TrafficStars Privacy Policy

Effective Date: July 2017
Last Updated: 7 September 2026

1.   Preliminary

TRAFFIC STARS LTD is committed to protecting your personal data and your privacy. The personal data we collect depends on the service requested and agreed in each case by Traffic Stars Ltd and/or its Affiliates and/or related companies (collectively referred to as “Traffic Stars” or “Company” or “we” or “us” or “our” in this Privacy Policy). For all purposes of this Privacy Policy, Affiliate means any entity directly or indirectly, through one or more intermediaries, controlling, controlled by or under common control with Traffic Stars or by each other.

 

This Privacy Policy explains how we collect, use and processes your personal data, how we comply with our legal obligations to you and informs you about your privacy rights under the Processing of Personal Data (Protection of individuals) Law 125 (I)/2018) as amended from time to time and the EU General Data Protection Regulation (“GDPR”) 2016/679 as amended from time to time.

 

This Privacy Policy applies to the use of any and all personal data collected by us or provided by you in relation to your use of the Website.

Providing all the information requested through the Website is necessary in order to ensure optimum provision of the services offered to the user navigating our Website. If all the information required by Traffic Stars is not provided, we cannot guarantee that the information to be provided to you and the services to be rendered, are indeed provided or rendered or are rendered adequately or adjusted to your needs.

2.   Who we are 

TRAFFIC STARS LTD is a company duly registered in the Republic of Cyprus under registration number HE 335138 having its registered office and head office at Arch. Makariou III, 124, AGROTIS COURT, Floor 1, 3021, Limassol, Cyprus.

 

We have appointed a DPO who is responsible for overseeing questions in relation to privacy issues. Any questions about this privacy policy or any requests to exercise your legal rights shall be addressed to the DPO using the below details:

 

3.   Definitions and interpretation

In this Privacy Policy, the following definitions are used:

a)       racial or ethnic origin, political opinions, religious or philosophical beliefs;

b)      trade-union membership;

c)       genetic data, biometric data processed solely to identify a human being;

d)      health-related data;

e)       data concerning a person’s sex life or sexual orientation.

4.   Scope of this privacy policy

This Privacy Policy applies only to the actions of Traffic Stars and Users/Members with respect to this Website. It does not extend to any websites that can be accessed from this Website including, but not limited to, any links we may provide to social media websites.

5.   Collection and Use of Your Personal Data

If you are a User, we may collect the following personal data:

If you are a Member, we may collect the following personal data:

If you choose to use our Services and make a payment through our Website, your payment may be processed by one of our third-party payment service providers. These providers may collect and process your personal data, including payment details and other information necessary to complete and administer the transaction, in accordance with their own privacy policies. By proceeding with a payment, you acknowledge and agree that your personal data may be shared with and processed by the applicable payment service provider for the purpose of processing your payment and complying with applicable legal and regulatory obligations. We encourage you to review the privacy policy of the relevant payment service provider before completing your transaction.

 6.  Purposes of Processing Your Personal Data

We will use your personal data for one or more of the following reasons:

In the course of using our Website, we automatically log information such as IP address, browser type, referrer and other technical data for internal use only. This information is used to optimize our Website’s technical usability and for internal research data. In addition, when you provide your consent, you agree to receive from us promotional or services related communications which may contain sexually explicit content through emails or other means.

We also collect and use your data for the purpose of providing information about products or services you have shown interest in purchasing within a reasonable time afterwards, if you are already an existing Member, distributing our opt-in newsletters and contact for market research by email, telephone or fax, prior authorization of the Member, and to send promotions. You may remove yourselves through the unsubscribe link at the bottom of all emails or contact us by sending us an email to dpo@trafficstars.com .

Traffic Stars, directly or through third parties, is authorised to make any inquiries we consider necessary to validate your identity. This may include asking 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 or verifying your information against third party databases or through other sources.

We may also ask to see your driver’s licence or other government issued picture ID or any other identifying documents at any time, solely for identification and verification purposes. Traffic Stars reserves the right to close, suspend, or limit access to your account in the event we are unable to obtain or verify this information.

We do not collect, store or in any way process Sensitive Data.

7.   Transfer of Your Personal Data and Personal Data Recipients

In the course of the performance of our contractual and statutory obligations, your personal data may be provided to different departments within Traffic Stars and/or to third parties providing services to us. If it is necessary to share your personal data with a third-party service provider so we may perform our services and/or legal obligations, we enter into a contractual agreement with such third party to ensure that they comply with the data protection law and GDPR and they observe confidentiality.  We require all third-party service providers to respect the security of your personal data and to treat it in accordance with the law. We only permit our third-party providers to use your personal data for specified purposes and in accordance with our instructions and we only provide the necessary information they need to perform their specific services.

 

Your personal data may be transferred to entities outside the European Economic Area (the “EEA”) if this is necessary for the performance of our contractual relationship or if such a transfer is required by law. The EEA includes all the EU Members States plus three additional countries namely, Norway, Iceland and Liechtenstein.

 

To protect your personal data when transferred outside the EEA, we enter into the Standard Contractual Clause as provided by the European Commission.

 

We may transfer personal data to countries for which the European Commission has judged by its decisions (Adequacy Decisions) that transfer to these countries is safe because they ensure an equivalent level of personal data protection. Countries to which the transfer of personal data is assimilated to intra-EU transmission of personal data can be found here: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_el

 

Recipients of personal data may be, for example: third party/ies service provider/s, income tax authorities, auditors and accountants, legal consultants and external legal consultants, service providers, suppliers, agents, business partners, financial and business advisors, file storage companies, archiving and/or records management companies, cloud storage companies, delivery couriers, IT companies who support our website and other business systems and so on.

8.   No Automated decision-making

We do not use fully automated decision-making processes, including profiling, that produce legal or similarly significant effects on individuals. While we utilize automated tools to assist in detecting fraudulent activity, ad targeting optimization and screening of ad campaigns, these tools serve only as a preliminary screening mechanism. Any decision that may impact users—such as suspending an account, rejecting an ad, or flagging a payment—undergoes human review before being finalized. This ensures that our decisions are fair, transparent, and consider all relevant factors beyond what an automated system can assess.

9. Use of Artificial Intelligence (AI)

Traffic Stars may develop, implement, operate, integrate, utilise, modify and discontinue AI technologies, AI-powered tools, AI-enabled features and other AI functionalities from time to time in connection with the provision, operation, administration, security, monitoring, maintenance and improvement of its Website, platform, products and services. Such AI technologies may be developed internally by Traffic Stars or provided by carefully selected third-party technology providers acting on our behalf.

AI-powered tools and functionalities made available by Traffic Stars are designed to assist Users and Members by providing information, facilitating communications and interactions, generating or analysing content, automating operational tasks, improving user experience, enhancing the efficiency, security and quality of our services, detecting misuse or fraudulent activity, and supporting other legitimate business operations. The nature, capabilities and functionality of such AI-powered tools and services may evolve over time as we develop, improve and introduce new features, products and services.

When you interact with an AI-powered tool or functionality that is intended to communicate directly with you, Traffic Stars will take appropriate measures to inform you that you are interacting with an artificial intelligence system where required by applicable law.

Where appropriate, and depending on the nature of the service or feature being used, you may request that your enquiry or request be transferred to a member of our support team or another authorised representative of Traffic Stars for further assistance.

Information you provide when using AI-powered tools or functionalities made available by Traffic Stars, including messages, prompts, files, documents, images, communications or any other content voluntarily submitted by you, may be processed for the purposes of providing the requested service or functionality, responding to your enquiries, improving the quality, safety, security, reliability and performance of our services, detecting and preventing abuse, fraud or unlawful activities, maintaining appropriate business records, complying with legal or regulatory obligations, and exercising or defending legal claims where necessary.

Traffic Stars implements appropriate technical and organisational measures designed to ensure that personal data processed through AI-assisted services is protected in accordance with applicable data protection legislation. Access to such information is limited to authorised personnel and authorised service providers who require such access for legitimate business purposes and who are subject to appropriate confidentiality and security obligations.

Where AI-powered services incorporate or rely upon technologies provided by carefully selected third-party technology providers, such providers shall process personal data only under appropriate contractual safeguards, in accordance with applicable data protection legislation and, where applicable, our documented instructions.

Although Traffic Stars implements reasonable measures designed to promote the accuracy, reliability and appropriate performance of its AI-powered tools and functionalities, AI-generated outputs may occasionally be inaccurate, incomplete, unavailable or inappropriate. AI-generated outputs are provided to support the functionality of the relevant AI-powered feature or service and should not be relied upon as legal, financial, tax, investment or other professional advice. Where appropriate, Users and Members should exercise their own judgement or seek further assistance from Traffic Stars or another suitably qualified professional.

Traffic Stars regularly reviews and monitors its AI technologies and AI-powered functionalities to promote their security, reliability, appropriate performance and compliance with applicable laws, including, where applicable, Regulation (EU) 2024/1689 (the EU Artificial Intelligence Act). For additional information about our use of artificial intelligence technologies and AI-powered features, please refer to our AI Policy.

10.   Security for Your Personal Data

Traffic Stars uses appropriate administrative, technical, and physical measures to protect your personal data. Authorised personnel and third parties service providers may have limited access to your personal data, and they will only process your data according to our instructions. We have implemented mechanisms to:

 

We have also established a policy for data breach, and we commit to notifying you and the competent authority for any breach or any suspected personal data breach where we are obliged by the law to do so.

11.   Data Retention

We will retain your personal data for as long as necessary, to fulfil the purposes we collected it for, and to comply with a regulatory or statutory obligation. Once the required legal period has elapsed, these data will be definitively erased.

 

The criteria used to determine our retention periods include:

 

Communications conducted through AI-assisted support services are retained in accordance with the same retention periods applicable to customer support communications unless a longer retention period is required by law.

You have the right to request deletion of your data. You can request us to erase your personal data (known as the ‘right to be forgotten’) where its process is of no further use or interest for Traffic Stars.

12.   Your Legal Rights

You have the right to:

(i)         request access to your personal data

(ii)   request correction of your personal data

(iii)  request erasure of your personal data

(iv)   Object to processing of your persona; data

(v)        Request restriction of your personal data

(vi)   Request transfer of your personal data

(vii)   Request withdrawal of the consent that you gave us

 

If you would like to exercise any of your rights, please contact our DPO by sending an e-mail to dpo@trafficstars.com or contact our support team by sending an email to support@trafficstars.com and submit the relevant request. It is provided that you may be requested to accompany a copy of your national Identification Card, passport or other valid document in order for us to identify you.

 

You also have the right to lodge a complaint at any time to the Office of the Commissioner for Personal Data (http://www.dataprotection.gov.cy).

 

You also have the right to lodge a complaint with the supervisory authority in the country of your habitual residence, place of work, or where the alleged infringement occurred, provided it is within the EEA.

 

We would appreciate the chance to deal with your concerns and address your queries before you approach the respective supervisory authority.

13.   Functionality of the website

To use all features and functions available on the Website, you may be required to submit certain Personal Data.

You may restrict your internet browser’s use of Cookies. For more information see the below clause.

14.   Cookies

This Website may place and access certain Cookies on your computer. Traffic Stars uses Cookies to improve your experience of using the Website and to improve our range of services. Traffic Stars has carefully chosen these Cookies and has taken steps to ensure that your privacy is protected and respected at all times.

All Cookies used by this Website are used in accordance with current applicable laws.

Before the Website places Cookies on your computer, you will be presented with a message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling Traffic Stars to provide a better experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Website may not function fully or as intended.

For more information about Cookies, please check our Cookies Policy available at https://trafficstars.com/cookies.

15.   California Consumer Privacy Act Notice

We do not specifically target or collect personal data from California residents. However, if a California resident voluntarily registers and uses our platform, we may process their personal information as part of our standard data processing practices.

To the extent that the California Consumer Privacy Act (CCPA) applies, California residents may have certain rights regarding their personal information. In addition to the rights we state under this policy and subject to the exceptions applicable under the CCPA, Consumers have the following rights:

Only you, or a person you have designated in writing as your authorised agent through a duly executed notarized power of attorney, may make a verifiable Consumer request related to your personal information. We reserve the right to require you or your authorised agent to provide sufficient information to allow us to reasonably verify that you are the person about whom we collected personal information.

This Website does not sell, nor has it sold personal information to third parties for monetary or other valuable considerations. We may, however, disclose certain personal information with third parties as described in this Policy in order to enable them to perform certain services on our behalf and namely to make the Website work properly. Regardless, we respect the California residents’ right to exclude personal information from such sharing arrangements and to thereby opt-out of any future sale of their personal information. If the CCPA is applicable to you and you would like to record such preference, please send us an email at support@trafficstars.com or at dpo@trafficstars.com.

16.  General

If any court or competent authority finds that any provision of this privacy policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this privacy policy will not be affected.

Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.

17.  Changes to this privacy policy

We may change this policy as new services are added or old ones are changed. Please check this Privacy Policy from time to time for updates on our Website. 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 Traffic Stars or substantially all of its assets are acquired, user information may be one of the transferred assets, without prejudice to applicable data protection requirements.