Traction on Demand
Effective as of September 2018
Information We Collect
When you use the Website, ToD 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 (“Personal Data”).
(2) Aggregate Information
Aggregate Information is information about your activities on or in connection with the Website that typically cannot be used to identify, locate, or contact you (“Aggregate Information”). For example, Aggregate Information includes information regarding the frequency of use of the Website and browser types used to access the Website.
(3) Cookies, etc.
Collecting Personal Data
ToD collects Personal Data when:
(1) you use certain features of the Website that require the collection of Personal Data in order for those features to function;
(2) you voluntarily enter or upload Personal Data to or through the Website; and
(3) you communicate with ToD, whether through the Website or through another form of communication, such as e-mail or telephone.
Collecting Aggregate Information
ToD collects Aggregate information resulting from your use of the Website.
Using and Sharing Personal Data
ToD uses Personal Data we collect:
(1) to provide services through the Website, such as downloading information or registration for various events;
(2) to improve the features and functionality of the Website;
(3) to communicate with you in response to any of your questions and requests; and
(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, ToD may be required, or may, acting in good faith, believe it is required, to share certain information with legal authorities. In such a case, ToD will provide only the minimum amount of information required and, unless prohibited by law, ToD will notify you of the Personal Data it has provided. Such cases include:
(1) if required by law;
(2) to protect or defend itself, you, or others against legal liability or immediate danger; and
(3) to investigate a possible crime, such as fraud or identity theft.
ToD may share Personal Data with third party service providers as ToD deems necessary for such third party service providers to perform their duties required for the Website to function. For example, the Website may utilize hosting providers. Such 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.
ToD does not sell or otherwise share Personal Data with unrelated third parties.
Using and Sharing Aggregate Information
ToD uses Aggregate Information:
(1) to provide the services offer through the Website, such as downloading information or registration for various events;
(2) to improve the features and functionality of the Website;
(3) to monitor and analyze usage of the Website;
(4) to research, compile, and report on usage trends, user demographics, and user behaviors; and
(5) for other legitimate business purposes.
ToD 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 and facilitate the Website.
Aggregate Information is anonymized and does not have the capacity to be used to identify an individual. In other words, ToD may share this information but no Personal Data will be disclosed to third parties.
The Website may contain links to third party websites operated by other people or companies. ToD is not responsible for those websites, and links to such websites are included solely for your convenience. Please review the privacy policies of such third party websites.
Security and Data Protection
ToD takes appropriate security measures to protect Personal Data against unauthorized access, alteration, disclosure or destruction.
Such measures include internal reviews of ToD’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.
Data Processing and GDPR
ToD is both the data processor and the data controller for your Personal Data. This means that ToD performs operations on Personal Data and controls your Personal Data. In the case where ToD uses third party service providers with respect to your Personal Data, ToD is the data controller and such third party is the data processor.
To the extent applicable, ToD will adhere to the requirements as outlined in Regulation (EU) 2016/679 (General Data Protection Regulation, commonly referred to as GDPR).
ToD may transfer your Personal Data to countries other than the one in which you live.
In the event that ToD may require certain financial information, such as credit card information to register for an event, on the Website, we will not share this financial information, other than the financial institutions involved in processing your payment. At all times, ToD will comply in all respects with applicable consumer protection laws.
Corrections and Removals
You may have the right to access your Personal Data and require ToD to update, delete, or correct this information. If any part of your Personal Data, such as your name, e-mail address, mailing address, telephone number or other personal information is incorrect or has changed, you may update, correct or remove the relevant information by contacting ToD. We will take reasonable steps to update or correct Personal Data in ToD’s possession or control.
Traction Sales and Marketing Inc.
Attention: Privacy Team
#500 2700 Production Way
Burnaby BC Canada V5A 0C2