Privacy Policy

Tractian and its affiliates (“we”, “our”, or “us”) acknowledge the responsibility to treat any and all personal data ethically and securely, in compliance with applicable Data Protection Laws and equivalent standards. Tractian’s Privacy Policy (“Policy”) reflects our commitment to transparency in Personal Data Processing, aiming to protect Data Subjects’ rights and ensure that the collected data is used responsibly for the benefit of innovation and operational efficiency.

Tractian is a global technology company providing industrial asset monitoring, maintenance management, reliability, and operational intelligence solutions through intelligent sensors integrated with a proprietary artificial intelligence-based platform.

We operate globally with a commitment to delivering innovative technologies that increase the efficiency, safety, reliability, and predictability of maintenance and industrial operations.

Tractian is composed of the following legal entities, each responsible for operations within its respective jurisdiction:

Depending on the nature of the processing activity, Tractian may act as a Controller, Joint Controller, or Processor:
• Controller / Joint Controller — Tractian acts as a Controller when it determines the purposes and means of processing Personal Data, including in connection with marketing activities, recruitment processes, website administration, information security activities, supplier management, business operations, compliance obligations, and other activities carried out on its own behalf.
• Processor — Tractian acts as a Processor when processing Personal Data submitted by or on behalf of a Customer through the Services and only processes such information in accordance with the Customer’s instructions and applicable contractual commitments.

Where Tractian acts as a Processor, the relevant Customer remains responsible for determining the purposes and means of processing Personal Data and for complying with its obligations as Controller under applicable data protection laws. Individuals seeking to exercise rights relating to Customer Data may need to direct their requests to the relevant Customer acting as Controller on whose behalf we act as a Processor.

Additional information regarding jurisdiction-specific requirements and the applicable Tractian entity may be found in Section 15 (Additional Information for Certain Jurisdictions).

For purposes of this Privacy Policy, the following terms and definitions apply:

• Aggregated Data Information that has been combined or summarized so that it does not identify, and cannot reasonably be used to identify, an individual, Customer, asset, equipment, or industrial process.
• Applicable Data Protection Laws All privacy, data protection, cybersecurity, and related laws and regulations applicable to the Processing of Personal Data, including, where relevant, the GDPR, UK GDPR, LGPD, CCPA/CPRA, U.S. state privacy laws, and other applicable regulations.
• Authorized User An employee, contractor, representative, agent, or other individual authorized by a Customer to access or use Tractian’s Products or Services on behalf of the Customer.
• Business Contact Information Professional or business-related information, such as name, business email address, business telephone number, employer, job title, department, and other information associated with an individual’s professional role.
• Controller The entity that determines the purposes and means of Processing Personal Data, and includes equivalent terms such as “business” under applicable data protection laws.
• Cookies Small text files or similar technologies stored on or accessed from a user’s device to enable websites and applications to function, recognize devices, remember preferences, analyze usage, support security, measure campaign performance, and provide or personalize content and advertising, where permitted by applicable law.
• Customer Any organization, company, entity, or individual acting on behalf of an organization that purchases, subscribes to, evaluates, accesses, or uses Tractian’s Products or Services. For purposes of Tractian’s contractual documents, a Customer may also be referred to as a “Client.”
• Customer Data Information, data, or content submitted, provided, collected, stored, or otherwise made available to Tractian by or on behalf of a Customer in connection with the Products or Services, which may include Personal Data.
• Data Security Incident An actual unauthorized access to, destruction of, loss of, alteration of, exfiltration of, theft of, or disclosure of Personal Data processed by Tractian, where such incident is subject to notification or remediation obligations under applicable law.
• Data Subject An identified or identifiable natural person whose Personal Data is processed by Tractian. Depending on the applicable law, a Data Subject may also be referred to as a “consumer” or similar term.
• De-Identified Data Information that has been de-identified, anonymized, or otherwise processed so that it cannot reasonably be used to identify an individual, whether directly or indirectly, and that Tractian maintains and uses in de-identified form except where re-identification is required or permitted by applicable law.
• Device Data Technical and usage-related information collected from devices, browsers, applications, systems, sensors, or networks, including IP addresses, device identifiers, operating systems, browser information, diagnostic information, and usage logs.
• Personal Data Any information relating to an identified or identifiable natural person, whether directly or indirectly identifiable, and includes “personal data,” “personal information,” or similarly defined terms under applicable data protection laws.
• Platform Tractian’s proprietary software platform, including web-based applications, dashboards, portals, mobile applications, and related services used to monitor assets, manage maintenance activities, analyze operational data, and provide insights to Customers.
• Processing / Process Any operation or set of operations performed on Personal Data, whether automated or manual, including collection, recording, organization, structuring, storage, adaptation, retrieval, consultation, use, disclosure, transfer, dissemination, alignment, combination, restriction, deletion, erasure, or destruction.
• Processor The entity that Processes Personal Data on behalf of and under the instructions of a Controller, and includes equivalent terms such as “service provider,” “contractor,” or similar terms under applicable data protection laws.
• Products Tractian’s hardware, software, applications, sensors, receivers, accessories, and related technologies made available to Customers in connection with the Services.
• Sensitive Personal Data Personal Data that is considered sensitive or subject to special protection under applicable data protection laws, including information relating to racial or ethnic origin, religious beliefs, political opinions, trade union membership, health, genetics, biometrics, sexual orientation, disability, or other categories designated as sensitive under applicable law.
• Services The services provided by Tractian to Customers, including software licensing, technical support, cloud-based services, mobile and web-based applications, hardware-related services, monitoring solutions, maintenance management solutions, and any related features, functionalities, support services, or offerings made available by Tractian.
• Subprocessor Any third party engaged by Tractian to Process Personal Data on behalf of Tractian in connection with the provision of the Services, excluding Tractian employees.
• Website Tractian’s websites, including www.tractian.com, its subdomains, localized websites, landing pages, and any other websites operated by or on behalf of Tractian that reference this Privacy Policy.

This Global Privacy Policy applies to all Personal Data collected, received, accessed, stored, used, disclosed, transferred, or otherwise processed by Tractian in connection with its business activities worldwide.

This Policy applies to Personal Data processed through:
• Tractian websites and online properties;
• software platforms and Software-as-a-Service (SaaS) solutions;
• cloud-based services and applications;
• mobile applications;
• hardware products and connected devices;
• customer support and service operations;
• marketing and communication activities;
• recruitment and talent acquisition processes;
• supplier, contractor, and partner management activities;
• events, webinars, and training programs;
• corporate and administrative operations; and
• any other products, services, technologies, or business activities operated by or on behalf of Tractian.

This Policy applies to Personal Data relating to:
• Visitors — Individuals who visit Tractian websites, interact with our digital properties, engage with our social media channels, attend events, or otherwise communicate with Tractian.
• Customers — Organizations and legal entities that purchase, subscribe to, evaluate, or otherwise use Tractian products and services.
• Authorized Users — Employees, contractors, representatives, agents, or other individuals authorized by Customers to access or use Tractian products and services on behalf of the Customer.
• Prospects and Marketing Contacts — Individuals who express interest in Tractian’s products, services, content, events, or marketing initiatives.
• Job Applicants and Candidates — Individuals who apply for employment, internship, contractor, or consulting opportunities with Tractian.
• Suppliers, Vendors, and Business Partners — Representatives, employees, contractors, and other individuals acting on behalf of suppliers, service providers, distributors, resellers, strategic partners, and other third parties with whom Tractian conducts business.

This Privacy Policy does not apply to the processing of Personal Data relating to Tractian employees, contractors, interns, and other workforce members in the context of employment or workforce management activities. Such processing is governed by Tractian’s Internal Privacy Policy and related Human Resources procedures.

The Personal Data we collect depends on your relationship with Tractian and the way you interact with our products, services, websites, facilities, and personnel.

The provision of Personal Data may be necessary for Tractian to provide its Products and Services, fulfill contractual obligations, respond to requests, or comply with applicable legal requirements. Where the provision of Personal Data is required to enter into or perform a contract or to respond to a request made by the individual, failure to provide such data may result in the inability to establish or maintain the contractual relationship or to deliver the requested Products, Services, or information.

In other cases, the provision of Personal Data is voluntary. However, failure to provide certain information may limit Tractian’s ability to respond to requests, provide relevant content, or deliver certain functionalities.

When organizations purchase, subscribe to, implement, or use Tractian Products and Services, we may collect and process Personal Data relating to customer representatives and Authorized Users.

Customer Data remains under the control of the Customer. Tractian processes Customer Data only as necessary to provide, maintain, support, secure, and improve the Services, and in accordance with applicable contractual commitments, including the applicable Data Processing Addendum.

Personal Data we may collect:
• Business Contact Information, such as name, business email address, telephone number, employer, department, and job title.
• Profile Information, such as signatures and photographs where applicable.
• Account and Authentication Information, such as authentication records, permissions, access rights, and account settings.
• Service Usage Information, such as platform activity, support interactions, operational records, and usage logs associated with the Services.
• User-Submitted Content, such as documents, information, files, and audio recordings voluntarily submitted through the Services.

Where required by applicable law, Tractian processes this Personal Data primarily for the performance of a contract or to take steps at the request of the Customer prior to entering into a contract. We may process this information to provide Products and Services, create and manage user accounts, identify and authenticate users, implement and configure Services, provide technical support, manage customer relationships, facilitate onboarding and training, manage billing and contractual relationships, improve Products and Services, maintain service quality and security, and provide functionality requested by Customers, including audio transcription features where applicable.

We may receive this information directly from Customers, directly from Authorized Users, from Customer administrators, through Product and Service usage, and through support interactions.

When individuals request demonstrations, download content, register for events, participate in webinars, complete forms, or interact with our sales and marketing teams, we may collect Personal Data.

We may collect:
• Business Contact Information, such as name, business email address, telephone number, employer, and job title.
• Location Information, such as city, country, and approximate geographic location.
• Marketing and Engagement Information, such as event participation, webinar attendance, campaign interactions, communication preferences, and marketing engagement data.
• Website Interaction Information, such as interactions with our Websites, landing pages, and marketing content.

Where required by applicable law, Tractian processes this Personal Data based on steps taken at the request of the individual prior to entering into a contract, as well as on consent, particularly for marketing communications, event registrations, and the use of Cookies and similar technologies where required by law.

We may process this information to respond to inquiries, schedule demonstrations, provide information regarding Products and Services, organize events and webinars, communicate marketing and promotional information, measure campaign effectiveness, understand customer interests, and improve marketing activities.

We may obtain this information directly from individuals, through Website forms, through event registrations, through Cookies and analytics technologies, and through advertising and marketing platforms.

When individuals visit Tractian websites, certain information may be collected directly or automatically through Cookies and similar technologies.

We may collect:
• Contact Information, such as name, email address, and telephone number.
• Professional Information, such as employer, company name, job title, and industry sector.
• Location Information, such as city and country.
• Communications and Submitted Information, including information contained in forms, surveys, registrations, support requests, and other interactions with Tractian.

Where required by applicable law, Tractian processes this Personal Data based on steps taken at the request of the individual prior to entering into a contract, as well as on consent, particularly where individuals voluntarily submit their information or register for events, communications, or other interactions.

We may process this information to respond to inquiries and requests, provide product demonstrations and consultations, manage customer and prospect relationships, deliver requested content and resources, register individuals for events, webinars, and training sessions, communicate regarding Products, Services, and updates, conduct marketing and business development activities, perform contractual and pre-contractual activities, and comply with legal and regulatory obligations.

We collect this information directly through Website forms, event registrations, webinar registrations, support requests, surveys and feedback submissions, and direct communications with Tractian.

Where permitted by applicable law and subject to applicable consent requirements, we may automatically collect:
• Device Information, such as device identifiers, browser type, operating system, and technical configuration data.
• Usage Information, such as pages visited, actions performed, browsing behavior, referring URLs, and interaction data.
• Network Information, such as IP address and related technical identifiers.
• Cookie and Tracking Information, including information collected through Cookies and similar technologies.
• Approximate Location Information, derived from IP address or device settings where available.

We may process this information to operate, maintain, and secure our Websites and Services, monitor system performance and availability, detect, prevent, and investigate fraud, abuse, and security incidents, analyze Website usage and engagement, improve functionality, user experience, and service performance, personalize content and communications where permitted by law, maintain audit logs and security records, and comply with legal, regulatory, and security requirements.

We collect this information through browsers and devices, Website logs, Cookies and similar technologies, analytics platforms, security monitoring tools, and advertising and marketing technologies.

When individuals apply for employment opportunities with Tractian, we may collect Personal Data necessary to evaluate and manage recruitment processes.

We may collect:
• Contact Information, such as name, email address, telephone number, and city.
• Professional and Educational Information, such as employment history, qualifications, certifications, education, and experience.
• Recruitment Information, such as interview notes, assessment results, references, and salary expectations.
• Diversity and Accommodation Information, including diversity, disability, and accessibility information voluntarily provided by candidates.
• Interview Information, including image and voice information collected during interviews.

Where required by applicable law, Tractian processes Personal Data collected in connection with recruitment activities based on steps taken at the request of the individual. For certain categories of Personal Data, including Diversity and Accommodation Information and Interview Information (such as image and voice recordings), processing is carried out based on the individual’s consent, where required by applicable law.

We may process this information to evaluate applications, assess qualifications, conduct interviews, communicate with candidates, manage recruitment processes, support diversity and inclusion initiatives, and comply with employment-related legal obligations.

We may receive this information directly from candidates, through recruitment platforms, through recruiters, and during interviews and assessments.

To establish and manage business relationships, we may collect Personal Data relating to vendors, suppliers, contractors, consultants, and business partners.

We may collect:
• Business Contact Information, such as name, email address, telephone number, employer, department, and job title.
• Identification Information, such as identification document information where required.
• Business Relationship Information, including contractual, payment, and supplier management information.

Where required by applicable law, Tractian processes this Personal Data based on the performance of a contract. We may process this information to conduct due diligence, manage supplier relationships, administer contracts, process payments, maintain business records, comply with legal obligations, and manage commercial relationships.

We may receive this information directly from the individual, from the individual’s employer, and from authorized representatives.

When individuals visit Tractian offices, laboratories, manufacturing facilities, or other locations, we may collect information necessary to manage access and maintain security.

We may collect:
• Visitor Identification Information, such as name, employer, visitor registration information, and identification document information.
• Access and Security Information, such as access-control records, visitor logs, and security-related information.
• Surveillance Information, such as CCTV recordings and images captured through security systems.
• Biometric Information, such as facial biometric information where access-control systems require its use and where permitted by applicable law.

Where required by applicable law, Tractian processes Personal Data based on the performance of a contract or procedures preliminary to entering into a contract, as well as on legitimate interests related to the prevention of fraud and the protection of the security of individuals.

We may process this information to manage physical access, protect personnel, protect facilities and assets, prevent unauthorized access, investigate security incidents, and comply with health, safety, and security requirements.

Information may be collected directly from visitors, through access-control systems, through visitor management systems, and through CCTV and security technologies.

Tractian does not require you to provide any sensitive data about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, health, genetics, or biometric data to use the Services.

Depending on the circumstances, this may include:
• disability-related information;
• accessibility-related information;
• diversity and inclusion information voluntarily provided; and
• facial biometric information used for access-control purposes.

Where required by applicable law, Tractian processes Sensitive Personal Data based on the explicit consent of the individual or, where applicable, where such processing is necessary for compliance with legal or regulatory obligations or for the prevention of fraud and the protection of the security, integrity, and safety of individuals.

We may process Sensitive Personal Data to provide accessibility accommodations, support diversity and inclusion initiatives, manage secure access to facilities, comply with legal obligations, and protect individuals and company assets.

Sensitive Personal Data is subject to enhanced security measures, including access restrictions, confidentiality obligations, and additional administrative, technical, and organizational protections.

Tractian may aggregate, anonymize, or otherwise de-identify Personal Data so that it can no longer reasonably be used to identify an individual.

Tractian may use Aggregated Data and de-identified information to operate, analyze, improve, develop, and enhance its products, services, technologies, security measures, artificial intelligence capabilities, business operations, and customer experience, as well as to conduct research, analytics, benchmarking, and other lawful business purposes.

Aggregated Data may be derived from Personal Data, including usage information, technical information, operational information, and interactions with Tractian’s Services. Such information may be collected through the Services, websites, Cookies, analytics tools, and other technologies described in this Privacy Policy.

Aggregated Data and de-identified information do not constitute Personal Data where they cannot reasonably be used to identify an individual, whether directly or indirectly.

Tractian may disclose, publish, distribute, or otherwise make available Aggregated Data to customers, business partners, service providers, researchers, industry participants, or other third parties, provided that such information does not identify any individual, Customer, Asset, Equipment, or Industrial Process. If Aggregated Data or de-identified information is combined with other information in a manner that allows an individual to be identified, Tractian will treat such information as Personal Data and process it in accordance with this Privacy Policy and applicable law. Tractian will maintain and use de-identified information in de-identified form and will not attempt to re-identify such information except where required or permitted by applicable law.

Tractian’s products and services are not directed to individuals under the age of 18 and are not designed to collect Personal Data from minors through their regular operation.

However, Tractian may process Personal Data relating to minors when such data is provided in the context of employment-related activities, including information regarding employees’ dependents, as permitted or required by applicable law and in accordance with Tractian’s internal privacy policies.

In such cases, Tractian processes this information only for legitimate business purposes, legal or regulatory compliance, administration of employment benefits, or other lawful purposes, and implements appropriate safeguards to protect the privacy and security of such data.

Where required by applicable law, minors may only access or use Tractian’s products and services with the involvement, supervision, and consent of a parent, legal guardian, or other authorized representative.

Tractian retains Personal Data only for as long as necessary to fulfill the purposes for which it was collected, as described in this Policy, or as otherwise required to comply with applicable legal, regulatory, contractual, or legitimate business obligations.

Once the applicable retention period has expired, or upon a valid request from the Data Subject where applicable, Personal Data will be disposed of in a secure and appropriate manner in accordance with applicable laws and industry standards, which may include anonymization in a manner reasonably incapable of being reidentified.

When determining appropriate retention periods, we consider various factors, including:
• applicable legal, regulatory, tax, accounting, and contractual requirements;
• the need to establish, exercise, or defend legal claims, as well as to support investigations or dispute resolution processes;
• the sensitivity of the Personal Data; and
• the purpose of the applicable processing activities and the necessity of maintaining accurate business, operational, and financial records.

In addition, Tractian maintains an internal data retention schedule that specifies retention periods and criteria applicable to different categories of Personal Data, based on legal, regulatory, and business requirements. Such schedules are periodically reviewed and updated to ensure ongoing compliance with applicable data protection laws and industry standards.

This section describes when Tractian may share Personal Data to fulfill the purposes described in this Privacy Policy and where there is an appropriate legal basis, legal obligation, or legitimate business need to do so.

Access to Personal Data within Tractian is restricted to authorized personnel who require such access to perform their responsibilities and who are subject to confidentiality obligations and applicable privacy and data protection requirements. Tractian may share Personal Data among its affiliates and group companies where necessary to support business administration, operational activities, information security, compliance functions, and the management of its global operations. Access to Personal Data remains restricted to authorized personnel who require such access to perform their responsibilities and who are subject to confidentiality obligations and applicable privacy and security requirements.

Where Tractian acts as a Controller or Joint Controller, Tractian may share Personal Data with third-party service providers that support the delivery of its products, services, and business operations. These providers may assist with cloud hosting and infrastructure, identity and access management, communications, customer support, analytics, recruitment activities, customer relationship management, marketing operations, and professional advisory services. Such providers are authorized to process Personal Data only on Tractian’s behalf and are contractually required to implement appropriate safeguards designed to protect the information they process.

Where Tractian acts as a Processor on behalf of a Customer, Tractian may engage Subprocessors to assist in processing Personal Data as necessary to perform its obligations under the applicable agreement. Subprocessors are contractually required to implement appropriate safeguards designed to protect the information they process.

Information regarding Tractian’s current Subprocessors is available through our Trust Center at https://trust.tractian.com/subprocessors.

For individuals who participate in SMS or RCS messaging programs, mobile phone numbers, messaging opt-in information, consent records, and related messaging data will not be shared with third parties or affiliates for their own marketing or promotional purposes. Such information is used solely to provide and manage the messaging services requested by the individual and to comply with applicable legal and regulatory requirements.

Tractian may share Personal Data with business partners where necessary to support service delivery, integrations, interoperability, contractual commitments, or joint business initiatives. Personal Data may also be disclosed to professional advisers, including legal counsel, auditors, insurers, accountants, and consultants, where necessary to obtain professional services or comply with legal obligations.

Tractian may disclose Personal Data to courts, regulators, law enforcement agencies, governmental authorities, or other third parties where required or permitted by applicable law, including to comply with legal obligations, respond to lawful requests, protect the rights, property, or safety of Tractian, its customers, or others, or investigate and address unlawful, fraudulent, or security-related activities.

Personal Data may be disclosed in connection with actual or proposed corporate transactions, including mergers, acquisitions, financings, reorganizations, asset sales, related due diligence activities, or in the unlikely event of insolvency, bankruptcy, or receivership, in which such information could be transferred to third parties as a business asset in the transaction. Where required by applicable law, appropriate safeguards will be implemented to protect Personal Data throughout such transactions.

Tractian operates globally and may transfer Personal Data internationally.

Personal Data may be transferred to countries where Tractian operates, where Tractian group entities are located, where service providers are located, or where infrastructure providers are located.

Where required by applicable law, Tractian implements safeguards designed to protect transferred Personal Data. Such safeguards may include contractual protections, Standard Contractual Clauses, adequacy mechanisms, technical safeguards, organizational safeguards, and other lawful transfer mechanisms.

Additional information regarding international transfers may be requested through the contact information provided in this Privacy Policy.

Tractian maintains administrative, technical, and organizational measures designed to protect Personal Data against unauthorized access, disclosure, alteration, loss, misuse, or destruction.

Our information security program is designed to support the confidentiality, integrity, and availability of Personal Data and includes safeguards in alignment with all applicable laws and regulations and as appropriate based on the sensitivity of the information.

While Tractian continuously reviews and enhances its security practices in accordance with applicable legal requirements, industry standards, and evolving threats, no method of transmission over the Internet or method of electronic storage can be guaranteed to be completely secure.

In the event of a security incident involving Personal Data, Tractian will investigate the matter, take appropriate remediation measures, and, where required by applicable law, provide notifications to competent supervisory authorities and affected individuals within the applicable legal timeframes.

Additional information regarding Tractian’s security program may be available through our Trust Center.

When users visit our websites, we use Cookies and similar technologies (e.g., pixels and web beacons) to collect information, improve the user experience across our digital channels, understand how users interact with our content, personalize services, and provide more relevant communications.

Pixels (also known as web beacons) are types of code embedded in a website, video, email, or advertisement that sends information about your use to a server. When you access a website, video, email, or advertisement that contains a pixel, the pixel may permit us or a separate entity to drop or read Cookies on your browser.

The information collected may relate to the user’s device, browser, IP address, Cookie identifiers, pages visited, browsing behavior, and preferences.

We use different categories of Cookies, including:
• Strictly Necessary Cookies, which are essential for the operation of the Website;
• Performance Cookies, which help us understand how the Website is used and improve our services;
• Functional Cookies, which enable us to personalize the user experience; and
• Advertising Cookies, which are used to deliver personalized content and measure the effectiveness of marketing campaigns.

Strictly Necessary Cookies cannot be disabled, as they are essential for the proper functioning of the Website, including features such as displaying the Cookie banner, remembering user preferences, authentication, and similar functions. Non-essential Cookies will only be activated upon the user’s consent, collected through our Cookie management mechanism.

Certain tracking technologies may be operated by third-party partners, including advertising and analytics platforms such as Meta Platforms, Google, LinkedIn, and other technology providers, which may process data in accordance with their own privacy policies. Such processing activities may involve the sharing of data for purposes such as performance analysis, campaign measurement, conversion tracking, content personalization, and behavioral advertising.

To learn more about and manage the Cookies used by Tractian, please click on Your Privacy Choices located in the bottom-right corner of our website.

Users may manage our use of Cookies at any time by accessing the privacy choices available through the link in the footer on our website or through their preferred browser settings. However, depending on the settings selected, certain Website functionalities and information security-related features may not operate as intended.

Tractian may use contact information to send content, informational materials, event invitations, updates about our products and services, as well as promotional and institutional communications. These communications are primarily directed to contacts who have expressed interest in our solutions, whether through registrations on our website, completion of campaign forms, including advertisements on platforms such as Google Ads, Meta Ads, and LinkedIn Ads, participation in events, or interactions with our sales team. If the Data Subject wishes to stop receiving this type of communication, they may unsubscribe at any time by clicking the unsubscribe (opt-out) link included in the footer of our emails, which will direct them to the unsubscribe process, or by submitting a request via email to [email protected].

Pixel tags may be used to market our services to you, measure the success of our marketing campaigns, and compile statistics about Website usage and response rates. These third parties may use Cookies, alone or in conjunction with web beacons or other tracking technologies, to collect information about you.

Some of these tracking technologies may track your activities across time and services for purposes of associating the different devices you use and delivering relevant ads and other content to you.

The companies we work with to provide you with targeted ads are required by us to give you the choice to opt out of receiving targeted ads. Most of these companies participate in the Digital Advertising Alliance (DAA) and/or the Network Advertising Initiative (NAI). To learn more about the targeted ads provided by these companies, and how to opt out of receiving certain targeted ads from them, please visit: DAA website choices, DAA app choices, and NAI choices.

Opting out only means that the selected participants should no longer deliver certain targeted ads to you. It does not mean you will no longer receive any targeted content or ads, including those connected with the participants’ other customers or from other technology services.

Our Digital Channels may contain links to other third-party Websites that have their own data processing policies, and any type of data processing related to the services of these third parties will be the sole responsibility of the respective third parties. We emphasize that Tractian is not responsible for the privacy policies used by these third parties, and we recommend that you carefully read the applicable terms and policies when accessing external websites, since the processing of personal data in these environments is carried out under the sole responsibility of the respective third parties.

Questions regarding this Privacy Policy, the processing of Personal Data, or contact with Tractian’s Data Protection Officer (DPO), provided through Grant Thornton Corporate Consultores de Negócios Ltda., may be directed to [email protected].

This section provides supplemental information for individuals located in certain jurisdictions. Where local law provides additional rights or disclosures, those provisions supplement the remainder of this Privacy Policy.

These include the following:
• States in the United States of America that have applicable privacy laws (including California);
• Brazil;
• Mexico;
• Europe (including Ireland and Poland); and
• Japan.

If there is a conflict between this section and the remainder of this Privacy Policy, the provisions applicable to the relevant jurisdiction shall prevail.

Where required by applicable law, Tractian processes Personal Data based on one or more legal bases established under applicable data protection laws.

Legal basis may vary by jurisdiction, but as a general matter, the legal bases we rely upon are the following:
• Performance of a Contract: where processing is necessary to provide Products and Services, fulfill contractual obligations, manage customer accounts, deliver technical support, administer subscriptions, or take steps requested before entering into a contract.
• Steps Prior to Entering into a Contract: where processing is necessary to respond to inquiries, evaluate business opportunities, schedule demonstrations, conduct recruitment activities, or otherwise take actions requested prior to establishing a contractual relationship.
• Legitimate Interests: where Tractian relies on legitimate interests as a legal basis for processing, we ensure that such interests are carefully balanced against the rights and freedoms of individuals. Examples may include information security, fraud prevention, service improvement, analytics, business administration, customer relationship management, and the protection of Tractian’s rights and assets. Prior to relying on legitimate interests, Tractian conducts an internal assessment to ensure that the processing is necessary and proportionate and that it does not override the fundamental rights and freedoms of individuals.
• Legal Obligations: where processing is necessary to comply with applicable legal, regulatory, tax, accounting, employment, reporting, or compliance requirements.
• Consent: where individuals have provided valid consent for a specific processing activity, including certain marketing communications, Cookies, or similar technologies where required by applicable law. Individuals may withdraw consent at any time.
• Other Lawful Bases: any other legal basis permitted under applicable data protection laws.

The legal basis applicable to a particular processing activity may vary depending on the jurisdiction, the nature of the relationship with Tractian, and the specific circumstances involved.

Tractian may use artificial intelligence (AI) and automated technologies to support the delivery, security, and improvement of its products and services.

Tractian’s AI-enabled functionalities may process industrial, operational, and equipment-related data in order to provide analytics, monitoring, predictive maintenance, and other service features. In accordance with Tractian’s contractual commitments, data relating to a Customer’s Assets, Equipment, or Industrial Processes is not used to train, fine-tune, or otherwise improve artificial intelligence or machine learning models unless such data has been irreversibly anonymized.

Personal Data is not used to train artificial intelligence or machine learning models unless otherwise disclosed and permitted by applicable law. Where model improvement activities occur, Tractian uses technical and operational information that has been aggregated and irreversibly anonymized so that individuals cannot be identified and no Customer-specific Asset, Equipment, or Industrial Process Data can be attributed to a particular Customer.

Tractian does not make decisions based solely on automated processing that produce legal or similarly significant effects on individuals. Where automated tools support decision-making, appropriate human oversight is maintained.

Certain U.S. states have expansive privacy laws that apply to Tractian and provide additional rights regarding Personal Data to residents of such states.

Where such state law applies to Tractian, you may have rights relating to access, correction, deletion, portability, appeal of denied requests, opt-out of targeted advertising, opt-out of profiling, and opt-out of sales of Personal Information where applicable.

Requests may be submitted through [email protected]. Authorized agents may submit requests where permitted by law. Verification requirements may apply.

This section applies solely to California residents and supplements the remainder of this Privacy Policy. Terms used in this section have the meanings assigned to them under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (CCPA/CPRA).

The following is intended as a CCPA Notice at Collection:
• To learn more about the categories of personal information we collect about California residents, please see Section 4 (Personal Data We Collect and How We Use It), including Sections 4.1 through 4.8.
• For more information about how we use those categories of personal information, please see Section 4 and Section 15.1 (Legal Basis for Processing).
• For more information about how we collect categories of personal information, please see Section 4 and Section 10 (Cookies and Similar Technologies).
• To learn more about how we disclose categories of personal information, and the categories of third parties with whom we disclose such information, please see Section 7 (Data Sharing and Disclosure).
• To learn more about how long we keep your information, please see Section 6 (Data Storage and Retention).

Please note that California law does not rely on legal basis designations set forth in Section 15.1 above.

The following is intended as a CCPA Notice of Sale or Sharing of Personal Information:
• Certain technologies implemented on our websites and digital channels may constitute “selling” or “sharing” under the CCPA because of certain disclosures of online identifiers, device information, Cookie identifiers, and internet activity information to advertising, analytics, and marketing partners for purposes of cross-context behavioral advertising.
• We have no actual knowledge that we sell the personal information of California residents who are under 16 years of age.
• Where applicable, California residents may exercise their right to opt out of such sharing through the privacy choices mechanisms made available on our websites.
• Where required by applicable law, Tractian recognizes and processes browser-based opt-out signals, such as Global Privacy Control (GPC), as a valid request to opt out of the sale or sharing of Personal Information.

The following is intended as a CCPA Notice in connection with the use of Sensitive Personal Information:
• Tractian does not use Sensitive Personal Information to infer characteristics about individuals.
• Tractian does not use Sensitive Personal Information except for purposes permitted in Cal. Code Regs. tit. 11, § 7027(m) without limitation.

Tractian will not discriminate against any individual for exercising rights provided under the CCPA/CPRA.

Authorized agents may submit requests on behalf of California residents where permitted by law. Tractian may take reasonable steps to verify the identity of the requestor and the authority of an authorized agent before responding to a request.

If you are a California resident under 18 years old and a registered user of the Website, you can request that we remove content or information that you have posted to our website or other online services. Fulfillment of the request may not ensure complete or comprehensive removal. To request removal of content or information, please send an email to [email protected] or contact us as otherwise provided in the Contact Us section above.

This section applies to individuals located in Brazil and supplements the remainder of this Privacy Policy. Personal Data is processed in accordance with the Brazilian General Data Protection Law (Lei Geral de Proteção de Dados Pessoais – Law No. 13,709/2018) (LGPD).

We rely on the legal bases set forth in Section 15.1 as allowed under the LGPD, including consent, performance of a contract, compliance with legal or regulatory obligations, legitimate interests, exercise of rights in legal proceedings, and other lawful bases permitted by applicable law.

Subject to applicable legal requirements and limitations, individuals may have the rights provided under Article 18 of the LGPD, including the rights to obtain confirmation regarding the processing of Personal Data, access Personal Data, correct incomplete, inaccurate, or outdated Personal Data, request anonymization, blocking, or deletion of Personal Data where applicable, request portability of Personal Data where applicable, obtain information regarding entities with which Personal Data has been shared, obtain information regarding the possibility of denying consent and the consequences of such denial where consent is the applicable legal basis, withdraw consent where consent is the applicable legal basis, and object to processing activities carried out in violation of applicable law.

Tractian recognizes the importance of providing appropriate safeguards when processing the Personal Data of elderly individuals. Where Personal Data relating to individuals aged 60 or older is processed, we seek to provide information in a clear, transparent, and accessible manner, enabling individuals to understand how their Personal Data is used and how they may exercise their privacy rights. When appropriate, we may offer additional support mechanisms to facilitate communications and help ensure that privacy-related decisions are made in an informed manner. Personal Data relating to elderly individuals is subject to the same security, confidentiality, and governance standards applied to all Personal Data processed by Tractian. In addition, we strive to ensure that such processing is conducted with particular attention to the principles of necessity, proportionality, transparency, and respect for individual rights.

For purposes of Brazilian data protection law, Tractian has appointed Grant Thornton Corporate Consultores de Negócios Ltda. as its Data Protection Officer service provider, represented by Alline Ribeiro Benfatti Vaz, with Caroline Moraes de Lima acting as substitute. Requests may be submitted through [email protected].

Individuals located in Brazil may also submit complaints regarding the processing of Personal Data to the Agência Nacional de Proteção de Dados (ANPD), in accordance with applicable law.

This section applies to individuals located in Mexico and supplements the remainder of this Privacy Policy. Personal Data is processed in accordance with the Federal Law on Protection of Personal Data Held by Private Parties (Ley Federal de Protección de Datos Personales en Posesión de los Particulares – LFPDPPP) and its applicable regulations.

Subject to applicable legal requirements and limitations, individuals may exercise ARCO rights, including access to Personal Data and information regarding its processing, rectification of inaccurate, incomplete, or outdated Personal Data, cancellation of Personal Data where applicable under law, and objection to the processing of Personal Data for specific purposes.

Where permitted by applicable law, individuals may also revoke consent previously granted for the processing of Personal Data, request limitations on the use or disclosure of Personal Data, and obtain information regarding transfers of Personal Data. Individuals located in Mexico may submit complaints regarding the processing of Personal Data to the National Institute for Transparency, Access to Information and Personal Data Protection (Instituto Nacional de Transparencia, Acceso a la Información y Protección de Datos Personales – INAI), in accordance with applicable law.

This section applies to individuals located in the European Economic Area (EEA) and supplements the remainder of this Privacy Policy. Personal Data is processed in accordance with the General Data Protection Regulation EU 2016/679 (GDPR).

Personal Data may be transferred outside the EEA in accordance with applicable data protection laws. Tractian implements appropriate safeguards for such transfers, and additional information is provided in Section 8 of this Privacy Policy.

Subject to applicable legal requirements and limitations, individuals may have the following rights under the GDPR: right of access, right to rectification, right to erasure, right to restriction of processing, right to data portability, right to object, right to withdraw consent where consent is the applicable legal basis, and right to lodge a complaint with a competent supervisory authority.

Where applicable, individuals may have rights relating to automated decision-making and profiling under Article 22 of the GDPR.

Individuals located in the EEA may lodge a complaint with the supervisory authority of their habitual residence, place of work, or place of an alleged infringement of applicable data protection law.

This section applies to individuals whose Personal Data is processed by Tractian Limited in connection with Tractian’s operations in the European Economic Area.

Individuals may lodge a complaint with the Irish Data Protection Commission (DPC) or with another competent supervisory authority within the European Economic Area, in accordance with applicable law.

Data Protection Commission (DPC) website: https://www.dataprotection.ie.

Where applicable under the GDPR’s one-stop-shop mechanism, the Irish Data Protection Commission may act as Tractian’s lead supervisory authority for cross-border processing activities carried out within the European Economic Area.

This section applies to individuals located in Poland. Individuals may lodge a complaint regarding the processing of Personal Data with the President of the Personal Data Protection Office (Urząd Ochrony Danych Osobowych – UODO) or another competent supervisory authority, in accordance with applicable law.

Urząd Ochrony Danych Osobowych (UODO) website: https://uodo.gov.pl.

This section applies to individuals located in Japan and supplements the remainder of this Privacy Policy. Personal Data is processed in accordance with applicable Japanese data protection laws, including the Act on the Protection of Personal Information (APPI), where applicable.

The purposes for which Personal Data is processed are described in Section 4 of this Privacy Policy. Tractian processes Personal Data within the scope necessary to achieve these purposes, in accordance with applicable law.

Personal Data may be transferred outside Japan as described in Section 8 (International Data Transfers). Where required by applicable law, Tractian implements safeguards designed to protect Personal Data transferred internationally, including contractual protections and other appropriate measures. Individuals may request additional information regarding the countries to which Personal Data is transferred and the safeguards implemented in connection with such transfers.

Subject to applicable law, individuals may have rights regarding their Personal Data, including rights to request disclosure of Personal Data, request correction, addition, or deletion of Personal Data where inaccurate, request suspension of use or restriction of processing of Personal Data where applicable, request suspension of provision of Personal Data to third parties, and submit inquiries regarding the handling of Personal Data.

Individuals may also contact the Personal Information Protection Commission (PPC) or another competent authority, where permitted by applicable law.

Individuals in the jurisdictions listed in Section 15 may submit privacy-related requests using the contact methods described in this Privacy Policy, including by contacting Tractian at [email protected].

Where Tractian processes Personal Data on behalf of a Customer as Processor, requests relating to Customer Data may need to be directed to the relevant Customer acting as Controller.

Tractian does not make decisions based solely on automated processing that produce legal or similarly significant effects on individuals without appropriate human oversight, except where permitted by applicable law. Where applicable, individuals may request a review of decisions based on automated processing.

Except where prohibited by applicable law, to protect individuals and prevent fraud, Tractian may require reasonable verification of identity before responding to a request. Tractian will assess and respond to requests in accordance with applicable legal requirements and within the deadlines established by applicable law. Where permitted by law, response periods may be extended when requests are particularly complex, numerous, or require additional verification. In such cases, Tractian will inform the individual of the extension and the reasons supporting it.

In certain circumstances, Tractian may decline or limit a request where permitted or required by applicable law, including where compliance with the request would conflict with legal or regulatory obligations, retention of Personal Data is necessary for the establishment, exercise, or defense of legal claims, Tractian must protect the rights, freedoms, or legitimate interests of other individuals or organizations, the request is manifestly unfounded, excessive, or repetitive, or Tractian is unable to adequately verify the identity or authority of the requestor where verification is not prohibited.

Certain Personal Data may need to be retained to comply with legal, regulatory, contractual, security, recordkeeping, or legitimate business requirements. As a result, some requests for deletion may not be fully satisfied where retention is required or permitted by applicable law. Where a request cannot be fulfilled, Tractian will provide an explanation consistent with applicable legal requirements.

Individuals located in jurisdictions that provide the right to lodge complaints with a supervisory authority may also contact the competent authority in accordance with applicable law. Where Tractian acts as a Processor on behalf of a Customer, requests relating to Customer Data may need to be submitted directly to the relevant Customer acting as Controller.

Tractian may update this Privacy Policy at any time, at its sole discretion, in order to enhance transparency for Data Subjects and to comply with applicable legal, regulatory, or administrative requirements.

Tractian encourages Data Subjects to review this Privacy Policy periodically to remain informed about how their Personal Data is processed.

When Tractian makes material changes to this Privacy Policy, we will provide notice through one or more of the following methods: (a) posting a prominent notice on the homepage of our Website; (b) updating the “Last Publication” at the end of this Privacy Policy; (c) sending an email notification to registered users at the email address associated with their account; or (d) displaying an in-platform banner or notification within the Services. The method of notification will depend on the nature and significance of the changes.

We encourage you to review this Privacy Policy whenever you access or use our Services to stay informed about our privacy practices.

Version 3.0 - Last update: June 30, 2026