Table of contents

  1. Purpose of this Cookie Policy
  2. What is a cookie or similar technology?
  3. Who places cookies on the Website and the Service?
  4. What categories of cookies and similar technologies does STRACKR use?
  5. Legal basis for the use of cookies and similar technologies
  6. Consent to cookies
  7. How can you manage your preferences ?
  8. Use of OpenPanel, server-side logs and technical analytics tools
  9. Shared device use
  10. International data transfers
  11. Updates to this Cookie Policy
  12. Contact

1. Purpose of this Cookie Policy

This Cookie Policy (the “Cookie Policy”) explains how STRACKR uses cookies and similar technologies in connection with Website, the Application and the Service.

It informs Website visitors, Clients or Authorized Users about the types of cookies and similar technologies used, their purposes, whether consent is required, how long they are retained, how they may be managed and the rights available to Data Subjects under applicable law.

This Cookie Policy is intended to comply in particular with Regulation (EU) 2016/679 (GDPR), Directive 2002/58/EC as amended (ePrivacy Directive), Law No. 78-17 of January 6, 1978, on Information Technology, Data Files, and Civil Liberties, as amended by the Law of June 20, 2018 (hereinafter the “Data Protection Act”) and applicable guidance and recommendations of the CNIL.

This Cookie Policy supplements and must be read together with the Terms and Conditions, the Privacy Policy and, where applicable, the Data Processing Agreement (DPA).

Capitalized terms used but not defined in this Cookie Policy shall have the meanings given to them in the Terms and Conditions.

2. What is a cookie or similar technology?

A cookie is a small text file stored on a user’s terminal (computer, smartphone, tablet or similar device) when visiting a website or using an application. It allows the issuer of the cookie to recognize the device during the cookie’s validity period and to store or access certain information.

In addition to cookies strictly speaking, STRACKR may use other similar technologies, including: local storage, session storage, software development kits (SDKs) in the Application where applicable, technical tags or scripts and server-side event logging. For the purposes of this Cookie Policy, these technologies are referred to together as “Cookies and Similar Technologies”, unless the context requires otherwise.

Cookies and Similar Technologies may be:

  • session cookies, which expire when the browser is closed; or
  • persistent cookies, which remain stored for a defined duration unless deleted earlier by the user.

They may also be:

  • first-party cookies, placed directly by STRACKR; or
  • third-party cookies, placed by a third-party provider whose service is integrated into the Website, the Application or the Service.

3. Who places cookies on the Website and the Service?

Cookies and similar technologies may be placed either by STRACKR or third-party service providers.

1) By STRACKR

These are first-party cookies or first-party technical mechanisms used directly by STRACKR to ensure the technical functioning of the Website and the Service, enable authentication and session continuity, secure access to Accounts, maintain system integrity; and generate aggregate, privacy-friendly usage statistics.

2) By third-party service providers

Certain service providers engaged by STRACKR may use cookies or similar technologies where their functionalities are activated. According to the Privacy Policy and its Annex, these providers may include in particular hosting, support, infrastructure monitoring, payment or email delivery providers, such as OVHcloud, Crisp, Datadog, OpenPanel, Stripe and Postmark.

Such providers may place their own technical cookies only to the extent necessary to deliver the relevant functionality, for example:

  • payment processing;
  • support messaging;
  • infrastructure monitoring; or
  • technical traffic and usage statistics.

STRACKR does not use third-party advertising networks and does not authorize behavioral advertising cookies on its Website or Service. This is consistent with the Privacy Policy, which states that STRACKR does not use advertising analytics tools such as Google Analytics and does not use statistics for advertising purposes.

4. What categories of Cookies and Similar Technologies does STRACKR use?

STRACKR uses a limited set of cookies and similar technologies tailored to the operation of a professional B2B SaaS service. The categories are the following.

1) Strictly necessary and Similar Technologies

STRACKR uses Cookies and Similar Technologies that are strictly necessary to enable secure authentication and maintain user sessions.

They may include session cookies, authentication cookies, session or local storage mechanisms, authentication tokens (including API tokens or similar mechanisms) and other technical identifiers necessary to maintain secure sessions.

They may imply the processing of data such as such as session identifiers, authentication status, security tokens, and technical routing data.

Without these cookies, the Service cannot function properly.

In accordance with Article 82 of the French Data Protection Act and the CNIL guidelines dated October 1, 2020, these cookies are exempt from prior consent to the extent they are strictly necessary for the provision of the Service requested by the user.

2) Functional cookies

Functional cookies are used to remember certain preferences that are not strictly necessary to deliver the core Service but improve user convenience and usability.

They may imply the processing of data such as preference values, user interface settings and non-essential personalization settings.

Such cookies are not strictly necessary and are subject to prior consent.

3) Audience measurement and usage statistics technologies

STRACKR may use privacy-oriented analytics mechanisms to understand how the Website, the Application and the Service are used. These cookies may imply the processing of data such as page visits, navigation events, timestamps, browser/device type, usage metrics.

As expressly stated in the Privacy Policy, statistics are generated using:

  • OpenPanel, used for website visit statistics and general usage analytics;
  • server-side logs; and
  • Datadog, used for system monitoring and technical log analysis.

These tools are implemented in a manner that does not involve behavioral advertising, cross-site tracking or marketing profiling. No advertising analytics tool such as Google Analytics is used.

Where these analytics technologies strictly comply with the conditions defined by the CNIL for audience measurement limited to the publisher’s exclusive needs (including in particular the absence of cross-site tracking, absence of data reuse and use of aggregated or anonymized data), they may be exempt from consent.

If these conditions are not fully met, prior consent shall be obtained before any such Cookies or Similar Technologies are placed.

4) Security and infrastructure monitoring technologies

STRACKR uses technical monitoring and logging mechanisms implemented on a server-side basis in order to ensure the security, integrity, availability and proper functioning of its systems.

These technologies include server logs, infrastructure monitoring tools (including, where applicable, Datadog), and security event tracking systems.

They involve the processing of the following categories of data: IP addresses, timestamps, system and access logs, device and browser metadata, error logs and technical events.

These mechanisms do not involve storing or accessing information on the user’s terminal within the meaning of applicable ePrivacy regulations and therefore do not constitute Cookies or Similar Technologies subject to Article 82 of the French Data Protection Act.

Their use is based on STRACKR’s legitimate interest in ensuring the security and proper functioning of its systems.

They do not require prior consent.

5) Support and payment-related cookies

When a user activates certain optional embedded functionalities, such as a support chat module or a payment flow, the relevant third-party provider may set technical cookies necessary for that specific functionality. The Privacy Policy expressly mentions that certain third-party service providers, such as payment and support tools, may use cookies when their functionalities are activated.

These cookies may imply the processing of session information, support interaction metadata, identifiers necessary for chat continuity.

Where these technologies are strictly necessary for the provision of a service expressly requested by the user, they do not require prior consent.

6) Absence of advertising and tracking cookies

No advertising analytics tools such as Google Analytics are used. The statistical tools used do not involve behavioral advertising, cross-site tracking or marketing profiling and STRACKR does not use statistical data for advertising purposes and does not sell Personal Data.

5. Detailed table of Cookies and Similar Technologies used

The table below describes the main categories of cookies and similar technologies that may be used by STRACKR. It is drafted on the basis of the current Terms and Privacy Policy and may be updated to reflect technical implementation changes.

Category Purpose Legal basis Retention Period
Strictly necessary Cookies and Similar Technologies Ensure the proper functioning, security and performance of the Website, Application and Service, including: - authentication - session management - secure access to accounts - fraud prevention - infrastructure protection - technical monitoring and - generation of privacy-friendly usage statistics strictly limited to STRACKR’s internal needs - Legitimate interest (security, system integrity, fraud prevention, service improvement): - Performance of the contract or provision of a service expressly requested by the user. Data retained for the duration of the user session or for a short period (7 days) strictly necessary to maintain session continuity when requested by the Client; automatically deleted upon logout or session expiration
Functional cookies Remember non-essential preferences such as language or optional interface settings Consent Up to 13 months from their placement on the user’s terminal, unless a shorter retention period is technically feasible or required by applicable law.
Audience measurement, privacy-friendly analytics Measure usage of the Website and Service, improve performance, reliability and usability Legitimate interest where exemption conditions apply, otherwise consent Data is retained for a duration strictly limited to what is necessary for the purposes pursued, in accordance with Article 5 of the GDPR; where possible, data is aggregated or anonymized.
Security and infrastructure monitoring technologies Ensure system security, detect unauthorized access, prevent fraud and maintain infrastructure integrity Legitimate interest IP addresses retained for a maximum of three (3) days, unless extended where strictly necessary for the investigation of a security incident; other technical logs retained for a duration strictly limited to what is necessary for security and operational purposes.
Support-related cookies and payment related cookies Enable support chat functionalities and secure payment processing Performance of the contract or provision of a requested service Data retained for the duration of the interaction or transaction session and, where applicable, for a short period strictly necessary to ensure service continuity and security

The categorization set out above is provided for transparency and information purposes and does not correspond to a legally binding classification under applicable law. Under Article 82 of the French Data Protection Act and the ePrivacy Directive, the determining criterion is whether the relevant technology is strictly necessary for the provision of a service expressly requested by the user or requires prior consent.

6. Legal basis for the use of cookies and similar technologies

Under GDPR and ePrivacy rules, STRACKR relies on the following legal bases depending on the type of cookie or similar technology concerned.

  • Strictly necessary Cookies and Similar Technologies are used because they are required to provide the service expressly requested by the user, to ensure authentication and session continuity, to secure the Website, Application and Service; and to maintain technical integrity and prevent abuse. These technologies do not require prior consent under applicable rules when they are genuinely necessary.
  • Consent: Where STRACKR deploys any cookie or similar technology that is not strictly necessary, STRACKR relies on the user’s prior consent. Consent must be freely given, specific, informed and unambiguous. It may be withdrawn at any time as easily as it was given.
  • Legitimate interest: For certain technical and security-related processing, including server-side logs and system monitoring, STRACKR relies on its legitimate interest in: ensuring the security, integrity and availability of its systems, detecting malicious activity or unauthorized access attempts, monitoring performance and improving the reliability and functionality of the Service.

Where statistics are further used for product improvement, internal reporting or business analytics, STRACKR states that it prioritizes the use of aggregated or anonymized data.

7. Consent to cookies

Except for Cookies and Similar Technologies that are strictly necessary for the operation of the Website or the provision of a service expressly requested by the user, cookies may only be placed after obtaining prior consent, where required by applicable law.

Therefore, in accordance with current regulations:

  • The use of non-essential cookies is subject to your prior consent.
  • This consent is obtained via a cookie banner during your first visit.
  • You can accept, decline, or customize your preferences via the preference manager.
  • Your choice is retained for 6 months, after which the consent request is displayed again.

8. How can you manage your preferences?

You may manage cookies and similar technologies in several ways.

  • through cookie management interface : an interface such as “Manage cookies” or an equivalent link may be made available on the Website or within the Application, allowing you to review and adjust your choices at any time
  • through your browser settings (Chrome, Firefox, Safari, Edge, etc.)

Given the limited and strictly necessary use of Cookies and Similar Technologies implemented by STRACKR, users are informed that most of these technologies are essential to the operation, security and performance of the Website, Application and Service and therefore cannot be disabled without affecting their proper functioning

9. Shared device use

If several persons use the same device, or if several browsers are installed on the same terminal, STRACKR cannot guarantee that the services displayed or the data associated with a given session correspond exclusively to one individual’s use.

The sharing of a device and the configuration of browser or device privacy settings remain under the user’s responsibility.

10. International data transfers

As stated in the Privacy Policy, certain third-party providers used by STRACKR may process Personal Data in the European Union and/or outside the European Economic Area, including in the United States, depending on the provider concerned.

Where the use of cookies or similar technologies involves Personal Data processed by such providers, STRACKR ensures that appropriate safeguards are implemented in accordance with Chapter V GDPR, including where relevant adequacy decisions, Standard Contractual Clauses (SCCs); and/or, supplementary contractual, technical and organizational measures.

Further information on third-party providers and international transfers is available in the Privacy Policy and its annex.

11. Updates to this Cookie Policy

This Cookie Policy may be updated in order to reflect legal or regulatory developments, CNIL or court guidance, technical changes to the Website, Application or Service, changes in the providers used by STRACKR; or changes in STRACKR’s cookie and analytics practices.

Where required, users will be informed of material changes by appropriate means, including through the Website, the Application, the Service or a renewed cookie notice.

The most current version of this Cookie Policy is the version made available online by STRACKR.

12. Contact

For any question relating to this Cookie Policy, or more generally to the processing of Personal Data by STRACKR, you may contact: contact@strackr.com

Where your request concerns Personal Data processed by STRACKR on behalf of a Client acting as data controller, you may also need to contact the relevant Client directly, in accordance with the allocation of roles described in the Privacy Policy.