Privacy Policy

Traction Layer AI, Inc. ("Traction Layer," "we," "us"), a Delaware corporation at 2882 Calais Dr., San Ramon, CA 94583, USA, runs tractionlayer.ai (the "Site"). We are responsible for the personal information described in this policy and act as its "controller" (GDPR), "business" (California law) and "data fiduciary" (India's Digital Personal Data Protection Act, 2023). Contact details are in section 14.

This policy covers personal information we collect through the Site, through emails you send to our published addresses, and through job applications. It does not cover data inside a customer's deployment of Traction Runtime. Traction Runtime runs in the customer's own environment, and prompts, model outputs, model weights and production data stay there. Where a customer gives us access to such data to provide support, we handle it only under that customer's agreement with us, and requests about it should go to the customer.

Information you give us. Our forms run on HubSpot. We collect only what each form asks for:

Please don't include confidential information, credentials, production data or sensitive personal information in forms or emails.

Information collected automatically.

• Analytics. We use Google Analytics to understand how the Site is used. It uses cookies to recognize a returning browser and records pages viewed, time on page, referring site, browser and device type, and approximate location (city and country), which Google estimates from your IP address. Google Analytics does not give us your IP address.
• HubSpot tracking. HubSpot's tracking code uses cookies to record the pages a browser views on the Site. If you then submit a form, HubSpot links that history to your submission, so we can reply with context.
• Server logs. Our hosting provider, Vercel, keeps standard server logs (IP address, request time, page requested and browser type) for security and troubleshooting.
• Email. If you subscribe to the Enterprise Digest, HubSpot records whether each issue was delivered, opened or clicked.

Where the law requires consent, analytics and HubSpot cookies are set only if you accept them (section 11).

Information from other sources. We may receive your business contact details from a partner or event organizer when you've asked to hear from us, or look up public information about your company to prepare for a conversation you requested.

We use personal information to:

• respond to your request, send the material you asked for, and follow up about it;
• send the Enterprise Digest if you have subscribed and confirmed;
• assess and respond to security reports;
• evaluate job applications;
• understand how the Site and our emails are used, so we can improve them;
• keep the Site and our systems secure, and prevent spam and abuse;
• remember your cookie choices;
• comply with law and enforce our Terms of Service.

We do not use your information for automated decisions that have legal or similarly significant effects on you, and we do not use it to train AI models.

If you are in the EU, the UK or Switzerland, we rely on: steps at your request before entering into a contract (assessment and quote requests); legitimate interests (responding to inquiries, sending requested materials, security, business-to-business follow-up and evaluating job applications), which we balance against your rights; consent (analytics and HubSpot cookies, the Enterprise Digest, and any marketing email you haven't otherwise requested), which you can withdraw at any time; and legal obligation where the law requires us to process or keep data, such as employment records.

We do not sell personal information, and we do not share it for cross-context behavioral advertising. We do not use Google Analytics' advertising features, such as Google signals or remarketing. We share personal information only with:

• Service providers that process it on our behalf under contracts requiring them to protect it and use it only to serve us (listed below).
• Partners, only when you ask us to connect you with one (for example, a cloud or hardware partner on a joint inquiry).
• Professional advisers, such as lawyers and accountants, under confidentiality duties.
• Authorities, when required by law or to protect our rights, users or the public.
• A buyer or successor, if Traction Layer is involved in a merger, acquisition or sale of assets, subject to this policy.

At the end of these periods we delete the information or make it anonymous, unless the law requires us to keep it longer or we need it for a legal claim.

We use reasonable administrative, technical and physical safeguards, including encryption in transit, access controls and least-privilege access for staff and providers. No system is perfectly secure. To report a vulnerability, email contactus@tractionlayer.ai.

We are based in the United States and work with team members in the United States and India. Our service providers (section 6) process data in the United States and in other countries where they operate. Your information may be processed in those countries, which may have different data-protection rules from yours. Where EU, UK or Swiss law requires it, we rely on the European Commission's Standard Contractual Clauses, the UK International Data Transfer Addendum, a provider's certification under the EU-U.S. Data Privacy Framework, or another lawful transfer mechanism.

Everyone. You can unsubscribe from the Enterprise Digest using the link in any issue, and change your cookie choices at any time with the Cookie settings link at the foot of every page. You can ask us to access, correct or delete your information by emailing contactus@tractionlayer.ai or writing to the address in section 14. We will verify your request using the email address we hold and respond within the time the law requires.

EU, UK and Switzerland. You have the right to access, rectify, erase, restrict and port your data, to object to processing based on legitimate interests (including direct marketing), and to withdraw consent at any time. You may also complain to your local data-protection authority, though we'd appreciate the chance to resolve your concern first.

California and other US states. Depending on where you live, you may have the right to know what personal information we collect and how we use and disclose it, to access, correct and delete it, and to opt out of its sale, sharing or use for targeted advertising (we don't do any of these). If your browser sends a Global Privacy Control signal, we treat it as a request to opt out of sale and sharing for that browser. We will not discriminate against you for exercising your rights. You may use an authorized agent; we may ask for proof of the agent's authority. We respond within 45 days, extendable by 45 days where permitted.

India. You have the right to access a summary of your personal data and how it is processed, to correct, complete, update or erase it, to withdraw consent, to nominate another person to exercise your rights if you die or become incapacitated, and to have grievances addressed. Contact our grievance officer, Sukumar Shankaran, at sukumar@tractionlayer.ai. If you are not satisfied with our response, you may complain to the Data Protection Board of India.

Cookies are small files a website stores in your browser. The Site uses three kinds, and no advertising cookies:

Where the law requires consent, including in the EU, the UK and India, we ask before setting analytics or HubSpot tracking cookies, and you can say no without losing access to the Site. You can change your choice at any time with the Cookie settings link at the foot of every page, and you can block or delete cookies in your browser settings. The Site does not respond to Do Not Track signals; it honors Global Privacy Control as section 10 describes.

The Site is for business and professional audiences. It is not directed at anyone under 18, and we do not knowingly collect personal information from them. If you believe a child has given us information, contact us and we will delete it.

We may update this policy. We will post the new version here with a new effective date, and where changes are material we will give notice on the Site or by email to Digest subscribers before they take effect.

Traction Layer AI, Inc., 2882 Calais Dr., San Ramon, CA 94583, USA

• Privacy requests and questions: contactus@tractionlayer.ai
• Grievance officer (India): Sukumar Shankaran, sukumar@tractionlayer.ai