1Who we are
Trace Marketing Ltd, registered in England and Wales, operates usetrace.io and the Trace app. We are the data controller for your account and a processor for the journey data collected on your sites.
2What Trace collects
On your sites Trace records behaviour, not people: pages viewed, the channel a visit arrived from, and whether a conversion happened. We do not collect names, emails or device fingerprints from your visitors, and we set no third-party cookies. On usetrace.io, if you allow Analytics in the cookie banner, Google Analytics measures your visit so we can see how the site is used. Nothing is sent to Google before you allow it. On usetrace.io, if you allow Marketing cookies, the Google Ads tag and the Meta pixel tell Google and Meta about your visit and whether you signed up after one of their ads, so we can measure our advertising and show our ads again to people who have visited. Nothing is sent to them before you allow it, and refusing Marketing cookies stops it. If you allowed Marketing cookies and the Google Ads tag missed a sign-up that followed a click on one of our Google ads, Trace sends Google Ads that sign-up from our server: the Google click id, the time and your consent status, never your name, email address or IP address. If you allowed Marketing cookies and the Meta pixel missed a sign-up within 7 days of a click on one of our Meta ads, Trace sends Meta that sign-up from our server: the Meta click id and the time, never your name, email address or IP address. For visitors in the EU, we and Meta Platforms Ireland are joint controllers for collecting and sending this data, under Meta's Business Tools Terms; Meta is responsible for what it does with it after that.
If you ask for a free attribution audit, we keep the work email address you give us, the website address you asked about, and the report we produce for it. We read only that site’s public pages, as any visitor could, and we keep nothing about its visitors. We use your address to send you the report and, twice, to ask whether you received it and whether it was useful. Every one of those emails has a link that stops them.
3Consent
On UK and EU sites Trace records a visitor’s journey only after they consent through your consent banner, unless you choose to count visitors from a place where the banner is hidden as accepted. Where consent is declined, nothing is stored and the gap is shown in Coverage. On sites elsewhere Trace records visitors unless they refuse, except where your banner asks first, and you are responsible for telling them.
4Sending conversions to ad platforms
If you switch on sending to Google Ads for a site, Trace tells Google about a conversion on that site that followed a click on your Google ad, when your own Google tag did not record it. We do this only on your instruction and as your processor. You are the controller for what is shared with Google, which receives it under its own terms with you. We send the Google click id from the ad link, the time of the conversion, its value and currency, your order number or another conversion reference so that Google does not count it twice, and the visitor’s consent status. We never send a name, email address, phone number, postal address, IP address or any hashed identifier, and we send nothing more than 90 days after the click. Where a site must have consent, we send only for a visitor who allowed Marketing and still allows it when we send. On any site we send nothing for a visitor who refused Marketing or whose browser sends Global Privacy Control. Sending is off until you switch it on, and stops as soon as you switch it off. We keep a record of what we have sent, with no visitor identifier, for 90 days.
5Google user data
How Trace uses Google user data: if you connect Google Search Console, Google Analytics or Google Ads to a site in Trace, Trace reads only what it shows you for that site: Search Console clicks and search queries by page, Google Analytics purchase revenue by day, and Google Ads campaigns, ads, clicks and costs. Trace uses this data only to show it to you and your team in Trace, beside that site’s journeys, so you can see which searches and ads bring results, and, combined with other customers’ data so that no customer can be identified, to measure how well Trace works, as section 7 describes. If you switch on sending to Google Ads, Trace also sends conversions to your Google Ads account, as section 4 describes. Trace never sells Google user data, never uses it to target or show ads, never shares it with other customers and never uses it to train AI models. The only use beyond your own account is the combined figures in section 7, which never name a customer. How Trace protects Google user data: the access Google gives Trace is stored encrypted with AES-256-GCM, all data travels over encrypted connections (HTTPS), and Trace’s database is encrypted at rest. Only people with access to that site in Trace can see the data. Trace staff open a customer’s data only to help that customer or to check the figures section 7 describes, and each such view is recorded in an audit log. Disconnecting in Integrations deletes the stored access at once, so Trace reads nothing more; data already read is deleted when the site or the account is deleted. Trace’s use and transfer of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements.
6Services that process data for Trace
The GDPR page lists every service that processes data for Trace, including these two for the Trace app. PostHog (PostHog Inc., EU Cloud, Frankfurt): error tracking and session recording in the Trace app, to find and fix problems. Slack (Slack Technologies): help conversations you start from the Help panel, so our team can answer them. Kept until your account is deleted. If you use the Trace app from Shopify, Shopify tells Trace which Trace plan your shop has chosen, its status and its dates, so we can apply it. Shopify takes the payment; Trace never sees your card.
7Retention
Identifiable data about the visitors to a site is deleted once it is older than the history window of the site’s plan: 90 days on Starter, 1 year on Plus, 2 years on Pro and 3 years on Enterprise. The site owner can choose a shorter period for their site in its settings, down to 90 days. Before deletion, anonymised totals are kept as aggregated statistics that identify no one, except for visitors whose browser sends Global Privacy Control, who are never included. Trace also uses the consented journeys of many customers’ sites to produce anonymous benchmarks, shown to customers as typical ranges for a sector, such as how many visits it usually takes to convert. A sector benchmark is built from at least 10 sites, never identifies a site, a customer or a visitor, never includes anyone whose browser sends Global Privacy Control or who did not consent, and is never sold or shared outside Trace. Trace also works out figures about what it measures across customers’ sites, for its own marketing. For this it reads the journeys and conversions on those sites, and the advertising and Shopify order data connected to them, and keeps counts and totals for each site, including conversion value and ad spend, with no visitor, journey or click id. A figure Trace publishes is the median across at least 10 sites, with no site over 25% of the sample and Trace’s own site left out. It never names a customer or a site and is not about any visitor. Only the journeys of visitors who agreed to analytics are read for it, including journeys recorded before this section said so. Trace does not try to identify anyone from these figures and does not sell them. A customer can ask for their sites to be left out by writing to privacy@usetrace.io. The counts for each site are kept for up to six years and are deleted with the site. A figure fixed for marketing, and the counts and totals behind it under a label that does not name the site, are kept as evidence for six years after Trace stops using the figure, including after the site is deleted. Session recordings of the Trace app are kept for 30 days. Help conversations you start from the Help panel are kept until your account is deleted. Account data is deleted 30 days after you close your account.
A free audit, with the address that asked for it and the report itself, is deleted 180 days after the request. The private link stops working at the same time.
8Trace Earn, our partner programme
Trace Earn is the partner programme run by Trace Marketing Ltd. If you apply to be a partner, we keep your name, your email address, where you will promote Trace, your website, how you heard of the programme and, once you choose how to be paid, your payout details. We use them to decide on your application, to check that you are not referring yourself, and to run your partner account and pay you. If you claim a reward for the views on a post, we keep the number of views you give and the screenshot of the platform’s analytics with the claim. Only Trace staff deciding or reviewing the claim see the screenshot, and we delete the claim and the screenshot with your account. If you create an invite, we keep the private note you give it, which only you see, and delete it with the invite or your account. You send invites yourself, from your own email: we never ask who an invite goes to and never email them. To pay you we share the amount, and the payout details for the method you chose, with that provider, and nothing about the people you refer. Bank payouts and Trace credit go through Stripe Connect: Stripe takes your identity and bank details on its own pages, and we keep only the id of your Stripe account. For Wise payouts your bank details go straight to Wise, and we keep only Wise’s recipient id. Your own tax on what you earn is yours to pay. We keep payout and earning records for six years for HMRC, including after your account is deleted. Everything else we hold about you as a partner is deleted with your account.
9People referred by a partner
If you sign up to Trace through a partner, we record that you were referred by that partner. The partner sees only the stage you have reached (signed up, awaiting set-up, tracking live, customer), never your name or your figures. If you ask for a free audit through a partner’s link, we keep that partner’s code with the request, and if you sign up with the same email address within 180 days of the request, we match the two inside Trace and record you as referred by that partner.
10Your rights
You can access, correct, export or erase your account data at any time. Erasure requests for your visitors can be made through the DSAR API or by email.
11Contact
Our data protection officer can be reached at privacy@usetrace.io. You may also complain to the ICO at ico.org.uk.
Write to privacy@usetrace.io. We reply within one working day.