Trakmode Privacy Policy

Last Updated: July 6, 2026

Trakmode LLC ("Trakmode," "we," "us," or "our") has prepared this Privacy Policy to explain how we collect, use, disclose, store, and protect personal information in connection with our website, web application, creator tools, buyer experiences, embedded players, storefronts, landing pages, waitlists, campaign pages, communications, billing, invoicing, payout workflows, and related services (collectively, the "Service").

This Privacy Policy also explains your choices and rights regarding your personal information.

In this Privacy Policy, "personal information" also includes "personal data" where that term is used under applicable privacy and data protection laws.

For purposes of data protection laws of the United Kingdom, European Economic Area, and Switzerland, Trakmode LLC is the controller of the personal information covered by this Privacy Policy, unless otherwise stated.

This Privacy Policy is Trakmode's general privacy policy. Certain creator-page interactions may also be governed by the Trakmode Creator Privacy Policy, which explains how personal information may be processed when users visit, purchase from, download from, book, message, follow, subscribe to, request updates from, or otherwise interact with creators through Trakmode.

By accessing or using the Service, you acknowledge that you have read and understood this Privacy Policy.

1. Scope of This Privacy Policy

This Privacy Policy applies to personal information we collect from:

- visitors to our website; - users who sign up for early access, newsletters, waitlists, event pages, or campaign landing pages; - creators who apply for or use Trakmode creator tools; - buyers or fans who purchase, download, book, message, or otherwise interact through the Service; - users who visit creator storefronts, public Trak links, embedded players, editorial pages, or discovery pages; - users who contact us for support, feedback, or business inquiries; - users whose information we receive through third-party integrations, payment providers, tax providers, payout providers, compliance vendors, infrastructure providers, analytics tools, email tools, or related services.

This Privacy Policy does not apply to third-party websites, services, payment processors, social platforms, partner tools, or creator-owned external properties that operate under their own privacy policies.

2. Personal Information We Collect

2.1 Information You Provide to Us

We may collect information you provide directly to us, including:

- name, stage name, artist name, company name, and professional aliases; - email address and phone number; - username, login credentials, and account profile information; - social media handles, streaming profile links, website links, and other public-facing creator identifiers; - information about your role or relationship to a creator, business, or brand, such as artist, producer, engineer, manager, label representative, agency representative, collaborator, or buyer; - creator onboarding submissions, application materials, portfolio links, credits, and business information; - billing, payout, invoice, tax residency, and compliance-related information where applicable; - limited status information or metadata received from supported payment, payout, tax, identity verification, fraud-prevention, or compliance providers; - profile content, bios, artwork, images, links, and brand assets; - information about products, services, offers, licenses, pricing, files, and fulfillment settings; - messages, support requests, feedback, survey responses, and other communications you send to us.

2.2 Information From Third-Party Accounts and Integrations

If you choose to sign in through, connect, or otherwise link a third-party service to Trakmode, such as Google Account, Apple ID, a social platform, a payment provider, a payout provider, or another supported integration, we may receive information from that third party, such as your name, email address, profile information, account identifiers, authentication status, connection status, and related account information, subject to your settings and the third party's own privacy practices.

If you create an account using an email address and password, we process your email address, password authentication data, account status, login activity, password reset activity, and related security information to create, secure, maintain, and recover your account.

You are responsible for using a valid email address, keeping your login credentials secure, and maintaining access to the email address connected to your account. We do not require users to share passwords with Trakmode support.

2.3 Sources of Personal Information

We may collect personal information directly from you, automatically from your use of the Service, and from other sources, including:

- your representatives, team members, collaborators, or business contacts; - payment processors, payout providers, tax providers, invoicing providers, compliance providers, fraud-prevention vendors, and identity verification vendors; - connected third-party platforms and integrations; - publicly available sources, such as public websites, social media pages, streaming profiles, or other public creator pages; - other users where relevant to a purchase, booking, inquiry, dispute, refund, or support request; - business transaction partners where relevant to a financing, merger, acquisition, reorganization, asset sale, insolvency, bankruptcy, receivership, or similar transaction.

2.4 Creator Information

If you use creator features, we may collect:

- legal name and artist name; - payout country; - connected payout account status; - creator billing approval status; - transaction and payout ledger history; - reserve and risk review flags; - service listings, digital products, files, pricing, licensing, and metadata; - onboarding responses; - creator performance data; - optional partner participation settings.

2.5 Buyer, Fan, and Customer Information

We may collect:

- name and contact information; - billing address; - billing country or state; - VAT ID where applicable; - purchase and booking history; - invoice history; - refund and dispute records; - licensing and delivery information; - download history; - service booking details; - quote request details; - messaging and creator-user communication history; - customer support interactions.

2.6 Payment, Billing, Tax, and Payout Information

We do not generally store full payment card details.

Payments, invoices, taxes, identity verification, compliance checks, and payouts may be processed by third-party providers such as Stripe, PayPal, tax automation providers, payout providers, identity verification providers, fraud-prevention providers, and other supported vendors. These providers may process your information under their own terms and privacy policies.

Where supported payment, payout, tax, identity verification, or compliance providers collect information to process payments, payouts, tax forms, fraud checks, identity checks, or compliance reviews, that information is generally collected and processed directly by those providers.

Trakmode may receive limited related information, such as:

- transaction IDs; - invoice numbers; - payment status; - payout status; - payout ledger entries; - billing country; - tax amounts; - VAT, GST, or sales tax calculations; - fraud indicators; - chargeback and reserve data; - tax verification status; - KYC or identity verification status; - account status; - creator billing approval metadata; - compliance metadata.

2.7 Website, Usage, and Technical Information

When you visit our website, creator storefronts, public player pages, embedded Trak links, waitlist pages, editorial pages, campaign landing pages, event pages, or other public areas of the Service, we and our service providers may automatically collect technical and usage-related information, including:

- IP address; - browser type and version; - device type; - operating system; - language settings; - time zone; - approximate geographic region derived from IP; - referring URLs; - pages viewed; - storefronts, offers, or creator pages visited; - embedded player interactions; - clicks, taps, scroll depth, and navigation paths; - time spent on pages; - download attempts; - wallet pass or QR scan events; - event RSVP interactions; - timestamps of activity; - error logs; - crash data; - performance and latency data; - attribution and campaign source information where available.

2.8 Uploaded Content and Transactional Content

Because Trakmode is a commerce infrastructure platform, we may process:

- creator files; - digital products; - stems, presets, packs, drops, and related metadata; - service descriptions; - booking details; - preview assets; - messages submitted through workflows; - licensing selections; - order and fulfillment history.

Creator Content and user-generated content may include audio files, previews, recordings, stems, sample packs, presets, artwork, images, video, text, comments, messages, chats, product descriptions, service descriptions, metadata, and other materials you upload, transmit, publish, or make available through Trakmode.

Some uploaded or shared content may contain personal information, such as your voice, likeness, name, image, credits, collaborators, contact details, project information, or other identifiable information. You are responsible for ensuring that you have the rights and permissions necessary to upload, share, publish, sell, license, or otherwise make such content available through Trakmode.

2.9 AI-Related Information

If you use AI-related features or upload AI-assisted content, we may collect:

- AI content labels or classifications; - creator-selected AI categories; - workflow inputs necessary to provide AI-assisted features; - AI-generated metadata, descriptions, or layouts; - usage and quality data related to AI-assisted product features.

2.10 Information Required to Use Certain Features

In some cases, we are legally or contractually required to collect certain personal information in order to provide parts of the Service, including creator onboarding, billing approval, tax handling, identity verification, compliance checks, transaction processing, and payouts.

If you do not provide required information, we may be unable to provide certain features, complete a transaction, activate payouts, process a booking, deliver a download, respond to a request, or continue providing a particular service.

2.11 Sensitive Personal Information

Trakmode does not ask users to provide sensitive personal information through the Service and does not intentionally collect sensitive personal information as part of normal account creation, buyer accounts, purchases, downloads, messaging, following creators, or general use of Trakmode.

Please do not provide sensitive personal information through Trakmode unless we specifically request it for a clearly identified purpose or where it is required by a supported third-party payment, payout, tax, identity verification, fraud-prevention, or compliance provider.

Sensitive personal information may include social security numbers, government identification numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health information, biometric or genetic data, criminal background information, trade union membership, or other information treated as sensitive under applicable law.

If you voluntarily provide sensitive personal information to Trakmode where it was not requested or required, you consent to our processing of that information in accordance with this Privacy Policy to the extent necessary to provide the Service, respond to your request, comply with law, protect the Service, restrict access to the information, or delete it where appropriate.

If you do not consent to this processing, you must not submit sensitive personal information through the Service.

Where creator onboarding, payouts, tax, identity verification, fraud prevention, or compliance checks require sensitive information, that information may be collected and processed directly by third-party payment, payout, tax, identity verification, fraud-prevention, or compliance providers under their own terms and privacy policies. Trakmode may receive limited status information, verification results, compliance indicators, approval status, or payout-related metadata from those providers, but Trakmode does not need or request unnecessary sensitive personal information for normal use of the Service.

3. How We Use Personal Information

3.1 To Provide and Operate the Service

We use personal information to:

- create and manage accounts; - authenticate users and secure account access; - publish creator profiles, storefronts, and offers; - enable downloads, delivery, services, and bookings; - manage creator onboarding and approvals; - operate communications and notifications; - support optional partner and opportunity programs; - provide support and respond to requests, questions, and feedback.

3.2 To Process Transactions, Billing, Tax, and Payouts

We use personal information to:

- process purchases and bookings; - issue invoices and receipts; - calculate and collect VAT, GST, sales tax, and similar transaction taxes where applicable; - route creator payouts; - maintain payout and invoice ledgers; - support refunds, disputes, reserves, and chargebacks; - perform fraud checks and compliance reviews; - support creator billing approval workflows; - comply with DAC7, tax, accounting, bookkeeping, and legal reporting obligations where applicable.

3.3 To Improve and Develop the Service

We use personal information to:

- analyze usage trends; - improve landing pages, creator storefronts, and public player experiences; - measure traffic sources, campaign performance, and creator page engagement; - optimize conversion funnels, waitlists, and creator application flows; - improve wallet pass, QR, and event page experiences; - troubleshoot bugs and monitor performance; - develop creator tools, monetization workflows, and AI-assisted features; - personalize certain Service-related experiences where appropriate.

3.4 For Safety, Fraud Prevention, and Enforcement

We use personal information to:

- detect fraud, abuse, chargeback abuse, and misuse; - enforce our Terms of Service and policies; - monitor suspicious conduct and infringement; - protect users, creators, buyers, and Trakmode; - investigate disputes and complaints; - prevent unauthorized, harmful, unethical, or illegal activity.

3.5 For Creator Applications, Creator Eligibility, and Monetization Access

If you apply for creator access, request to switch from a general user account to a creator profile, attempt to activate creator monetization features, connect payout or payment infrastructure, publish paid offers, or use Trakmode's creator commerce infrastructure, we may use personal information to review creator eligibility, verify account quality, evaluate platform risk, prevent fraud, protect rights holders, support payment security, and determine whether creator features or monetization tools should be approved, restricted, suspended, or subject to additional review.

3.6 Marketing and Business Communications

Where permitted by law, we may send updates, launches, creator opportunities, campaigns, newsletters, and event information.

You may opt out of marketing communications as described in this Privacy Policy.

3.7 Research, Analytics, and Aggregated Data

We may create aggregated, anonymized, or de-identified data for lawful business purposes, including analytics, benchmarking, research, operational reporting, and product development.

We do not attempt to re-identify data that has been properly anonymized.

3.8 To Comply With Law

We may use personal information to comply with tax, legal, accounting, invoice retention, KYC, AML, financial reporting, sanctions, consumer protection, privacy, and platform safety obligations where applicable.

4. Legal Bases for Processing

If you are located in the EEA, UK, or Switzerland, we rely on one or more of the following legal bases, depending on the circumstances:

- performance of a contract with you; - consent where required; - legitimate interests, including operating, improving, securing, and developing the Service; - legal obligations, including tax reporting, seller verification, KYC or AML obligations, invoice retention, and other compliance requirements where applicable.

Where we rely on consent, you may withdraw that consent at any time. This will not affect the lawfulness of processing carried out before your withdrawal.

Additional information for users in the EEA, UK, and Switzerland is provided in the "Notice to EEA, UK, and Switzerland Users" section below.

5. How We Share Personal Information

We do not sell your personal information for money.

5.1 Service Providers

We may share personal information with service providers that help us operate the Service, including providers of:

- cloud hosting; - storage; - email delivery; - customer support; - software monitoring; - analytics; - communications infrastructure; - security and fraud prevention; - auditing and infrastructure support.

Where required, our service providers process personal information on our behalf under appropriate contractual safeguards.

5.2 Between Creators and Buyers

We may share transaction-relevant, fulfillment-relevant, and communication-relevant information between creators and buyers where necessary or appropriate to support purchases, free downloads, services, bookings, quote requests, custom offers, messaging, support requests, licensing, delivery, refunds, disputes, chargebacks, tax records, customer support, or creator-user communication.

When you buy from, download from, book, message, follow, subscribe to, request updates from, or otherwise interact with a creator through Trakmode, the creator may receive or access information related to that interaction, such as your name, email address, username, order details, download details, selected license type, booking details, quote request details, message content, support context, and contact details you voluntarily provide.

Creators are responsible for how they use personal information they receive, export, or process independently outside Trakmode, subject to the Creator Agreement, Creator Privacy Policy, applicable law, and platform rules.

5.3 Payment, Tax, Payout, and Compliance Providers

We may share personal information with:

- payment processors; - payout providers; - tax automation providers; - invoicing providers; - fraud prevention vendors; - identity verification providers; - compliance and KYC vendors; - accounting, audit, and bookkeeping partners.

5.4 Merchant of Record and Transaction Processing

For creator transactions where the creator is the Merchant of Record, Trakmode may still process and store transaction, order, invoice, payment status, refund, dispute, tax, payout, and compliance information as the technology infrastructure provider.

This processing supports checkout, payment routing, creator dashboards, buyer access, digital delivery, service bookings, refunds, disputes, chargebacks, accounting, tax, fraud prevention, platform security, legal compliance, and enforcement of our agreements.

Where Trakmode is Merchant of Record for selected offers, selected creators, selected campaigns, or separate written arrangements, Trakmode may process additional seller-side transaction, tax, invoice, refund, dispute, and buyer-support information as needed for that specific transaction or arrangement.

5.5 Professional Advisors

We may share data with lawyers, accountants, insurers, auditors, and financial advisors where necessary in the course of the professional services they provide to us.

5.6 Compliance and Safety

We may disclose personal information where required by law, regulation, legal process, or governmental request, or where we believe disclosure is necessary to prevent fraud, abuse, illegal activity, infringement, or harm to Trakmode, our users, creators, buyers, or others.

5.7 Corporate Affiliates and Entities Under Common Control

We may share personal information with our corporate affiliates and entities under common control, if any, for purposes consistent with this Privacy Policy.

5.8 Campaign, Opportunity, and Industry Partners

Where relevant to a creator opportunity, campaign, event, brand collaboration, distribution workflow, or other optional program you choose to participate in, we may share relevant personal information with partners involved in operating that opportunity or fulfilling that program, subject to this Privacy Policy and any additional terms or disclosures provided at the time.

5.9 Business Transfers

We may transfer personal information in connection with a financing, merger, acquisition, reorganization, asset sale, insolvency, bankruptcy, receivership, or similar corporate transaction.

5.10 With Your Direction or Consent

We may share personal information with third parties where you direct us to do so, where it is necessary to complete an action you request, or where you otherwise consent.

5.11 Public Areas and Creator Pages

Certain parts of the Service are public-facing, such as creator storefronts, public profile pages, Trak links, embedded players, editorial pages, campaign pages, public posts, product pages, service pages, and similar surfaces.

Information you choose to make public through those areas may be visible to other users, buyers, fans, collaborators, search engines, platform partners, or the general public.

Public information may be viewed, copied, cached, indexed, screen captured, downloaded, shared, or stored by other users, third parties, search engines, or external services. Trakmode is not responsible for how other users or third parties use information that you choose to make public.

Please use care when deciding what information to publish publicly.

6. Analytics, Cookies, and Similar Technologies

Trakmode uses a privacy-focused, cookie-less analytics solution to understand aggregated website traffic, public storefront visits, landing page performance, embedded player engagement, campaign attribution, and general Service usage trends.

Our analytics implementation does not use cookies, local storage, persistent identifiers, or cross-site tracking technologies for website measurement.

We currently use Plausible Analytics, a privacy-first analytics provider designed to operate without collecting personal data used to identify individual visitors.

Plausible processes only limited aggregated usage and technical signals such as page paths, referrers, browser category, device category, approximate geographic region, and campaign attribution parameters in anonymous form.

We do not currently use cookies, tracking pixels, cross-site tracking technologies, or advertising identifiers for targeted advertising or cross-context behavioral advertising in connection with Trakmode's website, creator pages, storefronts, embedded players, or core platform measurement.

If we introduce non-essential cookies, advertising technologies, tracking pixels, or similar tools in the future, we will update this Privacy Policy and provide any notice or consent required by applicable law.

Because there is not yet a consistent industry standard for "Do Not Track" signals, we do not currently respond to browser-based Do Not Track signals. However, where required by applicable law and technically supported, we will honor legally recognized browser-based privacy preference signals, such as the Global Privacy Control.

7. Automated Processing, Profiling, and Creator Eligibility Reviews

For normal user accounts, buyer accounts, purchases, downloads, following creators, messaging, and general use of Trakmode, Trakmode does not engage in automated decision-making or profiling that produces legal or similarly significant effects.

Trakmode may use automated tools, algorithmic review, manual review, or a combination of automated and manual review to support platform safety, fraud prevention, abuse prevention, rights protection, payment risk review, account security, content moderation, and creator eligibility decisions.

Automated processing, profiling, manual review, or algorithm-assisted review may apply when a user applies for creator access, requests to switch from a general user account to a creator profile, attempts to activate creator monetization features, connects payout or payment infrastructure, publishes paid offers, or uses Trakmode's creator commerce infrastructure.

These reviews may consider information such as account information, application information, public profile data, portfolio links, credits, content metadata, platform activity, payment or payout status, fraud or abuse signals, rights or compliance concerns, risk indicators, and other information relevant to creator access, monetization, platform safety, or legal compliance.

Trakmode may approve, reject, restrict, suspend, or require additional review before allowing a user to access creator features, publish paid offers, activate payouts, or use monetization-related infrastructure.

Where required by applicable law, if Trakmode makes a decision based solely on automated processing that produces legal or similarly significant effects, you may have the right to request human review, express your point of view, and contest the decision.

Trakmode does not use automated decision-making or profiling to make legally or similarly significant decisions about ordinary buyer accounts or normal non-creator use of the Service.

8. Marketing Communications

You may unsubscribe from marketing emails at any time by using the unsubscribe link in the email or by contacting us.

Transactional, account, billing, legal, safety, purchase, download, booking, support, and service-related notices may still be sent.

9. Data Retention

We retain personal information for as long as reasonably necessary to provide the Service, operate our business, resolve disputes, prevent fraud, enforce our agreements, and comply with legal obligations.

To determine the appropriate retention period, we may consider the amount, nature, and sensitivity of the personal information, the risk of harm from unauthorized use or disclosure, the purposes for which we process the information, whether we can achieve those purposes through other means, and applicable legal, accounting, tax, payment, fraud-prevention, and recordkeeping requirements.

Examples of retention periods or retention logic include:

- account information: while your account is active and for a reasonable period afterward; - waitlist, newsletter, and marketing information: until you unsubscribe, opt out, or we no longer need the information for those purposes; - transaction, order, payout, invoice, tax, reserve, refund, dispute, and compliance records: for as long as required by applicable tax, accounting, anti-fraud, payment, and legal obligations, which may in some cases be up to 7 years or longer where required by law; - creator onboarding, billing approval, KYC, and tax verification records: for as long as required by payment, compliance, and legal obligations; - support and complaint records: for as long as needed to resolve the issue and maintain appropriate business records.

Creator files, digital products, previews, artwork, metadata, messages, delivery records, and related creator account data may be retained for as long as reasonably necessary to operate creator storefronts, process secure delivery, support buyer access, maintain order history, resolve disputes, prevent fraud, comply with legal or payment-related obligations, and enforce our agreements.

If Trakmode permanently discontinues the Service or shuts down creator commerce functionality, we may retain transaction records, invoices, receipts, payment-related records, tax-related records, refund records, dispute records, chargeback records, compliance records, and related account information for as long as reasonably necessary or required by law, even after user-facing access is discontinued.

Where technically and commercially reasonable, Trakmode may use personal information to provide account notices, export opportunities, download instructions, or transition communications before discontinuing relevant features.

When we no longer require personal information, we may delete it, anonymize it, de-identify it, or isolate it from further processing where deletion is not immediately possible, such as where information is stored in backup archives or retained for legal, accounting, fraud-prevention, dispute, payment, or compliance purposes.

We may also retain de-identified or aggregated information for lawful business purposes. In some cases, we may retain information for a longer period where necessary to comply with legal obligations, resolve disputes, prevent fraud, or enforce our agreements.

10. Data Deletion Requests

You may request deletion of your personal information by contacting privacy@trakmode.com, subject to legal, financial, tax, fraud-prevention, compliance, payment, dispute, chargeback, security, and recordkeeping retention requirements.

11. Data Security

We use reasonable technical, organizational, and administrative safeguards designed to protect personal information.

However, no method of transmission, processing, or storage is completely secure, and we cannot guarantee absolute security.

12. International Transfers

Trakmode is based in the United States and may process personal information in the United States and other jurisdictions that may have data protection laws different from those in your country of residence.

If you use the Service from the EEA, United Kingdom, Switzerland, or another region outside the United States, your personal information may be transferred to, accessed from, or processed in the United States and other countries where Trakmode, our service providers, payment processors, infrastructure providers, support providers, or partners operate.

Some of these countries may not be recognized by your local authorities as providing the same level of data protection as your home jurisdiction.

Where required by applicable law, we use appropriate safeguards for international transfers, including contractual protections such as the European Commission's Standard Contractual Clauses, the UK International Data Transfer Addendum or other UK-approved transfer mechanisms, Swiss transfer safeguards where applicable, adequacy decisions where available, or other lawful transfer mechanisms.

In limited circumstances, we may rely on legal exceptions or derogations permitted under applicable law, such as where a transfer is necessary to perform a contract with you, complete a transaction you requested, establish or defend legal claims, comply with law, or where you have provided explicit consent where required.

You may contact us for more information about the transfer mechanisms we use.

13. Your Choices

You may access or update certain account information by logging into your account where those features are available.

You may opt out of marketing emails by using the unsubscribe link in the email or by contacting us. Even if you opt out of marketing communications, we may still send transactional, account, billing, legal, safety, purchase, download, booking, support, and service-related messages.

If you connect Trakmode to a third-party platform, such as Google Account, Apple ID, a social platform, a payment provider, a payout provider, or another supported integration, you may be able to adjust permissions through your settings with that third-party service. Revoking access may limit certain Trakmode features and will not necessarily affect information already received before access was revoked.

You may request to delete certain content or close your account by contacting us. Deletion and account closure requests are subject to legal, tax, payment, fraud-prevention, dispute, chargeback, security, compliance, and recordkeeping requirements.

If you decline to provide information that is required for a feature, transaction, account, payout, verification, tax, support, booking, download, or creator workflow, we may not be able to provide that feature or complete that action.

14. Your Privacy Rights

Depending on where you live and subject to applicable law, you may have the right to request:

- access to your personal information; - correction of inaccurate personal information; - deletion of your personal information; - restriction of processing; - objection to certain processing; - portability of certain personal information; - withdrawal of consent where processing is based on consent.

To exercise applicable rights, please contact us at privacy@trakmode.com.

We may need to verify your identity before completing your request.

15. Additional Rights for U.S. Residents

Residents of certain U.S. states with applicable privacy laws may have some or all of the following rights, subject to applicable exceptions:

- right to know and access categories and specific pieces of personal information we have collected; - right to correct inaccurate personal information; - right to delete personal information; - right to data portability; - right to opt out of the sale or sharing of personal information, if applicable; - right to opt out of the processing of personal information for targeted advertising, if applicable; - right to opt out of profiling in furtherance of decisions that produce legal or similarly significant effects, where applicable; - right to limit certain uses of sensitive personal information, where applicable; - right not to be discriminated against for exercising privacy rights.

You may also designate an authorized agent to submit certain requests on your behalf where permitted by law, subject to verification requirements.

If we deny your request, you may have the right to appeal that decision depending on your state of residence. To appeal, please contact privacy@trakmode.com with "Privacy Appeal" in the subject line and explain the basis for your appeal.

16. Additional Rights for California Residents

California residents may request information about the categories of personal information we collect, use, disclose, correct, or delete, subject to applicable exceptions.

We do not sell personal information for money.

We also do not currently share personal information for cross-context behavioral advertising or use personal information for targeted advertising in connection with Trakmode's website, creator pages, storefronts, embedded players, or core platform measurement.

In the preceding 12 months, we may have disclosed identifiers, commercial information, transaction data, billing information, internet or network activity, creator business information, buyer interaction information, messaging-related information, and compliance-related verification data to service providers, contractors, creators you interact with, payment-related vendors, and other permitted recipients for the business purposes described in this Privacy Policy.

California residents may also designate an authorized agent to submit requests on their behalf, subject to verification requirements.

California's "Shine the Light" law may permit California residents to request information about certain disclosures of personal information for direct marketing purposes. Requests may be sent to privacy@trakmode.com with "Shine the Light Inquiry" in the subject line.

17. Nevada Residents

Nevada residents may request to opt out of any future sale of certain covered information as defined under Nevada law by contacting privacy@trakmode.com.

18. Notice to EEA, UK, and Switzerland Users

This section applies to individuals located in the European Economic Area, the United Kingdom, or Switzerland.

Controller

Trakmode LLC is the controller of the personal information covered by this Privacy Policy, unless otherwise stated.

You may contact Trakmode about privacy questions or data rights requests using the contact details in the Contact section.

Legal Bases for Processing

Where applicable law requires a legal basis, we rely on one or more of the following legal bases:

Purpose: Account creation, login, authentication, and account security Categories of Personal Information: Contact data, profile data, authentication data, login activity, password reset activity, device and technical data Legal Basis: Contractual necessity; legitimate interests in securing accounts and preventing unauthorized access

Purpose: Providing and operating the Service Categories of Personal Information: Contact data, profile data, creator data, buyer data, uploaded content, messages, technical data Legal Basis: Contractual necessity; legitimate interests in operating and improving the Service

Purpose: Normal buyer accounts, purchases, downloads, messaging, and general user activity Categories of Personal Information: Contact data, buyer device data, order data, license data, messages, billing data, delivery records Legal Basis: Contractual necessity; legal obligations; legitimate interests in operating the Service, supporting transactions, and preventing fraud

Purpose: Creator profiles, storefronts, products, services, and public pages Categories of Personal Information: Creator information, Creator Content, metadata, public profile data, product and service information Legal Basis: Contractual necessity; legal obligations; legitimate interests in enabling creator commerce and public creator pages

Purpose: Creator applications, creator eligibility review, monetization access, payout activation, and creator risk review Categories of Personal Information: Account data, creator application data, public profile data, portfolio links, creator business data, content metadata, platform activity, payment or payout status, fraud indicators, compliance metadata, rights or risk signals Legal Basis: Contractual necessity; legal obligations; legitimate interests in creator verification, fraud prevention, rights protection, payment security, platform safety, and responsible access to monetization infrastructure

Purpose: Purchases, free downloads, bookings, quote requests, and digital delivery Categories of Personal Information: Buyer data, order data, download data, license data, booking data, billing data, delivery records Legal Basis: Contractual necessity; legitimate interests in transaction records, support, and fraud prevention

Purpose: Payments, payouts, tax, invoices, refunds, disputes, chargebacks, and compliance Categories of Personal Information: Billing data, payment status, payout data, tax data, invoice data, fraud indicators, compliance data Legal Basis: Contractual necessity; legal obligations; legitimate interests in fraud prevention, payment security, and dispute handling

Purpose: Messaging, support, and creator-user communication Categories of Personal Information: Contact data, messages, support requests, booking context, communication history Legal Basis: Contractual necessity; legitimate interests in enabling communication and resolving issues

Purpose: Safety, fraud prevention, abuse prevention, rights enforcement, and platform security Categories of Personal Information: Account data, device data, technical data, transaction data, Creator Content, messages, compliance data Legal Basis: Legal obligations; legitimate interests in protecting Trakmode, users, creators, buyers, and third parties

Purpose: Analytics, performance monitoring, product improvement, and platform stability Categories of Personal Information: Usage data, technical data, performance data, aggregated analytics data Legal Basis: Legitimate interests in operating, securing, improving, and developing the Service

Purpose: Marketing and business communications Categories of Personal Information: Contact data, marketing preferences, engagement with communications Legal Basis: Consent where required; legitimate interests where permitted by law

Purpose: Optional creator programs, campaigns, funding introductions, and partner programs Categories of Personal Information: Creator profile data, creator business data, performance data, opt-in settings, campaign information Legal Basis: Consent where required; contractual necessity; legitimate interests in operating optional programs

Purpose: Legal claims, business transfers, corporate transactions, and enforcement Categories of Personal Information: Relevant account, transaction, content, communication, compliance, and business records Legal Basis: Legal obligations; legitimate interests in protecting rights, continuity of service, and business operations

Purpose: Aggregated, anonymized, or de-identified data Categories of Personal Information: Any relevant data after aggregation, anonymization, or de-identification Legal Basis: Legitimate interests in analytics, research, product development, benchmarking, and service improvement

Where we rely on consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

Where we rely on legitimate interests, you may have the right to object to certain processing as described in this Privacy Policy.

Automated Processing and Creator Eligibility

For normal user accounts, buyer accounts, purchases, downloads, following creators, messaging, and general use of Trakmode, Trakmode does not engage in automated decision-making or profiling that produces legal or similarly significant effects.

Automated processing, profiling, manual review, or algorithm-assisted review may apply when a user applies for creator access, requests to switch from a general user account to a creator profile, attempts to activate creator monetization features, connects payout or payment infrastructure, publishes paid offers, or uses Trakmode's creator commerce infrastructure.

Where required by applicable law, if Trakmode makes a decision based solely on automated processing that produces legal or similarly significant effects, you may have the right to request human review, express your point of view, and contest the decision.

Your Rights

Subject to applicable law, you may have the right to request access, correction, deletion, restriction, objection, portability, withdrawal of consent, and to lodge a complaint with your local supervisory authority.

You may contact Trakmode at privacy@trakmode.com to exercise these rights.

If you are located in the EEA, you may contact your local data protection authority. If you are located in the United Kingdom, you may contact the UK Information Commissioner's Office. If you are located in Switzerland, you may contact the Swiss Federal Data Protection and Information Commissioner.

19. Children's Privacy

The Service is intended for users who are at least 18 years old.

We do not knowingly collect personal information from children or knowingly direct the Service to children. If we learn that we have collected personal information from a child in violation of applicable law, we will take steps to delete that information as required.

20. Third-Party Services

Third-party integrations, payment processors, social media platforms, partner tools, embedded services, creator links, and other third-party services operate under their own privacy policies and practices.

We are not responsible for those third-party privacy practices.

We encourage you to review their privacy policies before sharing information with them.

21. De-Identified and Aggregated Data

We may use de-identified, anonymized, or aggregated data for lawful business purposes, including analytics, product development, benchmarking, research, operational reporting, and service improvement.

We do not attempt to re-identify data that has been properly anonymized.

22. Changes to This Privacy Policy

We may update this Privacy Policy from time to time.

When we do, we will revise the "Last Updated" date at the top of the policy.

If we make material changes, we will provide notice as required by law, such as by email, through the Service, or by posting a prominent notice before the changes become effective.

23. Contact

Privacy questions, data rights requests, deletion requests, correction requests, access requests, objections, complaints, and privacy-related concerns should be sent to:

Trakmode LLC 8 The Green, Suite B Dover, DE 19901 United States

Privacy: privacy@trakmode.com Support: support@trakmode.com Telephone: 1-646-757-1206