Traffictune Ltd (“Company” or “us” or “our”) adhere to the practices detailed in this Privacy Policy (“Privacy Policy“) in respect of our users’ (“user” or “you” or “your”) access and use of our website (“Site”) and the Services provided therein (as defined in our Terms of Use.)
We have designed this Privacy Policy so that you can clearly understand our privacy practice and have included below information about which data is collected, how we process and use your data as required, according to the EU General Data Protection Regulation (“GDPR”) and the California Consumer Privacy Act (“CCPA”) where applicable.
In the event you are a California resident and the CCPA applys to you – please review our CCPA Privacy Notice ” https://traffictune.com/privacy-policy/
At the outset, we would like to explain the basis on which we process Personal Data (as defined below):
- Where you contact us, we process your Personal Data in order to perform our contract with you and provide you with the service you requested;
- If we have a legitimate interest in processing data, such as online identifiers when you access our Site; or
- We will also process your Personal Data where you have provided us with consent to do so, where such consent is required under applicable law.
We recommend you to read this Privacy Policy carefully prior to accessing our Site or using our Services in order to make informed decisions. For more details regarding the terms and conditions of our Site and Services, please read our Terms of Use. Note that, this Privacy Policy is an integral part of the Terms of Use. Definitions herein shall have the same meaning as defined therein.
If you have any questions about this Privacy Policy, please contact us at: support@traffictune.com
Types of Data We Collect
While you access the Site or use the Services, we may collect non-identifiable aggregated information (“Non-Personal Data“), such as technical information transmitted by your device. This Non-Personal Data is NOT used to identify individual users. The Non-Personal Data may include: certain software and hardware information, i.e., type of operating system, type of device, type of browser, language preference, statistical browsing information in the Site, approximate geographical location, etc.;
In addition, we may collect individually identifiable information (“Personal Data”, or “Personal Information”, as defined under applicable law).
We do not combine Personal Data you may provide voluntarily with the Non – Personal Data. However, if we do so, we will treat the combined information as Personal Data.
The table below details the types of data we collect and how we use it:
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Type of Data |
How Do We Use It? |
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In the event you contact us for support or other inquiries, either through the online form available in the Site, by sending us an email or by other means of communications we make available, you will be requested to provide us your name and a valid email address. |
We will use your contact details and save your contact history with us solely in order to respond to your inquiry, provide you with support, assistance or any other service requested by you. |
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IP, Online Identifiers and technical Non-Personal Data (as detailed above) which relates to your use of the Site. We also collect IP address and may create (by ourselves or by the Service Providers we engage with) a unique ID if and when you click and directed to the Third-Party Services). |
We use this data for our legitimate interests of (i) operating, providing, maintaining, protecting, managing, customizing and improving our Site and Services and the way in which we offer them; (ii) enhancing your experience with the Services; (iii) our legitimate interests of auditing and tracking usage statistics and traffic flow as well as calculate payment we are entitled to on behalf of our business partners (i.e., the Service Providers); and (iv) remarketing (as detailed below). |
How Do We Collect Your information?
Depending on the nature of your interaction with the Services, we may collect information as follows:
(i) Automatically – we may use Cookies and similar technologies (as elaborated in the Section below) to gather some information automatically.
(ii) Provided by you voluntarily – we will collect information if and when you choose to provide us with the information, such as through contact us communications, etc. all as detailed in this Privacy Policy.
Remarketing & Cookies
We use Cookies and other technologies (e.g. web beacons, pixels, etc.), as we gather some information automatically, by ourselves or by using third party service and store it in log files. “Cookies” are small text files that are placed on your hard drive by a web server when you access our Services. Cookies are used in purpose of making the interaction between you and the Services quicker and easier, by, for example, enabling automatic activation of certain features, efficient navigation between pages, remembering your preferences etc., as well as for remarketing purposes (as detailed below). More information about cookies is available at: www.allaboutcookies.org. You may be able to disable some cookies through your device or browser settings (for more information, see the “opt-out” section below). Please note that, if you choose to disable cookies, some features of our Services may not operate properly.
In addition to our cookies which are implemented and used for the purpose of operating the website and track performance of our campaigns, we may permit third parties to use cookies or other technology to collect information about your online and application usage activities across our Site, as follows:
Google Analytics. This cookie is placed in order to track and analyze the use of our Services, for internal purposes, and may include the collection of your IP. Additional information with respect to Google’s use of the data from our use of Google Analytics Cookies, is available in Google’s policies located at: www.google.com/policies/privacy/partners. We also recommend you to read about Google Analytics’ currently available opt-outs available at: https://tools.google.com/dlpage/gaoptout/
Google AdWords. We use Google AdWords remarketing services and cookie to advertise across the internet. AdWords remarketing will display relevant ads tailored to you based on the parts of the website you have viewed by placing a cookie on your device (e.g., the cookie will indicate you have visited a certain webpage and will show you ads relating to that webpage. Google AdWords remarketing allows to tailor marketing and to serve ads that are relevant to you. For more information please review Google’s currently available opt-outs and Ads Settings available at: https://adssettings.google.com/authenticated.
For additional information of our use of Google products, click https://policies.google.com/technologies/partner-sites here.
MaxMind. We use MaxMind for GEO Location Services (country level). This service provider privacy policy is available at: https://www.maxmind.com/en/privacy_policy
Note that, our business partners (i.e., the Service Providers) may include certain tracking technologies in the event you interact with their offers.
Disclosure of Information
The Personal Data we collect is not shared with third parties or any of our partners except in the following events, and solely to the extent needed:
(i) Authorized Disclosures: we may disclose your information to third parties when you consent to a particular disclosure. Please note that once we share your information with another company, that information becomes subject to the other company’s privacy practices;
(ii) Law Requirement and Policy Enforcement: we may share your information in order to comply with any applicable law, regulation, legal process or governmental request as well as for the purpose of enforcing our agreements and policies, and taking all actions derived thereof (i.e., investigate, detect, prevent, or any applicable action needs to be taken with resect to illegal activities, wrongdoing, suspected fraud or security needs) as well as to establish, exercise or defend our rights;
(iii) Third Party Rights: we may share your information in order to prevent harm to the rights (including any legal rights), property (including intellectual property) or other or safety of us, our users or any applicable third party;
(iv) Affiliated Companies: We may share your information with a parent company, subsidiaries, joint ventures, or other companies under common control (“Affiliated Companies“) solely if and when applicable or necessary for the purposes described in this Privacy Policy;
(v) Corporate Transaction: We may share information, in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, consolidation or asset sale), provided however, that our Affiliated Companies or acquiring company will assume the rights and obligations as described in this Privacy Policy;
(vi) Service Providers. We may disclose Personal Data to our service providers so that they can perform requested services on our behalf. These entities are prohibited from using your Personal Data for any purposes other than providing us with requested services (e.g., analytic services).
(vii) Online Identifiers. We may share IPs collected by us (as detailed above), for the purpose of operating and improving our business, providing the Services and remarketing, calculating payments and auditing our business partners, as well as to detect fraud, security or technical issues in connection with the Site.
The Non-Personal Data we collect may be used or shared in any of the above circumstances, as well as (i) for the purpose of providing and improving our Services; or (ii) internally within the Company to conduct business and marketing analysis and enhance your experience. We reserve the right to use, disclose or transfer aggregated and processed data to third parties, including, inter alia, affiliates and consultants, for various purposes. This information may be collected, processed and analyzed by us and transferred in a combined, collectively and aggregated manner (i.e., your information is immediately aggregated with other users) to third parties.
Third Party Content and Sites
The Service and Site Content includes links to websites and services not owned or operated by us (“Third Party” and “Third Party Site” respectively). These Third Parties’ privacy practices may differ from ours. Since those Third Parties’ Sites, including any content, products or services therein, are provided by us solely as suggestions, we are not, and won’t be held responsible to such Third Parties’ privacy practices. Thus, we recommend you to carefully review the applicable Third-Party privacy policy once you leave our Site via any link directing to Third Parties’ Sites.
Retention and Security
We retain the information we collect solely for as long as required to fulfil the purposes for which it was collected. However, in some circumstances we may retain the information we collect for longer periods, for example, when we are required to do so in accordance with legal, tax and accounting requirements. In addition, we may also retain your Personal Data for longer periods if we reasonably believe, at our discretion, that we need to obtain an accurate record of your correspondence or any dealing with us, for example, in the event of any complaints, all, in compliance with applicable laws.
We use security techniques to prevent your information from being accessed without authorization, improperly used or disclosed, unlawfully destructed or accidental loss, as detailed in our Information Security Policy. However, although we make best efforts in this regard and adopt what we consider to be appropriate data collection and security measures, we can’t provide 100% security and we cannot be held responsible for unauthorized or unintended access that is beyond our control. If you believe that your privacy was treated not in accordance with this Privacy Policy, or you have reasonable concern with that any person attempted to abuse our Service, please contact us at: privacy@traffictune.com.
Further, in the event of a data incident, in which we discover your Personal Data may be at risk, then we will take reasonable efforts to notify you and the applicable authority (if required, subject to applicable laws).
Your Rights
Data protection and privacy laws provide you with the ability to exercise some rights regarding your Personal Data that we hold (which might be different in each jurisdiction) such as;
(i) you may request to access your Personal Data that we hold;
(ii) you may request the rectification of your Personal Data that we hold;
(iii) you may request the erasure of your Personal Data that we hold (as long as we do not have a legitimate reason for retaining the data);
(iv) you may request to restrict processing of your Personal Data;
(v) you may object to processing of your Personal Data by us;
(vi) you may request to exercise your right of data portability;
(vii) you may exercise your right to file a complaint to a supervisory authority in your jurisdiction; and,
(viii) you have the right to withdraw consent (in the event the Personal Data is processed subject to your consent).
For more information regarding users’ rights, please read our Privacy Rights Policy. In addition, if you wish to submit a request to exercise your rights, please download our form available here and send it to: privacy@traffictune.com.
If you wish to be provided with more information or in the event that you have any additional complaints about your privacy rights, please contact our Data Protection Officer at: privacy@traffictune.com . Please note that you have the right at any time to contact your local data protection authority.
When you contact us and request to exercise your rights regarding your Personal Data, we will require certain information from you in order to verify your identity and locate your data and that the process of locating and deleting the data may take reasonable time and effort, as required or permitted under applicable law.
Data privacy and related laws in your jurisdiction may provide you with different or additional rights related to the data we collect from you, which may also apply.
Opt-Out right
You may opt-out of the data collection, sharing process and advertising services related to our Site, as follows:
(i) you may set your browser to block all cookies, including cookies associated with our Services, or to indicate when a cookie is being set, by adjusting the privacy and security settings of your web browser. Please refer to the support page of the browser you are using. For your convenience, see more information about your controls in this regard, within the following links:
Safari; and
Edge.
(ii) you may contact us (as detailed below), and we will make best efforts to assist you;
(iii) you may opt out of certain advertisers’ cookies and browser-enabled, interest-based advertising at the Network Advertising Initiative’s (“NAI”) website – NAI consumer opt-out and the Digital Advertising Alliance’s (“DAA”) website – DAA opt-out page.
Note that once you opt out, part of the Services provided by us might no longer be available and some features may not work if you revoke the data collection.
Children’s Privacy
We do not use the Site or Services to knowlingly solicit data from or market to children (as defined under applicable laws). We request that such individuals do not provide Personal Data through our Services. We reserve the right to request proof of age at any stage so that we can verify that children are not using the Services. If you become aware or have any reason to believe that a child has shared any information with us, please contact us at: privacy@traffictune.com and we take reasonable steps to ensure that such information is deleted from our files.
Transfer of Data
We may store or process your information in the United States, EU or in other countries. If you are a resident of the European Economic Area (“EEA”) we will take appropriate measures to ensure that your information receives an adequate level of data protection upon its transfer outside of the EEA.
Do Not Track Disclosure
The Site does not respond to Do Not Track signals. For more information about Do Not Track signals, please see: http://www.allaboutdnt.com/.
Amendments
We reserve the right, at our discretion, to revise or update these this Privacy Policy at any time. Such changes shall be effective upon publication of the amended Terms. The last revision will be reflected in the “Last Modified” heading. Your continued use of the Services thereafter constitutes you consent to such changes and you agree to be bound by them. Please make sure to review our Privacy Policy periodically. In the event of a material change we will make best efforts to inform you.
Note to California Residents: Notwithstanding the above, as required under the CCPA, this Policy will be reviewed and updated every 12 months.
Contact Us
If you have any questions or comments about this Privacy Policy, please write to us at:
Wiseclicks Technologies Ltd.
Merchants Court,
2-12 Lord Street,
Liverpool,
L2 1TS
United Kingdom
You can also contact us via email at: support@traffictune.com
Data Protection Officer
If you have any requests regarding the data collected under this Policy, including without limitation, requests to remove, delete, amend, modify or transfer the data, please contact our Data Protection Officer at: privacy@traffictune.com.
Please be sure to include your name, address and email address in any correspondence to us so that we can respond to your inquiry in a timely manner.
