Last Modified: November 12^th, 2024

Introduction

Aylo Freesites Ltd (hereinafter “we”, “us” or “our”) operates the website https://www.TrafficJunky.com (hereinafter “TrafficJunky”) and, is the controller of the information collected or provided via TrafficJunky.

This Privacy Notice applies to TrafficJunky only. We understand the importance of privacy and we use best practices to uphold this while using TrafficJunky within a business-to-business relationship context. Our Privacy Notice ensures that you are protected while using TrafficJunky.

If you have any questions about our privacy practices, please see the section “Contact Information” below for information on how to contact us.

1. Collection and Our Use of Your Personal Information

We may collect and process different kinds of personal data about you, depending on whether you choose to create an account with us.

Persons who visit TrafficJunky without logging in or registering (“Unregistered Users”) and persons who choose to create an account as a business advertiser on TrafficJunky (“Business Advertisers”):

Persons who visit TrafficJunky without logging in or registering (“Unregistered Users”):

• Contact Data: We will only process your email address or any other information which you voluntarily provide to us at your direction for a specific function, namely, to participate in a contest or survey;
• Online Forms and Communication Data: We process Contact Data and other information that you submit through online forms provided on TrafficJunky or information send to us via email, online support chats or such as information provided in the context of support requests or any other inquiries, the content reporting and moderation of content, and our internal complaint handling system;
• Website activity data: While using TrafficJunky, we automatically log information such as your IP address, browser type, referrer and other technical data for internal use only. We process information about how you use TrafficJunky, products and services and interact with content and advertisements, including the pages you visit and search history on TrafficJunky, and the referring web page from which you arrived on TrafficJunky from. We process browser and operating system information, devices you use to access TrafficJunky and your time zone setting. We also process online identifiers, specifically, we process internet protocol (IP) address information, and we set cookies as explained below in the section on "Cookies and Automatic Data Processing Technologies"; and
• Identifiers: Some users may be asked to provide identifiers (including government-issued photo identification as well as other documentation) to verify that they are over the age of majority required to have access to TrafficJunky and to view their contents. In such cases, this information is processed by trusted third-party age verification service providers. This Privacy Notice does not apply to the privacy practices of these third-party age verification service providers. Read the privacy terms and conditions of these third party service providers carefully.

For persons who choose to create an account on TrafficJunky (“Business Advertisers”), we process the same categories of information described above for Unregistered Users, and additionally the following information:

• Contact Data: We process usernames, and email addresses. If you choose to register through a third-party platform, we will collect certain personal information from those platforms.
• User Submitted Personal Information: We collect identifiers you submit including your name and email address, as well as your birthday and telephone number and country of residence.
• Payment and Commercial Information: If you make a purchase and/or add funds to your TrafficJunky account, we collect customer records and commercial information you submit to us, including your name, address, and billing information. We also collect details about payments to and from you and details of products and services you have purchased or received from us.
• Identifiers and Biometric Information: If you choose to register to certain services on TrafficJunky, we collect identifiers you submit to us (including government-issued photo identification, utility bills, phone bills, bank statements and/or other documentation) in order for us to verify your identity. We may ask you for further information that will allow us to reasonably identify you, requiring you to take steps to confirm ownership of your email address or financial instruments. We may also collect biometric information to verify the authenticity of the identifiers you provide to us while registering for such services as further explained in the section “Biometric Information” below
• Marketing Emails: We will not send you marketing emails without your consent. You may opt out of marketing emails by using the link provided in our emails. We may continue to send you other types of transactional and relationship e-mail communications, such as emails about your account or orders.

We may process your data to produce and share aggregated insights that do not directly or indirectly identify you and are not associated with you. Such aggregate information is not personal information.

2. The Sources from Which We Collect Personal Information

We collect Personal Information in the following ways:

• Directly from you: We process the categories of information listed hereinabove which are directly provided to us by you;
• Automated technologies or interactions: As explained in the section below on Cookies and Automatic Data Processing Technologies, we set cookies and other automatic techniques to process website activity data when you visit TrafficJunky; and
• Third-Party Single Sign-on: We may obtain information if you choose to create or sign-in your account through a third-party platform if available, we will have access to certain information from that platform such as your name, email address or such other information you may have submitted and allowed this third party to share.

3. Purposes for which we use your Personal Information

We use personal information for the purposes described below.

• Provision of services: We use website activity data, and, additionally, for Business Advertisers only, identifiers and payment and commercial information and user submitted personal information to present TrafficJunky and its contents to you and to provide you with information, products or services that you request from us.
• Customer management (Business Advertisers only): We use identifiers, payment and commercial information and user submitted personal information to manage Business Advertisers’ accounts, to provide customer support and notices to Business Advertisers about their account, notices about changes to TrafficJunky or any products or services we offer or provide through it. We use identifiers and biometric information for the purpose of verifying your identity and the authenticity of the identifiers you provide to us while registering for certain services on TrafficJunky. Identifiers may also be used to allow you to confirm ownership of your email address and/or TrafficJunky account.
• Customization of content and marketing: We use identifiers, website activity data, user submitted personal information and user contributions to analyze your use of, or interest in, our TrafficJunky’s content, products, or services, in order to develop and display content and advertising tailored to your interests on TrafficJunky.

• Communications and handling of requests: We process Online Forms and Communications Data and other information as necessary to respond to and resolve any of your requests, including where this is required to ensure compliance with our legal obligations.
• Analytics: We use identifiers and website activity data to monitor TrafficJunky aggregate metrics such as total number of visitors, pages viewed, demographic patterns.
• Functionality and security: We may use any of the categories of data we collect to diagnose or fix technology problems, to verify your payment information, and to detect, prevent, and respond to actual or potential fraud, illegal activities, or intellectual property infringement.
• Compliance: We may use any of the categories of data we collect to enforce our terms and conditions and to comply with our legal obligations.
• Information you provide: We will use contact information and user submitted personal information in any other way we may describe when you provide the information; or for any other purpose with your consent provided separately from this Privacy Notice.

4. Biometric Information

We employ third-party service providers to help verify your identity and age and to check background records and the authenticity of identification documents you provide using facial recognition technology. Facial recognition technology creates a mathematical representation of your face and detects facial features from the live scan of your face, your selfie, and the government-issued ID you submit or previously submitted to us. Information derived from this mathematical representation, which may be considered biometric information/identifier/data under the laws of certain states and countries, is shared by our service providers with us as further described below.

Your biometric information will be processed to:

• verify you are a real, live person and to prevent the use of methods which would allow a user to identify as someone else;
• to match your selfie with your government-issued ID you submit or previously submitted to us to make sure that nobody is impersonating you; and
• to help confirm your age.

We will store your biometric information according to the section “Retention of Personal Information” below.

We may disclose your biometric information, face scan, selfie, and government-issued ID (including any government-issued ID or selfie you previously submitted to us) with members of our corporate group, and with third-party service providers. These entities may be in jurisdictions that do not offer the same level of data protection as your jurisdiction. You will be asked to provide your consent to biometric processing. You may withdraw your consent to this processing at any time by using the links below. Withdrawing your consent will not affect the lawfulness of any processing or disclosure that occurred prior to the withdrawal.

5. Our Legal Bases under Canadian and European Union (EU) Privacy Law

To the extent required by applicable law, we rely on several lawful bases to use your data in these ways. This means we process your personal data only where:

• You provide your consent to do so for a specific purpose: for example, when you allow us to show you personalized ads or to send you e-mail marketing;
• If any biometric information is requested, it will be processed only with your consent. You may withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any collection, use, processing, or disclosure that occurred prior to the withdrawal;
• It is necessary to perform our contractual obligations as per our terms and conditions on TrafficJunky, for example, to create your account;
• It is necessary to comply with legal obligations: for example, we may be required to collect, use, or disclose your information in connection with civil, criminal, corporate, taxation, regulatory matters, or litigation;
• It satisfies a legitimate interest which is not overridden by your data protection interests for example, to keep TrafficJunky safe and secure from fraud and illegal activities;
• It is used to protect your or others’ vital interests: for example, in case of emergency or to prevent a crime or fraud, and
• It is used for tasks carried out in the public interest: for example, to combat unlawful behaviour where it is in the public interest to do so and where the public interest is laid down by applicable law.

Depending on the circumstances, we may rely on different legal bases when processing your same information for different purposes. If you reside outside the European Economic Area (“EEA”), Switzerland or the United Kingdom (“UK”), the legal bases on which we rely may differ from those listed above.

6. Disclosure of Your Personal Information

We disclose your personal information when necessary to perform the services or for other purposes set out in this Privacy Notice. When we disclose your personal information, we usually rely on the performance of our contract with you as per our Terms of Service, our legal obligation to do so, our legitimate interest (e.g., operating TrafficJunky), so long as it doesn’t outweigh your interests or your consent, except when expressly stated otherwise below in the paragraph “To comply with the law or protect our rights or the rights of third parties”. Disclosure of your personal information may also involve transfers of your personal information outside the EEA. To the extent that we need to transfer personal information outside the EEA, we will do so according to the section “Transfers of Your Personal Information to Other Countries” or when necessary for the performance of the services and obligations under our Terms of Service. The parties to whom we may disclose your personal information include:

• To the public: When you submit advertisements for the purpose of being published, you are using TrafficJunky and its services to make this information publicly available. This includes the content of the advertisement (including, but not limited to, the name of the product, service or brand, the subject matter of the advertisement) and the natural or legal person on whose behalf the advertisement is presented.
• Our contractors and/or employees: To provide our services to you, our employees and/or contractors may receive access to your personal data only on a need-to-know basis. Such employees and contractors abide by confidentiality obligations.
• Our corporate group:  We may disclose any of the categories of personal information that we collect to members of our corporate group, to the extent this is necessary for the purposes described in this Privacy Notice and generally to operate our business, which includes: customer support, facilitate business development, provide IT, technical and engineering support. You acknowledge that in some cases, members of our corporate group might be established or operate outside the EEA.
• Service providers: We disclose certain categories of personal information to third party service providers to assist us or perform certain services on our behalf. These third-party service providers may have access or use your information only to perform these tasks on our behalf, such as risk and fraud detection and mitigation, customer service, advertising, analytics, security, hosting or supporting TrafficJunky functionality. These service providers may have limited access to personal information needed to perform their functions but are not permitted to process such information for any other purposes. Where required under applicable laws, we have entered into data processing agreements with such service providers to ensure that personal information is only processed securely within our instructions.
• Legal successors: We may disclose all categories of personal information we process to a buyer or other successor in the event of a merger, acquisition or sale or transfer of some or all our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding. Such transactions may be in our legitimate interest, particularly our interest in making decisions that enable our business to develop. 
• To comply with the law or protect our rights or the rights of third parties: We access, preserve and share all the categories of personal information with regulators, public authorities, law enforcement, government agencies, out-of-court dispute settlement bodies or others where we reasonably believe such disclosure is needed to:
  1. comply with applicable laws, regulations, court orders, government or public authority requests;
  2. enforce applicable Terms of Service, including prevention of potential violations thereof;
  3. detect, prevent, or otherwise address illegal or suspected illegal activities, security, or technical issues;
  4. protect against harm to the rights, property or safety of our company, our users, our employees, or others; or
  5. to maintain and protect the security and integrity of TrafficJunky or infrastructure. In such cases, we may raise or waive any legal objection or right available to us, in our sole discretion.

We may disclose your information to third parties for the above purposes when necessary to comply with legal obligations, perform a task in the public interest (where the public interest is laid down by applicable law), or under our legitimate interests and the interests of the public, including as part of investigations or regulatory enquiries to detect, investigate and prosecute illegal activity.

7. Cookies and Automatic Data Collection Technologies

As you navigate through and interact with TrafficJunky, we use automatic data collection technologies to collect website activity data.

The technologies we use for this automatic data collection may include cookies, which are small text files that are stored in your web browser or downloaded to your device when you visit a website.

We currently use the following types of cookies, which are set by TrafficJunky:

• Strictly necessary cookies: These are cookies that are required for the operation of TrafficJunky. These include, for example, cookies that enable a user to log in to TrafficJunky and to check if a user is allowed access to a particular service or content.
• Functionality cookies: These cookies help us to personalize and enhance your online experience on TrafficJunky. This type of cookies allows us to recognize you when you return to TrafficJunky and to remember, for example, your choice of language.
• Analytics cookies: These cookies allow us to recognize and count the number of users and to see how users use and explore TrafficJunky. These cookies help us to improve TrafficJunky, for example by ensuring that all users can find what they are looking for easily. Additionally, we are using third party session recording technologies that help us better understand our users’ experience, however, the recording data is pseudonymized.
• Targeting and Advertising cookies: These cookies record visits of a user on TrafficJunky, the pages a user visits and the links a user follows to enable us to make TrafficJunky more relevant to the user’s interests and to help us serve ads that might be of interest to the user. Targeting and advertising cookies are used for Unregistered Users and Business Advertisers.

Analytics, Functionality and Advertising / Targeting cookies can be switched off at any time by accessing the ‘Cookies Settings’ option that is located at the footer of TrafficJunky. However, if you decline to accept these cookies, some functionality on TrafficJunky may be disabled and can interrupt your access to certain parts of TrafficJunky.

Cookies can be either session cookies or persistent cookies. A session cookie expires automatically when you close your browser. A persistent cookie will remain until it expires, or you delete your cookies. Expiration dates are set in the cookies themselves; some may expire after a few minutes while others may expire after multiple years.

The following cookies are used on TrafficJunky:

Do Not Track: Our systems do not recognize browser “Do Not Track” signals.

Use of Google Analytics. We use Google as a service provider to collect and analyze information about how users use the website, including, by collecting website activity data through first-party cookies set by our domains, and third-party cookies set by Google. Because we activated IP anonymization for Google Analytics, Google will anonymize the last octet of a particular IP address and will not store your full IP address. Google will use the information only for the purpose of providing Google Analytics services to us and will not use this information for any other purposes. The information collected by Google Analytics may be transmitted to and stored by Google on servers in the United States pursuant to standard contractual clauses approved by the EU and the adequacy decision of the EU Commission C (2023) 4745 confirming an adequate level of data protection in the US under the EU-US Data Privacy Framework and applicable national extensions (for example the UK Extension to the EU-US Data Privacy Framework). You can learn more on how Google uses data here, and you can opt-out of Google Analytics by visiting the Google Analytics opt-out page or by accepting only necessary cookies.

8. Third-party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, on TrafficJunky are provided or served by third parties. These third parties may use cookies alone or in conjunction with other tracking technologies to collect information about you when you click to view, access, or use any of the third-party feature on TrafficJunky or directed to such third-party website. Unless expressly stated otherwise, TrafficJunky does not provide any personal information to these third parties, however, when you click on a third-party internet-based advertising, they may collect information, including your IP address, advertisements you click, time zone setting and location, and information about your browser, operating system, and devices you use to access TrafficJunky to provide targeted content.

You can set your browser to refuse all third-party cookies, or to alert you when cookies are being sent.

9. Your Rights Related to Your Personal Information

Subject to local law and applicable legal requirements and exemptions, you have certain rights regarding your personal data:

• Right of access: you have the right to receive information on the personal data we hold about you and how such personal data is used, as well as a copy of your personal data;
• Right to rectification: you have the right to rectify inaccurate personal data concerning you;
• Right to be forgotten: you have the right to delete/erase your personal data;
• Right to data portability: you have the right to receive the personal data provided by you in a structured, commonly used, and machine-readable format and to transmit this personal data to another data controller;
• Right to object: you have the right to object to the use of your personal data where such use is based on our legitimate interests or on public interests;
• Right to restriction of processing: you have the right in some cases, to restrict our use of your personal data; and
• Right to file a complaint: If you are in the EEA or the UK, you also have a right to file a complaint with your local data protection authority.

If we ask for your consent to process your personal data, you have the right to withdraw your consent at any time with effect for the future. Note that, in that case, you may no longer able to use several functionalities on TrafficJunky or access TrafficJunky in some cases.

You can exercise your rights by sending us an e-mail at support@traffickjunky.com. Please note that we have one month to respond to your request.

Prior to processing an access or deletion request, we will need to verify your identity and ensure your right to access or delete the information. This is an appropriate and reasonable security measure to ensure that personal data is not disclosed to any person who has no right to receive it or deleted in an unauthorized way.

Please note that unless you have created an account with us, we may not have sufficient information to identify you and therefore we may not be able to process your request. Additionally, in some cases, to adequately verify your identity or your authorization to make the request, we may require you to provide additional information.

Note that some requests to delete certain personal information will require the deletion of your user account as the provision of user accounts are inextricably linked to the processing of certain personal information (e.g., your e-mail address). If you delete your account, your personal data and all account related information including, but not limited to, user profile data, sharing data and any data or content specifically associated with your account will no longer be accessible by you. If, after deleting your account, you wish to have an account with us in the future, you will have to sign up for a new account as none of the information you previously provided or saved within your account will have been saved. Please also note that after two years of inactivity, your account will be removed.

10. California Rights and Choices

The California Consumer Privacy Act (“CCPA”) provides you certain rights in relation to your personal information, as this term is defined under the CCPA. In addition to the rights that we state under this Privacy Notice, and subject to the exceptions found under the CCPA, Consumers have the right to:

• Opt-out of the sale of their personal information, should we sell their personal information;
• Be informed of certain information concerning our collection and use of their personal information;
• Request that we delete certain personal information we collected from them;
• Appoint an agent to exercise their rights provided for by the CCPA, provided that a duly executed notarized power of attorney is presented and provided that the agent has information deemed sufficient to allow us to verify the identity of the consumer in question and to locate his/her information in our systems;
• Not be subjected to discrimination for the exercise of these rights. We will not deny California residents the use of our service, neither will we provide a different level or quality or services for exercising any of their CCPA rights, unless as permitted under the CCPA.

 If the CCPA is applicable to you and you would like to exercise your rights, please send us an email at support@trafficjunky.com with the email subject line “CCPA Request.” You will need to provide the following information to verify your identity and enable us to locate your information in our systems: your username and email address that you used to create an account with us, as well as any other information which we may reasonably request for us to verify your identity. We may require you verify that you have access to your account and/or email account that you used to register with us.

You can designate an agent to make a request by executing a notarized power of attorney to have that person act on your behalf and providing that person with the information listed above that allows us to verify your identity and locate your information. Alternatively, you will need to directly confirm your identity with us using the methods described above, sign an authorization for the agent to act on your behalf and provide us with confirmation that you have done so.

TrafficJunky does not sell, nor has it sold in the past twelve (12) months personal information to third parties for monetary or other valuable considerations. We may however disclose certain personal information with third parties, service providers and entities within our corporate group to enable them to perform certain services on our behalf and namely to make TrafficJunky work properly, as described in the section above titled “Disclosure of Your Personal Information”.

11. Resident’s Rights – Jurisdictions in the United States, Where Applicable

We do not sell, trade, or exchange the Business Advertisers’ personal information with anyone for money.

12. Notice to Law Enforcement

The following information serves as a guideline for law enforcement officials seeking disclosure of records. You may serve us a valid court order, subpoena, search warrant or equivalent legal or official administrative document by respecting the following conditions:

• The document(s) is uploaded, and all required fields have been filed out adequately on our platform for Legal Service Process located at: https://legalservice.aylo.com/legal/datarequest;
• The document(s) you are serving is correctly issued to Aylo Freesites Ltd by a valid court of law or equivalent legal or administrative authority to us;
• The document(s) is also sent by mail at the following address: 195-197 Old Nicosia-Limassol Road, Block 1 Dali Industrial Zone, Cyprus 2540.

We reserve the right to refuse online service through TrafficJunky, namely in cases where the above requirements are not met and require formal legal service at the above address. In such an event, you will be notified. We may raise or waive any legal objection or right available, in our sole discretion.

13. Transfers of Your Personal Information to Other Countries

We may share the information we collect globally, across our corporate group and with our service providers and other third parties. Transfers are necessary for a variety of reasons, including our operation and provision of the services stated in our Terms of Service and this Privacy Notice to fix, analyze, and improve our website, products and services. Whenever we transfer personal information to countries outside the EEA and other regions with comprehensive data protection laws, we will ensure that the information is transferred in accordance with this Privacy Notice, as permitted by the applicable laws and based on appropriate mechanisms.

Where available, we rely on decisions of the European Commission, known as “adequacy decisions”, recognizing that certain countries offer a level of protection of personal data that is essentially equivalent to the EEA. In other situations, we rely on standard contractual clauses approved by the European Commission (and the equivalent standard contractual clauses for the UK, where appropriate) or on derogations provided for under the applicable law to transfer information to a third country.

For more information or to obtain a copy of our standard contractual clauses, please see the section “Contact Information” below on how to contact us.

14. Retention of Personal Information

We will only retain your personal information for as long as your account is active, or for as long as necessary to fulfil the purposes we processed it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider several factors, including what personal data we are processing, the risk of harm from any unauthorized disclosure, why we are processing your personal data and whether we can achieve this outcome by another means without having to process it.

Where we no longer need to process your personal information for the purposes set out in this Privacy Notice, we will delete your personal information from our systems.

For more information on data retention periods, please see the section “Contact Information” below on how to contact us.

Where permissible, we will also delete your personal information upon your request as explained above in the section “Your Rights Related to Your Personal Information”.

15. Third-Party Links and Sites

If you click on a link to a third-party website, you will be taken to websites we do not control. This Privacy Notice does not apply to the privacy practices of these websites. Read the Privacy Notice of other websites carefully. We are not responsible for these third-party practices.

16. Reviewing and changing Your Personal Information

Upon creating an account, you will be able to review and change your information through TrafficJunky. This is accomplished by logging in to your account and clicking on the “My Account” tab. From there, you can update individual information provided by you regarding your account. To reduce the occurrence of unauthorized access to your account information, TrafficJunky strongly urges you to periodically change your password. Upon request, TrafficJunky will remove your credit card or any other information from our system. To make this request, contact our support team. TrafficJunky will keep information in our files, including credit card information that you have requested to remove only in some circumstances, such as to comply with federal and state laws, resolve disputes, troubleshoot problems, comply with merchant banking and association agreements, reduce fraud, enhance security, and to enforce our Privacy Notice, Terms of Use and Rules and Regulations.

17. Security

TrafficJunky has security measures in place to protect and prevent the misuse and loss of the information under our control. We use industry standard efforts to safeguard the confidentiality of your personal identifiable information. Our technical experts at TrafficJunky work hard to ensure your secure use of our services.

18. Changes to this Privacy Notice

We may modify or revise our Privacy Notice from time to time. We may attempt to notify you of any material changes as required by law. Please also periodically review the most up-to-date version of our Privacy Notice, which will be posted at this location, so you are aware of any changes. The date of change will be reflected in the “Last Modified” date mentioned herein above.

19. International Payment Processing

Aylo Freesites Ltd is registered as part of a VAT group the representative member of which is Aylo CY Holdings Ltd. Its VAT registration number is CY99000217P.

20. Contact Information

If you have any questions about this Privacy Notice or our information-handling practices, please contact us by email at support@trafficjunky.com.

You may also contact us at 195-197 Old Nicosia-Limassol Road, Block 1 Dali Industrial Zone, Cyprus 2540, Phone: +357 22662 320, Fax: +357 22343 282.

Our Data Protection Officer can be contacted at the following email address: support@trafficjunky.com.