Sensitive personal information is collected only where entered by the user within investigation-related content.​

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2.How We Collect and Use Your Personal Information

1. Direct Collection

 

We collect personal information directly from you when you interact with our Services, for example, when you register for an account, update your profile, access our website or Platform, or request our software products or services.

 

This information is used to create and manage user accounts, provide access to our Platform and its features, support workplace investigations and generate reports, respond to support requests, maintain platform security, and comply with legal obligations. Where required by Canadian privacy laws we ensure that your consent is obtained clearly and explicitly, and that the purposes for which your information is collected is communicated to you on or before collection.

 

1. Indirect Collection

 

We may collect personal information about individuals from third parties, such as colleagues, witnesses, or investigators, in the context of workplace investigations conducted through our Platform. This may include information submitted by others during the course of an investigation or through the use of our Services. The User is responsible for ensuring that collection is limited to what is necessary, and that individuals are informed of the purposes for which their information is being used, unless an exception applies (e.g., where informing the individual would compromise the investigation).

 

We may collect technical information from your device or browser through cookies and similar technologies. Cookies are small text files stored on your browser that help us understand how users interact with our website, remember your preferences, and improve your experience. While cookies do not collect personally identifiable information, they may capture data such as your IP address, device ID, browser type, operating system, access time, and referring website.

 

You can manage your cookie preferences through your browser settings. Disabling cookies may affect the functionality of our online services. By continuing to use our website or Platform without disabling cookies, you consent to our use of cookies in accordance with this Privacy Notice.

 

1. Automatic Collection

 

When you use our Platform, we automatically collect limited technical information necessary to operate the service securely — such as your IP address, device and browser type, and access times — through cookies, browser storage, and server logs.

The cookies and browser storage we use fall into two categories:

• Strictly necessary: Required for the Platform to function — authentication and session management, security of the anonymous reporting portal, recording your cookie choices, and completing payment transactions. These cannot be disabled without preventing the Platform from working.

• Functionality and preference: Remember choices you make to improve your experience — such as your language selection (English/French), display and accessibility settings (theme, font size, contrast), and interface layout. These are not required to run the service, and the Platform remains functional without them.

We do not use analytics, advertising, or cross-site tracking cookies. We do not use your personal information to make decisions based solely on automated processing.

1. Aggregated Insights

 

We generate aggregated, statistical information about overall platform usage — for example, the total number and types of investigation cases handled across the platform over a given period. This information is fully de-identified: it contains no names, no case content, and nothing that identifies any individual, organization, or case, and small counts that could allow re-identification are suppressed. Because this aggregated information is not personal information, we may use it to understand trends, improve our Services, and in our marketing. We never use the content of individual cases for these purposes.

 

We apply appropriate safeguards to protect your personal information and ensure compliance with applicable privacy laws.

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3.How We Share Your Personal Information

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We do not sell or distribute your personal information. You have entrusted us with your personal information and we want to maintain that trust.  We only share your information in limited circumstances and we take measures to limit who we share your personal information with, how much information we share, and how your personal information will be used.

Personal information of individuals may however be shared in circumstances where the User has incorporated information into their investigation on the Platform.

We may share your personal information under the following circumstances:

1. To help us run our business: we use various internal service providers and processors which may include accountants, consultants and providers for email distribution, software developers, etc. They may have access to some of your personal information, which they need to provide us with their service. Some of these processors are online cloud-based service providers. It is possible that your personal information may reside on servers located outside of Quebec (but in Canada).

2. With other third parties: with your consent or where required by or permitted by law.​​​ 

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4.Data Security

We implement a layered security framework combining organizational, technical, and physical safeguards to protect your personal information from unauthorized access, use, disclosure, or loss. These safeguards are tailored to the sensitivity of the data we process and are detailed in our Terms. For more information about our security safeguards please visit our Terms.  

While we take extensive measures to secure your information, no system or method of communication is entirely immune to risk. We encourage you to remain vigilant and take steps to protect your own environment, particularly when sharing reports with third parties.

Our website may also contain links to third-party sites with their own privacy practices; we are not responsible for the privacy policies or content of those external sites and recommend reviewing their policies before sharing any personal information.

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5.Data Storage and Retention

We retain personal information only as long as necessary to fulfill the purposes outlined above, for the duration of your active subscription, or as required by law.

Inactive accounts. An account is considered inactive when no authorized user has logged in or taken a recorded action for 90 consecutive days. If your account becomes inactive, we will send written notice to your registered administrator email at 45 days of inactivity, advising that your data will be permanently deleted if inactivity continues. We will send reminder notices every 14 days, and a final notice 7 days before deletion. Any login or recorded action resets the inactivity period. If the account remains inactive for 90 consecutive days, all associated personal information is scheduled for permanent deletion.

Cancellation. If you cancel your subscription, your account remains accessible in read-only mode for 60 days so that you can export your data. We will send written notice at cancellation, at 30 days remaining, and at 7 days remaining. At the end of this period, your personal information is permanently deleted from our production systems within 30 days.

Deletion on request. We will permanently delete specified personal information upon written instruction from an authorized representative, within 10 business days, subject to any legal obligation requiring us to retain it.

We may retain personal information beyond these periods only where required by law, and only for the period that law requires.

Data residency. All personal information is stored in Canada, on Amazon Web Services infrastructure in the Canada Central region (Toronto, Ontario). If you are located in Quebec, note that your personal information may be stored outside Quebec but remains within Canada.

 

6.Your Choices and Rights

You have the right to access and correct your personal information, request its deletion, withdraw your consent at any time (subject to legal or contractual restrictions), and file a complaint with the Office of the Privacy Commissioner of Canada or, if you reside in Québec, with the Commission d’accès à l’information du Québec.

We provide you with several ways to control how your personal information is collected and used:

• Access and correction: If you have created an account on our Platform, you can review, verify, and correct your personal information at any time by logging into your account.

• Cookies and browser storage: We use strictly necessary cookies and browser storage (for authentication, session security, and completing payments) and functionality cookies and browser storage (to remember preferences such as your language and display settings). You can manage or clear these through your browser settings, though disabling strictly necessary items may prevent the Platform from working. We do not use advertising, analytics, or cross-site tracking cookies, and we do not participate in interest-based advertising

• Marketing communications: If you have opted in to receive marketing communications from us, you may unsubscribe at any time using the link in our emails, by adjusting your preferences, or by contacting us directly. Please allow up to ten (10) days for your request to be processed. You may still receive transactional or service-related communications

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7.Make a Privacy Inquiry or Contact Us

For questions, requests, or privacy concerns, please contact us at:

Email: privacy@tractsoftware.ca

Mailing Address: trACT Software Inc., 201 King Street, London Ontario

 

If you are concerned about your personal information, we would appreciate hearing about it first to try and resolve your concerns. If we did not respond satisfactorily to your complaint or inquiry, you have the right to notify the Privacy Commissioner of Canada:

Office of the Privacy Commissioner of Canada
30 Victoria Street
Gatineau, Quebec
K1A 1H3

Toll-free: 1-800-282-1376
Phone: (819) 994-5444
TTY: 819-994-6591
www.priv.gc.ca