Privacy Policy

Last Updated: March 13, 2026

RefriTrak ("we," "us," or "our") operates the RefriTrak platform (the "Service"). This Privacy Policy describes our practices regarding the collection, use, disclosure, and retention of your information. By using the Service, you agree to the collection and use of information in accordance with this policy.

1. Information Collection and Use

We collect several types of information for various purposes to provide and improve the Service.

1.1 Personal Data

While using the Service, we may ask you to provide certain personally identifiable information ("Personal Data"), including but not limited to:

  • Email address
  • First name and last name
  • Phone number
  • Business name, address, state, province, ZIP/postal code, and city

1.2 Usage Data

We automatically collect information about how the Service is accessed and used ("Usage Data"), including your IP address, browser type and version, the pages you visit, the time and date of your visit, time spent on pages, and other diagnostic data.

1.3 Refrigerant and Compliance Data

As part of the Service, you may upload equipment records, refrigerant logs, service histories, and related compliance data ("User Data"). You retain ownership of your User Data. RefriTrak processes this data solely to provide the Service and as described in Section 7 (Data Aggregation and Anonymization).

2. Tracking & Cookies Data

We use cookies and similar tracking technologies to maintain session state, remember preferences, and analyze usage. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, certain features of the Service may not function properly without cookies.

Types of cookies we use:

  • Session Cookies: Required to operate the Service.
  • Preference Cookies: Remember your settings and preferences.
  • Analytics Cookies: Help us understand how users interact with the Service (e.g., via Vercel Analytics).

3. How We Use Your Information

We use the information we collect to:

  • Provide, operate, maintain, and improve the Service.
  • Process your account registration and manage your subscription.
  • Send administrative communications, security alerts, and support messages.
  • Respond to your inquiries and support requests.
  • Detect, prevent, and investigate fraud, abuse, or security incidents.
  • Comply with applicable legal obligations.
  • Create Anonymized Data as described in Section 7.

We do not sell your Personal Data to third parties for their own marketing purposes.

4. Disclosure of Data

RefriTrak may disclose your Personal Data only in the following circumstances:

  • Legal Obligations: To comply with applicable law, regulation, legal process, or enforceable governmental request.
  • Protection of Rights: To protect and defend the rights or property of RefriTrak, including enforcement of our Terms of Service.
  • Safety: To prevent or investigate possible wrongdoing or threats to public safety in connection with the Service.
  • Business Transfers: In connection with a merger, acquisition, reorganization, or sale of assets, your information may be transferred to the acquiring entity. We will notify you before your Personal Data becomes subject to a different privacy policy.
  • With Your Consent: For any other purpose with your explicit consent.

5. Third-Party Service Providers

We employ third-party companies and individuals ("Service Providers") to facilitate the Service on our behalf. Current Service Providers include:

  • Vercel — Application hosting and edge network
  • MongoDB Atlas — Database storage
  • Amazon Web Services (AWS) — File and object storage
  • Resend — Transactional email delivery

These Service Providers have access to your Personal Data only to perform their specific tasks on our behalf and are contractually obligated to protect your data and not to disclose or use it for any other purpose.

6. Data Retention

We retain your Personal Data for as long as your account is active or as needed to provide the Service. Specifically:

  • Account Data: Retained for the life of your account plus 90 days following account deletion or termination, after which it is permanently deleted or anonymized.
  • User Data (Refrigerant Records): Retained for the life of your account. You may request earlier deletion by contacting us.
  • Usage and Log Data: Retained for up to 12 months for security, debugging, and operational purposes.
  • Legal Hold: Notwithstanding the above, we may retain data for longer periods if required by law, regulation, or ongoing legal proceedings.

To request deletion of your account and associated data, contact us at legal@refritrak.com.

7. Data Aggregation and Anonymization

RefriTrak reserves the right to create, use, and commercialize Aggregated and Anonymized Data derived from User Data. Anonymized Data has been modified or combined such that it cannot reasonably be used to identify any individual user or specific organization.

  • Purpose: We may use Anonymized Data for industry benchmarking, environmental trend analysis, product optimization, and research.
  • Non-Personal: Because Anonymized Data does not identify you, it is not considered Personal Data under this policy or under applicable privacy laws including the CCPA.
  • Commercial Use: RefriTrak may share, license, or sell Anonymized Data sets to third parties (such as researchers, industry analysts, or government agencies) at its sole discretion.
  • CCPA Carve-Out: Your CCPA right to opt out of the "sale" of Personal Data (Section 9) does not apply to Anonymized Data, as Anonymized Data is not Personal Data. This is consistent with Cal. Civ. Code § 1798.140(o).

8. Data Security

We implement industry-standard technical and organizational measures to protect your Personal Data, including TLS 1.2+ encryption in transit, AES-256 encryption at rest, role-based access controls, and regular security assessments. However, no method of internet transmission or electronic storage is 100% secure. We cannot guarantee absolute security.

Data Breach Notification: In the event of a data breach that affects your Personal Data, RefriTrak will notify you and any applicable regulatory authorities as required by applicable law (including California's data breach notification law, Cal. Civ. Code § 1798.82). We will provide notice without unreasonable delay, and in no event later than 72 hours after we become aware of a breach that triggers notification obligations, where practicable.

9. California Privacy Rights (CCPA/CPRA)

If you are a California resident, you have the following rights under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA):

  • The Right to Know: You may request disclosure of the categories and specific pieces of Personal Data we have collected about you, and the purposes for which we use it.
  • The Right to Delete: You may request deletion of Personal Data we have collected, subject to certain legal exceptions.
  • The Right to Correct: You may request correction of inaccurate Personal Data we maintain about you.
  • The Right to Opt-Out of Sale/Sharing: RefriTrak does not sell Personal Data in the traditional sense. To the extent RefriTrak engages in sharing of Personal Data for cross-contextual behavioral advertising, you have the right to opt out. Note: this right does not apply to Anonymized Data (see Section 7).
  • The Right to Limit Use of Sensitive Personal Information: You may direct us to limit the use of your sensitive Personal Data to that which is necessary to perform the Service.
  • The Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA rights.

To exercise these rights, contact us at legal@refritrak.com. We will respond to verifiable requests within 45 days, as required by law.

10. Children's Privacy

The Service is not directed to, and we do not knowingly collect Personal Data from, anyone under the age of 18. If we become aware that a person under 18 has provided us with Personal Data, we will delete that information promptly. If you believe a minor has provided us with Personal Data, please contact us at legal@refritrak.com.

11. Third-Party Links

The Service may contain links to third-party websites or services. We are not responsible for the privacy practices or content of those sites. We encourage you to review the privacy policies of any third-party sites you visit.

12. Changes to This Policy

We may update this Privacy Policy from time to time. For material changes, we will notify you by email or by posting a prominent notice within the Service at least 30 days before the changes take effect. Your continued use of the Service after the effective date constitutes your acceptance of the updated policy.

13. Contact Us

For any questions, concerns, or requests related to this Privacy Policy or your Personal Data, please contact us at:

RefriTrak 611 Gateway Blvd Suite 120 South San Francisco, CA 94080 legal@refritrak.com

Privacy Policy — RefriTrak