the right to:

• Confirmation of the existence of processing;
• Access to your data;
• Correction of incomplete, inaccurate, or outdated data;
• Anonymization, blocking, or deletion of unnecessary or excessive data;
• Data portability to another service provider;
• Information about public and private entities with which we have shared data;
• Information about the possibility of denying consent and the consequences;
• Withdrawal of consent.

To exercise your rights, please contact us at [email protected]. We will respond within the timeframe required by the LGPD.

We may disclose your information to a third party where we believe, in good faith, that it is desirable to do so for the purposes of a civil action, criminal investigation, or other legal matter. In the event that we receive a subpoena affecting your privacy, we may elect to notify you to give you an opportunity to file a motion to quash the subpoena, or we may attempt to quash it ourselves, but we are not obligated to do either.

In addition, if we feel that a user abuses the TRAKTRAIN site in any way, we reserve the right to use and share certain information with third parties. Abuses include (but are not limited to) possible copyright infringement, possible libel and slander, and possible fraudulent or illegal activity.

We use SSL certificates to help secure our website. However, we make no representations as to the security or privacy of your information. It is in our interest to keep our website secure, but we recommend that you use anti-virus software, firewalls, and other precautions to protect yourself from security threats.

We maintain appropriate technical, administrative and physical safeguards to help protect the security of your Personal Data against unauthorized access, use or disclosure. The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure.

We retain Personal Data only as long as necessary for the purposes in this Policy, to comply with law, resolve disputes, and enforce agreements. Typical retention periods include:

• Account data — for the life of the account and up to 2 years after closure (unless longer required by law or disputes).
• Transaction/payment records — generally 7 years (tax/audit).
• Operational logs/security — typically 12–24 months.
• Marketing preferences and consent records — as required to demonstrate compliance (usually 2–5 years).

We may retain de-identified or aggregated data without a time limit.

We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Services, or we are legally obligated to retain this data for longer time periods.

Our Services are not directed to children under 13. We do not knowingly collect Personal Data from children under 13 (or the minimum digital consent age where you reside, which may be 13–16 in some jurisdictions). If you are a parent/guardian and believe your child provided Personal Data, contact us to request deletion. If we learn we collected such data without required consent, we will delete it.

Our Services may contain links to other websites that are not operated by us. If you click on a third-party link, you will be directed to that third party's website. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party websites or services.

We may provide paid products and/or services within the Services. In that case, we use third-party services for payment processing (e.g. payment processors). For Creator memberships, payments are processed to the Creator's account; Traktrain is not the seller of those memberships.

We do not respond to Do Not Track (DNT) signals. However, where required by law (e.g., in California), we honor Global Privacy Control (GPC) signals as an opt-out of cross-context behavioral advertising ("sharing") and apply your choice to the browser sending the signal. We apply GPC choices to the specific browser sending the signal, whether or not you are logged in.

You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

Stripe Connect & Creators. For Creator Memberships, payments are processed to the Creator's Stripe Connect account. Stripe and the Creator may process Personal Data as independent controllers under their respective privacy notices. See Stripe's Privacy Policy: https://stripe.com/us/privacy

The payment processors we work with are:

Their Privacy Policy can be viewed at https://www.paypal.com/webapps/mpp/ua/privacy-full

Their Privacy Policy can be viewed at https://stripe.com/us/privacy

Any inquiries about your rights under this Privacy Policy, or any other matters regarding your privacy, can be directed to

[email protected]

The Website works with Mediavine to manage third-party interest-based advertising appearing on the Website. Mediavine serves content and advertisements when you visit the Website, which may use first and third-party cookies. A cookie is a small text file which is sent to your computer or mobile device (referred to in this policy as a “device”) by the web server so that a website can remember some information about your browsing activity on the Website.

First party cookies are created by the website that you are visiting. A third-party cookie is frequently used in behavioral advertising and analytics and is created by a domain other than the website you are visiting. Third-party cookies, tags, pixels, beacons and other similar technologies (collectively, “Tags”) may be placed on the Website to monitor interaction with advertising content and to target and optimize advertising. Each internet browser has functionality so that you can block both first and third-party cookies and clear your browser’s cache. The "help" feature of the menu bar on most browsers will tell you how to stop accepting new cookies, how to receive notification of new cookies, how to disable existing cookies and how to clear your browser’s cache. For more information about cookies and how to disable them, you can consult the information at All About Cookies.

Without cookies you may not be able to take full advantage of the Website content and features. Please note that rejecting cookies does not mean that you will no longer see ads when you visit our Site. In the event you opt-out, you will still see non-personalized advertisements on the Website.

The Website collects the following data using a cookie when serving personalized ads:

• IP Address
• Operating System type
• Operating System version
• Device Type
• Language of the website
• Web browser type
• Email (in hashed form)

Mediavine Partners (companies listed below with whom Mediavine shares data) may also use this data to link to other end user information the partner has independently collected to deliver targeted advertisements. Mediavine Partners may also separately collect data about end users from other sources, such as advertising IDs or pixels, and link that data to data collected from Mediavine publishers in order to provide interest-based advertising across your online experience, including devices, browsers and apps. This data includes usage data, cookie information, device information, information about interactions between users and advertisements and websites, geolocation data, traffic data, and information about a visitor’s referral source to a particular website. Mediavine Partners may also create unique IDs to create audience segments, which are used to provide targeted advertising.

If you would like more information about this practice and to know your choices to opt-in or opt-out of this data collection, please visit National Advertising Initiative opt out page. You may also visit Digital Advertising Alliance website and Network Advertising Initiative website to learn more information about interest-based advertising. You may download the AppChoices app at Digital Advertising Alliance’s AppChoices app to opt out in connection with mobile apps, or use the platform controls on your mobile device to opt out.

For specific information about Mediavine Partners, the data each collects and their data collection and privacy policies, please visit Mediavine Partners.