TrackPay — Privacy Policy

Effective Date: April 16, 2026 Last Updated: April 16, 2026

This Privacy Policy explains how TrackPay ("we," "us," or "our") collects, uses, stores, and shares your information when you use the TrackPay platform ("Platform"). By using TrackPay, you agree to the practices described in this policy.

1. Information We Collect

1.1 Information You Provide

• Account Information: Name, email address, password, and profile details provided during registration
• Payment Information: Payout details such as PayPal email, bank account information, or other payment identifiers. We do not store full payment credentials — these are handled by our third-party payment processor
• Content Submissions: Video URLs, sound links, campaign details, and other content you submit through the Platform

1.2 Information from Third-Party Platforms

When you connect your TikTok, Instagram, or YouTube account via OAuth, we collect:

• Your username and display name
• Profile avatar
• Follower count
• Video metadata (video ID, view count, like count, share count, comment count)
• Sound/music metadata associated with your videos
• OAuth access and refresh tokens (stored encrypted)

We only request the minimum permissions necessary to operate the Platform's features. We do not access your direct messages, contacts, or any data beyond what is listed above.

1.3 Automatically Collected Information

• Log Data: IP address, browser type, operating system, referring URLs, pages visited, and timestamps
• Device Information: Device type, unique device identifiers
• Cookies and Tracking: Session cookies for authentication, and analytics cookies to understand Platform usage (see Section 6)

2. How We Use Your Information

We use the information we collect to:

• Create and manage your account
• Verify connected social media accounts and display follower data on your public profile
• Process video submissions and run automated performance checks (the 10% rule)
• Facilitate peer-to-peer payouts between Artists and Editors
• Send transactional emails (submission confirmations, payout notifications, account alerts)
• Detect and prevent fraud, abuse, and violations of our Terms of Service
• Improve and maintain the Platform
• Comply with legal obligations

We do not use your information for targeted advertising and we do not sell your data to advertisers.

3. How We Share Your Information

TrackPay does not sell your personal information. We may share your information only in the following circumstances:

3.1 With Other Users

Your public profile information — including your username, avatar, and TikTok follower count — is visible to other users on the Platform as part of normal Platform operation.

3.2 With Service Providers

We share data with trusted third-party vendors who help us operate the Platform, including:

• Payment processors (e.g., Stripe, PayPal) to facilitate payouts
• Cloud hosting providers to store and serve Platform data
• Analytics providers to understand Platform usage
• Email service providers to send transactional communications

All service providers are contractually required to use your data only as directed by us and in accordance with this Privacy Policy.

3.3 For Legal Reasons

We may disclose your information if required to do so by law, subpoena, court order, or other governmental request, or when we believe disclosure is necessary to protect our rights, protect your safety or the safety of others, or investigate fraud.

3.4 Business Transfers

If TrackPay is involved in a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction. We will notify you via email or in-app notice before your data is transferred and becomes subject to a different privacy policy.

4. Data Retention

We retain your personal information for as long as your account is active or as needed to provide you services. Specifically:

• Account data is retained until you delete your account
• Submission and payout records are retained for 7 years for financial and legal compliance purposes
• OAuth tokens are deleted immediately upon disconnecting a social media account
• Log data is retained for up to 12 months

You may request deletion of your account and associated data at any time (see Section 7).

5. Data Security

We implement industry-standard security measures to protect your information, including:

• Encryption of OAuth tokens and payment credentials at rest
• HTTPS/TLS encryption for all data in transit
• Access controls limiting who on our team can access user data
• Regular security reviews

However, no method of transmission over the internet or method of electronic storage is 100% secure. We cannot guarantee absolute security and are not responsible for unauthorized access resulting from your own actions (e.g., sharing your password).

6. Cookies

TrackPay uses cookies and similar tracking technologies for:

• Authentication: Keeping you logged in
• Preferences: Remembering your settings
• Analytics: Understanding how users interact with the Platform (e.g., via Google Analytics)

You can control cookies through your browser settings. Disabling cookies may affect certain Platform functionality, including staying logged in.

7. Your Rights and Choices

Depending on your location, you may have the following rights regarding your personal data:

• Access: Request a copy of the personal data we hold about you
• Correction: Request correction of inaccurate or incomplete data
• Deletion: Request deletion of your account and personal data, subject to legal retention obligations
• Portability: Request your data in a portable format
• Withdraw Consent: Disconnect third-party accounts (TikTok, etc.) at any time from your profile settings

To exercise any of these rights, contact us at privacy@trackpay.com. We will respond within 30 days.

8. Children's Privacy

TrackPay is not intended for users under the age of 18. We do not knowingly collect personal information from anyone under 18. If we become aware that a user is under 18, we will terminate their account and delete their data promptly. If you believe we have collected data from a minor, contact us at privacy@trackpay.com.

9. Third-Party Links and Services

The Platform integrates with and may contain links to third-party services including TikTok, Instagram, YouTube, and payment processors. This Privacy Policy does not apply to those third-party services. We encourage you to review the privacy policies of any third-party service you connect to or use in conjunction with TrackPay.

10. California Privacy Rights (CCPA)

If you are a California resident, you have the right to:

• Know what personal information we collect, use, disclose, and sell
• Request deletion of your personal information
• Opt out of the sale of your personal information (note: TrackPay does not sell personal information)
• Non-discrimination for exercising your privacy rights

To submit a CCPA request, contact us at privacy@trackpay.com.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we make material changes, we will notify you via email or a prominent notice on the Platform prior to the change taking effect. Your continued use of the Platform after the effective date constitutes acceptance of the updated policy.

12. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy, please contact us at:

privacy@trackpay.com