EFFECTIVE DATE: JULY, 2017

LAST MODIFIED: MARCH, 2025

WEBSITE(S) COVERED: TRAFFICSTARS.COM

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:

Email address: dpo@trafficstars.com

Postal address: Arch. Makariou III, 124, AGROTIS COURT, Floor 1, 3021, Limassol, Cyprus

3. Definitions and interpretation

In this Privacy Policy, the following definitions are used:

Cookies means a small text file placed on your computer by this Website when you visit certain parts of the Website and/or when you use certain features of the Website. Details of the cookies used by this Website are set out in our Cookies Policy.

Member means a person who creates an account on this Website and signs up to access any of the Website’s content or Company’s services.

Personal Data means any information relating to you that identifies you or could reasonably be used to identify you, and that is recorded in any form.

Sensitive Data means as per Article 9 of the GDPR, Personal Data revealing:

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.

User or You means any third party that accesses the Website and is not either (i) employed by us and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to us and accessing the Website in connection with the provision of such services.

Website means the website that you are currently using, trafficstars.com, and any sub-domains of this website, unless expressly excluded by their own terms and conditions.

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:

· IP (Internet Protocol) address

· Location data to deliver targeted advertisement to you

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

· Full name;

· Governmental issued identification documents such as national ID, passport or driver’s license;

· Email address;

· Residential address;

· Billing address;

· Financial data such us bank account and payment card details (where applicable)

· Ad interactions with advertisements, including ad clicks and views to evaluate the effectiveness of ads and optimize campaigns.

· Phone number;

· Skype account;

· Telegram account

· IP (Internet Protocol) address

We use Paxum, Trustpay, Bivial AG, Inxy, Cryptologist, and Capitalist as payments methods. If you choose to use our services and make a payment through our website, these payment processors may collect and process your personal data, including payment details and other identifying information. By proceeding with a payment, you acknowledge and agree that your personal data will be processed by the respective payment processor in accordance with its privacy policy. For more information on how your data is handled, please refer to the respective privacy policies of these payment processors.

6. Purposes of Processing Your Personal Data

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

a) To perform the contract we are about to enter into or have entered into with you.

b) For our legitimate interests.

c) To comply with a legal or regulatory obligation.

d) Where disclosure is necessary for a competent authority.

e) You have provided your consent. Please be informed that you have the right to revoke your consent at any time by sending an email to dpo@trafficstars.com stating that you wish to remove the consent you provided us with for the application of non-essential cookies, for example.

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. 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:

· Ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services.

· Restore the availability and access to personal data in a timely manner in the event of a physical or technical incident.

· Regularly test, assess and evaluate the effectiveness of technical and organisational measures for ensuring the security of the data.

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.

10. 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:

- The length of time we have an ongoing relationship with you and provide the services to you.

- Whether there is a legal obligation to which we are subject.

- Whether retention is advisable considering our legal position (such as litigation or regulatory investigations).

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.

11. 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.

12. 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.

13. 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.

14. 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:

· Right to opt-out: you may request us to stop selling your personal information;

· Right to know: you may request us to disclose to you what personal information we have collected, used, shared or sold about you, and why we collected, used, shared or sold that information;

· Right to delete: subject to the exceptions applicable under the CCPA, you may request us to delete personal information we collected from you;

· Right to non-discrimination: we will not deny goods or services, charge you a different price, or provide a different level or quality of goods or services for exercising any of your CCPA rights. However, if you refuse to provide your personal information to us or ask us to delete or stop selling your personal information, and that personal information or sale is necessary for us to provide you with goods or services, then we may not be able to complete that transaction.

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.

15. 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.

16. 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.