TRACTICS

Tractics, Inc. (also referred to as “Tractics” or “we” or “us” or “our”) is a technology company that provides project management tools for heavy and civil construction companies. This privacy policy (“Privacy Policy”) covers how we may collect, store, use, and share information, including Personal Information collected on behalf of our Customers, when you access or use our website (https://tractics.io) or applications (the “Site”), or our construction project management tools (collectively, the “Services”). By accessing the Site or using the Services, you agree to our collection, use, and disclosures of your information as outlined in this Privacy Policy. If you access our Services through your employer or another entity (our “Customer”), note that this data and your account are controlled by the Customer and we process this data at their direction.

1  INFORMATION WE COLLECT & HOW WE COLLECT IT

a. Information you provide directly. We may collect or receive the following categories of personal information when you, your employer, or your employer’s designated administrator access the Site, request to receive information about Tractics or its Services, create an account, verify your identity, use any of the Services, or otherwise communicate with us, including through customer support channels.

i.    Identification Information, such as name, address, email, phone, etc.
ii.   Work details, such as employee ID, hours, location, jobs, tasks, wages, etc.
iii.  For employers, details about business processes, equipment owned, financial information, employee details, etc.
iv.  Electronic files such as resumes, photos, emails, etc.
v.   Other information you voluntarily provide, such as feedback, job applications, event or webinar attendance, etc.

b.   Information collected automatically.

i.    Electronic and online identifiers (IDs), such as mobile device, carrier,
device ID, mobile advertising IDs, operating system, Internet Protocol (IP) address
ii.    Geolocation information
iii.   Driving data, including, but not limited to, dash cam video, braking patterns, harsh driving, etc.
iv.   Internet and app usage information, such as your log-in and log-out information, pages visited before, during, and after using our Services
v.   Single Sign-On Information (SSO) that allows us to verify your authorized access to the Services from another service you use and with which we partner.
vi.  Information collected using cookies and pixels, which we call Tracking Technologies. Data collected with Tracking Technologies may help us to provide access to our Site or Services, detect against illegal or fraudulent behavior, analyze Site or Service performance, enhance Site or Service functionality, and/or target advertising.

1. 1. 1. Visitors are informed about the use of cookies and can choose to accept or decline them.
      2. Cookies are small text files that contain a string of alphanumeric characters. Cookies may be “session,” which are deleted when you close your browser or “persistent,” which help us manage the opt-out process for our Services and remain on your device until you delete them, or they expire.
      3. Pixels, which collect information about engagement on our Site or with emails

vii.   Analytics

1. 1. 1. Reports for Customer. Creation of one-time or automated reporting analyzing estimate vs. actuals, profitability, opportunities for optimization, etc.
      2. Internal Site Analytics. Our Site uses Google Analytics to gather data on visitor demographics, device types, referral sources, and overall site performance to better understand the audience and improve the functionality and content.

vii.   Social media platforms. Our Site or Services may contain social media buttons such as Facebook, LinkedIn, and Instagram (that might include widgets such as the “Share” button or other interactive programs). These features may collect your IP address, which page you are visiting on our Site or Service, and may set a cookie to enable the feature to function properly. Your interactions with these platforms are governed by the privacy policy of the company providing it.

c.    Information collected from third parties. We may collect and receive information about you, including personal information, from third parties, such as your employer or your employer’s service providers, or your business vendors or service providers (e.g., payroll and HR platforms, accounting systems, etc.), for the purposes described in this Privacy Policy.

2.  HOW WE USE YOUR INFORMATION

a.   To develop and provide you with the Site and Services, including to operate, improve, personalize, and enable use of the Site and Services.
b.   If you download the Tractics application (the “App”), we will request access to your device location. If you grant the App access to your device location we will be able to track the physical location of your device using GPS and WiFi signals. We use this information to provide the Services. You can remove or restrict the App’s access to your device location at any time by changing your privacy settings on your device or within the App. Restricting access to your device location may limit the features and functionality of the Services you can use.
c.   To protect Tractics and comply with applicable law, regulation, or legal process, including:

i.   Validate user information for fraud and risk detection purposes
ii.   Resolve disputes
iii.  Respond to claims and legal process (such as subpoenas)
iv.  Monitor and enforce compliance with the applicable Terms of Service
v.  Prevent or stop any activity that may be illegal, unethical, or legally actionable

d.   To operate our business, including managing contracts, compliance, auditing, recruiting, or aggregate data
e.   To communicate with you as part of the Services, including to respond to questions or inquiries, provide notices, or collect feedback
f.   To understand and analyze how you use our Site
g.   To advertise or market to you.
h.   To help Tractics, your employer, or our third-party providers understand driving conditions and behaviors, traffic information, opportunities for improvement and optimization, and more
i.   For any other purpose for which you, your employer, or your employer’s third party expressly authorize us to use your information.

Information is retained only as long as required to complete the Services or the work related to the purpose of the collection, and for a reasonable time thereafter for auditing purposes.

3. DISCLOSURE OF INFORMATION

We share your information with the categories of third parties listed below for the purposes described above in Section 2, “How We Use Your Information” section, unless otherwise noted at the point of collection.

a.   Service Providers that have signed an agreement with us that limits how they use your information and promises to keep your information confidential. Examples include companies that provide services such as cloud storage (e.g., AWS) and customer management (e.g., Zoho).

b.  With our Advertising Partners to provide relevant advertising to interested parties.

c.  With our Customers to carry out the purpose of software subscription.

d.  Location Information. If you download the Tractics application (the “App”), we will request access to your device location. If you grant the App access to your device location, we will be able to track the physical location of your device using GPS and WiFi signals. We use this information to provide the Services. You can remove the App’s access to your device location at any time by changing your privacy settings on your device, and/or you may also permit the App to only track your location under specific conditions by changing your privacy settings within the App. Not enabling access to your device location may limit the features and functionality of the Services that you can use.

e.  Our Company may share user information with government agencies at the request of our Customers in connection with auditing, compliance with federal wage requirements, and other related legal obligations. Such disclosures will only be made when required by law or when requested by our Customers to fulfill their legal or regulatory duties. We will take reasonable steps to ensure that any information shared is limited to what is necessary for these purposes and that it is handled securely in accordance with applicable privacy laws.

f.  For the fulfillment of our customer referral program.

g.  For any other purpose and to any other person with whom you, your employer, or your employer’s third party expressly authorize us to share your information.

4.  YOUR PRIVACY CONTROLS

If you wish to prevent cookies from tracking your activity on our Site, you can set your browser to block cookies or notify you when a cookie is set. If you block cookies, certain features on our Site may not work. For more information on how you can customize your browser’s cookies setting, please visit the link to your web browser below:

• Google Chrome. For more information, visit Google Chrome
• Internet Explorer. For more information, visit Internet Explorer
• Mozilla Firefox. For more information, visit Mozilla Firefox
• Safari – Desktop. For more information, visit Safari (Desktop)
• Safari – Mobile. For more information, visit Safari (Mobile)
• Android – Browser. For more information, visit Android Browser

If you’d like to opt out of having Tractics collect your information, visit our opt-out page. When you opt out, we will place an opt-out cookie on your computer that tells us not to collect your information. Note that if you delete, block, or otherwise restrict cookies, or if you use a different computer or Internet browser, you may need to renew your opt-out choice.

Additional Information for California Residents

Your rights may vary depending on your location. This section of the Privacy Policy provides additional information for residents of California, as directed by the California Consumer Privacy Act of 2018 (“CCPA”). To the extent we process your Personal Information as part of the Services for one of our Customers, we are not permitted to fulfill your request unless directed to do so by that Customer. This means we may have to forward you to that Customer for you to make your rights request.

Categories of Personal Information Collected:

Category	Tractics collects?	Tractics discloses to Customer?
Identifiers and Contact Information (e.g., name, email)	Yes	Yes
Protected classification information	No	N/A
Internet or other electronic network activity	Yes	Yes
Geolocation data	Yes	Yes
Biometric information	No	N/A
Professional and employment-related information	Yes	Yes
Education information	No	N/A

CCPA grants California residents the right to submit a verifiable request for the following, free of charge:

• Right to know: You can request that we disclose to you: (1) the categories and/or specific pieces of personal information we have collected about you, (2) the categories of sources for that personal information, (3) the purposes for which the business uses that information, (4) the categories of third parties with whom we disclose the information, and (5) the categories of information we sell or disclose to third parties. You can make a request to know up to twice a year, free of charge.
• Right to delete: You can request that we delete personal information we collected from you and tell our service providers to do the same, subject to certain exceptions (such as if we are legally required to keep the information).
• Right to opt-out of sale or sharing: You may request that we stop selling or sharing your personal information (“opt-out”). Following a successful opt-out, we cannot sell or share your personal information unless you later authorize us to do so again.
• Right to correct: You may ask us to correct inaccurate information that we have about you.
• Right to limit use and disclosure of sensitive personal information: You can direct us to only use your sensitive personal information (for example, your precise geolocation data) for limited purposes, such as providing you with the services you requested.

This section does not apply to personal information collected from residents of California who are Tractics’ job applicants, independent contractors, current or former employees, officers, investors, and the like.

To exercise these rights, you may:

• Visit our CCPA Request Page
• Email privacy@tractics.io – include your name, email address, and a telephone number where you can be reached regarding your request
• Call (816) 762-5001 and press 0 to leave your contact information for a return call

We will respond to all verifiable requests as required by the CCPA. Consumers have the option to designate an authorized agent to make a request on your behalf; we require proof of this authorization before proceeding with the request.

We will not discriminate against any consumer for exercising their rights under the CCPA.

5.  INFORMATION SECURITY

We take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. These include internal reviews of our data collection, storage and processing practices and security measures, as well as physical security measures to guard against unauthorized access to systems where we store personal data, as well as audits by a third party. This includes but is not limited to the use of firewalls and encryption. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while we strive to use commercially acceptable means to protect your information, we cannot guarantee its absolute security. If you have any questions about our security practices, please send an email to us a privacy@tractics.io. If you become aware of any breach of security or privacy, please notify us immediately. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized disclosure.

6.  CHILDREN’S INFORMATION

The Services are not directed to children under 16 and we do not knowingly collect data from or target children under the age of 16, nor do we have actual knowledge of any sale of personal information of children under 16. If you are a parent or legal guardian and believe we may have collected any information about your child, we strongly encourage you to contact us (privacy@tractics.io) immediately to have the data deleted.

7.  LINKS TO OTHER SITES

This Privacy Policy only covers the privacy practices of Tractics. It does not apply to the practices of third-party websites, services, or applications, even those who we have partnered or integrated with. Third-party services handle your information in accordance with their own practices and privacy policies. We are not responsible for their policies, practices, or handling of your information.

8.  CHANGES TO THIS PRIVACY POLICY

Any information that we collect is subject to the Privacy Policy in effect at the time such information is collected. We may, however, modify and revise our Privacy Policy from time to time. If we make any material changes to this policy, we will notify you of such changes by posting them on the Site, informing you through the Services, or sending you an email or other notification, and we will indicate when such changes will become effective. By continuing to access or use the Site or the Services after those changes become effective, you agree to be bound by the revised policy.

9.  CONTACT INFORMATION

If you have any questions about our privacy practices or this Privacy Policy, or to exercise your privacy rights as detailed in this Privacy Policy, please contact us at:

TRACTICS
Attn: Privacy Director
14 W 3^rd Street, Suite 200
Kansas City, MO 64105