Satrack USA Privacy Policy

SATRACK USA CORP, identified with EIN 61-1848742 (“SATRACK USA”), is committed to the privacy and protection of the data of users of the SERVISAT Platform and, more generally, to the data of all individuals whose Personal Data it collects and processes. 

1. Purpose

This Privacy Policy (“Policy”) is intended to describe the practices and standards followed by SATRACK USA CORP (“SATRACK USA”) in the Processing of Databases and the Personal Data contained therein, with the purpose of safeguarding such information and ensuring the protection of the rights of the Data Subjects. By providing us with Personal Data, the Data Subject declares that they have fully read and understood this Policy. 

2. Scope

The guidelines established in this Policy must be observed during the Processing of all Personal Data that SATRACK USA collects, stores, uses, circulates, or deletes, by all Employees, collaborators, or Processors who handle Personal Data on behalf of SATRACK USA. 

3. Relevant Terms in This Policy

4. Controller of the Processing

5. What Personal Data Does SATRACK USA Collect and Process?

SATRACK USA will collect different types of Personal Data depending on the context of its interactions with Consumers, the requests Consumers may make regarding the Processing of their information, and the services or products used by the Consumer from SATRACK USA. Among the Personal Data SATRACK USA may collect are identifiers, contact information, commercial and preference-related data, geolocation data, financial information, and biometric data, described as follows: 

1. First name
2. Last name
3. Country
4. Address
5. City
6. Phone number
7. Email address
8. Contact details
9. Position or profession
10. Interests or preferences
11. Username and password
12. Precise geolocation
13. Card information or other payment information
14. Image and/or video data

The Personal Data indicated from item (k) onwards are considered Sensitive Data; therefore, their Processing will follow the rules applicable to this type of information in accordance with this Policy. 

6. How Is Personal Data Collected?

Within the scope of its functions, SATRACK USA, through its different departments, collects Consumers’ Personal Data as follows: 

SATRACK USA will only process the Personal Data that has been previously, expressly, and informedly authorized by the Consumer through consent given in writing or verbally, via a Privacy Notice. Evidence of such Consent will be retained by SATRACK USA. 

At the time the Consumer provides Consent, SATRACK USA will inform them, among other things, of the purposes and Processing to which their Personal Data will be subject, their rights, and the means by which they may exercise them. The Consumer, among other rights, may revoke their authorization and request the immediate deletion of their Personal Data through the channels established in this Policy. 

SATRACK USA will not be obligated to delete Personal Data in the following cases: (i) 

When necessary to complete a transaction in the context of the purposes for which the information was collected, provide a service requested or reasonably expected by the Data Subject, or comply with an ongoing contract; (ii) To ensure the security and integrity of systems and services; (iii) To identify and correct errors in system functionality (debugging); (iv) To exercise freedom of expression rights, whether of SATRACK USA, third parties, or others recognized by law; (v) To conduct historical, or statistical research of public interest, provided applicable ethical and privacy standards are met, and where deletion of the data would significantly impair or prevent the research, subject to the informed consent of the Data Subject; (vi)For legitimate internal uses reasonably aligned with consumer expectations and the context in which the information was collected; and, (vii) To comply with a legal obligation. 

7. How Is Personal Data Processed?

SATRACK USA will process Consumers’ Personal Data either directly through its Employees or through its Processors. In doing so, SATRACK USA will assume all obligations and rights established under the applicable DPL. Additionally, the Processing of Personal Data, besides being subject to this Policy, may be carried out either physically or electronically. 

8. Purposes of Processing

SATRACK USA will process Personal Data for the following purposes:

1. To enable the linking of owned or third-party vehicles to schedule and manage freight transportation services; manage and view them in SERVISAT; and allow the use of all Platform functionalities.
2. To identify the location of and track in real time the vehicles linked to SERVISAT, improving operational efficiency, route planning, delivery management, and the safety of cargo, vehicles, and individuals.
3. To get to know SERVISAT Users and those related to linked vehicles based on their activities, driving habits, and additional information provided.
4. To analyze driving habits and generate alerts and reports that promote road safety for vehicles, cargo, or individuals.
5. To serve as an emergency contact in cases of theft, cargo loss, and other situations affecting the safety of the vehicle, cargo, or individuals.
6. To interconnect with other GPS operators to centralize geolocation information of all vehicles linked to SERVISAT.
7. To identify the vehicle operator for the purpose of managing safety of vehicles, cargo, or individuals, as well as their driving habits.
8. To transfer or transmit Personal Data to business partners, affiliates, subsidiaries, allied companies, SERVISAT Users, or third parties, to fulfill the purposes described herein or within strategic transactions.
9. To provide contracted products and/or services and carry out all activities necessary to execute the commercial relationship.
10. To enable interaction among Users of the SERVISAT Platform.
11. To allow Transport Companies or Cargo Generators to control the vehicle, including starting and shutting it down, to secure the cargo under service.
12. To conduct satisfaction campaigns, statistical studies, data analytics, and monitoring of the quality of SATRACK’s products and/or services.
13. To manage participation in service selection or assignment processes.
14. To verify information in credit bureaus or restricted lists as part of evaluating service applicants and calculating a score for classification and selection purposes.
15. To receive and manage transportation service requests to identify, evaluate, and assign the most suitable applicant.
16. To conduct commercial and marketing activities, even after the commercial relationship has ended, through email or other suitable means.
17. To verify and update Personal Data, and inform about changes in this Policy and/or in the purposes of processing.
18. To maintain relevant communications for the commercial relationship, including invoices, account statements, or any other document required by law.
19. To send commercial and advertising content; conduct commercial prospecting to identify customer needs and interests; and monitor the services provided.
20. To carry out collection and debt recovery activities through email or other suitable means.
21. To conduct verifications and information reporting in restricted lists and/or credit bureaus, including prior notifications when required by applicable regulations.
22. To conduct Know Your Customer (KYC) procedures to prevent money laundering, terrorist financing, and detect fraud, corruption, and other illegal activities.
23. To record inbound and outbound calls for quality control and information security purposes.

SATRACK USA informs Consumers that, to date, it has not sold, transferred, or commercialized the Personal Data collected. Any change in this practice will be communicated to Consumers in advance, clearly and expressly, in accordance with the provisions of the applicable DPL. 

9. How Are Sensitive Data Processed?

SATRACK USA will collect Consumers’ Sensitive Data primarily through precise geolocation, usernames and passwords, card or other payment information, and image and/or video data. In these cases, SATRACK USA will inform Data Subjects of the Sensitive Data to be processed, the specific purposes of such Processing, and will state that, given the nature of Sensitive Data, they are under no obligation to provide it. Additionally, SATRACK USA will implement an opt-out mechanism so that Consumers may limit the Processing of their Sensitive Data. 

10. How Is the Personal Data of Children and Adolescents Processed?

SATRACK USA will limit the collection and Processing of Personal Data of Data Subjects who are children or adolescents strictly to the context of precise geolocation. The Processing of children’s or adolescents’ Personal Data will be carried out in accordance with, and in respect of, the best interests of minors and in full protection of their fundamental rights. 

In such cases, SATRACK USA will request the corresponding Authorization from their legal representative and will make its best effort to verify that the person acting as legal representative of the child or adolescent effectively holds such capacity. Nevertheless, SATRACK USA will rely on the good faith of the person granting the Authorization and asserting that they are the legal representative. 

11. Who Accesses Personal Data?

Access to the Databases under the responsibility of SATRACK USA will be restricted exclusively to SATRACK USA Employees who require access to and processing of such information for the performance of their duties. 

SATRACK USA will not share or disclose the Databases or the Personal Data stored therein with third parties with whom it has no relationship. 

However, when necessary to achieve the purposes authorized by the Consumer, Personal Data may be lawfully transmitted to providers, who may be located either inside or outside the country, including jurisdictions with different data protection regulations and levels of protection such as Colombia. In such cases, the relevant data transfer agreements will be executed to protect the information, the rights of the Data Subjects, and to ensure that Processing of the Databases and Personal Data is carried out in compliance with this Policy. 

Among the providers with whom Personal Data are usually shared are: 

Additionally, SATRACK USA may share information with some of its subsidiaries for back-office or commercial purposes, such as: 

For all purposes, SATRACK USA may only disclose information contained in its Databases to Consumers, their successors or legal representatives, public or administrative entities in the exercise of their legal duties, or pursuant to a court order; and to third parties authorized by the Data Subject or by applicable Data Protection Laws. SATRACK USA reserves the right to request additional documentation in order to verify the status of the person requesting the information.

12. SATRACK USA’s Security Commitment

SATRACK USA is committed to the confidentiality and security of the Personal Data stored in its Databases, ensuring restrictions on access, availability, and consultation by unauthorized third parties. 

Accordingly, SATRACK USA informs Consumers that it has adopted appropriate measures and practices for the preservation of Personal Data under industry-standard security conditions, aimed at preventing alteration, loss, theft, public disclosure, unauthorized or fraudulent use or access, as well as implementing internal practices that contribute to a secure information environment. 

Nevertheless, SATRACK USA cannot guarantee the absolute security of any Processing of Personal Data carried out via the internet or through data storage systems. If any Consumer believes their Personal Data is not being processed securely, SATRACK USA encourages them to promptly notify the company so the matter may be reviewed with the urgency it requires. 

13. For How Long Is Personal Data Processed?

SATRACK USA will keep a record of Consumer information before, during, and after the end of its relationship with them (e.g., contractual relationship), which may include Personal Data, solely and exclusively for the purpose of achieving the objectives authorized by the Consumer. SATRACK USA will store Personal Data for as long as necessary to properly fulfill the purposes authorized by the Data Subject and/or to comply with SATRACK USA’s legal or contractual obligations. Once this period has ended, SATRACK USA will destroy the Personal Data and/or delete it from its Databases. 

14. What Are the Rights of Data Subjects?

Data Subjects of Personal Data have the following rights: 

1. Right of Access: The Consumer may request confirmation from SATRACK USA as to whether it holds or processes their personal data and obtain a copy of such data. This right allows the Consumer to know what personal information has been collected and is being used by the company. 
2. Right of Rectification or Correction: The Consumer may request the correction of inaccurate or outdated personal data held by SATRACK USA. 
3. Right of Deletion (Erasure): The Consumer has the right to request the deletion of their personal data collected by SATRACK USA. Upon receiving a valid request, the organization must erase the Consumer’s data from its systems (subject to legal exceptions) and also instruct its Processors or service providers, as well as third parties with whom data was shared, to delete such data where applicable. 
4. Exceptions to Deletion:  Companies may retain data necessary to fulfill a contract, ensure security, detect fraud, exercise legal rights, or for other purposes explicitly permitted by law. 
5. Right to Data Portability:  The Consumer may obtain a copy of their personal data in a portable and commonly used format. This enables the Consumer to reuse their information and transfer it to another provider if they wish. In some cases, this applies only to the data the Consumer provided directly, while in others it may include all personal data collected about them. 
6. Right to Opt-Out: The Consumer has the right to opt out of certain forms of data processing. In particular:  Opt-out of targeted advertising: The right to object to the use of their personal data for behavioral advertising (personalized advertising based on tracking). Once exercised, SATRACK USA must cease using the Consumer’s data for targeted ads. Opt-out of profiling with legal or significant effects: The Consumer may object to automated profiling when it is used to make decisions that produce legal or similarly significant effects (e.g., credit, employment, insurance decisions). SATRACK USA must refrain from such processing or, at minimum, provide a manual review as required by applicable law. 
7. Sensitive Data :The Consumer has the right to limit the use or disclosure of sensitive personal information and may request that such data (e.g., ethnic origin, financial data, precise geolocation, health data, sexual orientation, information about minors) not be used for secondary purposes such as advertising or profiling, but only for what is strictly necessary to provide the service. The Consumer also has the right to prevent their data from being processed if they do not provide prior consent for the processing of sensitive data. It is prohibited to sell or share the data of minors under 16 years of age without affirmative authorization (opt-in) from the minor (if between 13-15 years old) or their parents (if under 13). 
8. Right to Non-Discrimination : SATRACK USA may not deny services or provide different treatment to a Consumer solely because they exercise their privacy rights. This means that higher prices may not be charged, products/services may not be denied, and service quality may not be degraded as retaliation for exercising rights such as access, deletion, or opt-out. 
9. Right to Withdraw Consent : If data processing is based on the Consumer’s consent, they have the right to withdraw such consent at any time. Once consent is revoked, SATRACK USA must stop processing the data for those purposes. 
10. Right to Appoint an Authorized Agent : The Consumer may designate an authorized agent to make requests on their behalf. SATRACK USA may require proper verification (such as written authorization or proof of mandate) before acting on a request submitted by an agent. 
11. Right to Be Informed About Automated Technologies : Consumers have the right to be informed if automated decision-making systems or profiling are being used.   

15. Who Is Responsible for Handling Inquiries and Claims?

In accordance with Data Protection Laws, SATRACK USA has appointed a Data Protection Officer (“DPO”). The DPO’s responsibilities include promoting the protection of personal data, ensuring compliance with applicable laws, and addressing inquiries and claims related to the processing of personal data. 

Any questions or inquiries related to this Policy and the practices concerning the Processing of Personal Data by SATRACK USA may also be submitted through this contact information. 

16. How to Submit Requests or Exercise Rights

The Data Subject, their representative, their successors, or their Authorized Agent may submit requests to exercise their rights in the following manner: 

• California 

If the Consumer resides in California, the law grants broad rights regarding their personal data. To exercise them, the Consumer may submit a verifiable request through at least two of the contact methods made available by SATRACK USA. When doing so, the Consumer must provide sufficient information for SATRACK USA to reasonably verify their identity (for security reasons, SATRACK USA may request data already on record to confirm the requester’s identity). The Consumer will not be required to create a new account solely for this procedure. 

Once SATRACK USA receives the Consumer’s verifiable request, it will acknowledge receipt promptly and provide a substantive response within 45 calendar days. This period may be extended once for up to an additional 45 days (90 days in total) where the complexity or volume of requests justifies it, with prior notice to the Consumer before the expiration of the initial term. 

Responses will be provided free of charge, except in cases of repetitive or unfounded requests within a short period, where the law allows the company to charge a reasonable administrative fee or deny duplicate requests. 

The information will be delivered in a commonly used, portable format, either through a secure account on the website, by email, or by postal mail, as applicable. In the case of deletion requests, SATRACK USA will delete the Consumer’s personal data and confirm the operation; if deletion is partial, the Consumer will be expressly informed. For correction requests, the data will be updated in internal systems, and the Consumer will be notified of the adjustment. 

The Consumer may also appoint an Authorized Agent to submit requests on their behalf. SATRACK USA will process such requests once the authorization has been verified, granting the Authorized Agent the same facilities as the Consumer.  

In the case of Sensitive Data, SATRACK USA will make available a link allowing the Consumer to “Limit the use of your sensitive personal information.” SATRACK USA will not discriminate against any Consumer for exercising their rights. Services will not be denied, nor will additional charges be applied as a result of submitting a privacy request. 

Although California law does not provide for a formal internal appeal process, the Consumer may contact SATRACK USA for additional clarifications or, if necessary, file a complaint with the California Privacy Protection Agency (CPPA) or the California Attorney General. 

• Colorado 

The Consumer may submit requests for access, rectification, deletion, portability, and opt-out through the channels established in this Policy. SATRACK USA will respond within a maximum of 45 calendar days from receipt of the request, extendable once for up to an additional 45 days when necessary. 

The handling of these requests will be free of charge (up to two requests per right, per consumer, per year). If SATRACK USA cannot fully comply with the request, it will inform the Consumer of the reasons for the denial or limitation. 

SATRACK USA will provide an internal appeal process. If the Consumer disagrees with the response received, they may submit an appeal within a reasonable time following the instructions provided in the initial notification. SATRACK USA will have an additional 45 days to review the case and issue a written decision on the appeal. If the request is still not resolved to the Consumer’s satisfaction, they may escalate the complaint to the Attorney General of the State of Colorado. 

The Consumer may exercise the right to opt-out, which covers not only the sale of personal data but also targeted advertising and profiling with significant consequences. If this right is exercised, SATRACK USA will cease processing the Consumer’s personal data for personalized marketing and/or impactful automated decision-making, as applicable. 

Likewise, the Consumer may designate an Authorized Agent to submit requests on their behalf. SATRACK USA will process such requests provided the agent’s authority is duly verified. In no case will SATRACK USA require the Consumer to create new accounts to exercise their rights, nor will any discriminatory treatment be applied for submitting a privacy request. 

• Connecticut 

The Consumer may contact SATRACK USA through the available channels to submit their requests. SATRACK USA will respond within 45 calendar days, extendable up to 90 days in total when the complexity of the case requires it, with prior notice to the Consumer. 

In the event of an adverse response, the Consumer may file an appeal within 60 days following the initial notification. SATRACK USA will review the case and issue a decision on the appeal within an additional 60 days. If, after this process, the request is definitively denied, SATRACK USA will inform the Consumer of their right to file a complaint with the Attorney General of the State of Connecticut. 

SATRACK USA will respect any technical preference not to receive advertising that the Consumer activates on their devices or browsers, in accordance with applicable standards. The processing of sensitive personal data will always require the Consumer’s explicit prior consent. Such authorization may be denied at the outset or revoked at any time. 

All guarantees provided—including non-discrimination, free-of-charge procedures, and the ability to act through an Authorized Agent—will likewise apply in the State of Connecticut. 

• Delaware 

If the Consumer resides in Delaware, they may exercise their rights of access, rectification, deletion, portability, and opt-out through the channels provided in this Policy. SATRACK USA will acknowledge receipt and respond within a maximum of 45 calendar days, extendable once for up to an additional 45 days when necessary. 

If the Consumer is not satisfied with the initial response, they may request an internal review, which will be resolved within 60 days, with the final decision communicated in writing. If the outcome remains unfavorable, the Consumer will be informed of the possibility of filing a complaint with the Delaware Attorney General’s Office. 

The Consumer may exercise the right to opt-out with respect to the use of their data for targeted advertising and for profiling with significant effects, by indicating to SATRACK USA that they do not wish their data to be used for those purposes. SATRACK USA will honor this choice. 

As in other jurisdictions, SATRACK USA will not charge any fee for processing requests, except in the exceptional cases provided by law, such as repetitive or manifestly unfounded requests. 

The exercise of these rights does not require the creation of an account, and under no circumstances will goods or services be denied for this reason. Likewise, the Consumer may appoint an Authorized Agent to submit requests on their behalf, which will be processed once proper authorization has been verified. 

• Florida  

If the Consumer resides in Florida, they may exercise their rights by submitting a request to SATRACK USA through two or more of the contact methods enabled and described in this Policy. 

SATRACK USA will make available a clear and accessible Privacy Notice, indicating the Consumer’s rights and the mechanisms for exercising them. This notice will be updated at least once a year. 

Requests will be addressed within a maximum of 45 calendar days from receipt. This period may be extended once for up to 90 days in total, with notice to the Consumer before the expiration of the initial term. If SATRACK USA is unable to comply with the request, it will notify the Consumer within the same period, indicating the justification. 

The Consumer may file an appeal within a reasonable period after receiving an adverse response. SATRACK USA will review the case and communicate the appeal outcome within a maximum of 60 additional days. If the disagreement persists, SATRACK USA will inform the Consumer of the possibility of filing a complaint with the Florida Attorney General’s Office. 

When the request is submitted by an Authorized Agent, SATRACK USA may require proof of the corresponding authorization, as well as verification of the Consumer’s identity, as a necessary condition for processing the request under Florida law. 

In addition, SATRACK USA will provide on its website a clear opt-out mechanism if it sells personal data or uses data for targeted advertising. SATRACK USA guarantees that it will not take any retaliatory action against Consumers for exercising their privacy rights. 

• Georgia 

SATRACK USA voluntarily maintains high privacy standards and complies with applicable federal regulations. If the Consumer resides in Georgia, they may contact SATRACK USA with any questions related to their personal data, and the company will make its best effort to address them. 

However, in this state there is no formal procedure for the submission and handling of rights requests, unlike the processes established in jurisdictions with specific privacy laws. 

• Illinois 

Any Illinois resident who wishes to know, update, or delete information that SATRACK USA may hold about them may contact the company through its customer service channels. 

SATRACK USA will evaluate the request in accordance with applicable legislation and its internal policies, even though no explicit legal right exists in this state to mandate such requests. 

• Iowa 

Residents of Iowa may exercise their rights by submitting a request through the channels provided in this Policy. SATRACK USA will respond without undue delay and, in any case, within a maximum of 90 days from receipt of the request. This period may be extended once for up to 45 additional days (for a total of 135 days in exceptional situations), with notice to the Consumer of the extension and its reasons within the initial period. 

Requests will be handled free of charge up to two times per year per Consumer. If repetitive or unfounded requests are submitted, SATRACK USA may, under the Iowa Consumer Data Protection Act (ICDPA), charge a reasonable administrative fee or refuse to act, providing justification for such decision. 

If a request is denied (due to inability to authenticate it or for another legal reason), SATRACK USA will inform the Consumer of the procedure for appealing the decision. The appeal will be addressed within a reasonable timeframe (not specified in days under the ICDPA but generally understood to be up to 60 days). If, after the appeal, the request continues to be denied, SATRACK USA will inform the Consumer how to file a complaint with the Iowa Attorney General’s Office. 

In its Privacy Notice, SATRACK USA will clearly explain the methods available for Consumers to submit requests in a secure and reliable manner, considering how they usually interact with the company and the need to verify their identity. SATRACK USA will provide secure communication channels and will not require the Consumer to register for new services to submit a request (although, if the Consumer already has an account, they may be asked to use it as an authentication mechanism). 

• Maryland 

If the Consumer resides in Maryland, they should note that the applicable regulation does not establish a legally enforceable procedure for requesting access to or deletion of their personal data from SATRACK USA, beyond what the company voluntarily offers in its internal policies. 

Nevertheless, SATRACK USA maintains transparency and accountability practices. Therefore, the Consumer may contact the company to inquire about what personal data is being processed or to request its deletion. Such requests will be evaluated on a case-by-case basis, even if no specific obligation is provided under state law. 

• Massachusetts 

If the Consumer resides in Massachusetts and submits a request related to their personal data, SATRACK USA will make every effort to address it in accordance with applicable privacy principles and through the channels provided in this Policy for the exercise of rights. 

• Minnesota 

For Consumers residing in Minnesota, requests to exercise their rights must be submitted through the channels designated by SATRACK USA. The company will respond within 45 calendar days from receipt of the request, extendable once for up to an additional 45 days, with notice to the Consumer within the initial period. 

In accordance with Minnesota regulations, if SATRACK USA decides not to take action on a request, it must inform the Consumer of the reasons and offer the possibility of filing an appeal. SATRACK USA has an internal appeal process through which the Consumer may request further review. The company must respond to the appeal within a maximum of 45 additional days. If, after the appeal, the denial is maintained, SATRACK USA will inform the Consumer of their right to file a complaint with the Minnesota Attorney General’s Office. 

SATRACK USA will fully honor any opt-out request submitted by a Minnesota Consumer, immediately ceasing the relevant processing. Under no circumstances will it require the creation of new accounts or payment of fees to exercise rights, and it will ensure that Consumers are not discriminated against for exercising them. 

• Nebraska 

If the Consumer resides in Nebraska, they may submit their requests to SATRACK USA through the channels provided by the organization and referenced in this Policy. SATRACK USA will respond within a maximum of 45 calendar days, extendable once for up to an additional 45 days, with prior notice to the Consumer. 

If the Consumer receives an unsatisfactory response, they may file an appeal, which will be resolved by SATRACK USA within 60 days of receipt. The result of the appeal will be communicated in writing. 

If, after the appeal, the request is definitively denied, SATRACK USA will provide the Consumer with the relevant contact information so that, if they wish, they may file a complaint with the Nebraska Attorney General’s Office. 

• New Jersey 

SATRACK USA voluntarily extends its transparency practices to all Consumers. Therefore, if the Consumer resides in New Jersey and submits an inquiry or request related to their personal data, they may do so through the contact methods described in this Policy. Although no explicit legal obligation exists in this state, SATRACK USA will respond to such requests in good faith. 

• New México 

At SATRACK USA, the privacy of all Consumers, including residents of New Mexico, is valued, and the company will make every effort to address any reasonable request related to their personal data within its capabilities. In the absence of a specific legal framework, such requests will be handled in accordance with the principles established in this Policy and applicable general obligations. 

• New York 

SATRACK USA complies with the applicable federal and sectoral laws in the State of New York. This Policy also reflects the company’s commitment to transparency. Although there is no formal procedure in place, the Consumer may contact SATRACK USA through the channels described in this Policy to inquire about their personal data. SATRACK USA will make every effort to provide the requested information or assistance, on a voluntary basis. 

• North Carolina 

If the Consumer resides in North Carolina, SATRACK USA will process their data in accordance with this Policy and applicable federal laws. However, in this state there is no specific procedure for submitting rights requests, beyond the possibility for the Consumer to contact SATRACK USA with any concerns through the channels referenced in this Policy. 

• Ohio  

To exercise their rights in Ohio, the Consumer must submit their request through the channels provided in this Policy. SATRACK USA will respond within 45 days of receipt, extendable once for up to 45 additional days when necessary, with notice to the Consumer within the initial period. 

If SATRACK USA denies the request, it will inform the Consumer of the procedure to submit an internal appeal. The Consumer may file such an appeal within the indicated timeframe, and SATRACK USA must issue a written response within a maximum of 60 days from receipt. 

If the appeal is also denied, SATRACK USA will provide the Consumer with the necessary information to, if they wish, file a complaint with the Ohio Attorney General’s Office. 

• Oregon 

If the Consumer resides in Oregon, they may exercise their rights by requesting from SATRACK USA: access to the personal data it holds, correction, deletion, obtaining portable copies, as well as the possibility to opt out of the sale of data, targeted advertising, or significant profiling. 

The request must be submitted through the accessible channels provided by SATRACK USA. A response will be issued within 45 days of receipt, extendable once for up to an additional 45 days, with notice given within the initial period. In complex cases, SATRACK USA may take up to 90 days in total, always informing the Consumer. 

If a request is denied, SATRACK USA will indicate the procedure for filing an internal appeal, which will be resolved within a maximum of 45 additional days. If, after the appeal, the request is still denied, SATRACK USA will inform the Consumer how to escalate their case to the Oregon Department of Justice (Attorney General). 

The exercise of these rights will be free of charge, and SATRACK USA will not discriminate against the Consumer for exercising them, in compliance with applicable law. 

• Pennsylvania 

If the Consumer resides in Pennsylvania, they may request information or raise concerns about their personal data with SATRACK USA’s Data Protection Officer. Although state law does not establish a formal response procedure, SATRACK USA, in the interest of transparency, will make every effort to address such requests and provide the Consumer with the requested information or assistance on a voluntary basis. 

• Tennessee 

To exercise their rights in Tennessee—including knowing what personal data is processed, requesting its correction or deletion, obtaining portable copies of the data provided, and opting out of data sales, targeted advertising, or automated decisions with significant effects—the Consumer may submit a verifiable request through the channels designated by SATRACK USA. 

SATRACK USA will acknowledge receipt and respond within 45 days, with the possibility of a 45-day extension if needed to address the request. The response will be free of charge once per right per year, except in cases of excessive requests as provided by law. 

If the initial request is denied, the Consumer may appeal within a reasonable period. SATRACK USA will have 60 days to resolve the appeal and communicate the outcome in writing. If the denial is upheld, SATRACK USA will inform the Consumer how to file a complaint with the Tennessee Attorney General’s Office. 

SATRACK USA will not discriminate against Consumers for exercising their rights and will allow authorized agents to act on behalf of Consumers in submitting opt-out requests, in accordance with applicable law. 

• Texas 

If the Consumer resides in Texas, they may exercise their rights through the reliable methods made available by SATRACK USA, taking into account how the company normally interacts with its customers and ensuring a secure process to verify identity. The Consumer will not be required to create a new account to submit a request; however, if they already have an active account, they may be asked to use it for authentication purposes. 

Upon receiving the request, SATRACK USA will respond within a maximum of 45 days. This period may be extended once for up to an additional 45 days (90 days in total) when justified by the complexity of the case or the volume of requests, with notice to the Consumer within the initial 45-day period explaining the reasons for the extension. If SATRACK USA decides not to act on the request (for example, due to an applicable legal exception), it will inform the Consumer within the same period, provide the reasons for the decision, and explain how to appeal. 

The Consumer may file an internal appeal within a reasonable period after receiving the denial. The appeal process will be similar to the initial request, and SATRACK USA will resolve the appeal within a maximum of 60 days from receipt, providing a written outcome and justification. If the request remains denied after the appeal, SATRACK USA will provide the Consumer with an online mechanism to contact the Texas Attorney General and file a formal complaint. 

SATRACK USA will enable at least two secure and accessible methods for Consumers to exercise their rights. The Consumer may also designate an authorized agent—whether an individual or technology—to submit requests on their behalf, including opt-out requests for data sales or targeted advertising. SATRACK USA will honor valid requests from authorized agents under the same conditions as if they were submitted directly by the Consumer. 

In its Privacy Notice, SATRACK USA will clearly describe the procedure for exercising rights and the appeal process. SATRACK USA will not discriminate against Consumers for exercising their rights and will ensure their personal data is processed in accordance with the principles of minimization, security, and purpose limitation set forth in the Texas Data Privacy and Security Act (TDPSA), which forms part of this Policy. 

• Utah 

If the Consumer resides in Utah, they may exercise their rights to access, delete, and obtain a copy of their personal data, as well as to opt out of the sale of personal data or its use for targeted advertising. 

Requests may be submitted through the channels provided by SATRACK USA. The company will respond within 45 days of receiving the request. This period may be extended once for up to an additional 45 days, with notice to the Consumer before the expiration of the initial term. 

Unlike other states, Utah law does not require SATRACK USA to provide a right of correction. Likewise, there is no formal appeal mechanism; however, SATRACK USA will provide Consumers with the necessary information to contact the Utah Attorney General’s Office if they wish to file a complaint after a denial. 

All rights must be exercised free of charge at least once per year. In the case of manifestly unfounded, excessive, or repetitive requests, SATRACK USA may charge a reasonable administrative fee or refuse to act on the request, in accordance with applicable law. 

SATRACK USA will not discriminate against Consumers for exercising their privacy rights, nor will it require them to create a new account to submit a request. Authorized agents may also act on behalf of Consumers, provided that their authority can be properly verified. 

• Virginia 

If the Consumer resides in Virginia, they may exercise their rights of access, correction, deletion, data portability, and opt-out (including sale of personal data, targeted advertising, and profiling with significant effects) through the channels established by SATRACK USA. 

SATRACK USA will respond to requests within 45 days of receipt. This period may be extended once for up to an additional 45 days when reasonably necessary, provided the Consumer is notified before the initial period expires. 

If SATRACK USA denies the request, the Consumer may file an internal appeal within a reasonable period. Appeals will be resolved within 60 days of receipt. The final decision will be communicated in writing, including an explanation of the reasons for the denial. If the Consumer remains dissatisfied, SATRACK USA will inform them of their right to escalate the case to the Virginia Attorney General’s Office. 

Requests will be processed free of charge, unless they are manifestly unfounded, excessive, or repetitive, in which case SATRACK USA may charge a reasonable fee or refuse to act, with proper justification. 

Consumers will not be discriminated against for exercising their rights, and they will not be required to create new accounts to submit requests. Additionally, Consumers may designate an authorized agent to act on their behalf, provided the agent’s authorization is duly verified. 

• Washington 

This Policy primarily acknowledges the privacy rights set forth in the applicable state laws. However, if a Consumer resides in the State of Washington and has concerns regarding their personal data, they may contact SATRACK USA through the available channels. SATRACK USA will address such requests voluntarily to the extent possible. In the absence of a comprehensive privacy law in Washington, any such handling is provided as a courtesy and a demonstration of corporate commitment, rather than as a general legal obligation. 

• Delaware 

If the Consumer resides in Delaware, SATRACK USA, in its capacity as Controller, shall handle rights requests in accordance with the following rules: 

• Response timeframe: SATRACK USA will respond without undue delay and, in any case, within 45 days of receiving the request. This period may be extended once for an additional 45 days, where reasonably necessary, provided that the Consumer is notified before the expiration of the initial period and informed of the reasons for the extension. 

• Denial of action: If SATRACK USA decides not to act on the request, it will notify the Consumer without undue delay and, at the latest, within 45 days, providing the justification and instructions on how to appeal the decision. 

• No cost and limitations: The first response to a Consumer within any 12-month period will be free of charge. If a request is manifestly unfounded, excessive, or repetitive, SATRACK USA may charge a reasonable fee or refuse to act, provided it can demonstrate such circumstance. 

• Authentication of the request: SATRACK USA will not be required to comply with a request if it cannot reasonably authenticate the Consumer’s identity, in which case it will notify the Consumer and request the additional information necessary. Opt-out requests do not require authentication; however, SATRACK USA may deny them if it determines in good faith that they are fraudulent, notifying the Consumer of the reason for denial. 
• Deletion of data obtained from third parties: Where SATRACK USA has obtained personal data from sources other than the Consumer, it will be deemed to have complied with the deletion request if it maintains a record of the request and retains the minimum data necessary to ensure that the information remains deleted and is not used for other purposes. 
• Iowa 

A Consumer may exercise, at any time, the rights recognized in this section by submitting a request to the Controller through the designated channels, expressly indicating the rights they wish to exercise. The parent or legal guardian of a known child may exercise these rights on behalf of the minor with respect to the processing of the child’s personal data. 

The Controller shall comply with any duly authenticated request for the exercise of the following Consumer rights: 

• Access and confirmation: Confirm whether it is processing the Consumer’s personal data and provide access to such data. 

• Deletion: Delete the personal data provided directly by the Consumer. 

• Portability: Obtain a copy of their personal data (excluding those defined as “personal information” in Section 715C.1 and protected against security breaches) in a portable and, to the extent technically feasible, readily usable format that allows the Consumer to transmit the data to another Controller without hindrance, provided that the processing is carried out by automated means. 

• Opt-out: Exclude themselves from the sale of their personal data. 

• Nebraska 

The Controller (the company or organization that determines how personal data are processed) must make available to the Consumer at least two secure and reliable methods for exercising their rights under the law. 

When defining such methods, the Controller shall take into account: 

• The manner in which it normally interacts with Consumers. 

• The need to ensure secure and reliable communications. 

• The ability to adequately authenticate the identity of the individual submitting the request. 

*NOTE: other states not expressly mentioned — If the Consumer resides in a state not specifically listed in this Policy, they may nonetheless contact us through the designated channels to exercise their rights or submit any request related to the processing of their personal data. SATRACK USA will evaluate such requests in accordance with applicable law and its internal privacy and data protection standards. 

17. How will EWB browser cookies be used? 

SATRACK USA will inform Consumers, in their capacity as Data Subjects, through the corresponding Privacy Notice, about the use of this technology, its terms, and scope. In this way, Consumers who do not wish Cookies to be installed may reject them, either in full or in part, by selecting the “I do not accept” or “Choose cookies” options, respectively, in the Privacy Notice implemented on the Website. 

If the Consumer rejects or disables Cookies, in whole or in part, certain functional aspects of the Website may be affected during their browsing experience. 

18. Validity of the Policy and Databases

1. This document came into effect on March 24, 2025. 
2. The databases managed by SATRACK USA shall remain in effect for as long as the Personal Data are used for the purposes described in this Policy; Personal Data contained therein will be retained unless the Data Subject requests their deletion and there is no legal or contractual obligation to retain the information. 
3. SATRACK USA informs that any substantial change to the Personal Data and Information Processing Policy will be communicated in a timely manner through its website. 

Satrack USA Corp.
EIN 61-1848742
Miami, Florida 33156
9100 South Dadeland Boulevard Suite 1537
customer.service@satrack.com
+1 833 700 8883