Privacy Notice.

1. Introduction

This Privacy Notice for TRACTIONCORE ("we," "us," or "our") describes how and why we access, collect, store, use, disclose, protect, and otherwise process personal information when you use our services ("Services"), including when you:

• Visit our website at https://www.tractioncore.com (the "Service")
• Register in our talent database or partnership programs
• Engage with us for revenue operations, workforce solutions, consulting, sales, marketing, or events
• Communicate with us directly or through integrated third-party platforms

We are committed to protecting your privacy and handling personal information responsibly and lawfully, including in compliance with the Philippines Data Privacy Act of 2012, United States Federal and State privacy laws, GDPR / UK GDPR, Australia Privacy Act 1988, South Africa POPIA, and other applicable international data protection regulations.

2. Global applicability

This Privacy Notice is intended to apply globally. Where local data protection laws impose additional requirements beyond those described here, we apply such requirements to the extent applicable to individuals in those jurisdictions, including but not limited to the United States, European Union, United Kingdom, Australia, South Africa, Canada, and Singapore.

3. Questions or concerns?

Reading this Privacy Notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you have questions or concerns, please contact us at privacy@tractioncore.com.

4. Summary of key points

What personal information do we process?

We process information you voluntarily provide (such as names, contact details, resumes, job titles, professional credentials, and payment details) and information collected automatically (such as IP addresses, cookies, device data, and usage data) to operate our website, facilitate talent matching, deliver revenue operations services, conduct analytics, ensure security, and meet legal obligations.

Do we process sensitive personal information?

We may process professional credentials, background checks, compensation data, or similar employment-related information strictly where required for talent placement or compliance. We do not intentionally process special categories of sensitive personal data (e.g., race, religion, health data, biometric identifiers) unless required by law in the relevant jurisdiction.

How do we keep your information safe?

We use administrative, technical, and physical safeguards such as encryption, access controls, secure cloud infrastructure, firewalls, and staff confidentiality obligations, aligned with recognized international security standards. See our Data Security Protocol.

What are your rights?

Depending on your location, you may have rights to access, correct, delete, restrict, object to processing, withdraw consent, or request portability of your personal data.

5. What information do we collect?

Personal information you disclose to us

We collect personal information that you voluntarily provide when you register, apply, engage in partnerships, request services, or contact us, including:

• Identifying information such as your full name, email address, phone number, and business or postal address.
• Professional information including your resume or CV, job titles, skills, certifications, work history, assessments, and salary or compensation expectations.
• Billing details, payment information, and payroll-related data where necessary, which are processed through secure third-party payment processors.
• Information contained in emails, inquiries, support messages, feedback, and other correspondence you send to us.

Information automatically collected

When you access or use our Services, we automatically collect:

• Information relating to how you access and use our Services, including your IP address, browser type, access timestamps, pages viewed, and interaction patterns, in order to monitor performance, maintain security, and improve functionality.
• Information about the device you use to access our Services, such as your operating system, unique device identifiers, and hardware and software characteristics, to ensure compatibility, optimize performance, and prevent misuse.
• Approximate geographic location information derived from your IP address, such as city or country-level data, to support security measures, analytics, and service improvement.
• We use cookies, pixels, web beacons, and similar technologies to enable essential site functionality, analyze usage trends, measure advertising effectiveness, enhance performance, and protect the security of our Services.

Important: You may configure your browser to refuse cookies. Certain features of the Services may not function properly without them. See our Cookie Policy for details.

6. How do we process your information?

We process personal information in order to provide, operate, maintain, and secure our website and Services, including ensuring functionality, reliability, and protection against unauthorized access or misuse. Personal data is used to facilitate offshore talent matching and workforce partnerships, deliver revenue operations, consulting, and support services, and manage ongoing business relationships. We also process information to improve, personalize, and expand our offerings, analyze usage trends, and develop new products, services, and features.

In addition, we use personal information to communicate with users directly or through authorized partners regarding service-related matters, operational updates, and permitted marketing communications. Where applicable, we process information to complete transactions, manage billing and payroll obligations, detect and prevent fraud or security incidents, and comply with applicable legal, regulatory, and contractual requirements.

7. Legal bases for processing

We process personal information only when permitted by applicable law and where a valid legal basis exists. This includes situations where you have provided your consent, where processing is necessary to perform a contract or take steps at your request before entering into a contract, and where processing is required to support our legitimate business interests, such as operating and securing our Services, conducting analytics, improving functionality, and preventing fraud.

We may also process personal information where necessary to comply with legal, regulatory, or statutory obligations under the laws of the Republic of the Philippines and other applicable international data protection frameworks.

8. When and with whom do we share your information?

We may share personal information with clients or talent partners where necessary to support workforce placement, talent engagement, and related business relationships. We may also share personal information with trusted service providers who perform services on our behalf, including cloud hosting providers, customer relationship management and communication platforms, email marketing services, secure payment processors, and content delivery networks, solely to support the operation, security, and delivery of our Services. In addition, we may share information with analytics and advertising providers, such as website analytics tools and advertising technologies, to help us understand usage patterns, improve performance, and measure the effectiveness of our communications.

Personal information may also be disclosed to business counterparties in connection with a merger, acquisition, restructuring, or sale of all or part of our business or assets. Finally, we may disclose personal information to government authorities, regulators, law enforcement, or other third parties where required to comply with applicable laws, regulations, legal processes, or enforceable governmental requests.

We do not sell personal information.

9. Data retention

We retain personal information only for as long as necessary to fulfill the purposes described in this Privacy Notice, including maintaining active accounts or partnerships, fulfilling contractual obligations, complying with legal and regulatory requirements, and resolving disputes or enforcing agreements.

In general, personal information related to website usage, inquiries, marketing communications, and inactive accounts is retained for up to twenty-four (24) months from the date of last interaction, unless a longer retention period is required or permitted by law. Personal information related to contracts, financial records, payroll, invoicing, and other legally significant business records may be retained for up to seven (7) years, as required under applicable accounting, tax, employment, or regulatory laws.

When personal information is no longer required for a legitimate business or legal purpose, we securely delete, de-identify, or anonymize it in accordance with applicable laws and internal data retention policies.

10. Data security

We implement reasonable and appropriate technical, administrative, and organizational safeguards to protect personal information. However, no method of electronic transmission or storage is 100% secure. Use of the Services is at your own risk, and we recommend accessing them only in secure environments. See our Data Security Protocol for further detail.

11. Your privacy rights

Depending on your jurisdiction, you may have the right to:

• Access and review personal data
• Correct inaccurate or outdated data
• Request deletion or anonymization
• Restrict or object to processing
• Request data portability
• Withdraw consent at any time

12. United States — state privacy rights

Depending on your U.S. state of residence, you may have additional rights under applicable state privacy laws (including California, Virginia, Colorado, Connecticut, Texas, and others), such as the right to confirm processing, access personal data, request correction or deletion, obtain a portable copy, and opt out of targeted advertising or certain data processing activities. We will honor such rights where required by law.

13. GDPR / UK GDPR (EEA & UK residents)

Residents of the EEA and the United Kingdom have enhanced rights under GDPR and UK GDPR, including rights related to profiling and automated decision-making. See our dedicated GDPR page for details.

14. CCPA / CPRA (California residents)

California residents have the right to know, delete, correct, and opt out of the sale or sharing of personal information, and will not be discriminated against for exercising their rights. See our dedicated CCPA / CPRA Privacy Notice for details. Requests may be directed to privacy@tractioncore.com.

15. Children's privacy

Our Services are not intended for individuals under the age of 18. We do not knowingly collect personal data from children. If such information is identified, it will be promptly deleted.

16. International data transfers

Your personal information may be transferred to and processed in countries outside your jurisdiction. Where required, we rely on appropriate safeguards such as contractual protections, Standard Contractual Clauses, or equivalent legal mechanisms to ensure consistent protection of personal data.

17. Governing law and dispute resolution

This Privacy Notice is governed by the laws of the Republic of the Philippines. Any disputes relating to this Notice shall be subject to the exclusive jurisdiction of the courts of Quezon City, Philippines, or resolved through binding arbitration as provided in our Terms of Service.

18. Changes to this Privacy Notice

We may update this Privacy Notice from time to time. Updates will be posted on this page with a revised "Last Updated" date. Continued use of the Services constitutes acceptance of the updated Privacy Notice.

19. Contact us

Questions about this Privacy Notice may be directed to our Data Protection Officer using the details below.