Privacy & Data Collection Policy

Effective Date: January 31, 2019

This privacy policy (the “Privacy Policy”) describes the types of information Traction Pulse Inc. (“” or “we”) collects from you, or from subscribers (“you” or “your”) to’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’s collection, use, and disclosure of such information.

We understand the importance of your privacy and the privacy of your employees and customers who access the Services (“Users”) 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, may collect three types of information:

  1. Aggregate Information. Aggregate Information is information about your activities on or in connection with the Services that typically cannot be used to identify, locate, you or Users. 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.

  2. 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 to track your activity on the Services. We obtain information from Cookies when, for example, you or a User visit’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.

  3. Personal Data. Personal Data is any information directly or indirectly relating to you that you provide us, such as a name, an identification number, location data, location, time zone, User language preferences, email address and employment goals. It may also include data from your mobile device such as User ID, Device ID and product interactions.

  4. Sentiment. Sentiment is data that is logged by the end user, including

    1. Subject; a generic categorization of the activity
    2. Context; learning, doing, or sharing
    3. Details; additional text provided by the user
    4. Sentiment score; a value of 1 to 5 represented by images

Collecting Personal Data collects Personal Data when:

  1. you sign up for the Service.
  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 User voluntarily enter or upload Personal Data to or through the Services.
  4. you communicate with, whether through the Services or through another form of communication, such as e-mail or telephone.

Collecting Aggregate Information collects Aggregate information resulting from your use and the use by your Users of the Services.

Using and Sharing Personal Data 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

In rare cases, may be required, or may, acting in good faith, believe it is required, to share certain information with legal authorities. In such a case, will provide only the minimum amount of information required and, unless prohibited by law, 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, your Users, or others against legal liability
  3. to protect itself, you, your Users, or others from immediate danger, such as personal injury or death
  4. to investigate a possible crime, such as fraud or identity theft. may share Personal Data with third party service providers as deems necessary for such third party service providers to perform their duties required for the Services to function. 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. does not sell or otherwise share Personal Data with unrelated third parties.

Personal Data may be transferred to’s affiliates or as part of a sale of substantially all of the assets of 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 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. 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, may share this information but no Personal Data will be disclosed to third parties.

Location Information may use the Services to collect and use location information to provide certain functionality. 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. 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. is not responsible for those websites, and links to such websites are solely for your convenience. takes appropriate security measures to protect Personal Data against unauthorized access, alteration, disclosure or destruction.

Such measures include internal reviews of’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. 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 GDPR is a data processor and not the data controller for Users’ Personal Data. This means that performs operations on Personal Data, but it does not control your Users’ Personal Data. With respect to Users’ Personal Data, the controller is the party whose business provides the User with the Services.

If you are a User that uses the Services, by accessing the Services, you may be sharing your Personal Data with such business. The business’ use and disclosure of Users’ 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, is not an affiliate of such business and is not responsible for the business’ access, use, and disclosure of Users’ Personal Data. processes Personal Data only for the purposes for which it was collected and in accordance with this Privacy Policy. 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 has access to, or processes Personal Data for individuals who are subject to GDPR, that is, Personal Data originating from the European Union, will adhere to the requirements of GDPR. may transfer your Personal Data to countries other than the one in which You live.

You may have the right to access your Personal Data and require to update, delete or correct this information. The Services permit you to update this information directly. To the extent you are a User and you do not have access to do so directly through the Services, you may contact the business that provided you with access to to update your Personal Data. You may e-mail for further access and assistance if the business that provided you with access to is unable to update your Personal Data. We will take commercially reasonable steps to update or correct Personal Data in’s possession.

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: by contacting the business that provided access to; or, if the business that provided you with access to is unable to update your Personal Data then you may contact to update your Personal Information.


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 Pulse Technology Platform Inc.

Attention: Privacy officer

#500 2700 Production Way
Burnaby BC Canada V5A 0C2