Privacy Policy

1. APPLICATION OF THIS POLICY

MG 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 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 (including Yoti Ltd.) to help verify your identity and to check 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, and which is considered biometric information/identifier/data under the laws of certain states and countries. Your biometric information will be used 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.

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 (including Yoti Ltd.). These entities may be located in jurisdictions that do not offer the same level of data protection as your jurisdiction. Any of these entities may perform facial recognition and collect your biometric information from your face scan, selfie and any government-issued ID, and use your biometric information for the above purposes.

Your biometric information will be stored for as long as you have a business advertiser account. We will delete your biometric information within three years of you deleting your business advertiser account or withdrawing your consent. 

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 collection, use, 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. OUR LEGAL BASES UNDER EU LAW

We have the following legal bases under EU law for processing your personal data for the purposes described under Section Purposes for Which We Use Your Personal Information:

  • 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 TrafficJunky 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.

6. 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 collection of your personal information over the past 12 months, including the specific pieces of information we collected.
  • Right to Request Deletion: You have the right to request that we delete any of your personal information we collected 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.

We do not sell California residents’ personal information.

7. NOTICE TO NEVADA RESIDENTS/YOUR NEVADA PRIVACY RIGHTS

We do not exchange Nevada residents’ personal information for money with anyone so they may license or sell the personal information to additional parties.

8. DISCLOSURE OF YOUR INFORMATION

We disclose personal information:

  • 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.

We do not rent or sell any identifiable personal information provided by you or about you to any third party without your permission.

9. REVIEWING AND CHANGING YOUR PERSONALLY IDENTIFIABLE 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 Law, resolve disputes, troubleshoot problems, comply with Merchant Banking and Association Agreements, reduce fraud, enhance security, and to enforce our Terms of Use Agreement

10. COOKIES AND SESSION MANAGEMENT

This site uses cookies for session management. We also use form and URL elements that may contain a unique user ID. Cookies, form elements and other related management techniques are used to ensure a continuous user session.

11. 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.

12. CHILDREN

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

13. 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 Notice 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 Notice 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.

14. INTERNATIONAL PAYMENT PROCESSING

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

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