Last Modified: September 9^th, 2025

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.

Please read this Privacy Notice carefully, as your access to and use of TrafficJunky signifies that you have read and understand all terms within this Privacy Notice. We respect your privacy and are committed to protecting your personal data.

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

Scope

For the purposes of this Privacy Notice, “process”, “processed” or “processing” means any operation or set of operations performed on personal data or on sets of personal data (excluding disclosure thereof), whether by automated means, including one or several of the following operations: collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, alignment or combination, restriction, erasure, or destruction. Information on disclosure of personal data or of sets of personal data may be found in the “Disclosure of Your Personal Information” section below.

This Privacy Notice applies to information we process: 

• on TrafficJunky; and
• on your communications with TrafficJunky via email, online support chats, phoneline support or otherwise. 

The Data We Process About You

“Personal Data” or “Personal Information” means any information that identifies, relates to, describes, or could reasonably be linked, directly or indirectly, with a particular individual. It does not include data that has been anonymized or aggregated.
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”):

• 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 sent 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.
• Activity Data: 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”.
• 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 process information you submit to personalize your account or for a specific function, for example date of birth, age, gender, your interests, preferences, feedback, your preferences in receiving marketing from us and our third parties, and your communication preferences, as well as any other information which you voluntarily provide to us at your direction for a specific function. 
• 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 for certain services on TrafficJunky or if this is required for age verification purposes, we process identifiers you submit to us (including government-issued photo identification, utility bills, phone bills, bank statements and/or other documentation) for us to verify your identity, age, and record checks. Our third-party service provider will also process your face scan, which is considered 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. This Privacy Notice may not always reflect the privacy practices said third-party service providers and therefore invite you to consult their privacy notices and terms and conditions of these third-party service providers. 
• Marketing Emails: We will not send you marketing emails without your consent. You may opt-out from 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. 
 

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 above directly from 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.
• 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.
   

Purposes for which we use your Personal Information

We process Personal Information for the purposes described below.

• Provision of services: We process 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 accounts, 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 of Use 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.
   

Biometric Information

We employ third-party service providers to help verify your identity, age, and to verify the authenticity of the identification documents you provide us with, using facial recognition technology. Facial recognition technology creates a mathematical representation of your facial features which are detected from the live scan of your face, your selfie, and the government-issued ID you submit or have previously submitted to us. Face recognition data is collected by and remains with our third-party providers. We do not process face recognition data. Where applicable, your biometric information may 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;
• match your selfie with your government-issued ID which you will submit or have previously submitted to us namely to make sure that nobody is impersonating you; 
• help confirm your age.

You will be asked to provide your consent to biometric information processing which you may withdraw at any time. Withdrawing your consent will not affect the lawfulness of any collection, use, processing or disclosure that occurred prior to the withdrawal.
This Privacy Notice may not always reflect the privacy practices of said third-party service providers, and you are therefore invited to consult the privacy notices and/or other, relevant terms of these third-party service providers.
 

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 Information 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. You may withdraw your consent at any time, but withdrawing your consent will not affect the lawfulness of any collection, use, processing, or disclosure that occurred prior to the withdrawal;
• Biometric information may also be processed via a third-party service provider with your consent;
• It is necessary to perform our contractual obligations per our Terms of Use, 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;
• It is used for tasks carried out in the public interest: for example, to combat unlawful behavior 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.
 

Disclosure of Your Personal Information

We disclose your Personal Information when necessary to deliver 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, our legal obligation to do so, our legitimate interest (e.g., operating TrafficJunky), so long as it does not 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 contract between us. The parties to whom we may disclose your Personal Information include:

 

• To the public. When, if applicable, 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.
• 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 run their services outside the EEA.
• Service providers. We disclose certain categories of Personal Information to our authorized service providers that perform certain services on our behalf. These services may include risk and fraud detection and mitigation, customer service, advertising, analytics, security, hosting or supporting TrafficJunky functionality. These service providers may have access to Personal Information needed to perform their functions but are not permitted to share or use such information for any other purposes. Where required under applicable laws, we 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 your 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. satisfy any applicable law, regulation, legal process, or governmental request;

  2. enforce applicable Terms of Use, including investigation 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;

  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 our legal obligations, to 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.
 

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 include cookies and other similar technologies. Cookies are small text files that are stored in your web browser or downloaded to your device when you visit TrafficJunky. For more information on how we use cookies, please refer to our Cookie Notice, available here.
 

Your Choices About How We Collect, Use and Disclose Your Personal Information

We strive to provide you with choices regarding the Personal Information you provide to us:

• You can choose not to provide us with certain Personal Information, but that may result in you being unable to use certain features of TrafficJunky because such information may be required for you to create an account, use our products or services, communicate with our support teams, or initiate other activities on TrafficJunky.
• The Cookie Banner can be utilized to customize your cookie preferences. The Cookie Banner will record when you have consented to our cookies. For Business Advertisers, we will ask for consent once a year or when we have major changes to our cookies, to ensure you stay up to date with changes to our cookies and Privacy Notice. For Unregistered Users, your Cookie Banner selection will be kept only for the specific session. The Cookie Banner specifically controls the functionality, analytics, and advertising cookies set by using TrafficJunky. Strictly necessary cookies cannot be disabled, nor can the tool be used to block cookies on third party websites linked from our website. You can access the Cookie Banner anytime by clicking on the “Cookie Settings” option that is located at the footer of TrafficJunky.
   

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. However, please note that, in such cases, you may no longer be able to use or access one or several functionalities on TrafficJunky. 
You can exercise your abovementioned rights by sending us an e-mail at support@trafficjunky.com. Please note that we have one (1) month to respond to your initial request.

Prior to processing a request for access or deletion of your data, 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 or delete it 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 may, therefore, be unable to respond to your request. In some cases, to adequately verify your identity or your authorization to make the request, we may require you to provide additional information.
 

California Rights and Choices

The California Consumer Privacy Act of 2018 (“CCPA”) provides California residents (“Consumer(s)”) certain rights with respect to their 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, such 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;
• Appoint an agent to exercise their rights provided 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.

You can exercise your rights, by sending us an email at support@trafficjunky.com with the email subject line “CCPA Request.” If you need assistance regarding the exercise of your rights, you can also send an e-mail at support@trafficjunky.com to help you with the process.
 

Resident's Rights – Jurisdictions in the United States, Where Applicable

We do not sell, trade, or exchange Business Advertisers’ Personal Information with anyone for money.
 

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.

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, in accordance with applicable data protection laws and appropriate safeguards. Transfers are necessary for a variety of reasons, including our operation and provision of the services stated in our Terms of Use 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 applicable, 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.
 

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”.

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.

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 enforce our Privacy Notice, Terms of Use and Rules and Regulations.

Security

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

 

Changes to this Privacy Notice

We keep our Privacy Notice under regular review. The purpose is to address any new legal requirements, technical developments or to add more clarifications, as needed.

Although we may attempt to notify you when major changes are made to this Privacy Notice, you are expected to periodically review the most up-to-date version found at this location, so you are aware of any changes, as they are binding on you. If we change anything in our Privacy Notice, the date of change will be reflected in the “Last Modified” date mentioned in the header of this Privacy Notice.

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.

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.