Legal

Privacy Policy

TRAFFY LIMITED Privacy Notice

This Privacy Notice applies to personal information processed by TRAFFY LIMITED (“Traffy,” “we,” “us,” and “our”) through our website traffy.com and related Traffy offerings. To make this Privacy Notice easier to read, our website and related offerings are collectively called the “Services.”

Personal information we collect

The categories of personal information we collect depend on how you interact with our Services.

Information you provide to us:

• Account information. If you create an account with us, we will collect personal information such as your name and email address in order to provision your account.
• Your communications with us. We collect personal information from you such as your name, email address, company, job title, messenger contact, phone number, or mailing address when you request information about our products and services, submit a contact or lead form, sign up for marketing from us, register for our newsletter, request customer or technical support, or otherwise communicate with us.
• Surveys. We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include personal information.
• Interactive features. We may offer interactive features such as blogs and social media pages. We and others who use our Services may collect the information you submit or make available through these interactive features. Any content you provide on the public sections of these features will be considered “public” and is not subject to the privacy protections referenced herein. By using these interactive features, you assume the risk that the personal information provided by you may be viewed and used by third parties for their own purposes.
• Conferences, trade shows, and other events. We may attend conferences, trade shows, and other events where we collect personal information from individuals who interact with or express an interest in Traffy. If you provide us with any information at one of these events, we will use it for the purposes for which it was collected.
• Business development and strategic partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.
• Job applications. We may post job openings and opportunities on the Services. If you reply to one of these postings by submitting your application, CV and/or cover letter to us, we will collect and process the information contained therein to assess your suitability, aptitude, skills, and qualifications for employment with us.

Information collected automatically:

• Automatic data collection. We may collect certain information automatically when you use the Services. This information may include your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile advertising and other unique identifiers, details about your browser, operating system or device, location information (including inferred location based off of your IP address), Internet service provider, mobile carrier, pages that you visit before, during and after using the Services, information about the links you click, information about how you interact with the Services, including the frequency and duration of your activities, and other information about how you use the Services.
• Cookies, pixel tags/web beacons, and analytics information. We, as well as third parties that provide content, advertising, or other functionality on the Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Services. Technologies are essentially small data files placed on your device that allow us and our partners to record certain pieces of information whenever you visit or interact with our Services.
  • Cookies. Cookies are small text files placed in device browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Services may not work properly.
  • Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in the Services that collects information about engagement on the Services. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.
  • Analytics. We may process analytics information on our Services, including through the use of Technologies.

The Technologies we currently use on traffy.com are: the first-party cookie traffy_attr (stored for 90 days), which remembers the campaign parameters (UTM tags and advertising click identifiers) of your first visit so that your inquiry is attributed to the right channel; Google Analytics cookies (_ga, _ga_*), loaded through Google Tag Manager, which collect statistics about site usage; and local storage used to remember interface preferences such as your selected language.

Information from Other Sources

We may obtain information about you from other sources, including from third party services and organizations — for example, advertising platforms whose lead forms you submit.

How we use your information

We use your personal information for a variety of business purposes, including:

To Provide the Services or Information Requested, such as:

• Fulfilling our contract with you;
• Responding to questions, comments, and other requests;
• Allowing you to register for events;
• Providing access to certain areas, functionalities, and features of our Services; and
• Answering requests for customer or technical support.

Administrative Purposes, such as:

• Pursuing legitimate interests, such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;
• Measuring interest and engagement in our Services;
• Improving the Services;
• Developing new products and services;
• Ensuring internal quality control and safety;
• Authenticating and verifying individual identities;
• Carrying out audits;
• Communicating with you about your account, activities on our Services and Privacy Notice changes;
• Preventing and prosecuting potentially prohibited or illegal activities;
• Enforcing our agreements; and
• Complying with our legal obligations.

Marketing our products and services. We may use personal information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law.

If you have any questions about our marketing practices or if you would like to opt out of the use of your personal information for marketing purposes, you may contact us at any time as set forth below.

Consent. We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.

How we use cookies and other technologies. We use the Technologies described above to operate the Services, attribute inquiries to the campaigns that brought them, and measure how the Services are used.

Use of de-identified and aggregated information. We may use personal information and other data about you to create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, information about the device from which you access our Services, or other analyses we create. De-identified and/or aggregated information is not personal information, and we may use and disclose such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes.

How we disclose your information

We may disclose your personal information to the following categories of third parties:

• Service Providers. We may share your personal information with service providers who perform functions on our behalf, such as hosting, IT services, CRM, analytics, customer service, and marketing.
• Affiliates. We may share your personal information with our affiliates for the purposes described in this Privacy Notice.
• Business Partners. We may share your personal information with our business partners to jointly offer you products or services.
• Legal Obligations and Rights. We may disclose your personal information if required to do so by law, or if we believe in good faith that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of Traffy, (iii) prevent or investigate possible wrongdoing in connection with the Services, (iv) protect the personal safety of users of the Services or the public, or (v) protect against legal liability.
• Corporate Transactions. We may disclose your personal information in connection with any transaction involving the sale, transfer, divestiture, financing, merger, or acquisition of all or a portion of our business to another company.

Legal Basis for Processing

TRAFFY LIMITED is registered in Hong Kong, and we process your personal information in compliance with the Personal Data (Privacy) Ordinance (Cap. 486). Where we process personal information of individuals in the European Economic Area (EEA) or the United Kingdom, we also comply with the General Data Protection Regulation (GDPR) and the UK GDPR. The legal bases for such processing are:

• Contractual Necessity: Processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract (e.g., to respond to your inquiry or manage your account).
• Legitimate Interest: Processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data (e.g., for securing our Services).
• Consent: We rely on your consent to process your personal information for certain purposes (e.g., marketing communications), and you have the right to withdraw your consent at any time.
• Legal Obligation: Processing is necessary for compliance with a legal obligation to which we are subject.

International Data Transfers

Your personal information may be stored and processed in any country where we have facilities or in which we engage service providers. By using the Services, you understand that your information may be transferred to countries outside of your country of residence, including the United States, which may have different data protection rules than your country.

In the event of a transfer of personal data from the European Economic Area (EEA) or the United Kingdom to countries not deemed to provide an adequate level of protection, we implement appropriate safeguards, such as entering into the Standard Contractual Clauses (SCCs) approved by the European Commission, or rely on other applicable legal mechanisms to ensure the adequate protection of your data.

Your Privacy Rights

Depending on your location and applicable law, you may have the following rights regarding your personal information:

• Right of Access. You have the right to request a copy of the personal information we hold about you.
• Right to Rectification. You have the right to request the correction of any inaccurate or incomplete personal information we hold about you.
• Right to Erasure (“Right to be Forgotten”). You have the right to request the deletion of your personal information under certain circumstances.
• Right to Restriction of Processing. You have the right to request the restriction of the processing of your personal information under certain circumstances.
• Right to Data Portability. You have the right to receive the personal information you provided to us in a structured, commonly used, and machine-readable format and to transmit it to another party.
• Right to Object. You have the right to object to the processing of your personal information based on our legitimate interests.
• Right not to be subject to Automated Decision-Making. You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
• Right to Withdraw Consent. Where we rely on your consent to process your personal information, you have the right to withdraw your consent at any time.

To exercise any of these rights, please contact us using the contact information provided below.

Additional Rights for California Residents (CCPA/CPRA)

If you are a California consumer, you have the right to:

• Know what personal information we collect, use, disclose, and sell.
• Request the deletion of your personal information.
• Opt-out of the sale or sharing of your personal information.
• Not be discriminated against for exercising your privacy rights.

To exercise these rights, please contact us using the contact information provided below.

Security of Your Information

We take reasonable administrative, technical, and physical security measures designed to protect personal information from accidental or unlawful loss, misuse, unauthorized access, disclosure, alteration, and destruction. However, no security system is impenetrable, and we cannot guarantee the security of our systems 100%.

Links to Third-Party Websites

Our Services may contain links to third-party websites. Any information you provide on those websites is governed by their privacy policies, and we encourage you to review their policies before submitting any information.

Changes to Our Privacy Notice

We may revise this Privacy Notice from time to time in our sole discretion. If we make any material changes to this Privacy Notice, we will notify you by posting a notice on the Services or by sending you an email.

Contact Information

If you have any questions or comments about this Privacy Notice, your privacy choices, or if you would like to exercise your rights, please contact us at:

Cookie settings — change or withdraw your cookie consent.