1. Introduction

Aylo Freesites Ltd (hereinafter “we”, “us” or “our”) operates the website https://www.TrafficJunky.com/ (hereinafter “TrafficJunky”) This Privacy Policy applies to TrafficJunky only. It will tell you how and why we gather and use information about users of TrafficJunky. We understand the importance of privacy and we use best practices, to uphold this while using our website within a business-to-business relationship context. Below is our privacy policy that ensures you are protected while using TrafficJunky. Please contact our support team if you have any further questions regarding this policy.

2. Collection and Our Use of Your Personal Information

We may collect different kinds of personal data about you, depending on whether you chose 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”):

• website activity data: In the course of using our site, we automatically log information such as IP address, browser type, referrer and other technical data for internal use only.

Strictly business advertisers:

• 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 also collect biometric information in order 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
• 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.

3. 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. The 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. This mathematical representation, which is considered biometric information/identifier/data under the laws of certain states and countries, is not shared by our service providers with us, and is deleted by our service providers 7 days after its creation. 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;
• to help confirm your age; and
• to check your criminal/background history.

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 located in jurisdictions that do not offer the same level of data protection as your jurisdiction.  We (and/or any of these entities) may perform facial recognition and process your biometric information from your face scan, selfie, and any government-issued ID, and processing your biometric information for the above purposes.

Biometric information shared by our service providers with us will be stored for as long as you have a business advertiser account.  We will delete your biometric information within three (3) years of you deleting your business advertiser account or withdrawing your consent, subject to any legal obligations we might have.

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.

4. 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: We use identifiers, payment and commercial information and user submitted personal information to manage business advertisers’ accounts, to provide customer support and notices to the business advertiser about their account, and 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.
• 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.
• 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 policy.

5. Disclosure of Your Personal Information

We disclose personal information:

• To the public: When you submit user contributions including audio/video content, you are using our website and services to make that information public.
• Within our corporate group: We may disclose any of the categories of personal information to members of our corporate group (including affiliates and related entities) to the extent this is necessary for our purposes listed in the sections above.
• Service providers: We disclose the categories of personal information we collect to our authorized service providers that perform certain services on our behalf. These services may include payment processing and fulfilling orders, identity and document authenticity verification, risk and fraud detection and mitigation, customer service, marketing and advertising, customization of content, analytics, security, or hosting TrafficJunky or supporting TrafficJunky’s 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.
• Legal successors: We may disclose all of the categories of personal information we collect to a buyer or other successor in the event of a merger, acquisition or sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding.
• To comply with the law or protect our rights or the rights of third parties: We access, preserve and share all of the categories of personal information with regulators, law enforcement or others where we reasonably believe such disclosure is needed to (a) satisfy any applicable law, regulation, legal process, or governmental request, (b) enforce applicable terms of use, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address illegal or suspected illegal activities, security or technical issues, (d) protect against harm to the rights, property or safety of our company, our users, our employees, or others; or (e) 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.

6. Cookies and Automatic Data Collection Technologies

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

We use 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 the website’ domains, or by other domains we own or control:

• Strictly necessary cookies: These are cookies that are required for the operation of our website. These include, for example, cookies that enable a user to log in to our website 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 our website. This type of cookies allows us to recognize you when you return to our website 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 our website. These cookies help us to improve our website, for example by ensuring that all users are able to find what they are looking for easily. Additionally, we are using third party session recording technologies that helps us better understand our users’ experience, however, the recording data is pseudonymized.
• Targeting and Advertising cookies: These cookies record visits of a user on our website, the pages a user visits and the links a user follows in order to enable us to make our website 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 Registered Users.

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

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.

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. 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.

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

• Some content or applications, including advertisements, on Pornhub 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 Pornhub or directed to such third-party website. Unless expressly stated otherwise, Pornhub 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 Pornhub to provide targeted content. 

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

8. Our Legal Bases under the Canadian and European Union (EU) Law

We have the following legal bases under the Canadian and EU privacy law for processing your personal data for the purposes described under Purposes for Which We Process Your Personal Information section:

• We process personal data for the purposes of providing the services, customer management, certain customization of content (e.g., based on your selected preferences, favorites and ratings), and functionality and security because the processing is necessary for the performance of a contract, specifically it is necessary to provide the services or products you have requested, or to provide our websites and services in a manner consistent with our terms and conditions and any other contract that you have with us.
• We process personal data, including identifiers, for the purpose of verifying your identity because such processing is necessary for us to comply with a legal or regulatory obligation.
• We process biometric information based upon your consent to do so.
• We process personal data for the purposes of customization of advertising, marketing, and analytics for our legitimate interests.
• We process personal data for functionality and security because it is necessary for our legitimate interests, and in certain cases because the processing is necessary for us to comply with a legal or regulatory obligation.
• We process personal information in specific circumstances where you have provided your consent to such processing.

9. Your Rights Related to Your Personal Information

Generally, in some regions like Canada, European Economic Area (“EEA”), and the United Kingdom, you have certain rights regarding the personal information we process and that is related to you, including the right:

• to receive information on the personal information we hold about you and how such personal information is processed (right to access);
• to correct inaccurate personal information concerning you (right to data rectification);
• to delete/erase your personal information (right to deletion, “right to be forgotten”);
• to receive the personal information provided by you in a structured, commonly used and machine-readable format and to transmit the personal information to another data controller (right to data portability);
• to object to the processing of your personal information where such processing is based on our legitimate interests or on public interests (right to object);
• in some cases, to restrict our processing of your personal information (right to restriction of processing); and
• to withdraw your consent at any time where our processing is based on consent (right to withdrawal of consent).

You may exercise your right to access and deletion using the buttons at the bottom of this page. Additionally, you may, at any time, send us an e-mail at support@traffickjunky.com to exercise your above rights in accordance with the applicable legal requirements and limitations. If you are located in the EEA or the United Kingdom, you have a right to lodge a complaint with your local data protection authority.

Please note that unless you have created an account with us, we may not have sufficient information to identify you and therefore may not be in a position to respond to your request. Additionally, in some cases in order 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).

10. California Rights and Choices

The California Consumer Privacy Act (“CCPA”) provides you certain rights in relation to your personal information:

• Right to Know: You have the right to request that we disclose certain information about our processing of your personal information over the past 12 months, including the specific pieces of information we processed.
• Right to Request Deletion: You have the right to request that we delete any of your personal information we processed from you and retained, subject to certain exceptions set forth in the CCPA.
• Right to Non-Discrimination for the Exercise of Your Rights: We will not discriminate against you because you have exercised any of your rights under the CCPA.

To exercise the rights described above, please contact us here with the email subject line “CCPA Request.” In either case 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 in order 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.

We disclose certain categories of California residents’ personal information for our business purposes, 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 Registered Users’ 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:

1. 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;
2. The document(s) you are serving is correctly issued by a valid court of law or equivalent legal or administrative authority to us (See websites’ footer to find our operating entity);
3. 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 our website, namely in cases where the above requirements are not met and require formal legal service at the above address. In such event, you will be notified. We may raise or waive any legal objection or right available, in our sole discretion.

13. 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 Terms of Use.

14. 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.

15. Minors

Minors in the country, province, or state in which they live, can only use this Site with the approval of a parent or guardian.

16. CHANGES TO THIS PRIVACY POLICY

We may change this policy as new services are added, or old ones are changed. Such changes will be effective when a notice of the change is posted on TrafficJunky. Please check this Privacy Policy from time to time for updates by checking the date of the "Last Update" at the top of this document. We may e-mail periodic reminders of our policies and terms of use, but you should check our website frequently to see recent changes. Unless stated otherwise, our current Privacy Policy applies to all information that we have about you and your account. As we continue to develop our business, we might reorganize or transfer our business units or assets. In such transactions, user information generally is one of the transferred business assets but remains subject to the promises made in any pre-existing Privacy Policy unless the user consents otherwise. Also, in the unlikely event that TrafficJunky or substantially all of its assets are acquired, user information be one of the transferred assets.

17. 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.