TrafficX Limited commits to protecting the personal information that you provide us with and we will take all reasonable actions to ensure that all such data remains intact. You entrust us with your privacy by using our services and we value this. We take every measure to make sure that all your personal information is safe with us. As we act in our clients’ best interests, we do not conceal the fact that we process your personal data. TrafficX Limited undertakes to protect your personal data and process it according to the applicable laws as follows:
- Maltese Data Protection Act (Chapter 586) (hereinafter referred to as the “DPA”), as well as various subsidiary laws issued in accordance with the same DPA law;
- Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation);
- Any other legislation or subsidiary legislation as amended from time to time.
- the type of data we collect whenever you visit our Website and/or use our Services;
- why we collect the data;
- how we handle your information and data;
- how we take care of your personal data; and
- your rights for privacy and how the regulations protect you.
In this Policy, all references to ”TrafficX Limited”, “we”, “us”, “for us”, “our” and “ours” refer to any company of the TrafficX Limited. Any references to “you”, “your”, “to you”, and “yourself” refer to the person, who uses our Website and provides us with personal information.
You are under no obligation to provide Personal Information to us. However, certain Personal Information is essential for us to provide you with our services. You might not be able to obtain certain services if you choose to withhold information, we have requested that is required for those services.
1. CONTACT DETAILS
Centris Business Gateway, Level 2M
Triq Is-Salib Tal-Imriehel, Central Business District, Zone 3
Birkirkara CBD3020, Malta
Company No C97451
1.1. The Data Protection Officer within TrafficX Limited is the designated person responsible for all issues connected with Data Protection and Confidentiality.
Centris Business Gateway, Level 2M
Triq Is-Salib Tal-Imriehel, Central Business District, Zone 3
Birkirkara CBD3020, Malta.
1.3. Requests from authorities must be sent to us in accordance with the procedure described in Guidelines for Authorities.
2. COLLECTED DATA
2.1. We gather personal data in cases where we have no opportunity to use anonymous or anonymized data.
2.2. Through interaction with you or through your interaction with us or our Services, we gather the following types (categories) of data:
- Data that you provide to us by filling forms on our website, for example:
- E-mail address;
- Skype ID.
- Information obtained by messaging with us through the Website, e-mails, phone, webchats, texts and other means of communication, including your complaints, interests, preferences, intentions, etc.;
- Payment transaction data may include:
- transaction date;
- transaction amount;
- transaction number;
- transaction status;
- name of payment system;
- partial or full ID’s of electronic payment systems; and
- partial or full Card Number.
- We automatically collect certain data, even if you are simply using our Website and not using our services.
This may include:
- your IP address;
- date and time when you used our Services;
- software and hardware details;
- browser that you are using;
- information about the operating system of the device that uses our Services, for instance, the latest versions of apps and language settings;
- data relating to your clicks, the pages showed to you and your response to information elements;
2.3. If you are using a mobile device, we may also receive the data that identifies it, device settings and features, malfunctions and other system activity. When you visit our Website, our system records by what means and through which websites you accessed our Website.
2.4. We don’t collect any specific categories of personal data about you (this includes your race or ethnicity, religious or philosophical beliefs, sexuality, sexual orientation, political beliefs, union membership, information about your health and genetic and biometric data). We also don’t collect any information about any possible criminal sentences and crimes committed by you. However, based on our experience, we cannot exclude that you, at your discretion, may send us such data during your communication with us.
2.5. In accordance with our Terms and Conditions, our Website is not intended for children under 18 years of age. We do not purposefully collect or process personal data of children under 18 years of age. If you become aware of this, please inform our Data Protection Officer via contact details listed in clause 1.2. We will take measures to correct or delete any such personal data.
2.6. Providing us with false details about yourself is illegal, and you are responsible for ensuring that we always have the most relevant and reliable information about you. If you find an error in the information provided to us, you are obliged to update your personal details.
2.7. In cases where you are unable to provide us with your personal data required in accordance with the law and/or in accordance with the terms of the agreement that you enter into, we will not be able to enter into an agreement with you and give you the opportunity to use our Services.
3. PERSONAL DATA USE
We use your personal data for various purposes in accordance with law. Your data can be used for the following reasons:
Services provision: We shall use your data to give you an opportunity to register at our Website, access it and to be able to use our Services.
Customer support: We provide support to our customers using various communication channels. Certain data about you, for example, information about your activity in using our Services or your account data assists you with problem solving and responds to your queries connected to the use of our Services and other related questions.
Service improvement: We also use your personal data for analytical purposes. This is part of our work to improve Services offered to our users. These data can also be used for testing purposes, to solve issues and to improve the functionality and quality of our Services. We strive to optimize our Website so that users enjoy browsing it and so that it meets their expectations and remains user-friendly.
Legal purposes: We can use your data to comply with legal regulations, process and resolve legal disputes, launch an inquiry at the request of government bodies, fulfill law enforcement requests, and ensure compliance with other conditions imposed on the company by certain authorities.
3.1. PURPOSES AND BASIS FOR THE USE OF PERSONAL DATA
Below, your will find descriptions of all the cases where we plan to use your personal data, and what legal basis or legal grounds we rely on. Please note that we may process your personal data for more than one legal basis depending on the specific purpose for which we use your data.
|№||Purpose||Data Category||Legal Basis|
|1||Services provision||a||Agreement performance|
|2||Customer support||a, b, c, d,||Agreement performance|
|3||Service improvement||a, b, c, d||Legitimate concern:|
• Business development and services improvement
|4||Legal purposes||a, c||Compliance with legal requirements|
You can find out more details about the basis we rely on when processing your personal data. To do this, you can contact our Data Protection Officer. Contact details can be found in clause 1.2.
4.1. To improve the quality of our Services and to provide you with the most attractive marketing offers, we may use your personal data to build a profile.
4.2. We may use automatic profiling systems to identify illegal actions from our customers. Profiling may be based on automated processes but not carried out without human intervention.
5. MARKETING INFORMATION
5.1. If you choose to receive marketing information, we may use your Personal Information, including your E-mail address and Skype ID, to provide you with advertisement messages about products, services, and promotions that we believe you may find interesting. This may also include information about other gaming products and services from our selected business partners.
5.2. If you would like to stop receiving marketing and other promotional materials, you can opt out of this service by selecting it in the appropriate menu in your Account Settings on our Website or by contacting our customer service at firstname.lastname@example.org. It is understood that if you decide to stop receiving marketing and other promotional materials from us, you will not be aware of the latest offers and bonuses related to our Products and Services.
5.3. Please note that even if you object to receiving direct marketing materials, we may from time to time need to send you some important messages regarding our Services, and these messages you cannot refuse.
6. TRANSFER OF PERSONAL DATA
We may transfer information that you provided to our business partners that we cooperate with to process the data specified in clauses 2 and 3 of this Policy.
6.1. ACCESS TO PERSONAL DATA
6.2. LIMITATIONS OF SHARING PERSONAL DATA
The Internet is a global medium. The use of the Internet to collect and process personal data is necessarily associated with data transfer. Therefore, we may also disclose the information you provide us with to our business partners, suppliers and subcontractors to fulfill any obligations under the agreements we may have with them or with you. To create awareness, we may give you information about any third party who we shared your personal data with.
6.3. SALE AND DISTRIBUTION OF PERSONAL DATA
We do not sell personal information about our customers to third parties. However, we can transfer personal data when acquiring new business structures. If the structure of the TrafficX Limited undergoes any changes, such as a merger, acquisition by another company or a partial acquisition, then it is probable that our customer’s personal data will be included in such sale or transfer. As part of our policy, we will inform our clients about this by e-mail before any such personal data transfer is carried out.
We reserve the right to share your personal data when we believe that it is necessary whenever required by law, authorities or when we need to protect our rights, property, security, or our partner companies, our customers, or other third parties.
6.4. PERSONAL DATA EXCHANGE
We can transfer parts of your personal data (for example, your e-mail address and Skype ID you specified during registration) to our partners for the purposes of countering fraud.
7. TERMS AND CONDITIONS
We hereby confirm that when collecting and processing your personal data in order to manage your Account, we undertake to comply with strict legal provisions on personal data security. Accordingly, we strive to protect your Personal Data and respect your privacy as required by law. Additionally, in order to avoid ambiguity, nothing will help us protect you from the dissemination of your Personal Data if required by law.
8. STORAGE OF PERSONAL DATA
As specified in these Terms and Conditions, both you and TrafficX Limited can at any time decide to close your Profile (Account). After closing your Account, we will no longer use your personal data, but we will keep it for a certain period of time as required by law. The data will only be used if it is required within the framework of compliance with any applicable law, to resolve disputes with any parties, as well as for other purposes allowing us to conduct commercial activities, including detection and prevention of fraudulent or other illegal activities.
|Data Category||Purpose of storage||Legal Ground||Retention period||Start of period|
|a, c||Accounting and tax||Compliance with law||10 years||Transaction time|
|a, b, c||Protection from government claims||Our legitimate concern||2 years||Account termination|
|a, b, c||Customer Claim Protection||Our legitimate concern||5 years||Account termination|
|a||Company’s legitimate concern||Ability to communicate with the customer in order for him to reinstate the Account||2 years||Account termination|
|d||Technological constraints||Time necessary for regular procedures||6 month||Account termination|
If you have questions regarding the specific period of storage of a certain personal data type processed by us, you can contact us by using contact details specified in clause 1.2.
9. CONTROL OF PERSONAL DATA
9.1 We want you to control how we use your personal data. You can do this in the following ways:
- confirm the relevance of the personal information that we receive from you and store with us;
- you can ask us for a list of your personal data that are at our disposal;
- you can inform us about any changes in your personal data or ask us to correct any information in the personal data that are stored with us;
- in some cases, you can ask us to remove your personal data, to block or restrict its processing and send a waiver regarding the specific use of your personal data;
- in some cases, you can contact us and ask us to send your personal data to third parties.
We use your personal data based on your consent. You may revoke such consent at any time in accordance with the applicable law. If you are against the processing of your personal data on the basis of legitimate interests and at the same time you don’t have a direct access to mechanisms that refuse data processing, you can contact our Data Protection Officer using his contact details provided in clause 1.2. However, we reserve the right to store certain personal data that we need to comply with legal requirements.
9.2 If you are a registered user of our Website, you can access a part of your personal data through our Website. You can find it in your Account.
If any part of your personal data stored with us is not available on the Website, you can send us a free request.
9.3 To correct or change your e-mail address, please contact our customer support.
If you decide to contact us via e-mail, please send an e-mail from the address that you registered with and provide the following information:
- contact details;
- full information regarding your request.
In some cases, we may ask you to provide us additional personal information so that we can verify your identity. If we are unable to satisfy your request, we will give a reason for that.
9.5 You can also file a complaint with the supervisory authority, in particular, in the Member State of your habitual residence, workplace or location of the alleged violation if you believe that personal data processing concerning your rights violates personal data safety laws and regulations.
10. YOUR RIGHTS
You have the following rights in relation to your Personal Information:
- a right to access your Personal Information as held by us (Subject access request);
- a right to receive certain Personal Information in machine-readable format;
- a right to have inaccurate Personal Information rectified;
- where we have specifically requested your consent to process your Personal Information and have no other lawful basis to process it, you have the right to withdraw this consent;
- a right to have certain Personal Information erased where it is no longer necessary for us to process it, where you have withdrawn your consent pursuant to the paragraph above, where you have objected pursuant to the paragraph below, where your Personal Information has been unlawfully processed, or where erasing your Personal Information is required in accordance with a legal obligation (Right to be forgotten);
- a right to object to processing where our lawful basis for processing it is that it is in our legitimate interests; but please note that we may still process your Personal Information where there are other relevant lawful bases or where we have compelling grounds to continue processing your Personal Information in our interests which are not overridden by your rights, interests or freedoms;
- a right to request an explanation of the logic involved where we make decisions about you solely through automated means;
- a right to complain to your national data protection supervisory authority;
- a right to object to direct marketing, which can be done by opting-out of direct marketing either through your account or by opting out via the communication itself. You also have a right to object to any profiling to the extent that it relates to direct marketing only.
11. PROTECTION OF PERSONAL DATA
Protecting the privacy of your personal data is our top priority. When creating our Website, we used the best standards for confidential information protection. We use specialized corporate systems, procedures, technical and physical restrictions on the use of your personal data and its access on our servers. Only the employees who need your personal data to perform their duties have the right to access it.
12. PAYMENT DATA PROCESSING POLICY
TrafficX Limited does not independently process bank or electronic payment systems transactions. For your convenience, we make any transactions using our business partners (Payment Services). Choose a payment partner depends on your account properties and your chosen payment method.
14. CHANGES AND UPDATES TO THIS POLICY
Effective date: August 15, 2023