Last updated: 20 December 2025

This Privacy Policy ("Policy") sets out how we collect, store, use, process and disclose your personal information in connection with our website, services and our Trace app ("App") (collectively, our "Services"). When we refer to "we", "us" or "our" in this Privacy Policy, we mean Ocean Labs Limited, New Zealand (Trace) and our related companies (as that term is defined in the Companies Act 1993). Beyond this Privacy Policy, your use of the Service is also subject to our service terms and service ("Terms").

We take our obligations in relation to your personal information seriously. We are committed to protecting your personal information and ensuring we comply with all relevant privacy laws, including the Privacy Act 2020 ("Privacy Act").

By providing us with your personal information, you agree to the collection, storage, use and disclosure of your personal information in accordance with this Privacy Policy. If you do not agree, you may not be able to use the Services.

We may need to change this Privacy Policy from time to time. If we make any changes, then we will tell you about them by posting an updated policy on our website. By continuing to use the Services, you will be agreeing to any changes to the Privacy Policy. Any changes will take effect from the date we update and post the Privacy Policy, so please check this Privacy Policy when you access our website.

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HOW DO WE COLLECT YOUR PERSONAL INFORMATION?

We collect your personal information for lawful purposes connected to our functions and activities (including providing the Services to you), for purposes directly related to this or where you have agreed we can do so. Information we collect may include:

• Registration information: When you sign up for an account with us you give us your name, email address, and country. We may also collect information such as your sail number, bib number, mobile phone number, personal information from social media websites if you choose to connect your account using your social media account.

• Payment details: When you add a credit card or payment method to your account with us, a third party that handles payments for us will receive your card information and this will be collected and processed pursuant to that third party payment providers privacy policy terms.

• Communications: If you contact us directly, we may receive additional information about you. For example, when you contact our Customer Support Team, we will receive your name, email address, the contents of a message or attachments that you may send to us, and other information you choose to provide. We may also collect information about your engagement with marketing, promotions or offers available through the Services (whether offered by us or any of our third-party service providers).

• Location Information: When you use the Service on your mobile device, we may receive your location in order to provide you with certain functionality. We may also collect the precise location of your device when the App is running in the foreground or background. Your location information is necessary to support the core services of the app such as tracking the route you took, your performance and sharing your location with others for social reasons. If you give us permission through your device settings to access your location information, we may also collect your location to identify promotions or service updates in your area.

• Device and usage information: We may collect analytics information such as your IP address, web browser type, mobile operating system version, phone carrier and manufacturer, app installations and website activity. To help us understand how you use Services and to help us improve it, we automatically receive information about your interactions with the Services, like the pages or other content you view, your actions when using the Service, and the dates and times of your visits and usage.

• Third party providers. We may also collect your personal information from a third party or other sources where you have authorised this or where it is consistent with the Privacy Act.

• Cookies and other tracking technology: Once you access our website or publish content through the Services, we and our third party suppliers that assist us in performing the Services, may collect information by using cookies and usage monitoring software such as pixel tags, web beacons, embedded web links, and similar technology. Information stored or collected regarding your usage of the Services helps us improve and offer the Services you need each time you visit.

• Refer to your device’s or browser's technical information for instructions on how to delete and disable cookies and other tracking or recording tools, if you wish to do so. Please note that if you delete or choose not to accept cookies from us, you may be missing out on certain features of the Services.

• Other information: We may collect any other information that you voluntarily provide to us.

You have no obligation to provide any information requested by us. However, if you choose to withhold any information requested, we or our suppliers involved in the provision of the Services may not be able to provide you with services or products that depend on the collection of that information.

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HOW DO WE USE YOUR PERSONAL INFORMATION?

We use your personal information only for purposes you have agreed to, for purposes directly related to our functions or activities or where we are authorised to under the Privacy Act.

We may use your personal information:

• to provide the Services to you, 

• To enable other users of the Service to connect with you and ;

• to help us offer, manage, improve and promote the Services and our operations;

• to notify you of services, products, offers, events or other benefits offered by us or our business partners that we think may be of interest to you;

• to conduct market research and to contact you with market, research or survey communications;

• to process transactions;

• to confirm any information you have provided to us;

• any other purposes you agree to.

We may de-identify and aggregate data collected through the Services and use it for any purpose. It is important to remember that such information does not identify you individually.

WHO DO WE GIVE YOUR PERSONAL INFORMATION TO?

We will only disclose your personal information where you have authorised such disclosure, where disclosure is connected to one of our functions or activities or where we are able to under the Privacy Act.

Examples where we may disclose your personal information are:

• to our service providers in order to provide the Services to you;

• to debt collection agencies;

• to law enforcement agencies for the purposes of prevention, detection, investigation and analysis of incidents or offences related to the Services;

• to meet our legal obligations;

• to protect users, ours or other rights, property or safety; and

• in order for us to sell any of our assets and parts of our business.

HOW DO WE STORE YOUR PERSONAL INFORMATION?

We will retain your personal information for no longer than is required for the purpose for which the information was initially collected and where necessary to comply with our legal obligations.

We primarily store and process your personal information using trusted third-party cloud service providers located in the United States, though data may be processed in other jurisdictions where our service providers maintain facilities.

By using the Services, you acknowledge that your personal information may be transferred to and stored on servers located outside of your country of residence.

We take reasonable steps to ensure that your personal information is protected against loss, unauthorised access, use, disclosure, alteration or destruction. We adopt policies and procedures to protect your personal information, and we review these regularly.

Communications over the internet, such as emails, are not secure, unless they have been encrypted. We may allow third parties to monitor our network for security and information assurance purposes.

PUBLIC SHARING & WEBVIEWS

The Service allows you (and your followers) to generate unique links to your activities. 

Please be aware that:

• Public Access: Anyone with access to a shared activity link can view your activity data—including your GPS track, performance metrics, and timing—without requiring a Trace account.

• Viral Sharing: Once a link is generated and shared (e.g., via SMS, email, or social media), it can be further distributed by others. Trace has no control over who views the data once a link has been shared outside of the App.

• Indexing: While we take steps to prevent search engines from indexing individual activity pages, any data shared via a public link should be considered "in the public realm."

• Revocation: You can typically disable link sharing via followers or delete the trace to break the link, but we cannot "un-see" or retrieve data that was already captured or screenshotted by third parties while the link was active.

USER RESPONSBILITY 

By using the sharing features of the Service including making a trace “Visible to Followers,” you acknowledge that you are intentionally moving your data from a private environment to a public one as your followers are able to view your data and also share a link publicly of your activity. You are responsible for the audience with whom you share links. We strongly recommend adjusting the visibility settings of your individual activities if you wish to keep your information private. 

PRIVACY AT A GLANCE

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MARKETING COMMUNICATIONS

We may contact you using the email address you provide to us to verify your account and for administration purposes, such as account management, customer service or system maintenance.

You consent to us sending you information connected with the above collection and use purposes via email or text message when you provide us with your email address and/or mobile phone number. We may also send you updates or push notifications related to the Services such as Service updates or to identify promotions, if you give us your permission. We may send you other information we think you may be interested in and which may market and promote the Services, or the products and services of our third party service providers. The messages you receive from us will have instructions for how you can remove yourself from our mailing list.

Email marketing will only be sent to your email address if you have given your consent. You may unsubscribe to any email marketing message at any time by following the unsubscribe instructions contained in the message.

ACCESS TO, CORRECTION, MODIFICATION AND DELETION OF YOUR INFORMATION

We take reasonable steps to ensure that the personal information we hold about you is accurate. You have the right at any stage to request us to provide you with access to your personal information. We will respond to any request by you to correct or access your personal information as soon as practicable following receipt of such request, but there are exceptions under the Privacy Act where we may not be able to do so. We will tell you if that is the case.

If you have any questions or requests for your information, please contact support@trace.zone

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