TraffCore has created this Privacy Policy in line with Alphaville Investment Limited, doing business as TraffCore (hereafter «TraffCore») commitment to your privacy on TraffCore website. The following document discloses TraffCore’s information gathering, dissemination, and protection practices.
The website operates the TraffCore Affiliate Program (hereafter referred to as the “Program”) and is solely restricted to adults who are capable of entering into contractual relationships. Any person under the age of 18 (eighteen) is strictly prohibited from using the Site or signing up for an account with the Program. We do not intentionally collect information on individuals under the age of 18 (eighteen).
By getting access to the website or using it, you authorize TraffCore to process your personal data according to the terms of the Privacy Policy, Affiliate Terms and Conditions and (i) consent to the terms of this Privacy Policy as amended from time to time, as well as the Affiliate Terms and Conditions also located on the website; (ii) consent to the collection and use of information in relation to this Privacy Policy, (iii) warrant and guarantee that you are over 18 (eighteen) years of age and capable of entering into the contractual relationships.
This document applies to all information, including but not limited to registration form, contact form, questions, subscriptions, feedback, comments and suggestions, collection and use of personal information that you can provide to us as a result of your activities on this website.
You can opt-out of our data requests or not accept our Privacy Policy, but you should understand that in this case, TraffCore may not be able to provide certain services, and you cannot use our website.
TraffCore reserves the right to modify or amend this Privacy Policy at its own discretion from time to time. The changes can be tracked on this website. Your subsequent use of TraffCore website constitutes your acceptance of those changes.
I. PERSONAL DATA
“Personal data” is any information related to an identified or identifiable individual (data subject), with the help of which the individual can be determined directly or indirectly. Such information includes, inter alia, name, location, online identifier or one or more factors specific to the physical, physiological, genetic, intellectual, economic, cultural or social identity of the individual (Paragraph 1, Article 4 of the General Data Protection Regulation (EU) 2016/679 (GDPR)).
TraffCore collects such Personal data:
Personal data you affirmatively choose to submit to us including, but is not limited to, the affiliate name, physical address, phone number, e-mail address, instant messenger address, payment method information (such as bank account information), password, and, on occasion, a unique identifier (such as pet name, for example). If an affiliate sends any personal communication or correspondence, by any means, to the website, or any of its employees, agents, or representatives, the website may collect any information regarding that communication and include that information in its customer database.
Personal data TraffCore receives from your use of TraffCore website, such as the IP address, browser type, ISP, referring/exit pages, platform type, date/time stamp, number of clicks, domain name and country/state of all visitors to TraffCore’s websites;
location information when you use TraffCore’s websites as TraffCore may collect and process information about your location. TraffCore uses «Google Analytics» to determine location;
information that is considered as aggregated data such as statistical or demographic data, which TraffCore may use for any purpose. Aggregated data may be derived from your Personal data but is not considered personal data in law as it does not directly or indirectly reveal your identity unless TraffCore combines or connects aggregated data with your Personal data so that it can directly or indirectly identify you;
TraffCore collects technical data from various third parties and public sources, such as analytics providers, advertising networks, search information providers, and others.
Other than as required by law, TraffCore websites do not collect any special categories of personal information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). TraffCore will not collect any information about criminal convictions and offenses.
II. USE OF PERSONAL DATA
TraffCore collects personal data so that we may custom the web experience for each affiliate and offer the best products and services to meet the needs of each affiliate. TraffCore uses your location information to tailor your experience with TraffCore websites. It may also use any non-personal information collected to enhance TraffCore website and your IP address for website diagnostics and administration. TraffCore will only retain your personal information for as long as necessary to fulfill the purposes it was collected for, including for the purposes of satisfying any legal, accounting, or reporting requirements, but, no more than 1 (one) year from the date of your last active session on the website or for more than 6 (six) months from the date of termination of an agreement between us (whichever is earlier).
We may use information collected from visitors to our website for any of the following purposes:
to send affiliates information and promotional materials about our company, which will not continue if opted out,
to send affiliates limited and only occasional information and promotional materials from our marketing partners and third parties,
to deliver highly targeted but very limited display advertisements and offers by email, which will not continue if opted out,
to contact affiliates to our website when necessary,
to allow one-click purchases or access to proprietary content by pre-populating fields, within registration or other transaction screens, with a visitor’s name, billing address, all as provided by that visitor,
to help diagnose problems with our server,
to administer our website,
to conduct internal reviews of our website (e.g., to determine the number of visitors to the website),
to help us better understand visitors’ use of our website, and
to protect the security or integrity of our website.
TraffCore will only use your Personal data for the purposes for which it was collected unless it reasonably considers that it is needed to be used for another reason that is compatible with the original purpose. If TraffCore needs to use your Personal data for an unrelated purpose, TraffCore will notify you, ask permission and explain the legal basis which allows TraffCore to do so.
TraffCore processes information on servers in many countries around the world and you consent to your Personal data being processed on a server located outside the country in which you reside. These countries may have data protection laws that are different from the laws of your country (and, in some cases, may not be as protective). However, TraffCore has taken appropriate precautions to require that your Personal data will remain protected in accordance with this Privacy Policy.
Since part of the personal data that is collected and safeguarded by us is your email address, we try very hard to respect your time and privacy by controlling and limiting the frequency of mailings. If you receive a mailing from us or one of our marketing partners, it is because your email address is either listed with us as someone who has expressly shared this address for the purpose of receiving information in the future, or you have registered or purchased or otherwise have an existing relationship with us. Your registration for our affiliate program is your consent to these occasional mailing.
There may be occasions when you will be presented with special offers either from us or from third-party service or content providers, which may include communications, newsletters, commercial advertising, or other promotional or special event materials (collectively referred to as “Offers”). Your consent to this Privacy Policy acts as your consent to receive these occasional mailings by us and by our third-party service or content providers.
The website is not responsible or liable for the use of any information that an affiliate may provide, or that is gathered by third-party websites that have ads or links on the website. This website does not control, monitor or endorse the information gathering practices or Privacy Policies of any of those third-party websites. Whenever applicable, each affiliate should seek to read the Privacy Policy of any third-party website provider that has an advertising banner, advertises or has a link on the website or in an email.
If you have received unsolicited email sent via this system or purporting to be sent via this system, please forward a copy of that email with your comments to[email protected].
We take the complaints about unwanted e-mail very seriously and maintain an opt-out system to assist you in removing your name from our mailing list.
III. EXCHANGE OF PERSONAL DATA
All Personal data is processed by our personnel. However, TraffCore may disclose your Personal data to the following categories of recipients within the framework of the original purpose:
to its group companies, authorized service providers and partners, who perform certain services on its behalf, including data processing services to TraffCore (for example, to support the delivery of, provide functionality on, or help to enhance the security of the website).
to any competent law enforcement body, regulatory, government agency, court or other third party where TraffCore believes disclosure is necessary (a) as a matter of applicable law or regulation, (b) to exercise, establish or defend its legal rights, or (c) to protect your vital interests or those of any other person.
to any other person with your consent to the disclosure.
No other third parties have access to your personal data unless the law allows them to do so.
IV. INFORMATION SECURITY
The website has security measures in place to protect the loss, misuse and alteration of the information under our control.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. For example, we store your personal information on secure servers, which are accessible only to exceptional individuals. We are trying to prevent access by any unauthorized parties by encrypting this information. We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
For all other information above our control, visitors and affiliates should consider this communication and information to be non-confidential, and consequently, we assume no responsibility or liability if any information relating to any visitor or subscriber is intercepted and/or used by an unintended recipient.
V. LINKS
TraffCore website can contain links, plug-ins, and applications to various third-party websites. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. TraffCore has no control over and is not responsible for the content, privacy policies or reliability of such third-party connections. When you leave TraffCore’s website, TraffCore encourages you to read the privacy notice and privacy policy of every website you visit.
VI. YOUR DATA PROTECTION RIGHTS
If your Personal data is protected by GDPR, you have the following data protection rights which you may be able to exercise by contacting TraffCore through the web interface provided as part of the Services, via contact us page, or using the contact details provided under the “Contact Details” section of this Privacy Policy:
• Right of Access and Right to Portability of Personal Data
You have a right to access your Personal data that TraffCore holds about you, such as (i) information whether your Personal data is retained, (ii) access to and/or (iii) duplicates of the Personal data retained (for data portability).
You have the right to request confirmation of the fact of processing your data, the place and purpose of the processing, the categories of Personal data being processed, information about third parties to which your personal data is disclosed, the period during which the data will be processed, and the source of receipt of personal data;
• Right to Rectification
TraffCore puts the best efforts to ensure by implementing suitable measures that your Personal data is accurate and up-to-date for the purposes for which it was collected. If your Personal data that was provided to us was inaccurate or incomplete, you can always correct and update it at any time by contacting TraffCore. However, we may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
• Right to Erasure
You have the right to the deletion of your Personal data that was collected concerning you. Please, be aware that we cannot delete your personal data except by also deleting your user account.
We will not store personal information for more than 6 (six) months from the date of your last active session on the website or for more than 6 (six) months from the date of termination of an agreement between us (whichever is earlier).
• Rights to Restriction of processing and Right to Object.
You can object to the processing of your Personal data, ask TraffCore to restrict processing of your Personal data or request portability of your Personal data by contacting TraffCore.
Also, you have the right to opt out of marketing communications that TraffCore sends you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing emails TraffCore sends you or by contacting TraffCore.
Similarly, if TraffCore has collected and processed your Personal data based on your consent, then you can withdraw your consent at any time using the contact details provided under the “Contact Details” section of this Privacy Policy. Withdrawing your consent will not affect the lawfulness of any data processing, which TraffCore has conducted prior to your withdrawal, nor will it affect processing of your personal information, which has been conducted in reliance on lawful processing grounds other than consent.
If you wish to raise a complaint about how we have handled your Personal data, you can contact us through the web interface provided as part of the Services, via contact us page, or using the contact details provided under the “Contact Details” section of this Privacy Policy and we will investigate the matter.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that Personal data is not disclosed to any person who has no right to receive it. You will not have to pay a fee to access your Personal data (or to exercise any of the other rights). However, TraffCore may charge a reasonable fee or refuse to comply with your request if your request is clearly unfounded, repetitive or excessive. TraffCore tries to respond to all legitimate requests within 72 hours of receipt. Occasionally, it may take longer if your request is particularly complex or you have made a number of requests. In this case, TraffCore will notify you and keep you updated.
Detailed information regarding rights and restriction of those rights
For more detailed information on the above mentioned rights regarding your Personal data and possible restrictions of those rights, please, read Chapter III (Rights of the data subject) of the official text of GDPR, which may be found via the link.
VII. PRIVACY RIGHTS FOR CALIFORNIA RESIDENTS
If you are a California resident, you have certain rights Under the California Consumer Privacy Act of 2018 (“CCPA”) regarding the personal information that is held about you. Following rights and requirements may not apply in certain situations, based on your relationship with TraffCore, its other legal obligations, and as otherwise provided for in the CCPA.
According to Article 1798.140 (o) (1) of the CCPA, personal information is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. TraffCore collects personal information about you as provided in the “Personal Data List” section of this Privacy Policy.
You have such privacy protection rights that apply to the California consumers under the CCPA, which you may be able to exercise by contacting TraffCore using the contact details provided under the “Contact Details” section of this Privacy Policy:
• Access to Specific Information and Data Portability Rights
You have the right to request that TraffCore disclose certain information to you about our collection and use of your personal information over the past 12 months. Once TraffCore receives and confirms your verifiable consumer request, it will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- The business or commercial purpose for collecting that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you.
• Deletion Request Rights
You have the right to request that TraffCore deletes any of your personal information that we collected from you and retained.
• Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request using the contact details provided under the “Contact Details” section of this Privacy Policy.
You may only request a copy of your data twice within a 12-month period.
The request must:
(i) Provide sufficient information that allows us to verify, to a reasonably high degree of certainty, that you are the person about whom TraffCore collected personal information. This may include 4 Privacy Notice for California Residents Rev. 001-20191219 requesting that you provide us with at least two or more pieces of personal information to match against personal information about you that TraffCore may or may not maintain and which it had determined to be reliable for verification.
(ii) Describe your request with sufficient detail that allows TraffCore to properly understand, evaluate, and respond to it. TraffCore cannot respond to your request or provide you with personal information if TraffCore cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a request does not require you to create an account with TraffCore. TraffCore will only use personal information provided in a verifiable affiliate request to verify the requester's identity or authority to make the request.
Only you, or a person you have designated in writing as your authorized agent, or who is registered with the California Secretary of State to ace on your behalf, or whom you have provided power of attorney pursuant to California Probate Code sections 4000 to 4465, (“Authorized Agent”), may make a affiliate request related to your personal information. You may also request on behalf of your minor child. If you wish to have an Authorized Agent request on your behalf, they will need to provide TraffCore with sufficient written proof that you have designated them as your Authorized Agent and we will still require you to provide sufficient information to allow us to reasonably verify that you are the person about whom we collect personal information.
No Sale of Personal Information
California residents may opt-out of the “sale” of their personal information. TraffCore does not “sell” your personal information as we understand that term to be defined by the CCPA and its implementing regulations.
Non-Discrimination
You have the right not to be discriminated against for exercising any of your CCPA rights. TraffCore will not discriminate against you for exercising your CCPA rights.
VIII. COOKIES
Cookies are a technology used by most sites online to collect and store information about the user. A cookie is a data transferred by the site to your hard drive for record-keeping purposes. They are an industry standard.
PLEASE NOTE: Most browsers allow you to deny or accept cookies, so it is your choice to allow us to use this technology “cookies”. If you do not accept cookies some of our online services and features may be affected.
TraffCore uses cookies to collect information and activity on our site. Cookies are only used to help provide services and can be refused by changing your browser settings. Please understand that TraffCore may be unable to offer certain services if this option is chosen. Read our Cookies Policy to learn more.
IX. CHILDREN UNDER THE AGE OF 18
Our website is not intended for children under 18 (eighteen) years of age. No one under age 18 (eighteen) may provide any personal information to or on the website. In accordance with the Children’s Online Privacy Protection Act of 1998 (“COPPA”), we do not knowingly collect personal information from children under 18 (eighteen). If you are under 18 (eighteen), do not use or provide any information on this website or on or through any of its features/by any possible means, make any purchases through the website (if any), use any of the interactive or public comment features of this website or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 18 (eighteen) without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18 (eighteen), please contact us at[email protected].
X. TRANSLATION
In case of any discrepancy within the meanings between English and other translated versions of this Agreement, the English version of this Agreement shall prevail.
XI. CONTACT DETAILS
It is important that the personal information TraffCore holds about you is accurate and current. Please keep TraffCore informed if your personal information changes during your relationship with TraffCore. Additionally, if you have any questions about this Privacy Policy, the practices of TraffCore website or your interaction with TraffCore via a website, please contact[email protected].