Privacy Policy
Effective Date: September 10, 2026
(1) About This Privacy Policy
Traction Complete Technologies Inc. (“Traction Complete”, “we”, “us” or “our”) provides this Privacy Policy to explain how we handle personal information collected through our website (the “Website”).
This Privacy Policy applies to the Website only. Our software products are not accessed through the Website, and personal information that we process on behalf of our customers in delivering those products is governed by our agreement with the relevant customer rather than by this Privacy Policy.
We may update this Privacy Policy from time to time. The version posted on the Website is the current one and takes effect on the date shown above.
By accessing or using the Website, you agree that we may collect, use, and disclose your Personal Data, as outlined in this Privacy Policy and to comply with applicable laws and regulations.
(2) Personal Information Covered by This Privacy Policy
“Personal information” means information about an identifiable individual, as defined by applicable law, which depends on the jurisdiction you live in.
Most of the information we collect is business contact information, such as your name, job title, employer, business email address, and other information you provide to us.
(3) Personal Information We Collect
3.1 Information you give us
We collect the information you choose to give us when you complete a form on the Website, download content, book a meeting or call, subscribe to our communications, or otherwise contact us by email, or online form. This usually includes your name, business email address, employer, job title and whatever you choose to include in your message or in the fields of the form.
3.2 Information we collect automatically
When you visit the Website, we and our analytics and third-party providers automatically collect: (i) technical information about your device and connection, including your internet protocol (IP) address, operating system, browser type, identifier and configuration, device type and version, and unique identifiers; and (ii) information about how you use the Website, the date, time and duration of your visit, and any errors you encounter.
We collect this information using cookies, pixels, local storage objects and similar technologies. Some are strictly necessary to make the Website work and cannot be switched off, while others help us remember your preferences, understand how visitors use the Website, measure the effectiveness of our marketing, and deliver advertising that is relevant to you, including on third-party websites. Some of these technologies are placed by our analytics and advertising providers, who may receive your IP address, device identifiers and information about your visit. Where the law requires your consent, we will not place non-essential cookies or similar technologies until you have given it, and you can review or change your choices at any time through the cookie preference tool on the Website or through your browser settings, though blocking cookies may affect how parts of the Website function.
When you visit the Website, we may collect IP address, browser type and version, operating system, device type, language settings, and time zone (collectively, “Device and Browser Characteristics”). This information is derived from your connection and browser rather than placed on your device, and some of these characteristics, alone or in combination, may be used to recognize a returning visitor across visits.
3.3 Information we receive from other sources
We supplement our records with business contact information obtained from third-party providers, and publicly available sources. This information typically includes your name, business contact details, and information about your role. We use it to keep our records accurate and current, to identify people who may be interested in our products, and to recognize when one of our contacts changes roles.
(4) How We Use Personal Information
We use personal information for the following purposes:
- to operate, maintain, secure and improve the Website;
- to respond to your questions, requests and enquiries, and to provide the information or materials you ask for;
- to arrange and hold meetings and calls that you book with us;
- to manage registration for, and attendance at, webinars, events, contests and promotions;
- to send you sales and marketing communications about our products, including newsletters, product updates, event invitations and offers, by email, telephone, text message and social media;
- to keep our customer and prospect records accurate, complete and current, including by verifying and enriching business contact information;
- to understand how visitors use the Website, to measure and improve the effectiveness of our marketing, and to deliver personalized advertising and content;
- to report internally on usage trends and on the characteristics of our audience and client base;
- to establish, exercise or defend legal claims, enforce our Terms and Conditions, resolve disputes, and protect our rights and the rights of others; and
- to comply with our legal and regulatory obligations.
(5) Consent and Your Choices
We collect, use and disclose personal information with your consent, except where the law permits or requires us to act without it. You may withdraw your consent at any time, subject to legal and contractual restrictions and reasonable notice, by contacting us using the details in Section 14. If you withdraw your consent, we may be unable to respond to your requests or to provide information you have asked for.
Marketing communications. Every marketing email we send includes an unsubscribe link, and you may also ask us to stop sending you marketing at any time using the contact details in Section 14. We will give effect to your request promptly, and in any event within the period required by applicable anti-spam legislation. We may still send you messages that are not promotional, such as replies to your enquiries, confirmations of registrations you have made, and notices about legal, security or technical matters.
Cookies, analytics and advertising. You can manage cookies and similar technologies through the preference tool on the Website and through your browser settings. Where the law requires it, we will not place non-essential cookies or similar technologies until you have consented. If the law that applies to you gives you the right to opt out of targeted advertising, or of the sale or sharing of personal information for cross-context behavioral advertising, you may exercise that right through the preference tool or by contacting us.
Device and Browser Characteristics operate in accordance with the choices you make through the consent mechanism presented on the Website. If you would like Personal Data collected through Device and Browser Characteristics technologies to be corrected or deleted, you may contact us as described in Section 14, or submit a request directly to the applicable provider as identified on our Cookies page.
(6) How We Disclose Personal Information
We do not sell personal information, and we do not disclose personal information to third parties for their own independent marketing purposes. We disclose personal information only as follows:
- Service providers. We use service providers to perform functions on our behalf, including website hosting, customer relationship management and marketing automation, analytics, advertising, meeting scheduling, chat, webinar and event platforms, data enrichment, security, accounting and professional advice. Our service providers may use personal information to provide services to us.
- Advertising and analytics partners. We disclose limited information, such as your IP address, device identifiers and information about your use of the Website, to advertising and analytics partners so that we can measure and optimize our marketing. Section 5 explains how to opt out.
- Affiliates. We disclose personal information within our corporate group for the purposes described in this Privacy Policy.
- Corporate transactions. We may disclose personal information in connection with, or during negotiations of, a financing, merger, acquisition, reorganization or sale of all or substantially all of our assets. The recipient will be required to hold and use personal information on terms at least as protective as those in this Privacy Policy.
- Legal and protective purposes. We may disclose personal information where required or permitted by law, including in response to a subpoena, court order, warrant or other lawful request, and where necessary to investigate suspected fraud or unlawful activity or to protect the rights, property or safety of any person.
- With your consent. We will disclose personal information for any other purpose you consent to or direct.
(7) De-identified and Aggregated Information
We create de-identified and aggregated information from the information we collect, such as statistics on how often the Website is used, the browsers visitors use, and the general characteristics of our audience. We use this information to operate and improve the Website and our marketing, to report on usage trends, and for other business purposes, and we may disclose it to our affiliates, service providers, investors and prospective investors.
(8) Links to Third-Party Websites
The Website may contain links to third-party websites that we do not operate or control. We are not responsible for those websites, and we include the links solely for your convenience. Please review the privacy policies of any third-party website before you provide personal information to it.
(9) Security
The security of your personal information is important to us, which is why we maintain administrative, technical and physical safeguards designed to protect your information’s security, confidentiality and integrity.
(10) Service Providers Outside Canada
Some of our service providers store or process personal information outside Canada, including in the United States. You may contact our Privacy Officer using the details in Section 14 for more information about our policies and practices in relation to service providers outside Canada.
(11) Your Privacy Rights
You have the right to ask us for access to the personal information we hold about you and to ask us to correct information that is inaccurate, incomplete or out of date. If your name, business contact details or other information change, you may ask us to update or remove them. We will respond to your request within 30 days or tell you if we need more time. We may ask you for information to verify your identity before we act on a request, and we may decline a request where the law allows or requires us to do so.
Depending on where you live, you may also have the right to ask us to delete your personal information, to receive a copy of it in a portable format, to opt out of targeted advertising or of the sale or sharing of personal information, and to be free from discrimination for exercising your rights. You may use an authorized agent to make a request on your behalf. If we refuse your request, you may appeal by writing to us using the details in Section 14, and we will respond within the period required by the law that applies to you.
If you have a concern about how we have handled your personal information, please contact our Privacy Officer first so that we can try to resolve it. You may also make a complaint to the Office of the Privacy Commissioner of Canada or to the privacy regulator in your province or state.
(12) Retention
We keep personal information only for as long as we need it for the purposes described in this Privacy Policy, and then delete it or de-identify it. In deciding how long to keep personal information we consider how recently you interacted with us, whether you have asked us to stop contacting you, and whether we need the information to comply with our legal obligations, to resolve a dispute, or to establish, exercise or defend a legal claim. We may keep de-identified and aggregated information indefinitely.
(13) Children’s Information
The Website is intended for business users. We do not direct the Website to children and we do not knowingly collect personal information from anyone under the age of majority in their province or state of residence. If you believe we have collected personal information from a minor, please contact us and we will delete it.
(14) How to Contact Us
Our Privacy Officer is responsible for our compliance with this Privacy Policy and with the privacy laws that apply to us. If you have a question, a request or a complaint about your personal information or about this Privacy Policy, please contact us at:
Traction Complete Technologies Inc.
Attention: Privacy Officer
PO Box 10431, 1250-777 Dunsmuir
Vancouver, B.C. V7Y 1K5 Canada
e-mail: privacy@tractioncomplete.com
If we are unable to resolve your complaint you may file a complaint with the Office of the Privacy Commissioner of Canada (OPC).