Effective Date: August 1st, 2014
Last Updated: May 25, 2018

• 1. GENERAL

  • 1.1.

    This Privacy Policy is hereby adopted by Traffic F, s.r.o., a company registered and existing under the laws of the Czech Republic, with registration number 029 08 204, having its registered seat at Krakovska 1366/25, 110 00 Prague 1, Czech Republic (hereinafter referred to as the “Company”), and applies to the website on which it appears

    • 1.1.1.

      Company is the operator of this Site. Hereinafter, when first-person pronouns are used in this Policy (Us, We, Our, Ours, etc.), these provisions are referring to Company operating as the Site on which this Policy appears, or as any other websites that We may choose to operate in the future. Additionally, when the terms “the Site” or “Site” are used, these terms refer to any website operated by Us, unless the website is stated as specifically exempt from this Policy.

    • 1.1.2.

      You, the User – As the User of this Site, this Policy will refer to the User as “You” or through any second-person pronouns, such as “Yours,” etc. Hereinafter, the User of the Site shall be referred to in applicable second-person pronouns.

  • 1.2.

    The Company is the responsible data controller in the sense of Article 4 (7) of European Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (hereinafter referred to as the “GDPR“).

  • 1.3.

    This Privacy Policy describes how We collect, use, process, and disclose information received about You when You visit Our Site or when You subscribe to, or otherwise use Our Site or online services. We are processing personal data only in accordance with this Privacy Policy.

• 2. PERSONAL INFORMATION THAT WE COLLECT

  • Personal data refers to any information that tells Us something about You or that we can link to You. We processes following categories of information:
  • 2.1.

    Information You Give to Us.

    We collect Your personal information that We received from You when You use the Site, including personal and financial information You provide to Us including when You: enquire or make an application for Ours services, register to use and/or use any of Our services, make a payment and when You communicate with Us through e-mail, the Site or portal, or any other electronic means.
    Such information may include:

    • user’s name including first name and family name, e-mail address, phone number, Skype ID, address, etc.
    • billing address, username, password, nationality and country of residence, etc.;
    • information relating to any purchased services, including the location of the purchase, the value, the time and any feedback that is given in relation to such purchase.
  • 2.2.

    Information We Automatically Collect from Your Use of the Site.

    We collect information about the services that You use and how You use them, like when You complete the advertiser application and when You utilize various features of the Site and/or services. This information includes:

    • Device information. We collect device specific information such as IP address, access dates and times, hardware and software information, device information, device event information, web browser settings, unique identifiers, crash data, cookie data.

    • Geo-location Information. When You use certain features of the Site, We may collect information about Your approximate location as determined through data such as Your IP address.

    • Usage Information. We collect information about Your interactions with the Site such as the advertiser application You made and other actions on the Site.

    • Cookies and Similar Technologies. We use cookies and other similar technologies. For more information on our use of these technologies, see our Cookie Policy.

  • 2.3.

    Information We Collect from Third Parties.

    We may collect information, including personal information, from other sources and combine that with information We collect through the Site. We do not control, supervise or respond for how the third parties providing Your information process Your personal data, and any information request regarding the disclosure of Your personal information to Us should be directed to such third parties.

    • Other Sources. To the extent permitted by applicable law, We may receive additional information about You, such as demographic data or fraud detection information, from third party service providers and/or partners and combine it with information We have about You.

    • Third Party Service Providers. We may receive your personal data from affiliate service providers and/or partners.

• 3. HOW WE USE INFORMATION WE COLLECT

  • We use, store, and process information, including personal information, about You to provide, understand, improve, and develop the Site, to protect Us and Our users and to comply with Our legal obligations. We also use this information to offer You tailored services.

  • 3.1.

    Provide, Improve, and Develop the Site.

    • Enable You to access and use the Site.

    • Operate, protect, improve, and optimize the Site.

    • Provide customer service.

    • Send You service or support messages, updates, security alerts, and account notifications.

    • Enable You to access and use the Payment Services.

    We process this information as it is necessary for the adequate performance of the contract with You and given Our legitimate interest in improving the Site and Our users’ experience with it.

  • 3.2.

    Protect Us and our Users and Comply with Legal Obligations.

    • Detect and prevent fraud, spam, abuse, security incidents, and other harmful activity.

    • Conduct security investigations and risk assessments.

    • Comply with Our legal obligations.

    • Resolve any disputes with any of Our users and enforce Our agreements with third parties.

    • Enforce our Terms of Service and other policies.

    • Enforce the Payment Terms and other payment policies.

    We process this information given Our legitimate interest in protecting the Site or pursued by a third party and to comply with applicable laws.

• 4. COOKIES POLICY AND GOOGLE ANALYTICS

  • 4.1.

    We use cookies to collect information about how the Site is used.

    Cookies are text files that are placed by the browser in the memory of a user’s device when Our Site is visited. Our Site uses session cookies and persistent cookies:

    Session cookies expire at the end of a browser session. They only enable Us to collect and connect the user’s actions during the particular browser session and are deleted when the browser is closed or the user logs off.

    Persistent cookies survive a browser session and are stored for a predefined period of time. We are using persistent cookies with the following information and for the following purposes:
    Identifying a registered user; and
    Saving the user’s preferences; and
    Keeping statistics regarding the speed loading of the pages.

    The user can disable the cookie function in his browser options. Please see the specific information of the browser used for visiting the Site. For details how to control and/or delete cookies, see aboutcookies.org. If cookies are disabled the user might not be able to use all the functions and services of the Site.

  • 4.2.

    In addition, We use Google Analytics, a web analytics service provided by Google, Inc. (hereinafter referred to as "Google"), using third-party cookies that enable Google to analyze the use of the Site. The information generated by the cookie about the use of this Site is transferred to a Google server in North America. Note that We have activated Google’s IP anonymization service “anonymizeIP” for our Site which shortens a user’s IP address prior to the transfer.

    Google will use this information on our behalf to evaluate the use of the Site, to compile reports for activities on the Site, and to provide other services to us relating to the Site.

    Google Analytics operates under the following terms:

    - Terms of Service: http://www.google.com/analytics/terms/gb.html

    - Privacy Statement: http://www.google.com/intl/en/analytics/learn/privacy.html

    - Privacy Policy: http://www.google.com/intl/en/policies/privacy

    The user can prevent Google from collecting and processing the data concerning the use of the Site (including the IP address) by installing a browser-plug-in which is available under https://tools.google.com/dlpage/gaoptout.

• 5. SECURITY

  Note that all data is kept in a secure environment. We protect personal data by using appropriate safeguard procedures and measures, in particular:

  • We use SSL encrypted connection.

  • We use firewalls to protect Your information.

  • We review Our information collection, storage and processing practices, including physical security measures, to guard against unauthorised access to systems.

  • We restrict access to personal information to employees, contractors and agents who need to know that information in order to process it for us and who are subject to strict contractual confidentiality obligations.

  If You know or have reason to believe that Your account credentials have been lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized use of Your account, please contact Us following the instructions in the Contact Us section below.

• 6. YOUR RIGHTS

  You may exercise any of the rights described in this section by adjusting settings in Your profile or by sending an email to support@trafficfactory.com. Please note that We will ask You to verify Your identity before taking further action on Your request, if We cannot identify You, We cannot act according to Your request.

  • 6.1.

    Managing Your Information.

    You are responsible for keeping Your personal information up-to-date. You may access and update some of Your information through Your account settings.

  • 6.2.

    Rectification of Inaccurate or Incomplete Information.

    You have the right to ask Us to correct inaccurate or incomplete personal information concerning You (and which You cannot update yourself within Your account).

  • 6.3.

    Data Access and Portability.

    You have a right to request copies of Your personal information held by Us. You are also entitled to request copies of personal information that You have provided to Us in a structured, commonly used, and machine-readable format and/or request Us to transmit this information to another service provider (where technically feasible).

  • 6.4.

    Data Retention and Erasure.

    We generally retain Your personal information for as long as is necessary for the performance of the contract between You and Us, to protect Our legitimate interest or legitimate interest of a third party and to comply with Our legal obligations. If You no longer want Us to use Your information to provide You the service, You can request that We erase Your personal information and close Your account. Please note that if You request the erasure of Your personal information:

    • We may retain some of Your personal information as necessary for Our legitimate business interests, such as fraud detection and prevention and enhancing safety. For example, if We suspend an account for fraud or safety reasons, We may retain certain information from that account to prevent that user from opening a new account in the future.

    • We may retain and use Your personal information to the extent necessary to comply with Our legal obligations.

    • Because We maintain the Site to protect from accidental or malicious loss and destruction, residual copies of Your personal information may not be removed from Our backup systems for a limited period of time.

  • 6.5.

    Restriction of Processing.

    You have the right to limit the ways in which We use Your personal information, in particular where (i) You contest the accuracy of Your personal information; (ii) the processing is unlawful and You oppose the erasure of Your personal information; (iii) We no longer need Your personal information for the purposes of the processing, but You require the information for the establishment, exercise or defence of legal claims; or (iv) You have objected to the processing pursuant to Section 6.6 and pending the verification whether the legitimate grounds of the Site provider override Your own.

  • 6.6.

    Objection to Processing.

    You have a right to require Us not to process Your personal information for certain specific purposes where such processing is based on legitimate interest. If You object to such processing We will no longer process Your personal information for these purposes unless We can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise or defence of legal claims.

  • 6.7.

    Lodging Complaints.

    You have the right to file a complaint about the data processing activities carried out before the competent data protection authorities, e.g. to The Office for Personal Data Protection. Also all users may contact: dpo@trafficfactory.com.

• 7. OPERATING GLOBALLY

  Where We transfer, store and process Your personal data outside of the EEA We have ensured that appropriate safeguards are in place to ensure adequate level of data protection. We rely on EU Model clauses and Privacy Shield Framework.

  We share certain data within our corporate group of companies and with the following groups of recipients:

  • Government authorities;
  • Third party service providers;
  • Financial institutions;
  • Providers of storage systems;
  • IT services providers;
  • Providers of services necessary for the performance of our activity (administrative activities, archiving, legal advice, receivables management, etc.)

• 8. CHANGES TO THIS PRIVACY POLICY

  We reserve the right to modify this Privacy Policy at any time in accordance with this provision. If We make changes to this Privacy Policy, We will post the revised Privacy Policy on the Site and update the “Last Updated” date at the top of this Privacy Policy. We will also provide You with notice of the modification. If You disagree with the revised Privacy Policy, You may cancel Your account. If You do not cancel Your account before the date the revised Privacy Policy becomes effective, Your continued access to or use of the Site will be subject to the revised Privacy Policy.

• 9. CONTACT US

  You may contact Us via email: support@trafficfactory.com

  Traffic F, s.r.o.
  Krakovska 1366/25
  Prague 1
  Czech Republic