Privacy Policy

This privacy policy (hereafter: the "Policy") applies to Traction DK Inc. (hereafter: "Traction" or "We").

The Policy applies to Personal Information (as defined below) about users of the website: https://www.tractiondk.com/ (hereinafter: the "Website"). It specifies how we manage and protect them within the limits imposed on us by law. The Policy does not apply to Personal Information about our employees, and those about our contractors.

If you are an employee or sub-contractor of one of our clients (hereinafter: the "Clients") or if you are a client of one of our Clients to whom we grant authorization to use our platform at the Client's request after the Client has paid the related fees, your information is protected under the PLATFORM'S PRIVACY POLICY. This Policy does not apply to your Personal Information.

The following articles provide information about:

• The nature of the Personal Information we collect and the means by which we do so;
• The scope of your consent;
• The security and governance measures to protect them that we follow;
• The purposes of their use;
• How we communicate and store it;
• Your rights in relation to them and how to exercise them.

"Personal Information" means any information relating to a natural person and which makes it possible, directly or indirectly, to identify that person.

We only collect Personal Information about you that is necessary to establish, manage and maintain our relationship with you. This collection is limited, in most cases, to the following Personal Information:

• First name;
• Last name;
• Email address;
• Phone number / mobile;
• Banking information, if applicable;
• As well as cookies (see article 9 of the Policy).

We may collect Personal Information on the Website, directly or via a conversation module available online and more broadly, during your email, telephone or in-person exchanges with one of our employees or representatives.

We also use a virtual assistant who can interact with you using natural language to guide you and quickly answer your questions (hereafter: "Chatbot").

Your consent to the collection, use or disclosure of your Personal Information must be clear, free and informed. It must be given for the specific purposes identified in this Policy.

Depending on the nature and sensitivity of your Personal Information, your consent may be express (such consent may be given verbally, in writing or electronically) or implied (when you voluntarily provide Personal Information, for example).

If you do not consent, please stop using the Website. Except where the law provides otherwise, you may withdraw your consent at any time, upon transmission of reasonable notice. Please note that if you choose to withdraw your consent to the collection, use or disclosure of your Personal Information, certain features of our Website may no longer be available to you or we may no longer be able to offer you some of our services.

Information security is a priority for us. In addition to the administrative measures detailed in the articles that follow, we have implemented physical and technological measures that are reasonable given the sensitivity of the Personal Information, its use, quantity, distribution and support.

We use the Personal Information of Website users only for the following purposes:

• Provide the Website and ensure its optimal functioning;
• Identify a user of the Website and ensure the authenticity of this identification;
• Send you information and promotional offers;
• Provide you with technical support;
• Obtain statistics on the use of the Website and our products and/or services.

All of our employees who use Personal Information are bound by confidentiality obligations and have received adequate training. In addition, they may only have access to the Personal Information necessary to perform their respective functions. In the event of a violation, our governance policies and practices provide for sanctions.

We only use Personal Information for the purposes expressed above except when we are authorized by law, in very limited cases, to do so without your consent.

A. To Whom?

We retain Personal Information only for as long as necessary to fulfill the purposes for which it was collected, except where legal requirements or contractual interests recognized by law require us to retain it for a longer period. We reserve the right to establish policies for the destruction of Personal Information from time to time. Upon request, we can inform you of the retention period of your Personal Information.

For users of the Website, you have the following rights:

• The right to be informed of their use, communication, storage and destruction, which is specifically covered by this Policy;
• The right to access your Personal Information and to obtain additional details on how we use, communicate, retain and destroy it;
• In some cases, the right to oppose, restrict or withdraw your consent to these operations by sending reasonable notice to the email address provided at the end of this Policy;
• The right to have your Personal Information corrected if it is inaccurate or ambiguous and to have it completed when it is incomplete;
• The right to have your Personal Information deleted subject to our legal obligations;
• The right to be informed of a confidentiality incident concerning your Personal Information which may cause you serious harm.

You can exercise these rights by sending an email to the address provided at the end of this Policy. We will respond to your requests within 30 days of receipt, except where the law allows an extension of this period.

Your use of the Website allows us to automatically compile certain information, or cookies, which may include:

• The Internet Protocol address (or IP address) of your computer;
• Your geolocation area;
• The operating system you are using;
• Preferred language;
• The identity of your internet service provider;
• The date and time you accessed the Website;
• The previous website you visited that provided you with a link to our Website;
• The content viewed and downloaded on our Website or the number of visits.

Generally, the cookies we use are grouped into three (3) categories:

If you wish, you can configure your browser to notify you when you receive cookies or to refuse them. However, in doing so, your use of our Website may be affected and you may no longer have access to all of its functions.

The Personal Information Protection Officer at Traction is Dave Renouf.

Traction reserves the right to modify the content of this Policy at any time. Any changes made will be posted on our Website and brought to your attention when you log in. We recommend that you print a copy of this policy for your records and review this section of our Website periodically.