Privacy Policy

This Privacy Policy applies to the Website and sets out how The Citizens Foundation (“TCF”) collects, uses, stores and otherwise processes Personal Data through this Website. 

  1. Applicability of Data Protection Laws 

The Website collects certain Personal Data from its Users. Accordingly, this Privacy Policy sets out how such Personal Data is collected and processed by TCF through the Website. Depending on the User’s location and the nature of the processing activities, additional data protection laws and requirements may apply to the processing of Personal Data, including, where applicable, the GDPR.  

The Users may contact TCF to obtain further information regarding the data protection standards applicable to them. 

  1. Owner/ Data Controller 

TCF is the Data Controller / Owner in respect of the processing of Personal Data through the Website.  

Address: Plot No. 20, Sector 14, Near Brookes Chowrangi, Korangi Industrial Area, Karachi 74900, Pakistan 

Contact email: info@tcf.org.pk 

  1. Types of Data collected 

Among the types of Personal Data that the Website collects, either directly from Users or through third parties are email addresses, Trackers, Usage Data, browsing history, clicks, page views, number of Users, session statistics, answers to questions, keypress events, motion sensor events, mouse movements, scroll position, touch events, device information, phone number. 

Further details regarding the categories of Personal Data collected are provided in the relevant sections of this Privacy Policy and, where applicable, in explanation texts displayed prior to the time of Data collection.  
 

Personal Data may be provided directly by Users, or, in case of Usage Data, collected automatically through their use of the Website. 
 

Unless specified otherwise, the provision of Personal Data requested by the Website is mandatory, and failure to provide such Personal Data may prevent the Website from providing the relevant Services. Where the Website specifically states that the provision of certain Personal Data is not mandatory, Users may choose not to provide such Personal Data without affecting the availability or the functioning of the relevant Services. Users who are uncertain about which Personal Data is mandatory may contact TCF.  
 

Any use of Cookies or other tracking tools by the Website or by the owners of third-party services used by the Website are for the purpose of providing the Services required by the User. in addition to any other purposes described in this Privacy Policy and / or the Cookie Policy. 

Users who provide Personal Data relating to a third party through the Website are responsible for ensuring that they are authorized to provide such Personal Data to TCF, published or shared through the Website and that any applicable notification or consent requirements have been satisfied. 

  1. Mode and Place of Processing the Personal Data 

Methods of Processing 

The Data Controller / Owner takes appropriate technical and organizational measures to protect Personal Data against unauthorized access, disclosure, modification, loss, destruction or other unlawful or unauthorized processing. 

 
Personal Data processing is carried out using computers and/or IT enabled tools, in accordance with appropriate organizational procedures and measures strictly related to the purposes for which it is processed. In addition to the Data Controller / Owner, where necessary, Personal Data may be accessible to authorized personnel responsible for the operation of the Website (administration, sales, marketing, legal, system administration) as well as external service providers such as technical service providers, mail carriers, hosting providers, IT companies, communications agencies engaged by TCF in connection with the Website. An updated list of the categories of such parties may be requested from TCF at any time. 

Place 

The Personal Data is processed at TCF’s operating offices and at locations of third parties involved in the processing of the relevant Personal Data.  
 
Depending on the User’s location, Personal Data may be transferred to and processed in a country other than the User’s country of residence. Further information regarding the locations in which Personal Data is processed and any applicable safeguards relating to international transfers is provided in the relevant sections of this Privacy Policy. 

Retention Time 

Unless specified otherwise in this document, Personal Data shall be processed and stored for no longer than is necessary to fulfil the purpose for which it was collected. Personal Data may be retained for a longer period where required or permitted by applicable law, including where necessary to comply with legal or regulatory obligations or to establish, exercise or defend legal claims. 

  1. The Purposes of Processing 

Personal Data concerning the User is collected and processed to allow the Data Controller / Owner to provide its Services, comply with its legal obligations, respond to enforcement requests, protect its rights and interests and those of its Users and third parties, and detect and prevent any malicious or fraudulent activity, as well as for the following purposes:  

  1. Hosting and backend infrastructure;  
  1. Managing contacts and sending messages; 
  1. Remarketing and behavioral targeting;  
  1. Advertising;  
  1. Analytics;  
  1. Spam and bots protection;  
  1. Tag management;  
  1. Displaying content from external platforms;  
  1. Handling payments; and  
  1. Contacting the User. 

For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”. 

  1. Detailed Information on the Processing of Personal Data 

Users’ Personal Data is collected for the following purposes and using the following services: 

  1. Advertising 

This type of service allows Users’ Personal Data to be utilized for advertising communication purposes. These communications are displayed in the form of banners and other advertisements on the Website, including, where applicable, based on Users’ interests and behavior. However, this does not mean that all Personal Data is used for this purpose. Further information regarding the Personal Data processed and the applicable terms of use is set out below. 

Some of the services listed below may use Trackers to identify Users or may use behavioral retargeting techniques, including the display of advertisements tailored to the User’s interests and behavior, including information regarding the User’s activities outside the Website.  
 

For more information, please check the privacy policies of the relevant services.  
 

Services of this kind usually allow Users to opt out of such tracking. Users may learn how to opt out of interest-based advertising more generally by referring to the relevant section of this Privacy Policy. 

  1.  Meta Ads Conversion Tracking (Meta pixel) (Meta Platforms, Inc.) 

Meta Ads Conversion Tracking (Meta pixel) is an advertising and conversion-tracking service provided by Meta Platforms, Inc. that connects data from the Meta Audience Network with actions performed on the Website. The Meta Pixel tracks conversions attributable to advertisements displayed through Facebook, Instagram and Meta Audience Network. 

Personal Data processed:    Trackers; Usage Data. 

Place of processing:              United States – Privacy Policy – Opt out

  1. Google Ad Manager (Google Ireland Limited) 

Google Ad Manager is an advertising service provided by Google Ireland Limited that allows the Data Controller to conduct advertising campaigns in conjunction with external advertising networks with which TCF may not have a direct relationship. 

  

This service uses Cookies and similar identifiers, including information transmitted automatically such as Users’ IP addresses, to identify Users’ devices and to monitor the use of the Website and Users’ interactions with advertisements, products and services offered through the Website. 

  

Users may manage their advertising preferences and disable advertising Cookies via Google Ad Settings. Disabling advertising Cookies may not prevent Users’ devices from being identified on the basis of information transmitted automatically, such as their IP address. 

  

In order to understand Google’s use of Data, consult their partner policy and their Business Data page

Personal Data processed:    Trackers; Usage Data. 

Place of processing:               Ireland – Privacy Policy

  1. LinkedIn Ads (LinkedIn Corporation) 

LinkedIn Ads is an advertising service provided by LinkedIn Corporation. 

Personal Data processed:      Trackers; Usage Data. 

Place of processing:                 United States – Privacy Policy – Opt out

  1. Reddit Ad Targeting (Reddit Pixel) (Reddit, Inc.) 

Reddit Ad Targeting (Reddit Pixel) is an advertising service provided by Reddit, Inc. that connects data from Reddit Ads with actions performed on the Website. The Reddit Pixel tracks conversions that can be attributed to advertisements on Reddit. 

Personal Data processed:   Trackers; Usage Data. 

Place of processing:              United States – Privacy Policy

  1. Analytics 

The services contained in this section enable the Data Controller to monitor and analyze web traffic and can be used to keep track of User behavior. 

  1. Meta Events Manager (Meta Platforms, Inc.) 

Meta Events Manager is an analytics service provided by Meta Platforms, Inc. By integrating the Meta Pixel, Meta Events Manager can give the Data Controller insights into the traffic and interactions on the Website. 

Personal Data processed:       Browsing history, clicks, page views, Trackers, Usage Data. 

Place of processing:                 United States – Privacy Policy – Opt out

  1. Google Analytics 4 (Google Ireland Limited) 

Google Analytics 4 is a web analysis service provided by Google Ireland Limited (“Google”). Google utilizes the Personal Data collected to track and examine the use of this Website, to prepare reports on its activities and share them with other Google services. Google may use the Personal Data collected to contextualize and personalize the ads of its own advertising network. In Google Analytics 4, IP addresses are used at collection time and then discarded before Personal Data is logged in any data center or server. Users can learn more by consulting Google’s official documentation

  

In order to understand Google’s use of Personal Data, consult their partner policy and their Business Data page

Personal Data processed:      number of Users, session statistics, Trackers, Usage Data. 

Place of processing:                 Ireland – Privacy Policy – Opt out

  1. Contacting the User 
  1. Phone Numbers 

Users that provide their phone number may be contacted for commercial or promotional purposes related to the Website, as well as for fulfilling support requests. 

Personal Data processed: Users’ phone numbers. 

  1. Mailing List or Newsletters 

By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning the Website. Users’ email addresses might also be added to this list as a result of signing up to the Website or after making a purchase. 

Personal Data processed: Email addresses, Trackers, Usage Data. 

  1. Displaying Content from External Platforms 

This type of service allows Users to view content hosted on external platforms directly from the pages of the Website and interact with them. Such services are often referred to as widgets, which are small elements placed on a website or app. They provide specific information or perform a particular function and often allow for user interaction. 
 

This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it. 

  1. YouTube IFrame Player (Google Ireland Limited) 

YouTube IFrame Player is a video content visualization service provided by Google Ireland Limited that allows this Website to incorporate content of this kind on its pages. 

  

Through this service, this Website may collect Personal Data directly or indirectly on or from Users’ devices, including by making use of trackers. Users may restrict such access to their Data via the security settings page provided by Google. Users may request the Data Controller for further information about these privacy settings at any time through the contact details provided in this Privacy Policy. 

  

Personal Data collected through this service may also be used to help third parties deliver interest-based advertising. Users can opt out of third-party interest-based advertising through their device settings or by visiting the Network Advertising Initiative opt-out page

Personal Data processed:    device information; Trackers; Usage Data. 

Place of processing:        Ireland – Privacy Policy – Opt out

  1. Handling Payments 

Unless otherwise specified, this Website processes any payments by credit card, bank transfer or other means via external payment service providers. In general and unless where otherwise stated, Users are requested to provide their payment details and personal information directly to such payment service providers. This Website isn’t involved in the collection and processing of such information. Instead, it will only receive a notification by the relevant payment service provider as to whether payment has been successfully completed. 

  1. Habib Bank Limited 

HBLPay Checkout is an umbrella brand for consolidated digital payment services which gives the Single, Simple & Quicker integration; one for all card schemes and direct transfer facility from accounts and wallets for  ecommerce merchants. 

  1. Hosting and Backend Infrastructure 

This type of service has the purpose of hosting Personal Data and files that enable this Website to run and be distributed or to provide a ready-made infrastructure to run specific features or parts of this Website. 

Some services among those listed below, if any, may work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data is stored. 

  1. Amazon Web Services (AWS) (Amazon Web Services, Inc.) 

Amazon Web Services (AWS) is a hosting and backend service provided by Amazon Web Services, Inc. 

Personal Data processed: various types of Data as specified in the privacy policy of the service. 

Place of processing: United States – Privacy Policy

  1. Managing Contacts and Sending Messages 

This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.  
 

These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message. 

  1. Amazon Simple Email Service (SES) (Amazon) 

Amazon Simple Email Service is an email address management and message sending service provided by Amazon.com Inc. 

Personal Data processed: email address. 

Place of processing: United States – Privacy Policy

  1. AdRoll Email (NextRoll, Inc.) 

AdRoll Email is an email address management and message sending service provided by NextRoll, Inc. NextRoll, Inc. performs a hash of the User’s email address in order to serve targeted advertising to other devices connected to them (i.e. cross-device tracking). 

  

Users can opt-out of receiving interest-based ads by visiting the Adroll opt-out page, following the instructions provided by the Network Advertising Initiative or directly through their device advertising settings. 

Personal Data processed: email address; Trackers; Usage Data. 

Place of processing: United States – Privacy Policy – Opt Out

  1. Constant Contact (Constant Contact, Inc.) 

Constant Contact is an email address management and message sending service provided by Constant Contact, Inc. 

Personal Data processed: email address; Trackers; Usage Data. 

Place of processing: United States – Privacy Policy

  1. Remarketing and Behavioral Targeting 

This type of service allows this Website and its partners to inform, optimize and serve advertising based on past use of this Website by the User.  
 

This activity is facilitated by tracking Usage Data and by using Trackers to collect information which is then transferred to the partners that manage the remarketing and behavioral targeting activity.  
 

Some services offer a remarketing option based on email address lists.  
 

Services of this kind usually allow Users to opt out of such tracking. Users may learn how to opt out of interest-based advertising more generally by visiting the relevant opt-out section in this document. 

  1. Facebook Remarketing (Meta Platforms, Inc.) 

Facebook Remarketing is a remarketing and behavioral targeting service provided by Meta Platforms, Inc. that connects the activity of this Website with the Meta Audience Network. 

Personal Data processed: Trackers; Usage Data. 

Place of processing: United States – Privacy Policy – Opt out

  1. Meta Custom Audience (Meta Platforms, Inc.) 

Meta Custom Audience is a remarketing and behavioral targeting service provided by Meta Platforms, Inc. that connects the activity of this Website with the Meta Audience Network. 

  

Users can opt out of Meta’s use of Trackers for ads personalization by visiting this opt-out page

Personal Data processed: email address; Trackers. 

Place of processing: United States – Privacy Policy – Opt out

  1. Google Ad Manager Audience Extension (Google Ireland Limited) 

Google Ad Manager Audience Extension is a remarketing and behavioral targeting service provided by Google Ireland Limited that tracks the visitors of this Website and allows selected advertising partners to display targeted ads across the web to them. 

  

In order to understand Google’s use of Data, consult Google’s partner policy

Personal Data processed: Trackers; Usage Data. 

Place of processing: Ireland – Privacy Policy – Opt Out

  1. Google Ads Remarketing (Google Ireland Limited) 

Google Ads Remarketing is a remarketing and behavioral targeting service provided by Google Ireland Limited that connects the activity of this Website with the Google Ads advertising network and the DoubleClick Cookie. 

  

In order to understand Google’s use of Data, consult Google’s partner policy

  

Users can opt out of Google’s use of Trackers for ads personalization by visiting Google’s Ads Settings

Personal Data processed: Trackers; Usage Data. 

Place of processing: Ireland – Privacy Policy – Opt out

  1. TikTok Remarketing ( TikTok Information Technologies UK Limited ) 

TikTok Remarketing is a remarketing and behavioral targeting service provided by TikTok Information Technologies UK Limited that connects the activity of this Website with the TikTok advertising network. 

Personal Data processed: Trackers; Usage Data. 

Place of processing: United Kingdom – Privacy Policy

  1. Spam and Bots Protection 

This type of service analyzes the traffic of this Website, potentially containing Users’ Personal Data, with the purpose of filtering it from unwanted parts of traffic, messages and content that are recognized as spam or protecting it from malicious bots activities. 

  1. Google reCAPTCHA (Google Ireland Limited) 

Google reCAPTCHA is a spam protection service provided by Google Ireland Limited. 

Personal Data processed: answers to questions; clicks; keypress events; motion sensor events; mouse movements; scroll position; touch events; Trackers; Usage Data. 

Place of processing: Ireland – Privacy Policy

  1. Tag Management 

This type of service helps the Data Controller to manage the tags or scripts needed on this Website in a centralized fashion.  

This results in the Users’ Data flowing through these services, potentially resulting in the retention of this Data. 

  1. Google Tag Manager (Google Ireland Limited) 

Google Tag Manager is a tag management service provided by Google Ireland Limited. 

  

In order to understand Google’s use of Data, consult their partner policy and their Business Data page

Personal Data processed: Trackers; Usage Data. 

Place of processing: Ireland – Privacy Policy

  1. Information on Opting out of Interest-Based Advertising 

In addition to any opt-out feature provided by any of the Services listed in this Privacy Policy, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section of the Cookie Policy. 

  1. Cookie Policy 

This Website uses Trackers. To learn more, Users may consult the Cookie Policy

  1. Further Information for Users in the European Union 

This section applies to Users in the European Union, to the extent that the processing of their Personal Data falls within the scope of the GDPR, and, for such Users, supersedes any other possibly divergent or conflicting information contained in the Privacy Policy. Further details regarding the categories of Personal Data processed, the purposes of processing, the categories of recipients of the Personal Data, if any, and further information about such processing can be found in the section titled “Detailed information on the processing of Personal Data” within this Privacy Policy. 

Legal Basis of Processing 

The Data Controller may process Personal Data relating to Users where at least one of the following lawful basis applies: 

  1. Users have given their consent to the processing of their Personal Data for one or more specific purposes; 
  1. processing is necessary for the performance of an agreement to which the User is party and/or for any pre-contractual obligations thereof; 
  1. processing is necessary for compliance with a legal obligation to which the Data Controller is subject; 
  1. processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Data Controller; 
  1. processing is necessary for the purposes of the legitimate interests pursued by the Data Controller or by a third party except where such interests are overridden by the interests or fundamental rights and freedoms of the User which require protection of Personal Data, in particular where the User is a child. 

Further Information about Retention Time 

Unless specified otherwise in this Privacy Policy, Personal Data shall be processed and stored for no longer than is necessary to fulfil the purposes for which it was collected and may be retained where required or permitted by applicable law, including where necessary to comply with a legal obligation or to establish, exercise or defend legal claims. 

Therefore: 

  1. Personal Data collected for purposes related to the performance of a contract between the Data Controller and the User shall be retained for as long as necessary to fulfil the contractual purposes and any related legal or regulatory obligations. 
  1. Personal Data collected for the purposes of the legitimate interests of the Data Controller shall be retained for no longer than necessary to fulfil those legitimate interests, subject to applicable legal and regulatory retention requirements. 

Where Personal Data is processed on the basis of the User’s consent, withdrawal of consent will not necessarily require the immediate deletion of such Personal Data where another lawful basis permits or requires its continued retention or processing. Furthermore, TCF may be required to retain Personal Data for a longer period where necessary to comply with a legal obligation or pursuant to an order of a competent authority. 

 
Once the applicable retention period expires, Personal Data shall be securely deleted or otherwise disposed of in accordance with applicable law, unless its continued retention is required or permitted by law. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period. 

Rights of Users  

Users may exercise the rights available to them under the GDPR in relation to their Personal Data processed by the Data Controller. 

In particular, subject to the conditions and limitations set out in the GDPR, Users have the right to: 

  1. Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. 
  1. Object to processing of their Personal Data. Users have the right to object to the processing of their Personal Data in the circumstances provided for under Article 21 of the GDPR. 
  1. Access their Personal Data. Users have the right to obtain confirmation as to whether their Personal Data is being processed and where applicable, access to such Personal Data and information concerning the processing, in accordance with Article 15 of the GDPR. 
  1. Verify and seek rectification. Users have the right to verify the accuracy of their Personal Data and request for it to be updated or corrected. 
  1. Restrict the processing of their Personal Data. Users have the right to request restriction of the processing of their Personal Data in the circumstances provided for under Article 18 of the GDPR. In this case, Personal Data may generally only be processed in accordance with the conditions set out in Article 18. 
  1. Have their Personal Data deleted or otherwise removed. Users have the right to request the erasure of their Personal Data in the circumstances provided for under Article 17 of the GDPR. 
  1. Receive their Personal Data and have it transferred to another controller. Users have the right to receive their Personal Data in a structured, commonly used and machine readable format and, where the conditions in Article 20 of the GDPR are satisfied, to transmit that Personal Data to another controller or request that it be transmitted directly, where technically feasible. 
  1. Lodge a complaint. Users have the right to lodge a claim before their competent data protection authority, in particular in the Member State of their habitual residence, place of work or place of the alleged infringement. 

Users are also entitled to receive information concerning any transfer of their Personal Data to a third country or international organisation, including information regarding the appropriate safeguards applicable to such transfer, in accordance with the GDPR. 

Users’ Right to Object to their Personal Data Processing  

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Data Controller or for the purposes of the legitimate interests pursued by the Data Controller , Users may object to such processing by providing grounds related to their particular situation to justify the objection. 

Users should note that in the event that their Personal Data is processed for direct marketing purposes, they may object to such processing at any time, free of charge and without providing any justification. This includes profiling to the extent that it is related to such direct marketing. Where the User objects to processing for direct marketing purposes, the Personal Data will no longer be processed for such purposes. To learn whether the Data Controller is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this Privacy Policy. 

Any requests to exercise Users’ rights may be directed to the Data Controller through the contact details provided in this Privacy Policy. Such requests shall be free of charge and shall be addressed by the Data Controller without undue delay and, in any event, within one month of receipt, subject to the extensions permitted under Article 12(3) of the GDPR. Any rectification or erasure of Personal Data or restriction of processing will be communicated by the Data Controller to each recipient, if any, to whom the Personal Data has been disclosed, unless this proves impossible or involves disproportionate effort. At the Users’ request, the Data Controller will inform the User about those recipients. 

  1. Additional Information about Data Collection and Processing 

Legal Action 

A User’s Personal Data may be processed by the Data Controller where necessary for the establishment, exercise or defense of legal claims in Court including in connection with any improper use of the Website or the related Services.  
 

The User acknowledges that TCF may be required to disclose Personal Data to competent public authorities where required by applicable law or pursuant to a lawful request. 

Additional Information about a User’s Personal Data 

In addition to the information contained in this Privacy Policy, the Website may provide Users with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request. 

System Logs and Maintenance 

For operation and maintenance purposes, the Website and any third-party services may automatically collect information relating to interactions with the Website including system logs or other Personal Data such as the IP addresses.  

Information not contained in this Privacy Policy 

Further information concerning the collection or processing of Personal Data may be requested from TCF at any time using the contact details provided in this Privacy Policy.  

Changes to this Privacy Policy 

TCF reserves the right to amend this Privacy Policy from time to time. Where appropriate, TCF will notify Users of material changes by posting the updated Privacy Policy on the Website and, where reasonably practicable and legally required, by providing notice through the contact details available to TCF. The date of the latest revision will be indicated in the Privacy Policy. 

  1. Definitions and Legal References 

Personal Data / Data means any information that directly, indirectly, or in connection with other information — including a personal identification number — relates to an identified or identifiable natural person. 

Usage Data means any information collected automatically through this Website (or third-party services employed on the Website), which can include the IP addresses or domain names of the device used by the Users, the URI addresses (Uniform Resource Identifier), the time of the request, the method used to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (e.g., successful outcome, error, etc.), the country of origin, the features of the User’s browser and operating system, duration of each visit (e.g., the time spent on each page within the Website), the path followed within the Website including the sequence of pages visited, and other parameters relating to the User’s device operating system and/or IT environment. 

User means an individual who accesses or uses the Website. 

Data Subject means the natural person to whom the Personal Data relates. 

Data Processor / Processor means the natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Data Controller, as described in this Privacy Policy. 

Data Controller means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing Personal Data, including the security measures concerning the operation and use of this Website. For purposes of this Privacy Policy, TCF is the Data Controller in respect of the processing of Personal Data through the Website. 

Website means  

www.tcf.org.pk 

Services means the services provided by the Website as described in the relative terms (if available). 

European Union / EU means the member states of the European Union. For purposes of this Privacy Policy, all references to the EU / European Union include the European Economic Area (EEA), where applicable. 

GDPR means the General Data Protection Regulation (EU) 2016/679. 

Cookie means a Tracker consisting of a small set of data stored on the User’s browser. 

Tracker means any technology including Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting technologies that enable information to be stored on or accessed from the User’s device or otherwise enables the tracking of Users.