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Privacy Policy

Last Modified: September 2,2021

Introduction

MG Freesites Ltd.(hereinafter “we”, “us” or “our”) operates www.hubtraffic.com (hereinafter the “Website”) and is the controller of the information collected or provided via this Website.

Please read this privacy policy carefully, as your access to and use of our Website signifies that you have read, understand and agree to all terms within this privacy policy. If you do not agree with any part of this privacy policy or our terms, please do not access or continue to use our Website or otherwise submit your personal data. We respect your privacy and are committed to protecting your personal data.

Scope

We collect, process and retain personal data to the extent it is necessary to provide users with our service. This privacy policy applies to information we collect:

  • on this Website, or
  • in e-mail, text and other communications between you and this Website.

It does not apply to information collected by:

  • pay or premium websites operated by us or our affiliates and subsidiaries, or mobile applications obtained from such websites. These websites and apps have their own privacy policy which apply to information collected through those sites; or
  • any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Website. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements.

The Data We Collect About You

We may collect different kinds of personal data about you if you chose to create an account with us:

  • Identifiers: real name, company name and VAT number, postal address, internet protocol (IP) address information, email address. We also set cookies as explained below in the section on Cookies and Automatic Data Collection Technologies.
  • Non-unique Identifiers: We collect the domain names you wish to use in relation to the Website, and the time on which you last logged in to your account.
  • Contact Information: We collect username or similar identifier and email address.
  • Payment and Commercial Information: We collect payment details and related information in order to make payments to you through the Website.
  • User Submitted Personal Information: We collect information you submit in order to personalize your account or for a specific function, for example, feedback, survey responses, and your communication preferences.

Personal information does not include aggregated information. We may use your data to produce and share aggregated insights that do not directly or indirectly identify you and are not associated with you.

We do not collect information that is considered special category Personal Information under EU law.

Data Collection from Minors

Our Website is not directed to persons under the age of 18 or the applicable age of majority in the jurisdiction from which the Website is accessed. We do not knowingly collect personal information from minors. If you become aware that your child has provided us with personal information, please contact us at support@hubtraffic.com. If we become aware that a minor has provided us with personal information, we take steps to remove such information and terminate that person’s account.

How Your Personal Information Is Collected

We collect Personal Information in the following ways:

  • Directly from you:We collect the categories of information listed above directly from you.
  • Automated technologies or interactions. As explained in the section below on Cookies and Automatic Data Collection Technologies, we set cookies to collect website activity data.

Purposes for Which We Use Your Personal Information

We use personal information for the purposes described below.

  • Provision of services: we use non-unique identifiers, identifiers, contact information, and payment and commercial information to present our Website and its contents to you, and to provide you with information, products or services that you request from us;
  • Customer management: we use identifiers and contact information, and payment and commercial information to manage your account, to provide customer support and notices to you about your account, including expiration and renewal notices, and notices about changes to our Website or any products or services we offer or provide through it;
  • Analytics: we use identifiers and non-unique identifiers to determine whether users of the Website are unique, or whether the same user is using the Website on multiple occasions, and to monitor aggregate metrics;
  • Functionality and security: we use website activity data, non-unique identifiers, identifiers, contact information, and payment and commercial information to diagnose or fix technology problems, to verify your payment information, and to detect, prevent, and respond to actual or potential fraud, illegal activities, or intellectual property infringement;
  • Compliance: we use website activity data, identifiers and contact information, payment and commercial information to enforce our terms and conditions and to comply with our legal obligations;
  • We will use contact information and user submitted personal information in any other way we may describe when you provide the information; or for any other purpose with your consent provided separately from this privacy policy.

Our Legal Bases Under EU Law

  • We have the following legal bases under EU law for processing your personal data: We process personal data for the purposes of providing the services, customer management and functionality and security because the processing is necessary to provide the services or products you have requested, or to provide our Website and services in a manner consistent with our terms and conditions and any other contract that you have with us.
  • We process personal data where such processing is necessary for us to comply with a legal or regulatory obligation.
  • We process personal information in specific circumstances where you have provided your consent to such processing.

Disclosure of Your Personal Information

We disclose personal information as explained below.

  • Within our corporate group: We may disclose any of the categories of personal information to members of our corporate group (that is, entities that control, are controlled by, or are under common control with us) to the extent this is necessary for the purposes of provision of services, customer management, analytics, verifications, functionality and security, and compliance.
  • Service providers: We disclose the categories of personal information we collect to our authorized service providers that perform certain services on our behalf. These services may include fulfilling orders, risk and fraud detection and mitigation, providing customer service, performing business and sales analysis, analytics, security, or hosting our Website or supporting our Website functionality. These service providers may have access to personal information needed to perform their functions but are not permitted to share or use such information for any other purposes.
  • Legal successors: We may disclose all of the categories of personal information we collect to a buyer or other successor in the event of a merger, acquisition or sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding.
  • To comply with the law or protect our rights or the rights of third parties:We access, preserve and share your personal information with regulators, law enforcement or others where we reasonably believe such disclosure is needed to (a) satisfy any applicable law, regulation, legal process, or governmental request, (b) enforce applicable terms of use, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address illegal or suspected illegal activities, security or technical issues, (d) protect against harm to the rights, property or safety of our company, our users, our employees, or others; or (e) to maintain and protect the security and integrity of our Website or infrastructure. In such cases, we may raise or waive any legal objection or right available to us, in our sole discretion.

Personal Information We Sold or Disclosed for a Business Purpose

In the prior 12 months we have disclosed each of the categories of personal information we collect within our corporate group and to our service providers as explained above.

Under California law, we are required to tell you if, within the prior 12 months, we have “s old” information as that term is defined by applicable law. Sell or sold means to share personal information with a third party for monetary or other valuable consideration.

We have not sold personal information within the prior 12 months based on our understanding of that term.

Choices About How We Collect, Use and Disclose Your Personal Information

We strive to provide you with choices regarding the personal information you provide to us.

  • You can choose not to provide us with certain personal information, but that may result in you being unable to use certain features of our Website because such information may be required in order for you to register as a member or initiate other transactions on our Website.
  • We may send you types of transactional and relationship e-mail communications, such as emails about your account or transactions, and administrative notices.
  • If you choose to open an account with us, you may delete and deactivate your account with us at any time. If you deactivate and delete the information of your account, your personal information and any and all other account related information including, but not limited to, user profile data, sharing data and any other data, or content specifically associated with your account will no longer be accessible by you.

Your Rights Related to Your Personal Information

Subject to local law, you have certain rights regarding the personal information we collect, use or disclose and that is related to you, including the right:

  • to receive information on the personal information we hold about you and how such personal information is used (right to access);
  • to correct inaccurate personal information concerning you (right to data rectification);
  • to delete/erase your personal information (right to deletion, “right to be forgotten”);
  • to receive the personal information provided by you in a structured, commonly used and machine-readable format and to transmit those personal information to another data controller (right to data portability);
  • to object to the use of your personal information where such use is based on our legitimate interests or on public interests (right to object); and
  • in some cases, to restrict our use of your Personal Information (right to restriction of processing).
  • to withdraw your consent at any time where our processing is based on consent.

Additionally, you may, at any time, send us an e-mail at support@hubtraffic.com to exercise your above rights in accordance with the applicable legal requirements and limitations. If you are located in the European Economic Area, you have a right to lodge a complaint with your local data protection authority.

Note that some requests to delete certain personal information will require the deletion of your user account as the provision of user accounts are inextricable linked to the use of certain personal information (e.g., your e-mail address). Also note that it is possible that we require additional information from you in order to verify your authorization to make the request and to honor your request.

California Rights and Choices

The California Consumer Privacy Act (“CCPA”) provides you certain rights in relation to your personal information, should you qualify as a consumerunder the CCPA:

  • Right to Know: You have the right to request that we disclose certain information about our collection of your personal information over the past 12 months, including the specific pieces of information we collected.
  • Right to Request Deletion: You have the right to request that we delete any of your personal information we collected from you and retained, subject to certain exceptions set forth in the CCPA.
  • Right to Non-Discrimination for the Exercise of Your Rights: We will not discriminate against you because you have exercised any of your rights under the CCPA.

To exercise the rights described above, please email us at support@hubtraffic.com with the email subject line “CCPA Request.” In either case you will need to provide the following information to verify your identity and enable us to locate your information in our systems: your username and email address that you used to create an account with us along with any other information we might need to verify the request.

You can designate a duly registered agent in accordance with the provisions of the CCPA to make a request by executing a notarized power of attorney to have that person act on your behalf and providing that person with the information listed above that allows us to verify your identity and locate your information.

Notice to Nevada Residents/Your Nevada Privacy Rights

We do not exchange Nevada residents’ personal information for money with anyone so they may license or sell the personal information to additional parties.

Cookies and Automatic Data Collection Technologies

As you navigate through and interact with our Website, we use automatic data collection technologies described below to collect website activity data (information about how you use our Website).

The technologies we use for this automatic data collection may include:

  • Cookies (or browser cookies). Cookies are small text files that are stored in your web browser or downloaded to your device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognizes that cookie, and allow a website to recognize a user’s device.

    We currently use the following types of cookies, which are set by the Website’s domain:

    • Cookies that are strictly necessary: These are cookies that are required for the operation of our Website. These include, for example, cookies that enable a user to log in to our Website and to check if a user is allowed access to a particular service or content.
    • Functionality cookies: These cookies are not essential, but help us to personalize and enhance your online experience on our Website. This type of cookies allows us to recognize you when you return to our Website and to remember, for example, your choice of language.
    • We do not require that you accept cookies and you may withdraw your consent to our use of cookies at any time by adjusting your browser’s privacy settings. However, if you decline to accept cookies, some functionality on our Website may be disabled and you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website. Cookies can be either session cookies or persistent cookies. A session cookie expires automatically when you close your browser. A persistent cookie will remain until it expires or you delete your cookies. Expiration dates are set in the cookies themselves; some may expire after a few minutes while others may expire after multiple years.

Do Not Track: Our systems do not recognize browser “Do Not Track” signals.

Use of Google Analytics. We use Google as a service provider to collect and analyze certain types of information, including pseudonymized IP addresses, device and software identifiers, referring and exit URLs, onsite behavior and usage information, feature use metrics and statistics, usage and purchase history, media access control address (MAC Address), mobile unique device identifiers, and other similar information via the use of cookies. Because we activated IP anonymization for Google Analytics, Google will anonymize the last octet of a particular IP address. Only in exceptional cases, the full IP address is sent to and shortened by Google servers in the USA. Google will use this information for the purpose providing services to us including helping us evaluate your use of the Website, compiling reports on Website ac tivity and managing advertising content. Google will not use this information for its own purposes or any other purposes than providing services to us. The information generated by Google Analytics about your use of the Website (including your IP address) may be transmitted to and stored by Google on servers in the United States pursuant to standard contractual clauses approved by the EU. You may opt out of Google Analytics by visiting the Google advertising opt-out page or by downloading and installing the browser plug-in available at Google Analytics opt-out page. You can find more information on how Google uses data when you use our Website here

Transfers of Your Personal Information to Other Countries

Whenever in the course of sharing information we transfer Personal Information to countries outside of the European Economic Area and other regions with comprehensive data protection laws, we will ensure that the information is transferred in accordance with this privacy policy and as permitted by the applicable laws on data protection.

You hereby agree to the transfer of information that we collect about you, including personal information, to other countries in which we, members of our corporate group (that is, entities that control, are controlled by, or are under common control with us) or our service providers are located.

Retention of Personal Information

We will only retain your personal information for as long as your account is active, or for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider a number of factors, including what personal data we are processing, the risk of harm from any unauthorised disclosure, why we are processing your personal data and whether we can achieve this outcome by another means without having to process it.

Where we no longer need to process your Personal Data for the purposes set out in this Privacy Policy, we will delete your Personal Data from our systems.

Where permissible, we will also delete your personal information upon your request as explained above in the section “Your Rights Related to Your Personal Information”.

Changes to Our Privacy Policy

We may modify or revise our privacy policy from time to time. If we change anything in our privacy policy, the date of change will be reflected in the “last modified date”. We may attempt to notify you of any material changes as required by law. Please alsoperiodically review the most up-to-date version of our privacy policy, which will be posted at this location, so you are aware of any changes.

Contact Information

If you have any questions about this privacy policy or our information-handling practices, please contact us at support@hubtraffic.com.

You may also contact us at 195-197 Old Nicosia-Limassol Road, block 1 Dali Industrial Zone, Cyprus 2540, Phone: +357 22662320, Fax: +35722343 282.