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Privacy Policy - Website





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: (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. 

2.Personal Information We Collect

By "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;

  • Name;

  • Email Address;

  • Phone number;

  • 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 ") (better known by the English name "chatbot").

3.Your Consent

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 and 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.

4.Security and governance

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

In terms of administrative measures, we have adopted policies that provide for the following:

  • The framework applicable to the use, communication, retention and destruction of Personal Information;

  • The roles and responsibilities of our employees throughout the life cycle of this information;

  • A process for handling complaints about the protection of this information.

At the technological level, we are implementing the following measures:

  • SSL (Secure Sockets Layer) protocol;

  • Access management - authorized person;

  • Access management - data subject;

  • Network monitoring software;

  • Computer backup;

  • Development of digital certificate;

  • Login password;

  • Firewalls.

5. Use of Personal Information

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 penalties.

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.

6.Communication of your Personal Information

To whom? 

We may disclose Personal Information to third parties in specific circumstances permitted by law. In the table below, we summarize these circumstances and the steps we take to protect Personal Information.


    • To subcontractors and agents.

  • Purpose

    • We sign contracts with subcontractors and agents in order to provide you with a service and/or improve existing services. 

  • Measures

    • A contract requires subcontractors to:​

      • Use only the Personal Information necessary to provide the service;  

      • Refrain from disclosing or communicating Personal Information without our consent;

      • Implement rigorous security measures; 

      • Allow us to audit these measures; 

      • Notify us immediately of a privacy incident;

      • Destroy Personal Information at the end of a contract.


    • To another party in a business transaction. 

      • Such a transaction is defined as the alienation or rental of all or part of our business or its assets, a modification of our legal structure by merger or otherwise, the obtaining of a loan or any other form of financing or security taken to guarantee one of our obligations (hereinafter the “business deal ").

  • Purpose

    • Conclude a Business Transaction.

  • Measures

    • A contract obliges the other party to:

      • Use only the Personal Information necessary to conclude the Commercial Transaction;

      • Implement rigorous security measures;

      • Refrain from disclosing or communicating Personal Information without our consent;

      • Notify us immediately of a privacy incident;

      • Destroy the Personal Information if the Commercial Transaction is not concluded or if it is no longer necessary for its conclusion.


    • To legitimate authorities.

  • Purpose

    • In order to comply with an order or decision of a court, including a valid search warrant, or regulatory authority, we may be required to provide Personal Information.

  • Measures

    • The laws that govern these authorities require them to put measures in place to respect and preserve the confidentiality of your Personal Information.

    • In general, we refuse to grant access if the request is not legally binding. 



    • To our lawyers or prosecutors.

  • Purpose

    • In order to ensure our defense or to assert our rights, it is possible that we communicate, in certain cases, your Personal Information.

  • Measures

    • Both the law and the retainer letters we sign require our lawyers to protect the confidentiality of all of our communications with them.

·Or ?

As part of the provision of our services, we may communicate Personal Information outside of Quebec, in particular in the following regions:

  • Europe;


  • Canada.


Before disclosing Personal Information outside of Quebec, we will conduct a privacy impact assessment that will take into account:

  • The sensitivity of the Personal Information;

  • The purpose of their use;

  • The protection measures from which they will benefit; And

  • The legal regime applicable in the State where this Personal Information will be communicated.

We will only proceed with this communication if this evaluation demonstrates that the Personal Information will benefit from adequate protection with regard to the principles of protection of Personal Information generally recognized. In addition, this communication must be the subject of a written contract that takes into account all the conclusions of the evaluation.  


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.

If you request the destruction of your Personal Information, we will use reasonable efforts to comply with this request as soon as possible. The deletion of your Personal Information is made within 30 days of the request.

8.Your rights


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, where applicable, 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. To this end, we keep a register which lists all confidentiality incidents and we assess the damage they may cause. 

You can exercise these rights by sending an email to the email 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.

Subject to the restrictions provided by law, in the event of a refusal to provide you with or to correct your information, we will communicate to you the reasons in support of this refusal, information on your recourses as well as the applicable articles of the law.

If we refuse to rectify your Personal Information, we will allow you to place in your file written comments regarding the Personal Information that was the subject of the refusal of rectification. We will also retain Personal Information that has been the subject of an access request for as long as necessary to allow you to exhaust the remedies provided by law.

9.Cookies (Cookies)

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; And

  • The content viewed and downloaded on our Website or the number of visits.

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

  • Technical cookies : Technical cookies are used throughout navigation to facilitate the use of our Website. For example, a technical cookie can be used to remember your user name to facilitate your connection, to remember your preferences or the options chosen;

  • Analytics cookies : These cookies are anonymous and are used to collect statistics on the use of our Website;

  • Advertising cookies : These cookies may be set by the Website or by other sites serving advertisements or advertisements. These cookies collect information anonymously and build your visitor profile. 

If you wish, you can configure your browser to notify you when you receive cookies or to refuse them. It is possible to erase cookies from your computer's hard drive, block the creation of cookies or receive a warning before a cookie is stored.

However, in doing so, your use of our Website may be affected and you may no longer have access to all of its functions. We invite you to visit the sitesAds Setting AndNetwork Advertising Initiative as well as the instructions or help section of your browser for more information on cookies.

10. Personal Information Protection Officer

The Personal Information Protection Officer at Traction is Dave Renouf.

For any question or request relating to the Policy, you can send an email to the following address: perso “at”


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.

This Privacy Policy was last modified on April 6, 2023.

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