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ComTrack Privacy Policy

Last Updated: 05/21/2026

This Privacy Policy describes how ComTrack Inc. (“ComTrack,” “we,” “us,” or “our”) collects, uses, discloses, protects, and retains information when you access or use our websites, software platform, applications, portals, integrations, retrieval services, support services, and related offerings (collectively, the “Services”).

This Privacy Policy applies to information we collect through the Services, including information provided by customers, authorized users, website visitors, and third-party systems connected to or accessed through the Services.

By using the Services, you agree to the practices described in this Privacy Policy. If you do not agree with this Privacy Policy, you should not use the Services.

1. About ComTrack

ComTrack provides software tools for insurance agencies, agents, organizations, and related businesses to manage commission statements, carrier data, compensation workflows, agent and upline portals, deposit matching, reporting, retrieval services, and related business operations.

ComTrack is an independent software platform. Unless expressly stated in writing, ComTrack is not affiliated with, endorsed by, sponsored by, or approved by any insurance carrier, FMO, IMO, NMO, government agency, Medicare program, payroll provider, CRM provider, financial institution, or other third-party platform referenced in or compatible with the Services.

2. Information We Collect

We collect information in several ways, including directly from you, from your authorized users, from uploaded files, from third-party integrations, from carrier portals or other third-party systems you authorize us to access, and automatically when you use the Services.

2.1 Account and Contact Information

We may collect information such as:

  • name;

  • business name;

  • email address;

  • phone number;

  • mailing address;

  • job title or role;

  • login credentials;

  • account settings;

  • user permissions;

  • billing contact information;

  • support and communication preferences.

2.2 Business and Agency Information

We may collect business-related information, including:

  • agency or organization name;

  • carrier relationships;

  • agent, upline, downline, and team hierarchy information;

  • writing numbers, producer numbers, national producer numbers, or other carrier identifiers;

  • commission structures;

  • compensation plans;

  • payroll-related configuration;

  • user roles and access permissions;

  • account setup and onboarding information.

2.3 Commission, Statement, and Carrier Data

The Services may process commission-related and carrier-related data, including:

  • commission statements;

  • carrier statement files;

  • policy numbers or application identifiers;

  • agent names and identifiers;

  • customer or policyholder names where included in carrier statements;

  • product names;

  • plan names;

  • premium amounts;

  • commission amounts;

  • chargebacks;

  • renewals;

  • advances;

  • overrides;

  • payment dates;

  • statement dates;

  • carrier portal reports;

  • book-of-business reports;

  • compensation records;

  • related imported, retrieved, uploaded, normalized, or calculated data.

2.4 Credentials and Retrieval Information

If you use features that allow ComTrack to retrieve data from third-party systems, we may collect and process information needed to access those systems on your behalf, including:

  • portal usernames;

  • passwords;

  • authentication tokens;

  • API keys;

  • MFA-related information or routing details;

  • security questions or answers, if provided;

  • carrier portal access instructions;

  • login metadata;

  • retrieval history;

  • retrieved files and reports;

  • error logs and troubleshooting records.

ComTrack uses this information to provide retrieval services at your direction and authorization.

2.5 Uploaded Files and User-Provided Content

You or your authorized users may upload, submit, or transmit files and content to the Services, including:

  • spreadsheets;

  • PDFs;

  • commission statements;

  • carrier reports;

  • payroll files;

  • agent lists;

  • hierarchy files;

  • banking or deposit records;

  • notes, comments, messages, or support materials;

  • other business records.

2.6 Portal, Chat, and Communication Data

If the Services include portals, messaging, chats, comments, notifications, or collaboration features, we may collect:

  • messages;

  • comments;

  • attachments;

  • notification preferences;

  • read receipts or delivery status;

  • sender and recipient information;

  • timestamps;

  • related metadata.

2.7 Billing and Payment Information

We may collect billing-related information, including:

  • billing name;

  • billing email;

  • billing address;

  • subscription plan;

  • invoice history;

  • payment status;

  • usage-based billing information;

  • transaction metadata.

Payment card, ACH, or bank payment details may be processed by our third-party payment processors. ComTrack does not necessarily store full payment card numbers or complete bank account credentials unless expressly stated in connection with a specific feature.

2.8 Bank, Deposit, and Accounting Data

If you use deposit matching, accounting, banking, payment, or transaction-related features, we may collect and process:

  • bank deposit descriptions;

  • deposit amounts;

  • transaction dates;

  • bank account metadata;

  • accounting classifications;

  • expense categories;

  • matched carrier or entity information;

  • related imported or connected financial data.

2.9 Integration Data

If you connect the Services to third-party platforms, we may collect and process information from those integrations, including data from:

  • Google services;

  • CRM platforms;

  • payroll providers;

  • accounting systems;

  • communication platforms;

  • file storage providers;

  • payment processors;

  • banking or financial data providers;

  • workflow automation tools;

  • other connected systems.

The specific data collected depends on the integration, your settings, and the permissions you grant.

2.10 Website, Device, and Usage Information

When you visit our website or use the Services, we may automatically collect technical and usage information, including:

  • IP address;

  • device type;

  • browser type;

  • operating system;

  • referring URLs;

  • pages viewed;

  • features used;

  • clicks and interactions;

  • session duration;

  • error logs;

  • performance data;

  • approximate location derived from IP address;

  • cookies and similar tracking technologies.

2.11 Support and Communications

If you contact us for support, sales, onboarding, or other communications, we may collect:

  • the content of your messages;

  • call or meeting notes;

  • screenshots or recordings, where applicable and permitted;

  • support tickets;

  • troubleshooting details;

  • contact history;

  • feedback and feature requests.

3. How We Use Information

We use information to operate, provide, secure, improve, and support the Services.

This includes using information to:

  • create and manage accounts;

  • authenticate users;

  • provide access to the Services;

  • process commission statements and carrier data;

  • retrieve data from authorized third-party systems;

  • normalize, classify, calculate, display, and export data;

  • configure agent, agency, upline, and team portals;

  • manage user permissions;

  • provide onboarding, support, and troubleshooting;

  • process billing and payments;

  • send administrative notices;

  • send product updates or service-related communications;

  • send SMS messages where you have opted in;

  • monitor service performance;

  • detect and prevent fraud, abuse, and security incidents;

  • debug errors and improve reliability;

  • develop new features;

  • comply with legal, regulatory, contractual, and security obligations;

  • enforce our Terms of Service and other agreements;

  • protect the rights, safety, and security of ComTrack, our customers, users, and third parties.

We may also use aggregated, anonymized, or de-identified information for analytics, benchmarking, product improvement, research, and business purposes, provided such information does not identify you or your customers.

4. Retrieval Services and Third-Party Portal Access

ComTrack may provide features that allow you to authorize ComTrack to access third-party carrier portals, agency systems, CRM systems, payroll systems, banking systems, file storage platforms, or other external systems on your behalf.

When you use these features, you authorize ComTrack to access, retrieve, download, process, and store data from those third-party systems at your direction.

We use retrieved information to provide the Services, including commission tracking, statement processing, reporting, data normalization, deposit matching, payroll-related workflows, and related functionality.

You are responsible for ensuring that:

  • you have authority to provide access credentials or permissions;

  • your use of retrieval services complies with applicable laws, agreements, carrier rules, employer policies, and third-party terms;

  • you have obtained all required consents and authorizations;

  • credentials and access permissions remain accurate and authorized.

ComTrack does not control third-party systems and is not responsible for their privacy practices, security practices, availability, terms, data accuracy, or changes.

5. How We Share Information

We do not sell personal information.

We may share information in the following circumstances.

5.1 With Service Providers and Vendors

We may share information with vendors and service providers that help us operate the Services, including providers of:

  • cloud hosting;

  • database infrastructure;

  • data storage;

  • authentication;

  • security monitoring;

  • payment processing;

  • customer support;

  • email and SMS delivery;

  • analytics;

  • logging and error monitoring;

  • file processing;

  • workflow automation;

  • professional services;

  • legal, accounting, and compliance services.

These vendors are authorized to use information only as needed to provide services to ComTrack, subject to contractual obligations where appropriate.

5.2 With Authorized Users and Account Administrators

Information may be visible to account owners, administrators, team members, agents, uplines, downlines, or other authorized users based on permissions, sharing settings, portal settings, and account configuration.

You are responsible for configuring permissions and determining who may access information in your account.

5.3 With Third-Party Integrations You Enable

If you connect or enable a third-party integration, we may share information with that third party as necessary to provide the integration.

For example, if you connect a CRM, payroll provider, accounting system, file storage account, communication platform, or payment provider, information may be transmitted to or received from that platform according to your settings and permissions.

Third-party integrations are governed by their own terms and privacy policies.

5.4 With Payment Processors

We may share billing and transaction information with payment processors to process payments, manage subscriptions, prevent fraud, resolve disputes, and comply with payment network rules.

5.5 For Legal, Security, and Compliance Reasons

We may disclose information if we believe disclosure is reasonably necessary to:

  • comply with law, regulation, subpoena, court order, or governmental request;

  • enforce our Terms of Service or other agreements;

  • protect the rights, property, or safety of ComTrack, customers, users, or third parties;

  • detect, investigate, or prevent fraud, abuse, security incidents, or unlawful activity;

  • respond to carrier, vendor, or third-party claims or disputes;

  • protect the integrity and security of the Services.

5.6 In Business Transactions

We may disclose or transfer information in connection with a merger, acquisition, financing, reorganization, bankruptcy, sale of assets, change of control, or similar business transaction.

5.7 With Your Consent or Direction

We may share information with third parties when you consent to or direct the sharing.

6. Protected Health Information and HIPAA

Some data processed through the Services may include health-related, insurance-related, or consumer information. However, not all such information is Protected Health Information (“PHI”) under HIPAA.

ComTrack is not acting as a HIPAA Business Associate unless ComTrack and the applicable customer have entered into a separately executed Business Associate Agreement (“BAA”).

Where ComTrack processes PHI on behalf of a covered entity or business associate under a signed BAA, ComTrack will handle such PHI in accordance with that BAA and applicable HIPAA requirements.

Unless a BAA is in place, you should not upload, transmit, store, or process PHI through the Services in a manner that would require ComTrack to act as a Business Associate.

You are responsible for determining whether information submitted to the Services is subject to HIPAA or other privacy laws and for obtaining all required permissions, authorizations, and consents.

If there is a conflict between this Privacy Policy and a signed BAA regarding PHI, the BAA controls with respect to that PHI.

7. SMS and Mobile Communications

If you provide your phone number and opt in to receive SMS messages from ComTrack, we may send you text messages related to account setup, product updates, service notifications, support, onboarding, reminders, or other communications related to the Services.

Message frequency may vary. Message and data rates may apply.

You may opt out of SMS messages by replying STOP. You may request help by replying HELP or contacting ComTrack support.

We do not sell or share SMS opt-in data or consent information with third parties for their independent marketing purposes.

SMS delivery may be handled by third-party communication providers that process messages on our behalf.

8. Google User Data and Google Workspace APIs

If you connect Google services to ComTrack, we may access, use, store, or transmit Google user data only as necessary to provide the features you authorize.

Depending on the permissions you grant and the features you use, this may include information from Google Workspace, Gmail, Google Drive, Google Sheets, Google Calendar, or related Google services.

ComTrack uses Google user data only to provide or improve user-facing features that you request or enable, such as importing files, syncing data, reading authorized documents, sending or receiving authorized communications, or supporting connected workflows.

ComTrack does not use Google Workspace API data to train generalized artificial intelligence or machine learning models.

ComTrack does not sell Google user data.

ComTrack does not share Google user data with third parties except as necessary to provide the Services, comply with law, protect security, or as otherwise directed by you.

ComTrack’s use and transfer of information received from Google APIs will comply with the Google API Services User Data Policy, including applicable Limited Use requirements.

You may revoke Google access through your Google account permissions or through applicable ComTrack account settings, where available.

9. Cookies and Tracking Technologies

We may use cookies, pixels, local storage, analytics tools, and similar technologies to:

  • keep you logged in;

  • remember preferences;

  • understand website traffic;

  • measure marketing performance;

  • improve the Services;

  • detect fraud and security issues;

  • analyze product usage.

You may be able to control cookies through your browser settings. Disabling cookies may affect functionality of the Services.

10. Analytics and Product Improvement

We may use analytics tools to understand how customers and users interact with the Services.

Analytics data may include pages viewed, features used, session activity, device information, browser information, approximate location, error logs, and performance information.

We may use aggregated, anonymized, or de-identified data to improve the Services, develop features, monitor trends, and understand customer needs.

11. Artificial Intelligence and Automated Processing

ComTrack may use automation, parsing, classification, rules-based processing, machine learning, or artificial intelligence technologies to provide features such as data extraction, document processing, statement normalization, matching, support, analytics, or workflow automation.

Unless expressly stated otherwise in writing, ComTrack does not use Customer Data to train generalized AI models for use outside ComTrack’s Services.

Where ComTrack uses third-party AI or automation providers, ComTrack takes reasonable steps to limit their use of Customer Data to providing services to ComTrack, subject to applicable agreements and settings.

Automated outputs may be incomplete or inaccurate. You are responsible for reviewing and validating outputs before relying on them.

12. Data Retention

We retain information for as long as reasonably necessary to provide the Services, operate our business, comply with legal obligations, resolve disputes, maintain security, enforce agreements, and support legitimate business purposes.

Retention periods may vary depending on the type of information, customer settings, account status, legal requirements, backup schedules, and operational needs.

After an account is canceled or terminated, ComTrack may retain, delete, archive, anonymize, or de-identify information according to its ordinary business practices and legal obligations.

You are responsible for exporting information you need before canceling your account or ending your subscription.

13. Data Security

ComTrack uses commercially reasonable administrative, technical, and organizational safeguards designed to protect information from unauthorized access, loss, misuse, alteration, or disclosure.

These safeguards may include, as appropriate:

  • encryption in transit;

  • encryption at rest where supported;

  • access controls;

  • authentication controls;

  • role-based permissions;

  • monitoring and logging;

  • vendor review processes;

  • secure cloud infrastructure;

  • internal policies and procedures.

No security system is perfect. We cannot guarantee that information will never be accessed, disclosed, altered, lost, or destroyed.

You are responsible for maintaining the security of your own devices, networks, credentials, account access, user permissions, and connected third-party systems.

14. International Users

ComTrack is operated from the United States. If you access the Services from outside the United States, you understand that information may be processed, stored, and transferred in the United States or other jurisdictions where we or our service providers operate.

Privacy laws in those jurisdictions may differ from the laws where you are located.

15. Your Choices and Rights

Depending on your location and applicable law, you may have rights regarding your personal information, including the right to:

  • access personal information;

  • correct inaccurate personal information;

  • delete personal information;

  • object to or restrict certain processing;

  • request a copy of personal information;

  • opt out of certain communications;

  • withdraw consent where processing is based on consent.

To make a request, contact us using the information below.

We may need to verify your identity before fulfilling a request. Some information may be exempt from deletion or access requests where retention is required or permitted by law, contract, security needs, dispute resolution, or legitimate business purposes.

If you are an end user of a ComTrack customer, such as an agent, employee, contractor, upline, downline, or team member, we may direct your request to the customer that controls your account or data.

16. Communications Preferences

You may opt out of marketing emails by using the unsubscribe link in the email or contacting us.

Even if you opt out of marketing communications, we may still send you administrative, transactional, security, billing, legal, or service-related communications.

You may opt out of SMS messages by replying STOP.

17. Children’s Privacy

The Services are intended for business users and are not directed to children under 13.

We do not knowingly collect personal information from children under 13. If we learn that we have collected personal information from a child under 13, we will take reasonable steps to delete it.

18. State Privacy Notices

Depending on your state of residence, including California or other states with comprehensive privacy laws, you may have additional privacy rights.

ComTrack does not sell personal information.

ComTrack does not knowingly sell or share personal information of consumers under 16 years of age.

ComTrack may disclose personal information to service providers, vendors, integrations, and other third parties as described in this Privacy Policy.

To exercise applicable state privacy rights, contact us using the information below.

19. Changes to This Privacy Policy

We may update this Privacy Policy from time to time.

When we make material changes, we may notify you by posting the updated Privacy Policy, sending an email, displaying an in-app notice, or using another reasonable method.

The updated Privacy Policy will be effective when posted or as otherwise stated in the notice.

Your continued use of the Services after the updated Privacy Policy becomes effective means you acknowledge the updated policy.

20. Contact Us

If you have questions about this Privacy Policy or wish to make a privacy request, contact us at:

ComTrack Inc.

2200 Aureum Dr, Suite 25319

Franklin, TN 37067


legal@comtrack.io