Contacts

Privacy Notice

Last update: 24 January 2023

We understand the significance of your privacy in a digital age and advocate for strict adherence to personal data protection laws.

We notify you that we will process your personal data following the provisions of Regulation (EU) 2016/679 (“GDPR”) for the purposes and on legal bases stated in this Notice.

In this Notice we are willing to inform you the following:

Important information about us, including our contact details, and the role in personal data processing activity;
Personal data we process and sources of personal data;
Purposes and legal bases for processing;
Personal data retention;
Disclosure of your personal data;
International transfers;
Your rights as a data subject.

Please read this Notice carefully to be aware of our privacy practices. It will take about 7-10 minutes.

Applicability of the Notice

This Notice covers the collection and processing of your personal data, when:

You access and use the functionality of the affiliate platform https://trafficnatives.com/ (“Platform”), including when you provide or obtain Services under Traffic Natives Terms & Conditions with the use of the Platform. This Notice applies to the processing of personal data of Affiliates, Affiliates as far as they are individuals or their authorized representatives;
You directly contact us on general matters or to find out more about the Platform through available means of communication, including email address and contact form on the Website.

Information about us & our role in personal data processing

Traffic Natives LTD isa company registered under the legislation of Cyprus, with its company number HE 419191, and its registered address at 9 Vasili Michailidi, Limassol, 3026, Cyprus (hereinafter the “Company”, “We”).

You can always contact us at [email protected] or through the contact page of the Platform for any personal data protection matters (e.g. obtain more information about personal data processing or exercise your data subject rights).

Since the Company makes core decisions on the purposes and means of the processing of personal data within the scope of this Notice, the Company acts as a controller according to the GDPR.

Personal data we process

We process different categories and types of your personal data. Nevertheless, we are trying to limit the personal data collected to a strict minimum that is necessary to achieve the purposes outlined in this Notice.

Personal data we collect include:

Personal data collected directly from you
- Registration data. When you submit an application to join the Platform you provide us with your first name, last name, your country, the name of the company you represent email address, phone number, and other information you voluntarily provide to us.
- Bank details (for Affiliates). To pay for the Affiliate Services the Company collects a number of your bank account, bank account type, and other details necessary to make payments to you.
- Communication data. In the context of communication with us via all available means, you may provide us with the information that is considered to be personal data, including the date and time of communications, the content of communications, and your responses to our communication.
Personaldata createdduring use of the Platform and Provision of Services
- Account data. When you use the Platform, you may fill out your Affiliate Personal Account with the information you consider to be relevant (e.g. your experience, successful projects
- Performance data (for Affiliates). When you provide Affiliate Services to Advertisers the number of Advertisers and their specific characteristics, means, and sources you use for Advertising, results of the Services provision, specific metrics are collected and recorded in your Affiliate Personal account on the Platform.
- Payment data. These include the amount of your remuneration for the Services, currency used, payments history.
- Log in data. When you access and use the Platform, we may automatically collect device information (IP address, information about your mobile operator or Internet provider, operating system, browser type, and version, screen resolution, set time zone, language settings, device type: its model and manufacturer (if applicable); log information (time, duration, and manner of use of the Platform); information about the source from which you visited the Platform.
Personal data collected from publicly available sources
- Search data. When you submit an application to join the Platform we may analyze information about you on social media platforms, publicly available websites, including your Advertising Space.
- Personal data collected through cookie files

We may collect personal data through cookies, small files stored in your browser’s folder. We use them for technical and security reasons and sometimes to collect information about your preferences.

Find out more in our Cookie Notice in a specific section of this Notice.

Purposes & legal bases

To be compliant with the lawfulness and purpose limitation principles we process your personal data for explicit purposes and on appropriate legal bases.

Purpose	Personal data	Legal bases
To assess your application and register your account on the Platform	Registration data Login data Search data	Contract with your
To provide you with access to the Advertisers Offers	Registration data Account data Performance data	Contract with your
To maintain the safety, security, and integrity of the Platform	Registration data Login data	Our legitimate interest to ensure the proper functioning of the Platform without mistakes and minimize any external threats to the Platform.
To estimate the scope and quality of Services you provide	Registration data Account data Performance data Search data	Contract with your
To calculate your remuneration for the Services and manage payments	Registration data Account data Performance data Bank details Payment data Search data	Contract with your
To communicate with you and process your questions, queries, or feedback regarding the use of the Platform, provision of Services, or om general matters	Registration data Account data Performance data Bank details Payment data Login data Other personal data	Contract with your Our legitimate interest to communicate with the public
To comply with applicable legislation (e.g. tax laws)	Any personal data processed by the Company	Legal obligation

Retention of your personal data

We will not keep your personal data longer than necessary for the purposes outlined in this Notice. We will store your personal data no longer than six (6) years following the termination of relationships with you, unless as otherwise required by applicable legislation.

Disclosure of your personal data

We may share your personal data with others in the following way:

We may share your personal data when it is needed to establish, exercise, or defend legal claims, enforce Traffic Natives Terms & Conditions, protect the rights of other Affiliates or Advertisers.

Personal data transfers

We notify you that some personal datais accessed and processed by service providers outside the European Economic Area. To secure an adequate level of protection of your personal information, we:

only transfer personal data to third countries where such transfer is based on an adequacy decision of the relevant regulator(s);
enter into agreements with service providers based on the standard data protection clauses adopted by the relevant regulator(s), so they are bound to preserve at least the same level of personal data protection as it is granted by the law applicable to us;
when none of the other transfer mechanisms are available, we may rely upon certain derogations to the prohibition on transfers outside the European Economic Area such as your explicit consent, the performance of a contract involving the data subject, important public interest, legal claims, or defenses.

Automated decision making

We notify you that we do not make a decision related to you solely by automated means.

Your data subject rights

Under the GDPR you are entitled to exercise the following rights:

The right to access (Article of the 15 GDPR). You have the right to receive confirmation from us as to whether your personal data are being processed, as well as to receive a copy of your personal data.
Right to rectification (Article 16 of the GDPR). You have the right to request the rectification of your personal data if the data are inaccurate, as well as the complete the data if the data are incomplete.
Right to erasure (Article 17 of the GDPR). You have the right to request the erasure of your personal data. This right applies if:
- Your personal data is no longer required for the purposes for which they were collected;
- Personal data are processed unlawfully;
- We do not need to store your personal data in order to comply with applicable law;
- In other cases where deletion is required or permitted by applicable law.
Right to restriction of the processing (Article 18 of the GDPR). You have the right to request the restriction of the processing of your personal data in the following cases:
- If you contest the accuracy of your personal data, we will restrict the processing of such data until we verify their accuracy;
- If you object to the processing of personal data based on our legitimate interest, we will restrict the processing of such data until the legitimate interest is confirmed;
- If the processing is unlawful, you can object to the deletion of personal data and request the restriction of their use instead;
- If we no longer need personal data, but you need it to establish, exercise or defend legal claims.
Right to object (Article 21 of the GDPR). You have the right to object to the processing of your personal data based on our legitimate interests. We will not continue to process personal data if we are unable to demonstrate the existence of compelling legitimate grounds for processing that override your interests, rights, and freedoms, or for the establishment, exercise, or defense of legal claims.
Right to lodge a complaint (Article 77 of the GDPR). You can always contact us with any questions regarding the processing of your personal data. However, if you believe that your rights have been violated, you can file a complaint with a supervisory authority, in particular in the country of your habitual residence, place of work or of an alleged infringement.

If you are within the EU, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence or place of work. You can find the list of data protection authorities in the EEA at https://edpb.europa.eu/about-edpb/about-edpb/members_en.

Cookie Notice

Cookies are small pieces of data that can be installed on your web browser when you use different websites. We use some types of cookies for each session when you use our website, but we are not interested in identifying you as an individual with the data from cookies. We use cookies:

to ensure that any choices you make on our website are properly recorded;
to determine your geolocation and, as a result, to provide you with the Website that is tailored to your geography and interests, as well as to process your data request with regard to your jurisdiction – for example, to provide you with the Website and services that are GDPR compliant;
for analysis of our website traffic, so as to allow us to make suitable improvements.

Please be aware that this website may be displayed inappropriately without cookies. If additional information about the Company’s use of Cookies is required, please get in touch with us.

Changes & Updates to the Notice

We reserve the right to update, modify and amend this Notice to be usually compliant with the data protection laws and for business reasons. The current version of the Privacy Notice will be posted on the Website.