Privacy Policy

Last updated: February 3, 2025

We at TrafficHubGroup Limited and/or any of our related entities (herein referred to as: “Affilitex”, “We”, “Our”, “Us”) have created this Privacy Policy to demonstrate our dedication to respecting your privacy. This Privacy Policy sets out our practices with respect to personal information collected from the visitors of Affilitex.com (hereafter referred to as the “Site”) as well as registered affiliates (collectively referred to as “you”). The Site operates the Affilitex Affiliate Program (hereafter referred to as the “Platform”) and is solely restricted to adults who are capable of entering into contractual relationships.

ANY PERSON UNDER THE AGE OF EIGHTEEN OR THE AGE OF MAJORITY IN THE JURISDICTION WHICH PERSON IS UTILIZING OUR SITE AND/OR PROGRAM IS STRICTLY PROHIBITED FROM USING THE SITE OR SIGNING UP FOR AN ACCOUNT WITH THE PROGRAM. WE DO NOT INTENTIONALLY COLLECT INFORMATION ON INDIVIDUALS UNDER THE AGE OF EIGHTEEN. IF YOU HAVE REASON TO BELIEVE THAT ANYONE UNDER THE AGE OF EIGHTEEN OR THE AGE OF MAJORITY IN THE APPLICABLE JURISDICTION HAS PROVIDED US WITH PERSONAL INFORMATION, YOU MAY CONTACT US IMMEDIATELY. IF WE BECOME AWARE THAT WE HAVE COLLECTED ANY PERSONAL INFORMATION FROM INDIVIDUALS UNDER THE AGE OF EIGHTEEN OR THE AGE OF MAJORITY IN THE APPLICABLE JURISDICTION WE WILL PROMPTLY TAKE STEPS TO REMOVE AND PERMANENTLY DELETE SUCH INFORMATION.

BY VISITING THE SITE, YOU AGREE AND CONSENT TO THE TERMS OF THIS PRIVACY POLICY AS AMENDED FROM TIME TO TIME, AS WELL AS THE TERMS OF USE ALSO LOCATED ON THE SITE. BY SIGNING UP FOR AN AFFILIATE ACCOUNT YOU ALSO AGREE AND CONSENT TO THE TERMS OF THE AFFILIATE TERMS AND CONDITIONS AND DATA PROTECTION ADDENDUM.

If you have any questions or concerns about our use of your personal information, please contact us using the contact details provided in Section 18 “CONTACT INFORMATION” of this Privacy Policy.

1. How We Collect Your Personal Information

The data we collect about you depends on the context of your interaction with us, the Site or the Platform, the choices you make, and the services and features you use. We obtain your personal data mainly through any information you provide directly to us or through information provided by third parties. Below is a list of ways in which we collect your personal information.

Information you directly provide to us:

• when you complete our registration or other forms, which are available on our Site or Platform;
• when you performing contractual obligations;
• when you contact us for any requests, support, complaints, or for any other reason;
• when you post information or content on our Site.

Personal information collected from other sources:

• when you interact with our Site through social networks, and
• via third parties including our business partners, advertisers, contractors, and/or vendors in a manner that is permitted, through tags in websites you use and/or manage or control.

Automatic Information. Like many websites, we use “cookies” and other unique identifiers (if used alone, these technologies do not personally identify you) and we obtain certain types of information:

• when your web browser or device accesses the Site or Platform.
• when you interact with content and services available through Site or Platform.
• Please find detailed information about Cookies in Section 3 “COOKIES” of this Privacy Policy.

2. What Information is Collected

Here are the types, purposes, and legal basis of personal information we may collect:

Email Communication and Opt-Out

We may use your email address to communicate with you about your transactions, orders, our products, services, updates, news, and events. By providing us with your email address, you consent to receiving such communications from us.

If you wish to stop receiving marketing emails from us, you can unsubscribe by using the unsubscribe link found at the bottom of the email. Alternatively, you can contact us directly and request to opt out of receiving future marketing emails. Please note that even if you opt out of receiving marketing emails, you may still receive transaction-related emails from us, including information specific to your account, planned services suspensions and outages, and updates to our terms or policies. We will make reasonable efforts to limit this type of communication to you.

3. COOKIES

We automatically collect certain information when you visit, use, or navigate the Site. This information does not reveal your specific identity (like your name or contact information). Still, it may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Site, and other technical information.  This information is primarily needed to maintain the security and operation of our Site and for our internal analytics and reporting purposes.

Additionally, we may use third-party software to serve ads on the Site, implement email marketing campaigns, and manage other interactive marketing initiatives. This third-party software may use cookies or similar tracking technology to help manage and optimize your online experience with us.

Note: that certain cookies are necessary to enable the Site to operate and refusing or disabling some or all cookies may limit your ability to make use of the Site.

4. WHO DO WE SHARE YOUR PERSONAL INFORMATION

We may share your personal information with the following categories of third parties:

• Payment providers who assist us with the verification of payments and the processing of payments;
• Web hosting, optimization, email marketing services, management, and CRM companies who assist us with the hosting, operation, optimization, and maintenance of our Site, the administration of the Platform accounts, and the provision of access to secure areas and functionality on our Site;
• Analytics. We may use web analytics services offered by Google or other third parties that track and report website traffic. Google uses the data collected to track and monitor the use of our Site. You can opt out of Google Analytics features by clicking here.

We may also disclose information about you:

• if we are required to do so by law or legal process;
• to law enforcement authorities or other government officials;
• when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity;
• if necessary to protect the vital interests or legal of another individual;
• in connection with a corporate reorganization or a sale or transfer of all or a portion of our business or asset; or
• to any other person with your consent to the disclosure.

5. WHERE DO WE TRANSFER YOUR PERSONAL INFORMATION

Your personal information may be transferred to, and stored on, computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those in your jurisdiction. If you are located outside the country where Affilitex is based and choose to provide personal information to us, please note that we may transfer the information to any location where Affilitex has place and process it there.

6. THIRD-PARTY LINKS

There may be occasions when you will be presented with special offers either from us or from third-party service or content providers, which may include communications, newsletters, commercial advertising, or other promotional or special event materials. Your consent to this Privacy Policy acts as your consent to receive these occasional mailings by us and by our third-party service or content providers.

Affilitex is not responsible or liable for the use of any information that you may provide, or that is gathered by third-party websites that have ads or links on the Site. This Site does not control, monitor, or endorse the information-gathering practices or Privacy Policies of any of those third-party websites. Whenever applicable, each affiliate should seek to read the Privacy Policy of any third-party website provider that has an advertising banner, advertises, or has a link on the Site or in an email.

7. YOUR CONTENT

Our Site offers a publicly accessible blog. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request the removal of your personal information from our blog, contact us at support@traffichubgroup.com. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so. Also, we cannot prevent such information from being used in a manner that may violate this Privacy Policy, our Terms of Use, the law, or your privacy.

8. SOCIAL NETWORK PLUGINS

Our Site also uses plugins from various social networks. These plugins allow you to share our blog articles. Integrating the plugins allows the social networks to receive the information that you have called up the relevant page of our Site and can collect your device and access data. If you are logged into the social network, the latter may also assign the visit to your account with the relevant social network. If you interact with the plugins, for example by clicking the Facebook “share” button or making a comment, the corresponding information will be transmitted by your browser directly to the social network and stored there. Even if you are not registered with the social networks, websites with active plugins may send data to the networks.

The purpose and scope of the data collection, the further processing and use of the data by the particular social networks, and your rights and configuration options concerning this to protect your privacy, can be found in the privacy notices of the respective social networks and websites. We use the following social media plugins on our Site:

Facebook and Instagram social plugins, check Meta’s privacy policy here.

X (ex. Twitter) social plugins, check X’s privacy policy here.

LinkedIn social plugins, check LinkedIn’s privacy policy here.

Google social plugins, check Google’s privacy policy here.

 9. INFORMATION FOR RESIDENTS OF EUROPEAN COUNTRIES

If you are located in the European Economic Area, the United Kingdom, or Switzerland (the “European Countries”), you have certain rights and protections under Regulation (EU) 2016/679 (General Data Protection Regulation) and The United Kingdom General Data Protection Regulation (UK-GDPR) regarding the processing of your “personal data” as defined under applicable law. Some of the information that Affilitex collects from you through its operation of the Site may constitute “personal data” under these laws.

Where we decide the purpose or means for which personal information we collect is processed, we are the “Controller.” As a Controller by the classification of GDPR and UK-GDPR, we have the appropriate technical and organizational measures in place ensuring that data processing is performed in accordance with GDPRs. Such measures will be reviewed and updated if necessary and in accordance with the specifics of the gathered data.

Notice that Affilitex will not be held responsible for the data collected by affiliates or advertisers who contract the services of Affilitex, being responsible for the processing of data.

As a Processor by the classifications of GDPRs, we cooperate with our partners (Data Controllers and other Data Processors) to make sure any kind of user data is handled under the agreed terms and in compliance with the pertinent regulations and laws.

What Data Protection Rights Do You Have

As available and except as limited under applicable law, the rights afforded to residents of European Countries are:

• Right of access – the right to be informed of, and request access to, the personal data we process about you;
• Right to rectification – the right to request that we amend or update your personal data where it is inaccurate or incomplete;
• Right to erasure – the right to request that we delete your personal data;
• Right to restrict – the right to request that we temporarily or permanently stop processing all or some of your personal data;
• Right to object – the right, at any time, to object to us processing your personal data on grounds relating to your particular situation; the right to object to your personal data being processed for direct marketing purposes;
• Right to data portability – the right to request a copy of your personal data in electronic format and the right to transmit that personal data for use in another party’s service; and
• Right not to be subject to automated decision-making – the right to not be subject to a decision based solely on automated decision-making, including profiling, where the decision would have a legal effect on you or produce a similarly significant effect.

Exercising Your Rights

How to exercise your rights please read in the Section 12 “REQUEST FOR EXERCISE OF RIGHTS” below.

We will process your requests to us within 30 days. We will also notify a relevant supervisory authority within 72 hours from a breach related to your personal information that we hold.

We have assigned a Data Protection Officer (DPO) who may be reached via dpo@affilitex.com. Our DPO is tasked with ensuring that we acknowledge and abide by our data protection responsibilities.

Data retention

We keep personal information for as long as it is necessary to fulfill the purpose for which the personal information was collected, for example during the period during which you are registered on our Site or Platform, to attend to any legal claims, for example, if we believe that you have violated our rights, or for as long as required by applicable law.

When the personal information that we have collected is no longer required, we will delete it securely. We may further process data for statistical purposes, but in such cases, data will be anonymized.

Transfer

In the course of business, we may transfer personal information to our related entities. We also may transmit your data to our (sub)contracted service providers, both in and out of the European Countries.

Where we transfer the personal information of users to our related entities or service providers in countries that have not been deemed to have an adequate level of protection under an adequacy decision of the EU Commission or The UK Adequacy Decision, we have put in place specific contracts containing the EU Commission’s standard contractual clauses or standard data protection clauses to be issued by the Commissioner under S119A(1) Data Protection Act 2018, which is incorporated into DPAs concluded with our partners, who should be considered “data importers”, in order to ensure that your personal information is treated by all parties in a way that is consistent with and which respects laws on data protection, in particular the GDPR and UK-GDPR.

10. CALIFORNIA CONSUMER PRIVACY RIGHTS

The California Consumer Privacy Act (“CCPA”) (as augmented and amended by the California Privacy Rights Act, or “CPRA” (California Civil Code Section 1798.100 et seq.))  gives California residents certain rights with respect to the processing of personal data. Under CCPA, “Personal Information” is defined as information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with California consumers or households. This supplement provides additional privacy disclosures and details additional rights and should be read in conjunction with our Privacy Policy.

The California Code of Regulations defines a “resident” as:

(1) every individual who is in the State of California for other than a temporary or transitory purpose, and

(2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose.

All other individuals are defined as “non-residents.”

For employee-related personal data-related requests, such as requests regarding job applications, benefits, and HR, please direct your requests to the Affilitex HR Department.

Please note that if you wish to exercise any of your rights with any of Affilitex’s clients, you must make your request directly to those Affilitex clients, based on information and procedures that they supply. 

The categories of personal information the Affilitex collects as well as the Purposes and Legal Basis for Processing Personal Information are described in Section 2 “WHAT INFORMATION IS COLLECTED” above.

What Data Protection Rights Do You Have

As a California resident, you have certain rights with respect to the personal information collected by businesses.

• Right to Access.  You have the right to receive information about the types of personal information that Affilitex collects, uses, discloses, and sells. Specifically, this right allows you to ask Affilitex for the following information: (a) the categories of personal information that Affilitex collects about you; (b) the categories of sources from which Affilitex has obtained personal information about you; (c) Affilitex’s business or commercial purpose for collecting or selling your personal information; (d) the categories of your personal information that Affilitex sells to third parties; (e) the categories of third parties that Affilitex sells your personal information to; and (f) the specific pieces of personal information that Affilitex has collected about you. Affilitex must disclose this information to you when you exercise your right to know, subject to proper verification of your request. You may make a verifiable consumer request related to your personal information free of charge twice per 12-month period.
• Right to Correct Inaccurate Personal Information. If you have reason to believe that Affilitex maintains inaccurate personal information, you have the right to request Affilitex to correct your inaccurate personal information.
• Right to be Forgotten. You have the right to request that Affilitex delete any personal information it has collected or maintains about you, subject to certain exceptions for business purposes outlined in the applicable law. Once Affilitex receives and confirms your verifiable consumer request, Affilitex will delete your personal information from its records, unless an exception applies.
• Right to Non-Discrimination. You have the right to non-discrimination if you exercise any of your rights under the CCPA. If you exercise your rights under the CCPA, Affilitex will not discriminate against you in any way.
• Right to Opt-Out. You have the right to direct Affilitex to not sell or share your personal information to third parties at any time. PLEASE NOTE THAT AFFILITEX HAS NEVER SOLD OR/AND SHARED AND NOT GOING TO SELL OR/AND SHARE ANY PERSONAL DATA OBTAINED FROM YOU.

Sensitive Personal Data Processing

The CPRA requires data controllers to obtain a consumer’s consent before processing their sensitive personal data.  Please note that Affilitex does not generally collect sensitive personal data from California residents who visit our Site and will not process such data if it is inadvertently collected. Therefore, we will not request consent for processing of such sensitive personal data collected from the Site.

Exercising Your Rights

How to exercise your rights please read in Section 12 “REQUEST FOR EXERCISE OF RIGHTS” below.

11. VIRGINIA, COLORADO AND CONNECTICUT CONSUMER PRIVACY RIGHTS

 If you are a resident of the State of Virginia, Colorado, or Connecticut subject to certain exceptions, you have certain data protection rights as defined by the Virginia Consumer Data Protection Act (“VCDPA”), Colorado Privacy Act (“CPA”) or The Connecticut Data Privacy Act (“CTDPA”) respectively. Affilitex aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your personal information.

Upon the request you may realize your following rights:

1. To confirm whether or not Affilitex is processing your personal data and to access such personal data;
2. To correct inaccuracies in your personal data, taking into account the nature of the personal data and the purposes of the processing;
3. To delete personal data provided by or obtained about you;
4. To obtain a copy of your personal data that you previously provided to Affilitex in a portable and, to the extent technically feasible, readily usable format;
5. To opt out of the processing of the personal data for purposes of (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects for you.

AS AFFILITEX DOES NOT CONDUCT THIS TYPE OF “SALE” AND PROFILING, WE DO NOT OFFER SUCH KINDS OF OPT-OUTS TO VIRGINIA, COLORADO, AND CONNECTICUT RESIDENTS.

Sensitive Personal Data Processing

The VCDPA and CTDPA require data controllers to obtain a consumer’s consent before processing their sensitive personal data.  Please note that Affilitex does not generally collect sensitive personal data from Virginia or Connecticut consumers who visit our website and will not process such data if it is inadvertently collected. Therefore, we will not request consent for processing of such sensitive personal data collected from the Site.

Exercising your Rights

How to exercise your rights please read in Section 12 “REQUEST FOR EXERCISE OF RIGHTS” below. In addition to the general procedure, Virginia, Colorado, and Connecticut consumers have the right to appeal the decision if Affilitex declines to take action regarding the consumer’s request. To exercise your right to appeal you may in the same way as another privacy rights, make an appropriate request according to Section 12 “REQUEST FOR EXERCISE OF RIGHTS”.

If the appeal is also denied, under request, we may provide you with an online mechanism, if available, or another method by which you may contact the Attorney General to file a complaint.

12. REQUEST FOR EXERCISE OF RIGHTS

To exercise your rights to know, access, correct and be forgotten described above, please submit a verifiable consumer request to Affilitex by email at dpo@affilitex.com or send a letter to the address:

AFFILITEX LIMITED
1202 Emperor Group Centre,
288 Hennessy Road, Wan Chai, Hong Kong.

Upon receiving your request, we will need to verify your identity to determine you are the same person whose information we have in our system. These verification efforts require us to ask you to provide information so that we can match it with the information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method that you have previously provided to us. We may also use other verification methods as the circumstances dictate.

NOTE: We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

REQUESTS MADE THROUGH AGENTS – You may designate, in writing or through a power of attorney, an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require the agent to provide proof you have authorized it to act on your behalf, and we may need you to verify your identity directly with us.

HOUSEHOLD REQUESTS – We currently do not collect household data. If all the members of a household make a Right to Know or Right to Delete request, we will respond as if the requests are individual requests.

WARNING! Please exercise your rights wisely and note that abuse of rights may entail your liability.

13. SECURITY

We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process which include:

• using secure shell protocol (SSH);
• multi-factor authentication;
• access control (physical and technical);
• link encryption.

The protection of your personal data is important to us. We maintain appropriate safeguards and current security standards to protect your personal information from unauthorized access, disclosure, or misuse, such as using Secure Socket Layer (SSL) encryption for all supplied sensitive/credit information. However, no system can be completely secure, and we cannot ensure or warrant the security of any information you provide to us. While we take meaningful steps to secure your information, we do not promise, and you should not expect, that your personal information will always remain secure. We do not accept liability for unintentional disclosure.

However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, the transmission of personal information to and from our Site or Platform is at your own risk. You should only access the services within a secure environment.

We are not responsible for the safety of any information that you share with third-party providers who advertise but are not affiliated with our Site.

14. AGE OF CONSENT AND CHILDREN’S PRIVACY

We do not knowingly collect, maintain, or use personal information from individuals under the age of consent (18 years of age). If you have reason to believe that anyone under the age of consent has provided us with personal information, you may contact us immediately. If we become aware that we have collected any personal information from individuals under the age of consent we will promptly take steps to remove and permanently delete such information.

Affilitex adheres to the Children’s Online Privacy Protection Act. We do not create nor use any behavioral advertising segments of children under 18 as part of our Services. Our Site is not directed at children under the age of 18. If we are made aware that we have received personally identifiable information from someone under 18, we will use reasonable efforts to remove that information from our records.

15. ACCEPTANCE OF THE PRIVACY POLICY

By visiting or registering to become an affiliate, you agree to the practices described in this Privacy Policy. We may at any time revise or amend any of these terms and conditions with or without notice to you depending on the type of changes. You are bound by any such revisions and should therefore periodically visit this page to review the then-current terms and conditions of this Privacy Policy to which you are bound. To the extent that any of the third-party sites accessible through our Site (such as our advertisers) have different privacy practices from those stated in this Privacy Policy, those third-party privacy practices govern the collection and use of information you provide when visiting those sites. We are not responsible for the policies, content, and practices of other companies that may collect personal information as a third-party web service provider that has an advertising banner or link on the Site.

16. CHANGES TO THIS POLICY

We may make changes to this Privacy Policy from time to time based on changes to applicable laws and regulations or other requirements applicable to us, changes in technology, or changes to our business. Any changes we make to the Privacy Policy in the future will be posted on this page, and where we change this Privacy Policy in ways that also affect how we process personal information about you, where appropriate, we will notify you via email or other contact with you, and we also may post a notice on our home page that this Privacy Policy has changed.

17. CONTACT INFORMATION

For any questions about our privacy practices, you may contact us by dpo@affilitex.com or support@traffichubgroup.com

Our postal address is: TrafficHubGroup Limited, 3rd floor, Andrea Kariolou 38, Agios Athanasios, CY 4102, Limassol, Cyprus