Privacy Notice

Traact

 Privacy Policy

Effective Date: August 9, 2025

1. INTRODUCTION. This Privacy Policy (the “Policy”) explains how Traact, Inc. (“Traact”, “we”, “us”, “our”) collects, uses, and discloses personal information through its website and its online platform (the “Platform”, and collectively with the website, the “Services”).  Any capitalized terms that are not defined in this Policy are defined in our Terms of Service (https://www.traact.com/termsofuse).
2. INFORMATION COLLECTED AND HOW WE USE IT.  As explained further in this section, you will have the opportunity to provide us with certain personal information. In addition, we may collect certain personal information automatically through your use of the Services. The rest of this section provides a more detailed explanation of the personal information we collect, how we use that personal information, and our lawful bases for processing that personal information.

1. Types of Personal Information We May Collect. We may collect, use, store and transfer different kinds of personal data about you which we group together as follows:

• Identity Data includes first name and last name.
• Contact Data includes email address, telephone numbers, company name and mailing address and customer representative contact information.
• Technical Data includes internet protocol (IP) address, and your login data.
• Profile Data includes your username and password.
• Usage Data includes information about how you use our Platform and Services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.

1. Voluntarily Disclosed Information. The following table identifies the specific purposes for which you may voluntarily disclose personal information to us, along with our lawful bases for processing that personal information.

Purpose for Collection	Type of Personal Information	Lawful Basis for Processing
For account creation purposes	Identity Data; Contact Data	Performance of a contract with you
To provide you with our Platform and Services and otherwise meet our contractual obligations	Identity Data; Contact Data; Profile Data; Technical Data; Usage Data	Your consent; Performance of a contract with you; Our legitimate interest of collecting payments owed to us
To manage our relationship with you, which will include: (i) notifying you about changes to our Terms of Service or this Policy and (ii) asking you to leave a review or take a survey	Identity Data; Contact Data; Profile Data; Marketing and Communications Data	Necessary to comply with a legal obligation; Performance of a contract with you; Our legitimate interest of keeping our records updated and studying how customers use our Platform and Services
To administer and protect our business, Platform, and Services (such as testing and troubleshooting, data analysis, system maintenance and support, data reporting and hosting)	Identity Data; Contact Data; Technical Data;	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise); Necessary to comply with a legal obligation
To use data analytics to improve our website, Platform, and Services, marketing, customer relationships and experiences	Technical Data; Usage Data	Necessary for our legitimate interests (to define types of customers for our Platform and Services, to keep our website updated and relevant, to develop our business, and to inform our marketing strategy)
To make suggestions and recommendations to you  about goods or services that may be of interest to you	Identity Data; Contact Data; Profile Data; Technical Data; Usage Data; Marketing and Communications Data	Necessary for our legitimate interests (to develop our Platform and Services and grow our business); Your consent

2. Automatically Collected Information. Whenever you interact with the Services, we automatically receive and record information on our server logs from your browser or device, which may include your IP address. You can learn more about our use of cookies and related technologies in our Cookie Policy. We use the data we automatically collect from you to customize content for you that we think you might like, based on your usage patterns.  We may also use it to improve the Services – for example, this data can tell us how often users use a particular feature of the Services, and we can use that knowledge to make the Services interesting to as many users as possible. We collect this information with your consent, to perform our contract with you, and for our legitimate interest of providing a smooth user experience on the Services.       

3. DISCLOSURE OF PERSONAL INFORMATION. We may disclose your personal information as detailed in this section.

1. Personnel and Third-Party Service Providers. We employ personnel and engage other companies and people to perform tasks on our behalf and need to share your personal information with them to provide products or services to you. For example, data that we receive is stored on servers hosted by AWS.       
2. Other Users. Please note that if you submit any information to a portion of the Services that is accessible by other users within your organization (e.g. your employer) (“Organization”), including an online forum or comment section, those users will be able to see that information. Accordingly, only include information in such submissions that you are comfortable sharing with other users at your Organization.
3. Third Party Applications. If you or your Organization use third party applications or services (the “Third Party Apps”) within the Platform, Traact will allow the providers of those Third Party Apps (the “Third Party Providers”) to access or use your personal information and any other you provide as required for the interoperation of the Third Party Apps and the Platform. Any Third Party Provider’s use of such information, including your personal information, is subject to the applicable agreement between either (i) your Organization and such Third Party Provider, or (ii) you and the Third Party Provider. Traact is not responsible for any access to or use of any information, including your personal information, by Third Party Providers. You and your Organization are solely responsible for the decision to permit any Third Party Provider to use all such information.
4. Analytics Services. We use third-party vendors, including MixPanel, to understand how visitors engage with our Services. You can learn more about the information that MixPanel has access to at the following website: https://mixpanel.com/legal/privacy-policy/.
5. Anonymous Information. We may de-identify your personal information so that you are not identified as an individual, and share that information with third parties. We may also provide aggregate usage information to third parties (or allow these third parties to collect aggregate information of activity on our Services), who may use that information to understand how often and in what ways people use our Services, so that they, too, can provide our users with an optimal online experience.
6. Business Transfers. If we (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, personal information could be one of the assets transferred to or acquired by a third party.
7. Legal Compliance. We reserve the right to access, read, preserve, and disclose any information that we believe is necessary to comply with governmental requests, law enforcement or court orders, or enforce or apply our Terms of Service and other agreements.
8. California Residents Under 16 Years of Age. California law requires us to confirm whether we have actual knowledge that we sell or “share” the personal information of users under 16 years of age, as those terms are defined under California law. We do not sell or share the personal information of users under 16 years of age.

4. INTERNATIONAL TRANSFERS. We may transfer the personal information of users from the European Economic Area, Switzerland, or United Kingdom to the United States. When doing so, we rely on adequacy decisions, data transfer agreements, or other legally compliant mechanisms for such transfers, including standard contractual clauses. You can ask for a copy of these standard contractual clauses by contacting us as set out below.
5. SECURITY. We use commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of your personal information. In addition, we rely on the technical safeguards provided by the third party service providers we use to host, store, and process your personal information. We cannot, however, ensure or warrant that your personal information on the Services may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.
6. YOUR RIGHTS.

1. Who To Exercise Your Rights With. You may have rights under data protection laws in relation to your personal information. You can learn more about your rights further down in this section. If we have collected your personal information as a result of our contractual relationship with you, we are a “controller” of that personal information and you can exercise your rights with respect to your personal information by following the instructions below. However, if we have collected your personal information as a result of agreements we have in place with our clients, we are a “processor” of your personal information and those clients control our use of your personal information and determine how and for what purpose we process your personal information.

If we are a processor of your personal information, and you have any questions or concerns about how your personal information is handled or would like to exercise your rights as a data subject, you should contact the client who has contracted with us to use the Services to process your personal information. That client’s privacy policy governs their use (and our processing) of your personal information. We will provide assistance to the client to address any concerns you may have, in accordance with the terms of our contract with them and applicable law.

2. Rights of Users in the EEA, Switzerland, and UK. If you reside in the EEA, Switzerland, or the UK and we are a controller of your personal information, you have the following rights:

1. Request access to your personal information. You may request a copy of the personal information we hold about you and to check that we are lawfully processing it.  Where we have good reason, and where applicable law permits, we can refuse your request for a copy of your personal information, or certain elements of the request. If we refuse your request or any element of it, we will provide you with our reason(s) for doing so.
2. Request correction of your personal information. You may request that we correct any incomplete or inaccurate data we hold about you.
3. Request erasure of your personal information. You may request that we delete or remove personal information where there is no good reason for us continuing to process it. You may also ask us to delete or remove your personal information where you have successfully exercised your right to object to processing (see below), where we may have processed your personal information unlawfully or where we are required to erase your personal information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. You may not request the removal of de-identified, anonymous, or aggregate data from our databases.
4. Right to Object to or Restrict Processing.  In certain circumstances, you have the right to object to our processing of your personal information (for example, if we are processing your personal information on the basis of our legitimate interests but there are no longer any compelling legitimate grounds to justify our processing overriding your rights and interests). You may also restrict our processing of your personal information, for example during a period in which we are verifying the accuracy of your personal information in circumstances where you have challenged the accuracy of that personal information.
5. Request the transfer of your personal information to you or to a third party. In certain instances, you have a right to receive the personal information that we hold about you (or a portion thereof) in a structured, commonly used and machine-readable format. In such circumstances, you can ask us to transmit your personal information to you or directly to a third-party organization on your behalf. While we are happy for such requests to be made, we are not able to guarantee technical compatibility with a third-party organization’s systems. We are also unable to comply with requests that relate to personal information of others without their consent.
6. Withdraw consent. You may withdraw your consent for our processing of your personal information where we are relying on consent to process that personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

3. Rights of All Other Users. Regardless of where you reside, through your account settings, you may access, edit and delete your profile information. Please understand, however, that it may be impossible to delete this information completely, due to backups and records of deletions. In addition, we may deny a deletion request if (i) the denial is necessary for us to comply with applicable law, or (ii) the request pertains to content that you posted on a publicly available portion of the Services and that cannot be deleted without impacting the Services experience for other users. You may not request the removal of de-identified, anonymous, or aggregate data from our databases.

4. How to Exercise Your Rights. If you wish to exercise any of the rights set out above and we are the controller of your personal information, please contact us at support@traact.com. If you have authorized an agent to exercise your rights on your behalf, the agent may contact us at support@traact.com. Please note that to protect your personal information and the integrity of our Services, we may need to collect additional information to verify your identity (and, if applicable, the authority of your agent) before processing your request. If you are not satisfied with any decision we make with respect to your request, you can let us know the reasons for your concern, and we will review your appeal. If we are the processor of your personal information, please contact the organization through which you have access to our Services in order to exercise rights you may have with respect to your information.

5. Supervisory Authorities. We welcome and appreciate the chance to address any concerns you may have about the Policy and our collection and use of your personal information. To the extent you feel like we have not addressed your concerns, and depending on your jurisdiction, you may have the right to make a complaint at any time to your data protection supervisory authority. For end users in the EEA, you can find contact information for each country’s supervisory authority here. For end users in the UK, you can find contact information for the Information Commissioner’s Office (ICO) on the ICO’s website here.

7. RETENTION OF INFORMATION. Subject to your right to request deletion of your personal information in accordance with Section 6, we will retain your personal information as long as needed for your use of the Services, your approved receipt of marketing communications from us, our compliance with legal obligations, and to protect our or other’s interests.
8. HOW WE RESPOND TO DO NOT TRACK SIGNALS. We will honor your exercise of your rights with respect to your personal information in accordance with Section 6. Apart from those rights, we do not respond to “Do Not Track” signals.
9. AGE OF USERS. Children under the age of 13 are not permitted to use, access or register for the Services in any way. We do not knowingly collect or solicit information from anyone under the age of 13. If we learn that we have collected personal information from a child under the age of 13, we will delete that information as quickly as possible.
10. CHANGES TO POLICY. We’re constantly trying to improve the Services, so we may need to change this Policy from time to time as well. The date of the last modification will be posted at the beginning of this Policy. It is your responsibility to check from time to time for updates. By continuing to access or use the Services, you are indicating that you agree to be bound by the modified Policy.
11. CONTACT US. If you have any questions or concerns regarding this Policy, please send us a detailed message to our data protection officer at dpo@traact.com, and we will try to resolve your concerns. In addition, please contact support@traact.com for all other inquiries.

Traact Cookie Policy

This Cookie Policy provides information about cookies, how we and third parties use them on the Services, and how you can manage our use of cookies with respect to your experience on the Services.

What is a Cookie?

A cookie is a small text file that can be stored on and accessed from your device when you visit and use our Services. Cookies enable us to “personalize” the Services for users by remembering information about our users. The Services use cookies to administer the Services, store your preferences, display content to personalize your visit, analyze trends on the Services, and track your movements around the Services.

How to Manage Cookies

Cookies are managed through web browsers, so please review your web browser settings to modify your cookie settings, to disable the use of cookies, or to delete cookies. The National Advertising Initiative provides a helpful overview for disabling cookies. Please note that if you delete, or choose not to accept, cookies from the Services, you may not be able to utilize the features of the Services to their fullest potential.

Types of Cookies

Cookies can be categorized in different ways:

• First-Party vs. Third-Party Cookies: If we use first-party cookies, we put them on your device. Third party cookies are placed on your device by a third party. You can learn more about the third-party cookies used on the Services below.

• Duration:

• Session Cookies: Temporary cookies that expire once your session on the Services ends or your web browser is closed.
• Persistent Cookies: Cookies that remain on your device for a longer period until you manually erase them or until their expiration date.

• Purpose:

• Necessary Cookies - These cookies are necessary for us to operate the Services and their core features (e.g., account login).
• Functionality Cookies – These cookies enable us to operate the Services in accordance with the choices you make. These cookies permit us to “remember” you in between visits. For instance, we will recognize your username and remember how you customized the Services (e.g., language preference, location), and these cookies allow us to provide you with the same customizations during future visits.
• Analytical - These cookies analyze how the Services are used (e.g., browsing habits) and how the Services are performing. These cookies include, for example, MixPanel cookies.

First-Party Cookies That We Use

We do not use any first-party cookies.

Third-Party Cookies That We Use

• MixPanel Cookies - We use MixPanel to analyze our web traffic and improve user experience. MixPanel uses cookies to generate statistical information about how our Website is being used. For more information on these cookies, please see here. 
• Cloudfare – We use Cloudfare for human authentication. You can learn more about Cloudfare’s cookies here.