Privacy Policy

Last Updated: 2 February, 2026

SCOPE: This Privacy Policy explains how Traction Layer(“Traction Layer,” “we,” “us,” or “our”) collects, uses, discloses, andprotects Personal Information when you (a) visit our website, (b) create oradminister an account, (c) communicate with us (e.g., sales, support, events),or (d) use our hosted platform and related services (collectively, the“Services”).

ENTERPRISE SERVICES: When an organization (a “Customer”)uses our Services, individuals may use the Services on the Customer’s behalf(“Authorized Users”). In many cases, Traction Layer processes PersonalInformation as a service provider/processor for the Customer, and the Customercontrols how that information is used. If you are an Authorized User, pleasealso review your Customer’s privacy notices and direct certain requests to yourCustomer as appropriate.

California Consumer Privacy Act and California Privacy Rights Act

If you are a California resident, you havethe following rights under the California Consumer Privacy Act("CCPA") and California Privacy Rights Act ("CPRA"):

- Right to Know. You may request detailson what personal data we collect, use, and share.

- Right to Delete. You can request deletionof personal data, subject to certain legal exceptions.

- Right to Correct. You may requestcorrections to inaccurate personal information.

- Right to Opt-Out. You can opt out of thesale or sharing of personal data for advertising.

- Right to Restrict Sensitive Data Use. You may limit the use ofsensitive personal information.

- Right Against Retaliation. The Company will notdiscriminate against you for exercising your rights.

Collection of your Personal Information

ENTERPRISE SERVICES & CUSTOMER CONTENT: Our Servicesmay process information that Customers or Authorized Users submit to theServices, including prompts, inputs, files, configuration data, logs, andoutputs generated by AI models (“Customer Content”).

CUSTOMER-CONTROLLED DEPLOYMENTS: In deployments within aCustomer’s cloud environment (including AWS, Azure, Google Cloud, and OracleCloud) or on-premises, Customer Content may remain within the Customerenvironment depending on the deployment architecture and Customerconfiguration.

SUPPORT ACCESS: Traction Layer may access Customer Contentonly as needed to provide support, operate and maintain the Services, addresssecurity or reliability issues, comply with law, or as otherwise permitted byour agreement with the Customer.

MODEL TRAINING: Traction Layer does not use CustomerContent to train or improve general models for other customers unless theCustomer expressly opts it in writing (or as expressly permitted by theCustomer agreement).

CUSTOMER INSTRUCTIONS: Where applicable, Traction Layer’sprocessing of Customer Content is governed by the contract with the Customerand any applicable data processing addendum. 

In order to better provide you withproducts and services offered, the Company may collect personally identifiableinformation, such as your:  

- Firstand last name  
- Emailaddress
- Phonenumber
- Employer
- Jobtitle  

If you purchase the Company's products andservices, we collect billing and credit card information. This information isused to complete the purchase transaction.

We do not collect any other personal informationabout you unless you voluntarily provide it to us. However, you may be requiredto provide certain personal information to us when you elect to use certainproducts or services. These may include: (a) registering for an account; (b)signing up for special offers from selected third parties; (c) sending us anemail message; (d) submitting your credit card or other payment informationwhen ordering and purchasing products and services. To wit, we will use yourinformation for, but not limited to, communicating with you in relation toservices and/or products you have requested from us. We also may gatheradditional personal or non-personal information in the future.

Cookies and Similar Technologies

COOKIES & SIMILAR TECHNOLOGIES. We and our serviceproviders may use cookies, pixels, SDKs, and similar technologies to operateour website, remember preferences, understand usage, and improve performance.Some cookies are strictly necessary for the website to function; others may beused for analytics and advertising-related purposes.

YOUR CHOICES. You can manage cookies through your browsersettings and, where available, through a “Cookie Preferences” or similar toolon our website. If you choose to disable cookies, some website features may notfunction properly.

GLOBAL PRIVACY CONTROLS. In certain jurisdictions, you maybe able to use browser-based opt-out preference signals (such as a globalprivacy control) to communicate your privacy choices. Where required byapplicable law, we will make reasonable efforts to honor such signals.

Use of your Personal Information

The Company collects and uses your personalinformation in the following ways:
  - tooperate and deliver the services you have requested
 - toprovide you with information, products, or services that you request from us
 - toprovide you with notices about your account
 - tocarry out the Company's obligations and enforce our rights arising from anycontracts entered between you and us, including for billing and collection
 - tonotify you about changes to Secure LLM Enclave or any products or services weoffer or provide through it
 - inany other way we may describe when you provide the information
 - forany other purpose with your consent.

The Company may also use your personallyidentifiable information to inform you of other products or services availablefrom the Company and its affiliates.

Children Under Thirteen

The Company does not knowingly collectpersonally identifiable information from children under the age of 13. If youare under the age of 13, you must ask your parent or guardian for permission touse this application.

Sharing Information with Third Parties

We do not share Personal Information with third parties fortheir own direct marketing purposes unless you have expressly consented or asotherwise permitted by applicable law.

HOW WE DISCLOSE INFORMATION:Traction Layer does notsell Personal Information. We may disclose Personal Information as follows:

SERVICE PROVIDERS: We may share Personal Information withvendors and service providers that perform services on our behalf, such aswebsite hosting, analytics, customer support tools, email delivery, securityservices, and payment processing. These vendors are authorized to use PersonalInformation only as necessary to provide services to us and are required toprotect it.

AFFILIATES: We may share Personal Information with ourcorporate affiliates, if any, consistent with this Privacy Policy.

LEGAL, SECURITY, AND COMPLIANCE: We may disclose Personal Informationif we believe in good faith that disclosure is necessary to comply withapplicable law, respond to lawful requests, protect the security or integrityof the Services, prevent fraud, or protect the rights, property, or safety ofTraction Layer, our Customers, users, or others.

BUSINESS TRANSFERS: We may disclose Personal Information inconnection with a merger, acquisition, reorganization, financing, or sale ofsome or all of our assets, subject to appropriate safeguards.

Data Retention

DATA RETENTION. We retain Personal Information only for aslong as reasonably necessary to fulfill the purposes described in this PrivacyPolicy, unless a longer retention period is required or permitted by law (forexample, tax, accounting, security, or legal compliance).

RETENTION CRITERIA. Retention periods vary depending on thetype of data, how it is used, and legal obligations. For example:

  • Website analytics and securitylogs may be retained for a limited period to help maintain and secure thewebsite.
  • Sales and marketingcontact information may be retained until it is no longer needed for businesspurposes or you request deletion or opt out.
  • Billing and transactionrecords may be retained for the period required by applicable law.
  • Customer Content is retained inaccordance with the Customer agreement, the selected deployment model, andCustomer configuration, including any deletion settings.

Security

We maintain administrative, technical, andphysical safeguards designed to protect Personal Information againstaccidental, unlawful, or unauthorized destruction, loss, alteration, access,disclosure, or use. However, no security measures are perfect, and we cannotguarantee absolute security.

International Transfers

Your PersonalInformation may be processed and stored in countries other than where you live.When we transfer Personal Information internationally, we take steps designedto ensure appropriate safeguards are in place and that transfers comply withapplicable data protection laws.

Your Rights

YOUR PRIVACY RIGHTS. Depending on where you live, you mayhave certain rights regarding your Personal Information, which may include theright to request access, correction, deletion, or portability of your PersonalInformation, and the right to opt out of certain processing (such as targetedadvertising in some jurisdictions).

HOW TO EXERCISE RIGHTS. You (or an authorized agent, wherepermitted by law) may submit a request by contacting us at [PRIVACY EMAIL] orvia our web form at [PRIVACY REQUEST URL]. We may request information to verifyyour identity and your request.

AUTHORIZED USERS. If you are an Authorized User of aCustomer, we may refer your request to the Customer or handle it in accordancewith the Customer’s instructions and applicable agreements.

APPEALS. In certain jurisdictions, you may have the rightto appeal our decision if we deny your request. You may submit an appeal bycontacting us at [PRIVACY EMAIL] with the subject line “Privacy RequestAppeal.”

Opt-Out of Disclosure of Personal Information to Third Parties

In connection with any personal informationwe may disclose to a third party for a business purpose, you have the right toknow:
- Thecategories of personal information that we disclosed about you for a business purpose.

 You have the right under the CCPA and CPRAand certain other privacy and data protection laws, as applicable, to opt outof the disclosure of your personal information. If you exercise your right toopt out of the disclosure of your personal information, we will refrain fromdisclosing your personal information, unless you subsequently provide expressauthorization for the disclosure of your personal information. To opt out ofthe disclosure of your personal information, visit this web page _________________.

Right to Deletion

Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:  
- Delete your personal information from our records; and
- Direct any service providers to delete your personal information from their records.

Under the CCPA and CPRA, you have the right to request that the Company, and any third parties with whom your personal information is sold or shared, delete any personal information that has beencollected about you. To exercise your rights, contact us atinfo@tractionlayer.ai.

Please note that we may not be able to comply with requests to delete your personal information if it is necessary to:
 - Completethe transaction for which the personal information was collected, fulfill theterms of a written warranty or product recall conducted in accordance withfederal law, and provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you,or otherwise perform a contract between you and us;
 - Detectsecurity incidents, protect against malicious, deceptive, fraudulent, orillegal activity; or prosecute those responsible for that activity;
 - Debugto identify and repair errors that impair existing intended functionality;
 - Exercisefree speech, ensure the right of another consumer to exercise his or her rightof free speech, or exercise another right provided for by law;
 - Complywith the California Electronic Communications Privacy Act;
 - Engagein public or peer-reviewed scientific, historical, or statistical research inthe public interest that adheres to all other applicable ethics and privacylaws, when our deletion of the information is likely to render impossible orseriously impair the achievement of such research, provided we have obtainedyour informed consent;
 - Enablesolely internal uses that are reasonably aligned with your expectations basedon your relationship with us;
 - Complywith an existing legal obligation; or
- Otherwiseuse your personal information, internally, in a lawful manner that iscompatible with the context in which you provided the information.

Opt Out and Unsubscribe from Third-Party Communications

We respect your privacy and give you an opportunity to opt out of receiving announcements of certain information. Users may opt out of receiving any or all communications from third-party partners ofthe Company by contacting us here:

 - Webpage: _http://www.tractionlayer.ai_________
 - Email:optout@tractionlayer.ai

Email Communications

From time to time, the Company may contact you via email for the purpose of providing announcements, promotional offers,alerts, confirmations, surveys, and/or other general communication. In order to improve our services, we may receive a notification when you open an email fromthe Company or click on a link there in.

If you would like to stop receiving marketing or promotional communications via email from the Company, you may optout of such communications by clicking on the Unsubscribe button.

Changes to This Statement

The Company reserves the right to change this Policy from time to time. For example, when there are changes in our services, changes in our data protection practices, or changesin the law. When changes to this Policy are significant, we will inform you.You may receive a notice by sending an email to the primary email address specified in your account, by placing a prominent notice on our Traction Layer,and/or by updating any privacy information. Your continued use of the application and/or services available after such modifications will constituteyour: (a) acknowledgment of the modified Policy; and (b) agreement to abide and be bound by that Policy.

Contact Information

The Company welcomes your questions orcomments regarding this Policy. If you believe that the Company has not adheredto this Policy, please contact the Company at:

Traction Layer
2882 Calais Dr San Ramon, California 94583

Email Address:
support@tractionlayer.ai
Effective as of February 02, 2026