Privacy policy

Effective October 2, 2026

Noldor Tech, Inc. (“Traxle”, “we”, “us” or “our”) operates the website at traxle.io (the “Website”) and the Traxle application (the “Application”). This policy covers the personal information we decide how to use.

Customer data is different. Our customers are third-party administrators of vehicle protection products. Information our customers put into Traxle about their staff, dealers and vehicle owners is processed on the customer’s instructions. For that information, the customer is in control. If you have a request about it, please send it to the customer, and we will help them respond.

1. Information we collect

Information you give us

• Demo requests. Your name, work email, company and role, how many new contracts you issue a month, the system you use today, and any note you add.
• Accounts. Your name, email address and password, which our authentication provider stores only as a hash; and your memberships and roles in the customer workspaces you belong to.
• Messages. The content of messages you send us.

Information collected automatically

• Logs. Our hosting provider keeps server and security logs, which record your IP address, your browser, the pages you request and when you request them.
• Application activity. Sign-in and activity records in the Application, kept in the audit trail of the customer workspace they belong to.
• Bot protection. Browser and device signals, processed by Cloudflare Turnstile when you use the demo request form.

Cookies

The Website uses no analytics or advertising cookies. The Application uses strictly necessary cookies to keep you signed in.

2. How we use it

We use personal information to:

• reply to demo requests and follow up with you about Traxle;
• provide, secure and support accounts;
• send service emails, such as address confirmations, password resets and invitations;
• prevent fraud and abuse;
• comply with the law; and
• improve the website and the application, using aggregated information.

We do not sell personal information, share it for cross-context behavioral advertising, or, for information we control under this policy, make decisions about you that have legal or similarly significant effects by automated means.

3. Legal bases (EEA and UK)

If you are in the European Economic Area or the United Kingdom, we rely on these legal bases to process your personal information:

• legitimate interests, to reply to a request you made, and to operate and secure the website and the application;
• contract, to provide your account; and
• legal obligation, to comply with the law.

4. How we share it

We share personal information:

• with the subprocessors listed on our subprocessors page, under contract and only to provide the website and the application;
• with the customer whose workspace you belong to, whose administrators can see your activity there;
• with our professional advisers;
• in a merger, acquisition or sale of assets, in which case it remains subject to this policy; and
• where the law requires.

5. International transfers

Traxle is operated by a US company. Application data is hosted in Ireland, and some of our providers are in the United States. Our team may access data from outside the United States, including from South Africa.

Where the law requires, these transfers rely on safeguards such as the European Commission’s standard contractual clauses and the UK’s International Data Transfer Addendum to them.

6. How long we keep it

• Demo requests: up to 24 months after our last contact with you.
• Account information: while the account is active, and deleted within 90 days of the account’s closure, except copies in routine backups, which are deleted on their normal cycle, and anything the law requires us to keep.
• Logs: for a limited period, for security and troubleshooting.
• Information our customers put into Traxle: as the customer’s agreement with us provides.

7. Security

We maintain reasonable administrative, technical and physical safeguards designed to protect personal information. Our security page describes some of them. No method of transmission or storage is completely secure.

8. Your rights

US state residents

If you live in California or another US state with a comprehensive privacy law, then depending on your state, you have the right to:

• know about and access the personal information we hold about you;
• correct it;
• delete it;
• receive a portable copy of it;
• opt out of its sale, its sharing and targeted advertising, although we do none of these;
• not be discriminated against for exercising a right;
• use an authorized agent to make a request; and
• appeal our decision on your request, by replying to that decision.

We honor Global Privacy Control signals.

California disclosures

In the last 12 months:

• Categories collected: identifiers; professional or employment information; and internet or other electronic network activity information.
• Sensitive personal information: account login credentials, used only to provide and secure your account.
• Sources: you, your organization and your browser.
• Purposes: those described in section 2.
• Disclosures: we disclosed each category for business purposes to service providers.
• Sale and sharing: we did not sell or share any personal information.

EEA and UK residents

You have the right to access your personal information, to have it rectified or erased, to restrict or object to its processing, and to receive it in a portable form. You may also complain to your supervisory authority.

How to make a request

Email privacy@traxle.io. We will verify your identity and respond within the time the law sets: 45 days for US state requests, and one month under the GDPR and UK GDPR, extendable where the law allows. If your information is something a customer put into Traxle, please contact the customer concerned.

9. Children

The website and the application are for businesses and are not directed to children under 16. We do not knowingly collect their personal information.

10. Changes

When we update this policy, we give it a new effective date. We will tell you about a material change by email or in the Application.

11. Contact