Privacy notice

Who we are

This notice explains how TRACE SYSTEMS LTD (“Trace Systems”, “we”, “us”) handles personal data from this website, from health reports, and, in outline, in our products.

TRACE SYSTEMS LTD is registered in England and Wales, company number 17445050. Registered office: 66 Paul Street, London EC2A 4NA. We are registered with the Information Commissioner’s Office (ICO), registration number ZC259053.

Contact for anything in this notice: [email protected].

What this website collects

If you use the contact form or email us, we receive what you choose to send. That is usually your name, company, email address, details of your equipment, and your message.

We use it to reply to you and, if you ask, to prepare a quotation. We do not sell contact details, and we do not use them for marketing unless you ask us to.

Our hosting provider processes basic connection data, such as IP address, browser type and pages requested, to deliver and protect the site.

Cookies

This site does not use advertising or analytics cookies or trackers. Our hosting provider, Cloudflare, may set a security cookie (__cf_bm) to tell people from automated traffic. It is strictly necessary for the site to work securely, so it does not need your consent.

Who handles it for us

• Cloudflare hosts this website and hub.tracesystems.uk, stores health reports for us, routes email sent to our addresses, and sends contact form messages to our inbox.
• We read email in iCloud Mail and Google Mail.

Each provider handles the data to provide its service to us, under its own terms.

Data outside the UK

Health reports are stored in Cloudflare’s European Union storage region. The UK recognises the EU as giving adequate protection for personal data.

Otherwise, our providers may process personal data outside the UK, and we cannot confirm in which countries. That includes Cloudflare’s network, which may carry traffic, including health reports in transit, through other countries.

For Cloudflare, the safeguards in its data processing addendum apply: the UK extension to the EU-US Data Privacy Framework, and the UK addendum to the EU standard contractual clauses where a transfer is restricted. We have not yet confirmed the transfer safeguards used by our current mailbox providers.

Health reports

Health reports are off unless the customer turns them on, through an IT user or the Owner in the software. When on, the installation sends a signed report to hub.tracesystems.uk every 10 minutes. The hub never connects into the installation.

A health report contains:

• an installation ID, software and content package versions, and how long the installation has been running;
• licence status, expiry date, seats and seats in use, and a fingerprint of the licence key (never the key itself);
• whether the AI is available, which AI model is in use, and, for the last 24 hours, how many answers it gave, their average time and how many parts searches were run;
• free disk space and database size;
• backup counts and times, and whether the off-device copy worked (never where it is stored);
• update status.

It never contains documents, parts data, fault reports, chats, names, email addresses, file names or paths. Because the report travels over the internet, we receive the installation’s IP address when it arrives. We do not store the IP address with the report. Our hub logs may record it for up to 7 days.

We are the controller of health report data, and Cloudflare processes it for us. Our lawful basis is our legitimate interest in monitoring installations for customers who have turned reporting on, so we can spot problems and support them.

We keep health reports for 90 days. We keep the latest report for each installation until that installation is removed from the hub.

How long we keep it

• Enquiries that do not lead to an order: deleted 12 months after our last contact with you. You can ask us to delete one sooner.
• Enquiries that lead to an order: kept with our contract records for 6 years after the contract ends.
• Invoices and payment records: kept for 6 years after the end of the financial year they relate to.
• Health reports: as set out above.
• Hub logs: up to 7 days, in Cloudflare’s logging service.
• Other hosting and security logs: kept by Cloudflare under its own retention policy. We do not keep our own copy.

Our products

Workshop Assistant, including Parts Finder, Parts Catalogue Look-Up, Interactive 3D Parts Finder and Diagnostic Assistant, runs on the customer’s own server. We do not provide a Trace Systems hosted service.

The customer controls the data on its installation, including staff names, accounts and any personal data in fault reports. Diagnostic Assistant draws only on that customer’s own documents and fault reports. They are never pooled with other customers’ data, and no model is trained on them.

We only see customer data that the customer sends us, or lets us access, for loading, support or a 3D build. In that work we act as the customer’s processor, under the contract.

The details are in each customer’s contract, which takes priority over this notice.

Lawful basis

• Website enquiries: our legitimate interest in replying to business contact, or steps you ask us to take before a contract.
• Hosting and security logs: our legitimate interest in keeping the site and hub working and secure.
• Health reports: our legitimate interest in monitoring installations for customers who have turned reporting on.
• Contract and payment records: performing our contract and meeting our legal obligations.
• Customer data in our products: we process it on the customer’s instructions under the contract.

Your rights

Under UK data protection law you can ask to see, correct or delete your personal data, to restrict or object to how we use it, and, where we process it for a contract, to receive it in a portable format. Email [email protected]. For data on a customer’s installation, contact that customer, as they control it.

You can complain to the Information Commissioner’s Office at ico.org.uk. We would like the chance to put things right first.

Changes

We will update this notice when the site or our practices change, and change the date at the top.