Privacy Policy.

Please note that we have updated our Privacy Policy which will be effective starting June 22, 2020. They are found below. If you would like to review our old Privacy Policy, click here.

This Privacy Policy (the “Privacy Policy“) describes the types of information Traction Guest Inc. (“Traction” or “we“) collects from you, or from subscribers (“you” or “your“) to Traction’s software applications, including the enhancements, features, related website, and contents (the “Services“). It also describes how we use and disclose such information, as well as your rights with respect to Traction’s collection, use, and disclosure of such information.

We understand the importance of your privacy and the privacy of visitors to your business location who access the Services (“Visitors“) and we treat all information we receive in a responsible manner. By downloading or accessing the Services, you agree that we may collect, use, and disclose Personal Data, Aggregate Information, and Cookies pursuant to this Privacy Policy.

Information We Collect

When you use the Services, Traction may collect three types of information:

  1. Personal Data Personal Data is any information directly or indirectly relating to an identified or identifiable individual, such as a name, an identification number, location data, an online identifier or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.
  2. Aggregate Information Aggregate Information is information about your activities on or in connection with the Services that typically cannot be used to identify, locate, or contact you or your Visitors. For example, Aggregate Information includes information regarding the frequency of use of the Services, quantity and type of data entered when using the Services, components of the Services most frequently accessed, and browser types used to access the Services.
  3. Cookies, etc. Cookies, beacons, device identifiers, or similar technologies (referred to for convenience as “Cookies“) are small pieces of data placed on your device that your web browser or device uses to access the Services and that permit Traction to track your activity on the Services. We obtain information from Cookies when, for example, you or a Visitor visit Traction’s website. You may turn off cookies in your browser or device settings, but this may limit functionality of the Services. Cookies help analyze usage and provide certain functionality. Cookies don’t contain Personal Data and for that reason, we treat Cookies in the same manner as we treat Aggregate Information. If Cookies do contain Personal Data, such Personal Data will only be used or disclosed in the same manner as other Personal Data pursuant to this Privacy Policy. Cookies cannot be used as a malicious tool.

Collecting Personal Data

Traction collects Personal Data when:

  1. you sign up for the Services
  2. you use certain features of the Services that require the collection of Personal Data in order for those features to function
  3. you or your Visitors voluntarily enter or upload Personal Data to or through the Services
  4. you communicate with Traction, whether through the Services or through another form of communication, such as e-mail, web chat or telephone.

Collecting Aggregate Information

Traction collects Aggregate information resulting from your use and the use by your Visitors of the Services.

Using and Sharing Personal Data

Traction uses Personal Data we collect:

  1. to provide the Services
  2. to improve the features and functionality of the Services
  3. to communicate with you in response to any of your questions and requests
  4. to provide relevant marketing and other information to you, but only if, and to the extent that, you have consented to us providing such marketing and other information to you in accordance with applicable laws. In such a case, we will provide an easy link to permit you to “opt-out” of receiving future marketing communications

In rare cases, Traction may be required, or may, acting in good faith, believe it is required, to share certain information with legal authorities. In such a case, Traction will only share what is legally necessary. When Traction do give this information to the authorities, it is for them to protect that information. Such cases include:

  1. if required by law
  2. to protect or defend itself, you, your Visitors, or others against legal liability
  3. to protect itself, you, your Visitors, or others from immediate danger, such as personal injury or death
  4. to investigate a possible crime, such as fraud or identity theft.

Traction may share Personal Data with third party service providers as Traction deems necessary for such third party service providers to perform their duties required for the Services to function. For example, the Services may utilize mail relays, payment processers and hosting providers. A list of third party service providers used by Traction for the Services can be found at the following website: https://tractionguest.com/platform-security/. These third party service providers are not authorized to retain, share, store or use Personal Data for any purposes other than to provide the services for which they have been retained to provide.

Traction does not sell or otherwise share Personal Data with unrelated third parties.

Traction will not keep Personal Data for longer than is legally necessary at which time it will either be deleted or anonymized. For Visitor Personal Data it is the business location that determines the length of time data is to be kept, refer to their privacy policy for more details.

Personal Data may be transferred to Traction’s affiliates or as part of a sale of substantially all of the assets of Traction. In such a case, each such party will be required to hold Personal Data and not disclose Personal Data except in accordance with terms at least as restrictive as those contained in this Privacy Policy.

Using and Sharing Aggregate Information

Traction uses Aggregate Information:

  1. to provide the Services
  2. to improve the Services
  3. to monitor usage of the Services
  4. to analyze usage of the Services
  5. to research, compile, and report on usage trends, user demographics, and user behaviors
  6. for other legitimate business purposes.

Traction may share Aggregate Information with its affiliates and certain third parties, such as investors, potential investors, and third party service providers we use to provide the Services.

Aggregate Information is anonymized and does not have the capacity to be used to identify an individual. In other words, Traction may share this information but no Personal Data will be disclosed to third parties.

Location Information

Traction may use the Services to collect and use location information to provide certain functionality, such as identifying a Visitor sign-in at a specific business location. All such information will be governed by this Privacy Policy.

External Links

The Services may contain links to third party websites operated by other people or companies. Traction is not responsible for those websites, and links to such websites are solely for your convenience.

Security and Data Protection

The Services may contain links to third party websites operated by other people or companies. Traction is not responsible for those websites, and links to such websites are solely for your convenience.

Traction takes appropriate security measures to protect Personal Data against unauthorized access, alteration, disclosure or destruction.

Such measures include internal reviews of Traction’s data collection, storage and processing practices and security measures, as well as physical security measures to guard against unauthorized access to systems where Personal Data is stored.

Traction restricts access to Personal Data to its employees, service providers and agents who need to know such information in order to operate, develop or improve the Services. These individuals are bound by confidentiality obligations and are required to treat such Personal Data confidentially and in accordance with this Privacy Policy.

Data Processing and CCPA

The California Consumer Privacy Act (“CCPA”), which is effective as of January 1, 2020, regulates how Traction handles personal information of California residents and gives California residents certain rights with respect to their personal information.

Traction is both a “business” and a “service provider” under the CCPA. The following supplemental section applies to information we collect in our role as a business—this is when we interact directly with you.

When we act as a service provider (for example, by providing our services to a business that you interact with including as a Visitor), we follow the instructions of the business that engaged us with respect to how we process your personal information. If you would like more information about how your personal information is processed by other businesses, including companies that engage us as a service provider, please contact those businesses directly.

The general privacy policy shall continue to apply to the extent that it applies to you as a resident of California. If you are a resident of California, we are required to disclose certain uses and disclosures in a certain format, as well as to inform you of certain rights you may have.

Information We May Collect:

We may collect the following categories of information:

  • Identifiers
  • Demographic Information
  • Commercial Information
  • Internet or other electronic network activity information
  • Geolocation data
  • Audio, electronic, visual, or similar information
  • Professional or employment-related information

For each category of information, we collect the information from a variety of sources, including directly from you, from your devices, from your social media profiles, and/or from third party providers. We collect the information to provide you with services, protect our customers and ourselves (including the services), and to improve the services. We do not share personal information with Third Parties as the term is defined under the CCPA.

Additional Disclosures:

We do not sell personal information of any individual, including personal information of minors under 16 years of age.

We have disclosed the following categories of personal information for a business purpose in the 12 months prior to this Policy’s last update.

  • Identifiers
  • Demographic Information
  • Commercial Information
  • Internet or other electronic network activity information
  • Geolocation data
  • Audio, electronic, visual, or similar information
  • Professional or employment-related information
  • Inferences drawn from any of the above information.

We have not disclosed any personal information for valuable consideration in the 12 months prior to this Policy’s last update.

Your Rights:

You may have certain rights with respect to your personal information, including:

  • The right to access, including the right to know the categories and specific pieces of personal information we collect;
  • The right to deletion of your personal information, subject to certain limitations under applicable law;
  • The right to request disclosure of information collected;
  • The right to disclosure of information disclosed for valuable consideration; and
  • The right not to be discriminated against for exercising certain rights under California law.

To exercise these rights, please submit a request by emailing privacy@tractionguest.com Please be as specific as possible in relation to the personal information you wish to access. Once we receive your request, we will review it, determine whether we can verify your identity, and process the request accordingly. If we need additional information to verify your identity, we will let you know. We will respond to your request within 45 days of receipt, or notify you if we require additional time.

Data Processing and GDPR

Traction is a data processor and not the data controller for Visitors’ Personal Data. This means that Traction performs operations on Personal Data, but it does not control your Visitors’ Personal Data. With respect to Visitors’ Personal Data, the controller is the party whose business location the Visitor has visited to interact with the Services.

If you are a Visitor to a business location that uses the Services, by accessing the Services at such location (such as by signing in or using the functionality of the Services), you may be sharing your Personal Data with such business. The business’ use and disclosure of Visitors’ Personal Data is governed by such business’ privacy policy or other agreement which you may have entered into with such business. Notwithstanding that such agreement may have been presented to you through the Services, Traction is not an affiliate of such business and is not responsible for the business’ access, use, and disclosure of Visitors’ Personal Data.

Traction processes Personal Data only for the purposes for which it was collected and in accordance with this Privacy Policy. Traction takes reasonable steps to ensure that Personal Data we process is accurate, complete, and current.

Effective May 25th, 2018, individuals located in or originating from certain regions, such as the European Economic Area, have certain rights in relation to their Personal Data, as outlined in Regulation (EU) 2016/679 (General Data Protection Regulation, commonly referred to as “GDPR”). To the extent Traction has access to, or processes Personal Data for individuals who are subject to GDPR, that is, Personal Data originating from the European Union, Traction will adhere to the requirements of GDPR.

Traction may transfer your Personal Data to countries other than the one in which You reside.

You can ask Traction for copies of the data that it holds on you in its capacity as a controller. This right always applies but there may be some exceptions. You have the right to request that Traction updates, delete, or corrects this information as well. You can ask Traction to restrict processing of your information in some circumstances.

To the extent you are a Visitor of a business and you do not have access to do so directly through the Services, you may contact the business you visited to update your Personal Data. In the alternative, you may e-mail Traction for further access and assistance. We will take reasonable steps to update or correct Personal Data in Traction’s possession.

Financial Information

Traction may require certain financial information, such as credit card information. We will not share this financial information, other than the financial institutions involved in processing your payment. At all times, Traction will comply in all respects with applicable consumer protection laws.

Corrections and Removals

If any part of your Personal Data, such as your name, e-mail address, mailing address, telephone number or other personal information changes, you may update, correct or remove the relevant information:

  1. if you are a Visitor to a business location that uses the Services, by contacting such business; or
  2. in all other cases, by contacting Traction.

Contact Traction

We have a designated privacy officer available to you if you have any questions or concerns about this Privacy Policy. If you would like to contact us about this Privacy Policy, please do so as follows:

Traction Guest Inc.
Attention: Privacy Officer
#500 2700 Production Way
Burnaby BC Canada V5A 0C2
e-mail: privacy@tractionguest.com

Effective Date: June 22, 2020.