CCPA / CPRA Privacy Notice.

1. Scope and application

This California privacy notice ("CCPA/CPRA Notice") is provided by TRACTIONCORE ("we," "us," or "our") and applies to California residents whose personal information we collect, and to the extent required by the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act of 2020 ("CCPA/CPRA"). It supplements our Privacy Notice and should be read together with it. Where this CCPA/CPRA Notice conflicts with the general Privacy Notice, this Notice controls for California residents.

This Notice also serves as our Notice at Collection for the categories of personal information described below.

2. Definitions

• Personal Information means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked with a particular California resident or household.
• Sensitive Personal Information includes government identifiers, account log-in and financial credentials, precise geolocation, racial or ethnic origin, religious beliefs, health data, and information about sex life or sexual orientation, as further defined by the CPRA.
• Sell means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating personal information to a third party for monetary or other valuable consideration.
• Share means sharing personal information with a third party for cross-context behavioral advertising, whether or not for monetary consideration.

3. Categories of personal information we collect

The table below summarizes the categories of personal information we may have collected in the preceding twelve (12) months, the sources, the business or commercial purposes, and the categories of third parties to whom we disclose it. This is a good-faith summary and may be updated as our services evolve.

4. Sensitive personal information

We may process sensitive personal information only as necessary for the purposes described above, including government identifiers and financial account information where required for contracts, billing, payroll, or compliance, and background-check information strictly where required for talent placement or as required by law. We do not use or disclose sensitive personal information for the purpose of inferring characteristics about you beyond what is permitted by the CPRA.

5. How we use personal information

• Providing, operating, maintaining, and securing our website and services;
• Facilitating talent matching, workforce partnerships, and engagement delivery;
• Communicating with you and administering accounts and relationships;
• Processing payments, billing, and payroll-related obligations;
• Analytics, improving and personalizing our offerings, and developing new services;
• Fraud prevention, security, and incident detection and response;
• Complying with legal, regulatory, and contractual obligations.

6. How we disclose personal information

We may disclose personal information to the following categories of third parties for business or commercial purposes: service providers and contractors (such as cloud hosting, CRM and communications, marketing automation, analytics, security, verification, and payment processors); Clients and talent partners where necessary to support an engagement; professional advisers and auditors; and government authorities or regulators where required by law. Each recipient is bound by contractual obligations that restrict its use of personal information.

7. Sale and sharing of personal information

TRACTIONCORE does not sell personal information in the ordinary course of our business, and we do not sell personal information of consumers we know to be under 16 years of age.

Certain cookies and similar technologies may constitute "sharing" for cross-context behavioral advertising (as defined under the CPRA) where enabled. Where this applies, you have the right to opt out of sharing, and you may exercise that right as described in Section 9. See our Cookie Policy for details on the cookies we use.

8. Your California privacy rights

Subject to applicable law and certain exceptions, California residents have the right to:

• Right to know and access — the categories and specific pieces of personal information we have collected, the sources, the purposes, and the categories of third parties to whom we disclose it.
• Right to delete — request deletion of personal information we have collected from you, subject to legal exceptions.
• Right to correct — request correction of inaccurate personal information.
• Right to opt out of sale or sharing — direct us not to sell your personal information or share it for cross-context behavioral advertising.
• Right to limit use and disclosure of sensitive personal information — limit our use of sensitive personal information to the purposes permitted by the CPRA.
• Right to data portability — receive the personal information you provided in a readily usable format, where technically feasible.
• Right to non-discrimination — we will not discriminate against you for exercising your privacy rights.
• Right to information about automated decision-making — where we use automated decision-making technology, you may request meaningful information about the logic involved and your rights in relation to it.

9. How to exercise your rights

You may exercise your rights by contacting us at privacy@tractioncore.com. We will confirm receipt within ten (10) business days and respond to a verifiable request within forty-five (45) calendar days, which may be extended by an additional forty-five (45) days where reasonably necessary, with notice to you.

To protect your privacy, we must verify your identity before fulfilling a request. Verification may require matching information you provide against our records, and for certain requests we may ask for additional information. You may also use an authorized agent to submit a request on your behalf, provided the agent is authorized in writing and we can verify your identity.

10. Do not sell or share / limit use of sensitive personal information

We do not sell personal information. To opt out of sharing personal information for cross-context behavioral advertising, or to limit the use and disclosure of sensitive personal information, you may:

• Email privacy@tractioncore.com with your request;
• Adjust your cookie preferences through our cookie settings interface (where available) or your browser settings; or
• Use a recognized opt-out preference signal as described in Section 11.

11. Global Privacy Control

We honor the Global Privacy Control (GPC) opt-out preference signal as a valid request to opt out of sale or sharing for the browser or device on which it is enabled, where technically supported. If you use a GPC-enabled browser or extension, we will treat the signal as an opt-out request consistent with applicable law.

12. Verification and authorized agents

Requests must be verifiable. We will not fulfill a request if we cannot verify your identity or authority to make the request and confirm that the personal information relates to you. Where you use an authorized agent, we may require proof of authorization and may contact you directly to confirm the request.

13. Retention

We retain personal information only for as long as reasonably necessary for the purposes described in this Notice and our Privacy Notice, or as required by law. Retention periods are determined by the nature of the information and the purpose for which it was collected, and information is securely deleted, de-identified, or anonymized when no longer required.

14. Children's privacy

Our services are not directed to individuals under 18, and we do not knowingly sell or share the personal information of consumers under 16 years of age. If we learn that we have collected personal information from a child under the age of 13 without appropriate consent, we will delete it.

15. Non-discrimination and financial incentives

We will not deny you goods or services, charge different prices or rates, provide a different level or quality of goods or services, or suggest that you will receive a different price or quality, for exercising your California privacy rights. We do not currently offer financial incentives in exchange for personal information.

16. Contact us

For questions about this CCPA/CPRA Notice or to exercise your rights, contact our Legal and Compliance Department using the details below.

Legal advice notice: This page describes our privacy practices and compliance posture in good faith and does not constitute legal advice. It does not expand any rights beyond those provided by applicable law.