TrackDrive Data Collection & Use Policy

Effective Date: December 4th, 2026

Notice of Amendment. We amended this Policy on November 4th, 2026 to revise Sections 4.3 and 5.4 and to add Section 13 (AI Assistants You Connect). These amendments take effect on December 4th, 2026.

1. Introduction. This Data Collection & Use Policy ("Policy") sets forth how TrackDrive, LLC, a Colorado limited liability company ("TrackDrive or “We"), collects and uses the information you provide to us and certain other information that we automatically collect through your access and use of our centralized Lead Automation platform made available on Trackdrive.com.

Users of our Platform are referred to throughout this Policy as "you" or "your". Capitalized terms shall have the same meaning as defined in the TrackDrive Terms of Service. Both our Platform and any associated applications are collectively hereinafter referred to as the "Website".

How to Contact Us If you have any general questions or concerns about this Policy, you can email us at support@trackdrive.com.

2. Modifications to this Policy. We reserve the right to update or modify this Policy at any time. If we decide to change this Policy, we will revise the effective date posted at the top of this Policy. For material changes, we may also notify you by posting a notice prominently on our home page, sending an email to your registered account address, or notifying you upon your next log-in to access the Website or Service. Your continued use of the Website or Service after the effective date of any changes constitutes your acknowledgment and acceptance of the revised Policy. If you do not agree to the modifications, your sole remedy is to cease using the Website and Service.

3. Information Collection Practices-How We Collect Your Data.

3.1. Personally Identifiable Information (“PII”). For the purposes of this Policy, "Personal Information" or "PII" refers broadly to any information that identifies, relates to, describes, or could reasonably be linked to a specific individual. TrackDrive collects and processes PII in two distinct contexts:

(a) Business User Data (Registration). When you register to use the Service, you must provide PII about yourself and your business. This includes, without limitation: (i) "Contact Data" such as your first and last name if you are a sole proprietor, phone number, fax number, mailing address, and/or email address; (ii) "Third-Party Social Media Account Data" such as your account information for connected social media integrations; and (iii) “Business Information”  such as Your business name, tradename, and any other business contact or identifying information provided directly by you (collectively “BI”).

(b) Consumer Lead & Call Data. While utilizing our routing and automation Service, TrackDrive processes PII belonging to your end-consumers that you upload, route, or generate through the Platform. This includes consumer names, birthdates, physical addresses, phone numbers, and other demographic data contained within your lead lists, as well as the Telephony & Audio Data (described below).

3.2. Automatic Traffic Data. We gather information that web browsers automatically make available, including: (i) IP addresses; (ii) Internet domain names; (iii) types of devices accessing TrackDrive's website; and (iv) types of web browsers accessing the website, which is anonymous information that is not meant to personally identify You.

3.3. Cookie & Tracking Policy. We use cookies, web beacons, and other automatic data collection tools in the operation of our Website. Cookies and similar collection tools are files with a small amount of data, which includes a unique identifier. TrackDrive uses two types of Cookies:

• First-Party Cookies. Used to gather visitors and access information relevant to customizing the Service to your interests, and to store your password so you do not have to re-enter it. If you refuse Cookies, you assume all responsibility for any resulting loss of functionality.
• Third-Party Cookies and Advertising. TrackDrive and third-party marketing partners (including Google and Facebook) may use cookies and web beacons across multiple devices to inform, optimize, and serve advertisements to you based on your use of the Service (retargeting). You may opt-out of using third-party Cookies by visiting the Network Advertising Initiative opt-out page.
  

3.4. API Use Data. We use an API key(s) for calls against the Platform made available to our users. We track user access patterns and API usage for logging and security. We also store your API keys in our databases, which are encrypted.

3.5. Financial Data. We collect and store your credit/debit card number and expiration date when you pay Service Use Fees.

3.6. Telephony & Audio Data. Call logs, routing information, SMS/MMS metadata, text message contents, transcriptions, and audio call recordings are captured via your use of the Service.

3.7. Website Forms. When you provide any PII, BI through any form contained on this Website in order to contact us, we collect and store this information. We may use your email as expressly set forth in this Policy.

3.8. Children Under 13. Children under the age of 13 are expressly prohibited from submitting or posting any PII on this Website. If TrackDrive obtains actual knowledge that it has collected personal information from a child under the age of 13, TrackDrive will delete such information immediately.

4. Information Use-How We Use Your Data.

4.1. Website Use Data. We may bundle your Website use history with any PII for a short period of time for internal analysis and security purposes only. The foregoing described bundled data is referred to hereinafter both singularly and collectively as "Use Data". We use Use Data strictly for internal analytics purposes and We do not share Use Data with third parties.

4.2. Promotional & Informational Use. TrackDrive uses information you provide to fulfill any purpose for which you provide it, to carry out TrackDrive's obligations and enforce its rights arising from the Services, and to notify you about changes to the Services. TrackDrive may use your Financial Data to bill you.

4.3. AI Processing and Transcriptions. TrackDrive offers features that use artificial intelligence, including Premium Services such as audio transcriptions and AI-powered communication bots, and automated answers in in-app support chat.

1. Audio & AI Processing. If you utilize call transcriptions or AI bots, your audio recordings and message contents will be processed by TrackDrive (and our authorized third-party AI sub-processors) to generate text, spot keywords, and facilitate automated conversations. While TrackDrive offers automated PII redaction features for transcriptions, you remain solely responsible for ensuring you have obtained all necessary consumer consents under applicable wiretapping and privacy laws to record, transcribe, and process such communications.
2. AI Features. When you use TrackDrive's AI features, such as support chat answered by an AI assistant, the content you submit is processed by TrackDrive and our authorized third-party AI service providers acting on our behalf to provide those features, as described in Section 5.4.

4.4. Opt-Outs, Suppression Lists, and Telephony Compliance. To comply with applicable telecommunications laws (including the TCPA and 10DLC guidelines), We process and store consumer Contact Data (such as phone numbers) on your behalf within "Suppression Lists" or "Blacklists" when a consumer revokes consent (e.g., replies "STOP"). TrackDrive retains and utilizes this data solely to prevent unauthorized outbound communications to opted-out consumers on your behalf and to facilitate your chosen third-party compliance integrations (e.g., TCPA Shield, Blacklist Alliance). Please note that while consumers may request the deletion of their personally identifiable information, TrackDrive and its users are legally required to retain opted-out phone numbers within these suppression lists to ensure ongoing compliance with consumer communication laws.

5. Disclosure Practices-How We Share Your Data.

5.1. Service Providers. We may share your information, including PII, with our agents, contractors, service providers, and other third parties used to support the Service (such as cloud hosting, billing processing, data storage, and security).

5.2. Telecommunications Partners and Registries. To provide the telephony and routing services, We must share certain Contact Data, BI, and Telephony & Audio Data (including call logs, caller ID information, and SMS/MMS metadata) with upstream telecommunications carriers, routing partners, and industry registries (such as The Campaign Registry). This disclosure is strictly required for the purposes of routing communications, maintaining network security, preventing fraud, responding to industry traceback requests, and ensuring compliance with modern telecom frameworks (such as A2P 10DLC and STIR/SHAKEN). We process and transmit this data to facilitate client-configured lead routing and real-time bidding distribution.

5.3. User-Authorized Third-Party Integrations. If you choose to connect or integrate the Services with third-party applications (such as Zoho CRM, Salesforce, Zapier, or other third-party platforms), you authorize TrackDrive to share, sync, and transmit your PII, BI, and Lead/Contact data (including call logs and agent details) with that third-party service to facilitate the requested integration. TrackDrive is not responsible for how these third-party services collect, use, or protect your data once it has been transferred. Your use of any third-party integration is governed solely by the privacy policies and terms of those third parties.

5.4. ​​Customer Support Tools and Internal Access. To provide efficient customer service, we utilize third-party customer support widgets (such as the "Help!" feature within the App) and communication tools like Microsoft Teams. When you interact with these tools, they may automatically collect your Contact Data, IP address, and session information. Furthermore, to assist with technical troubleshooting, authorized TrackDrive support personnel may be granted secure, temporary access to impersonate your user account. This internal access is strictly limited to resolving your support inquiries and is governed by TrackDrive's internal security access controls. In-app support chat may be answered by an AI assistant. To generate those answers, the text of your support conversation is sent to a third-party AI service provider acting as our service provider, which processes it to provide the service to us and may retain it for a limited period, normally up to 30 days for abuse monitoring and security, and longer where required by law or necessary to protect services or others. Anything you type into the chat is included, but we do not attach your name or email address from our records to it. To answer a question about your own account, the AI assistant may also look up your account's records with the access your user has, such as your calls and their event logs, call and lead totals, your account's configuration and your buyers' pings, and send the results to that provider. Before they are sent, phone numbers in them are masked, contact details are replaced with a placeholder and consumers' free-text content is withheld, but other text in a record, such as a name quoted in a call's event log, may still be included. To troubleshoot a support inquiry, authorized TrackDrive support personnel may also connect an AI assistant to your account with read-only access; the data it retrieves is processed by a third-party AI service provider acting as our service provider, and personal data in it is masked or withheld when redaction for AI connections is turned on for your account, as described in Section 13.4. Such a connection is not shown on your AI Connections page and does not send the approval email described in Section 13.3; each request it makes is recorded in TrackDrive's internal access logs.

5.5. Aggregated and De-Identified Data. TrackDrive may aggregate and de-identify information collected through the Services (such as overall call volume trends, routing performance metrics, SMS delivery rates, and general API usage statistics) so that it can no longer be reasonably linked to you, your business, or your specific consumers. We may use and share this anonymized, statistical data for our own legitimate business purposes, including system optimization, algorithm training, industry benchmarking, and public marketing materials (such as case studies or performance reports). Because this aggregated data is entirely stripped of all Personally Identifiable Information, it no longer constitutes PII and is not subject to the sharing restrictions of this Policy.

5.6. Protection of Client Lead Data & B2B Marketing Disclosures. As a B2B technology provider, TrackDrive acts as a data processor for the lead data our clients route through our Platform. TrackDrive will never access, aggregate, sell, or supply the personal information or lead data loaded into the TrackDrive Platform by our clients to any third-party marketing companies, affiliates, or data aggregation companies. Furthermore, regarding the Contact Data we collect directly from you, no mobile information, including B2B SMS consent or text messaging originator opt-in data, will be shared with third parties or affiliates for marketing or promotional purposes.

5.7. By Law or to Protect Rights. We may disclose certain PII if requested via a subpoena, court order, or local, state, federal or international law enforcement request to release any such information; or in order to investigate and help prevent security threats, fraud or other malicious activity; or to protect our rights or protect our property, or any of the rights of our customers or other third parties.

6. Communications & Opt-Out.

6.1. Email Marketing Opt-Out. You can opt-out of receiving any promotional emails or newsletters at any time by either clicking "unsubscribe" in the body of the email communication and following the opt-out procedure contained in the email, or by sending an email to support@trackdrive.com and requesting to opt-out of receiving such communications.

6.2. Electronic Communications. When you visit this Website or send emails to us, you are communicating with us electronically. You consent to receive communications from us electronically. You agree that all agreements, notices and other communications that we provide to you electronically satisfy any legal requirement that such communications be in writing.

7. Data Security. We take the security of your data very seriously. All traffic between your browser and our servers is encrypted during transmission using Secure Sockets Layer (SSL) encryption. The data we collect and store is protected by industry-standard firewall and password protection systems. However, we make no guarantee, warranty or representation that any information provided through this Website will remain secure at all times from any illegal or unauthorized access of any data including any PII by third parties. We will report any unauthorized access to your information promptly upon discovery, and we will use our best efforts to remedy any security vulnerability that contributed to unauthorized access.

8. Third-Party Websites. TrackDrive neither owns nor controls Third-Party Websites. Third-Party Websites are under no obligation to comply with this Policy except with respect to PII provided directly to them by TrackDrive. Before visiting or providing any personal information to Third-Party Websites, you should inform yourself of the privacy policies and practices of those websites.

9. General Information (Storage & Access).

9.1. Information Storage And International Transfer. Any PII and all other information that we collect on this Website will be stored and processed in our servers located in the United States. If you reside outside the United States, you consent to the collection, transfer, storage, and processing of any information from your country to the United States.

9.2. How to View Your PII. You can request to view any of your collected PII at any time by emailing us at support@trackdrive.com. Please include the words "Information Request". If you make any information requests, we will require that you provide proof of your identity. We also reserve the right to require that you sign and provide us with a notarized affidavit verifying your identity before we update or release any information to you.

9.3 Data Retention and Call Recordings. We retain Website Use Data, Contact Data, and BI for as long as your account is active or as needed to provide the Service to you. However, regarding consumer lead data and Telephony & Audio Data (including call recordings and transcriptions) processed on your behalf, you are solely responsible for configuring your account's data retention settings. TrackDrive provides tools to customize call recording retention periods (including auto-deletion schedules). You represent and warrant that your chosen retention periods comply with all applicable data minimization and privacy laws. TrackDrive is not responsible for your failure to delete consumer data in accordance with applicable law.

     9.3.1. Automated PII Redaction. In accordance with data minimization principles, TrackDrive employs automated systems to redact specific PII (such as names, addresses, and birthdates) from inactive data, call logs, and archives after a default period of ninety (90) days. While Business Users may configure these redaction timelines within their account settings to meet their specific compliance needs, TrackDrive strictly minimizes the long-term retention of raw consumer PII in its routing and system logs.

10. Business Transitions. Upon any acquisition, merger, sale or other change of control of our business/organization, we reserve the right to transfer any PII you have submitted to this Website as part of the property owned by us to our successor resulting from such merger, acquisition, sale, etc. In the event of our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, We reserve the right to transfer your PII to protect any of our rights or as required by law.

11. Do-Not-Track Disclosure. TrackDrive does not respond to "Do Not Track" signals sent by browsers.

12. U.S. State Privacy Rights (CCPA/CPRA and Similar Laws).

12.1. Applicability. This section applies exclusively to residents of states with comprehensive privacy laws in effect, including but not limited to California (CCPA/CPRA), Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA), and Utah (UCPA). It outlines your rights regarding your Personally Identifiable Information (PII) and how you can exercise those rights.

12.2. Notice of Collection and Use. In the preceding twelve (12) months, we have collected the categories of PII detailed in Section 3 (Information Collection Practices) of this Policy. We collect and use this information for the business and commercial purposes outlined in Section 4 (Information Use).

12.3. No Sale of PII. TrackDrive does not "sell" any of your PII to third parties for monetary consideration. However, we may "share" certain data (like cookies and tracking identifiers) with third-party advertising partners for targeted advertising purposes, as described in Section 3. You have the right to opt-out of this sharing.

12.4. Your Consumer Privacy Rights. Depending on your state of residence, you may have the following rights regarding your PII:

1. The Right to Know and Access. You have the right to request that we disclose what PII we have collected, used, shared, or sold about you over the past 12 months, including the specific pieces of data we hold.
2. The Right to Delete. You have the right to request the deletion of the PII that we have collected from you, subject to certain legal exceptions.
3. The Right to Correct. You have the right to request that we correct any inaccurate PII we maintain about you.
4. The Right to Opt-Out of Sharing. You have the right to opt-out of the sharing of your PII for cross-context behavioral advertising or targeted advertising.
5. The Right to Non-Discrimination. We will not discriminate against you for exercising any of your state privacy rights.

12.5. How to Exercise Your Rights. To submit a verifiable consumer request to exercise your Right to Know, Right to Delete, or Right to Correct, please contact us via one of the following methods:

• Email: support@trackdrive.com (Please use the subject line "State Privacy Rights Request")

13. AI Assistants You Connect.

13.1. Connections. You may connect a third-party AI assistant or agent, such as Claude or ChatGPT, to your account through TrackDrive's MCP server by approving the connection on our consent screen. Each connection is approved by one user for one company, with either Read or Manage access.

13.2. What We Collect and Store. For each connection, we store: (i) the name and return addresses the AI application registered with us; (ii) the user who approved the connection, the company, and the access level granted; (iii) when the connection was approved, last used and revoked; (iv) for each charge you opt into on the consent screen, the charge type, the rate shown, the consent text, and the IP address and browser user agent from which you agreed; (v) a record of each approval, and of each revocation on the AI Connections page, including the user who made it and the IP address and browser user agent it came from; (vi) how many times the connection used each tool and when it last did; (vii) for each phone number purchase an AI application requests, the request as the AI application made it, its cost, and who decided it, when, and from which IP address and browser user agent; and (viii) the credentials the connection uses, which we store encrypted. Changes to your account's AI assistant settings are recorded with the user who made them. For each request an AI application makes through a connection, we log the application's name, the tool it used, the names of the arguments it supplied but not their values, the TrackDrive API endpoints it called and their status, the outcome, the size of the answer and the duration. Each TrackDrive API call made through a connection is also recorded in our API request logs described in Section 3.4, including the address and parameters of the call, with phone numbers and contact-detail fields masked. We use these records and logs to operate and secure connections, to show your company who authorized what, to carry out and bill the purchases and charges you approve, to support you, and to investigate misuse.

13.3. What We Share. Through a connection, the MCP server returns to the AI application the data it requests, within the access you granted. This can include call records and call event logs, call and lead reports, help articles, your account's configuration (such as buyers and their pings, offers, call routers, traffic sources, ping endpoints, ping parsers and rate limiters, phone numbers, postbacks, agents, agent scripts, dialing schedules and contact fields), the names but never the values of your secret keys, available phone numbers and phone number purchase requests, and it can include the consumer lead and call data described in Sections 3.1(b) and 3.6. That data is transferred to the provider of the AI application at your direction, and that provider's terms and privacy policy govern how it handles the data (Section 5.3). When one of your users approves a connection, we email the company owner a notice of the approval.

13.4. Redaction. If redaction for AI connections is turned on for your account on the AI Connections page (a setting separate from the automated PII redaction described in Section 9.3.1, and off unless you turn it on), phone numbers in the data returned to an AI application are masked, contact details are replaced with a placeholder, consumers' free-text content is withheld, and any result that is not structured data is withheld. Otherwise, the data is returned as the user who approved the connection can see it through TrackDrive's API.

13.5. Retention. Each access token expires after a short period (currently one hour), and the connection obtains a new one with a refresh credential that changes each time it is used. A connection stops working as soon as it is revoked or after 30 days without use. Revocation deletes the connection's access tokens. We keep the other records described in Section 13.2, including the connection's refresh credentials, after a connection expires or is revoked, as the record of what was authorized. We keep the request logs described in Section 13.2 for up to one year and the API request logs for up to 90 days.

13.6. Your Controls and Revoking a Connection. You can revoke a connection at any time on the AI Connections page of your account. The company owner and users on a superuser team with the Access Tokens & Superuser Teams permission can see and revoke every connection your company's users approved, disconnect them all at once, turn AI assistant connections on or off for your account, hold every connection to read-only access, and turn redaction on or off (Section 13.4); other users can see and revoke the connections they approved. Revocation stops a connection from starting new requests immediately; a request already in progress when you revoke it may finish.