TRAFFNOW

Privacy Policy

Version 1.0 at 2017-07-19

This Privacy Policy for Personal Data (hereinafter referred to as Privacy Policy) applies to all information that the site TRAFFNOW, (hereinafter referred to as the Service) located on the domain name traffnow.com (and its subdomains), can get about the User while using the site traffnow.com (as well as its subdomains), as well as in the framework of providing services to the User. The policy is aimed at compliance with the Federal Law of the Russian Federation of September 27, 2006 No. 152-FL “About Personal Data”.

1. Definition of Terms

1.1 The following terms are used in this Privacy Policy:

1.1.1. "Site Administration" (hereinafter - the Administration) - authorized employees to manage the site TRAFFNOW , who organize and (or) carry out the processing of personal data, and also determines the purposes of personal data processing, the composition personal data to be processed, actions (operations) performed with personal data.

1.1.2. “Personal data” - any information relating to directly or indirectly determined, or determined by a natural or legal person (the subject of personal data).

1.1.3. "Personal data processing" - any action (operation) or set of actions (operations) performed with the use of automation tools or without the use of such tools with personal data, including collection, recording, systematization, accumulation, storage, refinement (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.

1.1.4. “Confidentiality of personal data” is a requirement for the Operator or another person who has obtained access to personal data to prevent their dissemination without the consent of the subject of personal data or the availability of other legal grounds.

1.1.5. “Website TRAFFNOW” is a collection of interconnected web pages located on the Internet at a unique address (URL): traffnow.com, as well as its subdomains.

1.1.6. "Subdomains" are pages or a collection of pages located on third-level domains belonging to the site TRAFFNOW, as well as other temporary pages, at the bottom of which is indicated the Administration’s contact information

1.1.5. “Site User TRAFFNOW” (hereinafter User) is a person having access to the site TRAFFNOW via the Internet and using information, materials and products of the site TRAFFNOW.

1.1.7. “Cookies” is a small piece of data sent by a web server and stored on the user's computer, which the web client or web browser sends to the web server each time in an HTTP / HTTPS request when trying to open the page of the corresponding site.

1.1.8. “IP-address” is a unique network address of a node in a computer network through which the User gets access to the Service.

1.1.9. "Terms of Service Agreement" (hereinafter - the Agreement) - terms of use of the Service by the User, in the form of a public offer published on the page: https://traffnow.com/ru/?mod=static&do=terms.

1.1.10. "Advertised website" - the website on which the User wishes to receive new visitors in accordance with the Agreement adopted by him.

1.1.9. “Web traffic (traffic)” - visitors directed in any way to the advertised website. 

1.1.10. “Order” is a specific service provided by the Service to the User (based on his application) for sending a certain number of visitors to the pages indicated by him on the Internet under the conditions specified in the Agreement, as well as in the specific parameters of his application.

2. General provisions

2.1. Use of the site TRAFFNOW by the User means acceptance of this Privacy Policy and the terms of processing of the User's personal data.

2.2. In case of disagreement with the terms of the Privacy Policy, the User must stop using the site TRAFFNOW.

2.3. This Privacy Policy applies to TRAFFNOW. The Service does not control and is not responsible for third-party sites to which the User can follow the links available on the site TRAFFNOW.

2.4. The administration does not verify the accuracy of the personal data provided by the User.

3. Privacy Policy Item

3.1. This Privacy Policy establishes the obligations of the Administration to protect the confidentiality of personal data, which the User provides upon request by the Administration when registering on TRAFFNOW, when subscribing to an e-mail newsletter or when placing an order.

3.2. The personal data allowed for processing under this Privacy Policy are provided by the User by filling in the forms on the website TRAFFNOW and include the following information:
3.2.1. surname, name, patronymic of the User;
3.2.2. User gender;
3.2.3. email address (e-mail);
3.2.4. Country of Residence.

3.3. In addition, the Service receives data from external analytics systems (for example, Yandex.Metrica) containing various impersonal aggregated statistics of advertised websites: transitions, sessions, depth of views, refusals, robotics, geography, etc. These data are not personal, because do not identify the User or the visitors of the advertised websites. Data from external systems analytics are also considered permitted to be processed under this Privacy Policy, as they are provided by external systems with the consent of the User by explicitly issuing read access to the Service. The Service uses data from external analytics systems that relate to the web traffic sent to them to improve the quality of Order execution. External analytics data about advertised websites on web traffic from other sources are not collected and used by the Service.

3.4. Service protects Data that is automatically transmitted when visiting pages:
- IP address;
- information from cookies;
- information about the browser
- access time;
- referrer (the address of the previous page).
3.4.1. Disabling cookies may result in the inability to access parts of the site TRAFFNOW that require authorization.
3.4.2. The service collects statistics on the IP addresses of its visitors. This information is used to prevent, detect and solve technical problems.

3.5. Any other personal information not specified above (site statistics, visiting history, browsers used, operating systems, etc.) is subject to reliable storage and non-proliferation, except as provided for in paragraphs. 5.2. and 5.3. of this Privacy Policy.

3.6. The personal data of the User is not distributed, nor is it provided to third parties without the consent of the User and is used by the Administration solely for the execution of the Agreement concluded with the User, or for the conclusion (and performance) of other agreements with the User being a legal entity.
4.2. User's personal data may be required by the Administration for the execution of the Agreement in the following cases:
4.2.1. Identification of the User registered on the site TRAFFNOW for his further authorization, ordering and other actions on the Site.

4.2.3. Establishing feedback with the User, including sending notifications, inquiries regarding the use of the site TRAFFNOW, providing services and processing requests and requests from the User.

4.2.4. Account creation (account registration) initiated by the User to use parts of the site TRAFFNOW for authorized Users (personal account).

4.2.5. User notifications by email.

4.2.6. Providing the User with effective technical support in case of problems related to the use of the site TRAFFNOW.

4.2.7. Providing the User with his consent special offers, information about prices, newsletters and other information on behalf of the site TRAFFNOW.

4.2.8. Implementation of promotional activities with the consent of the User.

4.2.9. Any other actions necessary for the execution of the Agreement.

5. Methods and terms of processing personal information

5.1. The processing of personal data of the User is carried out without time limit, in any legal way, including in the information systems of personal data using automation tools or without the use of such tools.

5.2. The User agrees that the Administration has the right to transfer personal data to third parties, in particular, courier services, postal communication organizations (including electronic), solely for the purpose of fulfilling the User’s Order issued on the website TRAFFNOW, including delivery of documentation or e -mail messages.

5.3. User's personal data may be transferred to the authorized state authorities of the Russian Federation only on the grounds and in the manner established by the legislation of the Russian Federation.

5.4. In case of loss or disclosure of personal data, the Administration has the right not to inform the User about the loss or disclosure of personal data.

5.5. The administration takes the necessary organizational and technical measures to protect the personal information of the User from unlawful or accidental access, destruction, alteration, blocking, copying, dissemination, as well as from other illegal actions of third parties.

5.6. The Administration together with the User takes all necessary measures to prevent losses or other negative consequences caused by the loss or disclosure of the personal data of the User.

6. Rights and obligations of the parties

6.1. User has the right to:
6.1.1. Make a free decision to provide your personal data necessary for the use of the site TRAFFNOW, and to give consent to their processing.

6.1.2. Update, supplement the information provided on personal data in the event of a change in this information.

6.1.3. The user has the right to receive from the Administration information relating to the processing of his personal data, if such a right is not limited in accordance with federal laws of the Russian Federation. The user has the right to demand from the Administration clarification of his personal data, their blocking or destruction if the personal data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, as well as take legal measures to protect their rights.

6.2. Administration is obliged: 
6.2.1. Use the information obtained solely for the purposes specified in clause 4 of this Privacy Policy.

6.2.2. To ensure the storage of confidential information in secret, not to disclose without the prior written permission of the User, and not to sell, exchange, publish, or disclose in any other possible way the transferred personal data of the User, except for p. 5.2 and 5.3. of this Privacy Policy.

6.2.3. Take precautions to protect the confidentiality of the User’s personal data in accordance with the procedure normally used to protect this type of information in existing business transactions.

6.2.4. Perform blocking of personal data relating to the relevant User from the time of the request or request of the User, or his legal representative or authorized body for the protection of the rights of personal data subjects during the verification period, in case of unreliable personal data or illegal actions.

7. Responsibility of the parties

7.1. The administration, which has not fulfilled its obligations, is liable in connection with the unlawful use of personal data, except as provided for in clauses. 5.2., 5.3. and 7.2. of this Privacy Policy.

7.2. In case of loss or disclosure of Confidential Information, the Administration is not responsible if this confidential information:
7.2.1. Became public domain before its loss or disclosure.
7.2.2. It was received from a third party before it was received by the Resource Administration.
7.2.3. It was disclosed with the consent of the User.

7.3. The user is solely responsible for compliance with the requirements of the laws of the Russian Federation, including laws on advertising, on the protection of copyright and related rights, on the protection of trademarks and service marks, but not limited to the above, including full responsibility for the content and form of materials.

7.4. The user acknowledges that responsibility for any information (including but not limited to: data files, text, etc.), to which he can have access as part of the site TRAFFNOW, is borne by the person who provided such information .

7.5. The User agrees that the information provided to him as part of the site TRAFFNOW may be intellectual property, the rights to which are protected and belong to other Users, partners or advertisers who post such information on the site TRAFFNOW. The User shall not be entitled to make changes, lease, transfer on loan terms, sell, distribute or create derivative works based on such Content (in whole or in part), unless such actions were explicitly authorized in writing by the owners of such Content in accordance with terms of a separate agreement.

7.6. In the case of text materials (articles, publications that are in free public access on the website TRAFFNOW), their distribution is allowed, provided that a link to the Service is given.

7.7. The Administration is not liable to the User for any loss or damage incurred by the User as a result of deletion, failure or inability to save any Content and other communication data contained on TRAFFNOW or transmitted through it.

7.8. The administration is not responsible for any direct or indirect damages resulting from: use or inability to use the site or individual services; unauthorized access to User’s communications; statements or behavior of any third party on the site.

7.9. The administration is not responsible for any information posted by the user on TRAFFNOW, including but not limited to: copyrighted information, without the direct consent of the copyright holder.

8. Dispute Resolution

8.1. Before going to court with a claim for disputes arising from the relationship between the User and the Administration, it is obligatory to submit a claim (a written proposal or an offer in electronic form about voluntary settlement of the dispute).

8.2. The recipient of the claim within 30 calendar days from the date of receipt of the complaint, in writing or in electronic form notifies the claimant of the results of the consideration of the claim.

8.3. If the agreement is not reached, the dispute will be referred to the Arbitration Court. 

9. Additional Terms

9.1. The administration has the right to make changes to this Privacy Policy without the consent of the User.

9.2. The new Privacy Policy takes effect from the moment it is posted on the website TRAFFNOW, unless otherwise provided by the new edition of the Privacy Policy.

9.3. Any suggestions or questions regarding this Privacy Policy should be reported to: support@traffnow.com.

9.4. The current Privacy Policy is located at: https://traffnow.com/ru/?mod=static&do=privacy.


User Consent to the processing of personal data
I hereby, hereinafter referred to as the “Subject of Personal Data”, pursuant to the requirements of Federal Law No. 152-ФЗ dated July 27, 2006 “On Personal Data” (as amended and added) freely, my I will give my consent by will and in my interest  to the Service TRAFFNOW to process his personal data specified during registration by filling out a web form on traffnow.com and its *.traffnow.com subdomains (hereinafter referred to as the Site) sent (filled oh) using the Site, as well as received by the Service during the execution of my Orders.

I agree with the current Privacy Policy, which is available on the page at: https://traffnow.com/ru/?mod=static&do=privacy.

By personal data, I mean any information relating to me as a Personal Data Subject, including my last name, first name, patronymic name, country of residence, contact details (email, postal address), data from analytics systems of websites advertised by me, other information . By processing personal data, I mean the collection, systematization, accumulation, refinement, updating, modification, use, distribution, transfer, including cross-border, depersonalization, blocking, destruction, permanent storage), and any other actions (operations) with personal data.

The processing of personal data of the Personal Data Subject is carried out solely for the purpose of registering the Personal Data Subject in the database of the Service with the subsequent sending to the Personal Data Subject of postal messages and email notifications, including advertising content, from the Service, as well as for the correct execution of Orders in public offer, published on the page: https://traffnow.com/ru/?mod=static&do=terms.

The date of issuance of the consent to the processing of personal data of the Personal Data Subject is the date of sending the registration web form from the Site.

The processing of personal data of the Subject of Personal Data may be carried out using automation equipment and / or without using automation equipment in accordance with the current legislation of the Russian Federation and the internal provisions of the Service.

The Service takes the necessary legal, organizational and technical measures or ensures their adoption to protect personal data from unlawful or accidental access to them, destruction, alteration, blocking, copying, provision, dissemination of personal data, as well as from other unlawful actions with regard to personal data, and also undertakes to maintain the confidentiality of personal data of the Personal Data Subject. The Service has the right to involve subcontractors for the processing of personal data of the Personal Data Subject, and also has the right to transfer personal data for processing to its affiliates, while ensuring that such subcontractors and affiliates accept the corresponding obligations regarding the confidentiality of personal data.

I have read (a) that:

1. this consent to the processing of my personal data specified during registration on the Site, sent (filled) using the Site, is valid indefinitely from the date of registration on the Site;

2. consent may be withdrawn by me on the basis of a written statement in any form;

3. The provision of personal data of third parties without their consent entails liability in accordance with the current legislation of the Russian Federation.