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Introduction
Trafficola ("Trafficola", "Trafficola.com" or "we" or "us" or "our") respects the privacy of its users ("user" or "you") whether they use our website located at Trafficola.com, including other media forms and media channels related or connected thereto (collectively, the "Website" or "Site") to meet and interact with others involved in Internet and other types of marketing, advertising and sales, or simply to view the Website.

The following privacy policy ("Privacy Policy") is designed to inform you, as a user of the Website, about the types of information that Trafficola may gather about or collect from you in connection with your use of the Website. It also is intended to explain the conditions under which Trafficola uses and discloses that information, and your rights in relation to that information. Each time you use the Website, the current version of this Privacy Policy will apply. Accordingly, each time you use the Website you should check the date of this Privacy Policy (which appears at the beginning of this document) and review any changes since the last time you used the Website.

Our Website is hosted in the United States of America and is subject to U.S. state and federal law. If you are accessing our Website from other jurisdictions, please be advised that you are transferring your personal information to us in the United States, and by using our Website, you consent to that transfer and use of your personal information in accordance with this Privacy Policy.

You also agree to abide by the applicable laws of applicable states and U.S. federal law concerning your use of the Website and your agreements with us. Any persons accessing our Website from any jurisdiction with laws or regulations governing the use of the Internet, including personal data collection, use and disclosure different from those of the jurisdictions mentioned above may only use the Website in a manner lawful in their jurisdiction. If your use of our Website would be unlawful in your jurisdiction, please do not use the Website.
This Privacy Policy describes how our company collects information from all end users of our Internet services (the "Services")-those who access some of our Services but do not have accounts ("Visitors") as well as those who may purchase Products and/or pay a monthly service fee to subscribe to the Service ("Members")-what we do with the information we collect, and the choices Visitors and Members have concerning the collection and use of such information. We request that you read this Privacy Policy carefully. By visiting our Company Web site, you are consenting to our policy of collecting and using your data.

By using or accessing the website, you are accepting the practices described in this privacy policy.

Children
The Children's Online Privacy Protection Act ("COPPA") protects the online privacy of children under 13 years of age. We do not knowingly collect or maintain personal information from anyone under the age of 13, unless or except as permitted by law. Any person who provides personal information through the Website represents to us that he or she is 13 years of age or older.

If we learn that personal information has been collected from a user under 13 years of age on or through the Website, then we will take the appropriate steps to cause this information to be deleted. If you are the parent or legal guardian of a child under 13 who has become a member of the Website or has otherwise transferred personal information to the Website, please contact Trafficola to have that child's account terminated and information deleted.

Gathering, use and disclosure of non-personally-identifying information

Users of the Website Generally
"Non-Personally-Identifying Information" is information that, without the aid of additional information, cannot be directly associated with a specific person. "Personally-Identifying Information," by contrast, is information such as a name or email address that, without more, can be directly associated with a specific person. Like most website operators, Trafficola gathers from users of the Website Non-Personally-Identifying Information of the sort that Web browsers, depending on their settings, may make available. That information includes the user's Internet Protocol (IP) address, operating system and browser type, and the locations of the Web pages the user views right before arriving at, while navigating and immediately after leaving the Website.

Trafficola analyzes Non-Personally-Identifying Information gathered from users of the Website to help Trafficola better understand how the Website is being used. By identifying patterns and trends in usage, Trafficola is able to better design the Website to improve users' experiences, both in terms of content and ease of use. From time to time, Trafficola may also release the Non-Personally-Identifying Information gathered from Website users in the aggregate, such as by publishing a report on trends in the usage of the Website.

Web Cookies
A "Web Cookie" is a string of information which assigns you a unique identification that a website stores on a user's computer, and that the user's browser provides to the website each time the user submits a query to the site. We use cookies on the Website to keep track of services you have used, to record registration information regarding your login name and password, to record your user preferences, to keep you logged into the Website, and to facilitate purchase procedures. Trafficola also uses Web Cookies to track the pages that users visit during each Website session, both to help Trafficola improve users' experiences and to help Trafficola understand how the Website is being used.

As with other Non-Personally-Identifying Information gathered from users of the Website, Trafficola analyzes and discloses in aggregated form information gathered using Web Cookies, so as to help Trafficola, its partners and others better understand how the Website is being used. Trafficola does not attempt to link information gathered using Web Cookies to Personally-Identifying Information. Trafficola users who do not wish to have web cookies placed on their computers should set their browsers to refuse web cookies before accessing the website, with the understanding that certain features of the website may not function properly without the aid of web cookies. Website users who refuse web cookies assume all responsibility for any resulting loss of functionality.

Third Party Advertisers
We may use third-party advertising companies to serve ads when you visit the Website. These companies may use information (not including any Personally-Identifying Information) about your visits to this and other websites that are contained in Web Cookies in order to provide advertisements about goods and services of interest to you. Using a tool created by the HYPERLINK "http://networkadvertising.org/" Network Advertising Initiative, you can HYPERLINK "http://networkadvertising.org/managing/opt_out.asp" opt out of several third party ad servers' and networks' Web Cookies simultaneously.

If you would like more information about this practice and to know your choices about not having this information used by these companies, please follow the following link: HYPERLINK "http://networkadvertising.org/managing/opt_out.asp" http://networkadvertising.org/managing/opt_out.asp. Please contact us if you would like to know the identity of the third-party advertising companies we are currently using to serve ads.

We may allow advertisers to choose the characteristics of users who will see their advertisements and we may use any of the non-personally identifiable attributes we have collected (including information you may have decided not to show to other users, such as your birth year or other sensitive personal information or preferences) to select the appropriate audience for those advertisements. We do not identify you to the advertiser.

Aggregated and Non-Personally-Identifying Information
We may share aggregated and Non-Personally Identifying Information we collect under any of the above circumstances. We may also share it with third parties and our affiliate companies to develop and deliver targeted advertising on our Website and on websites of third parties. We may combine Non-Personally Identifying Information we collect with additional Non-Personally Identifying Information collected from other sources.

We also may share aggregated information with third parties, including advisors, advertisers and investors, for the purpose of conducting general business analysis. For example, we may tell our advertisers the number of visitors to our Website and the most popular features or services accessed. This information does not contain any Personally-Identifying Information and may be used to develop website content and services that we hope you and other users will find of interest and to target content and advertising.

Collection, use and disclosure of personally-identifying information

Website Registration
As defined above, Personally-Identifying Information is information that can be directly associated with a specific person. Trafficola collects a range of Personally-Identifying Information from and about Website users. Much of the Personally-Identifying Information collected by Trafficola about users is information provided by users themselves at the time they register to open an account or otherwise interact with Trafficola. That information may include each user's name, address, email address, and telephone number, and, if you transact business with us, financial information such as your payment method (valid credit card number, type, expiration date or other financial information).

We also may request information about your interests and activities, your gender, age, date of birth, username, hometown and other demographic information, and other relevant information as determined by Trafficola from time to time. Users of the Website are under no obligation to provide Trafficola with Personally-Identifying Information of any kind, with the caveat that a user's refusal to do so may prevent the user from using certain Website features.

By registering with or using the website, you consent to the use and disclosure of your personally identifying information as described in this "collection, use and disclosure of personally-identifying information" section.

In instances where our company and a partner jointly promote our Services, we may provide the partner certain personal information, such as the name, address, and username of persons who subscribed to the Services as a result of the joint promotion for the purpose of offering you other products and services.

We may also generate non-identifying and aggregate profiles from personal information Members provide during registration (such as the total number, but not the names, of Members). As explained in more detail below, we may use this aggregated and nonidentifying information to sell advertisements that appear on the Services.

Our Company collects personal information through form you complete on the site, as well as but not limited to contests, sweepstakes, text messages, e-mails, faxes, telephone calls, postal mail or other communications with the user, as well as from outside sources such as credit card processors and database vendors.

For example, when you fill out a form subscribing to our emails, we are sent data information from our autoresponder company such as your name, email, the website you signed up from, geographical data such as your city, state, Postal code, country, Latitude, Longitude, Timestamp, Subscription method and IP address.

Also, with purchases, we supply our member's contact information, to our business partners, who then may contact the member by telephone after the member purchase.

Sales proceeds are collected by the that business partner company. We also may supply other companies with contact information, for mail offers we believe would be of interest to our members, with or without compensation from those companies. At times we may send an advertisement for a third party product, where we collect the sales proceeds, and forward the purchaser's information to that third party.

Online Postings
Certain Personally-Identifying Information collected from users is disclosed as a matter of course as a result of those users' use of the Website. We provide areas on our Website, such as forums, where you can post questions, comments, reviews, offers and other information relating to your activities on the Website. Such postings are governed by our Terms of Use. In addition, such postings may appear on other websites or when searches are executed on the subject of your posting.

Also, whenever you voluntarily disclose personal information on publicly-viewable web pages, that information will be publicly available and can be collected and used by others. For example, if you post your email address, you may receive unsolicited messages. We cannot control who reads your posting or what other users may do with the information you voluntarily post, so we encourage you to exercise discretion and caution with respect to your personal information. Users assume all responsibility for any loss of privacy or other harm resulting from their voluntary disclosure of personally identifying information.

Trafficola Disclosures
Trafficola will disclose Personally-Identifying Information under the following circumstances:
By Law or to Protect Rights. When we believe disclosure is appropriate in connection with efforts to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing; to protect and defend the rights, property or safety of our business, our users, our employees, or others; to comply with applicable law or cooperate with law enforcement; or to enforce our Terms of Use or other agreements or policies, in response to a subpoena or similar investigative demand, a court order, or a request for cooperation from a law enforcement or other government agency; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases, we may raise or waive any legal objection or right available to us.

Trafficola Communications
We may occasionally use your name and email address to send you notifications regarding new services offered by the Website that we think you may find valuable. We may also send you service-related announcements from time to time through the general operation of the service. Generally, you may opt out of such emails at the time of registration or through your account settings, though we reserve the right to send you notices about your account even if you opt out of all voluntary email notifications.

Marketing Communications
Trafficola may email users about products and services that Trafficola believes may be of interest to them. If a user wishes to opt-out of receiving marketing materials from Trafficola, user may do so by following the unsubscribe link in email communications, by going to your account settings or contacting us using the contact information below.

Business Partners
When you make purchases or engage in promotions offered through our Website or our services, we may share Personally-Identifying Information with the businesses with which we partner to offer you those products, services, promotions, contests and/or sweepstakes. When you elect to engage in a particular merchant's offer or program, you authorize us to provide your email address and other information to that merchant.

Some products and services may be offered to Visitors and Members in conjunction with an affiliate, independent contractor seller or non-affiliated partner. To provide Visitors and Members some of these products and services, the partner may need to collect and maintain personal information.

Online Shopping
At some Web sites, you can purchase products and services or register to receive materials, such as a newsletter, catalog or new product and service updates. In many cases, you may be asked to provide contact information, such as your name, address, email address, phone number, and credit/debit card information.

If you complete an order for someone else, such as an online gift order sent directly to a recipient, you may be asked to provide information about the recipient, such as the recipient's name, address, and phone number. Our company has no control over the third parties' use of any personal information you provide when placing such an order. Please exercise care when doing so.
If you order services or products directly from our company, we use the personal information you provide to process that order. We do share this information with outside parties that we do business with.

Online Advertisements
Our company may display our online advertisements. In those cases we share information about our Visitors and Members collected through the registration process as well as through online surveys and promotions with these advertisers.

Additionally, in some instances, we use this information to deliver tailored advertisements or joint ventures. For instance, an advertiser or joint venture company tells us the audience they want to reach and provides us an advertisement tailored to the audience. Based upon the information we have collected, we may then display or send the advertisement to the intended audience. Our company does share personal information about its Visitors or Members with these advertisers or joint venture companies.

By visiting our Company Web site, you are consenting to our policy of collecting and using your data. If you do not want to consent to our policy of collecting and using your data you can "opt out" of our Social Network and Facebook.com Website Custom Audience Ads advertising policy by notifying Company in the following manner:

Social Network and Facebook.com Website Custom Audience Ads (WCA)
A Custom Audience on Facebook.com is a list of people our company would like to show our ads to on Facebook.com, who have shown interest in our products and services, with ads we believe would be of interest to them. This audience consists of people, whose information and email addresses our Company already has, because they have already subscribed to receiving Company emails.
If you no longer have an interest in our products and services, you can opt-out of seeing Company's Facebook.com Website Custom Audience Ads. Unsubscribing from our Company's email list will remove you from Company's internal email database list and stop future emails from our Company, but not from being shown Facebook.com Website

Custom Audience Ads
The Facebook.com Website Custom Audience Ads external database, is different from our Company's internal database and requires the following Opting-out request.

Opting-out of Facebook.com Website Custom Audience Ads
To opt out of our Company's Facebook.com Custom Audience Ads, send an email, from the email address you are opting out, to Company using our email address provided in Company's contact information. Put "Opting Out of Facebook.com Website Custom Audience Ads " in the subject line of the email. In the body of the email include your name and email address. Our Company staff will forward your name and email address to Facebook.com with a request to delete you from all of Company's Facebook.com Website Custom Audience Ads.

Google.com Analytics
Our Company may use Analytics tracking code to support Display Advertising, and enable Google Analytics to collect data about your traffic via the DoubleClick cookie in addition to data collected through the standard Google Analytics implementation. Display Advertising lets us enable features in Analytics that aren't available through standard implementations, like Remarketing with Google Analytics, Google Display Network Impression Reporting, the DoubleClick Campaign Manager integration, and Google Analytics Demographics and Interest Reporting.

Our Company may use Remarketing with Google Analytics to advertise online: This allows third-party vendors, including Google, to show your ads on sites across the Internet. Our Company and third-party vendors, including Google, use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize, and serve ads based on someone's past visits to our website.

Our Company may implement Google Display Network Impression Reporting or the DoubleClick Campaign Manager: Our Company and third-party vendors, including Google, use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) together to report how your ad impressions, other uses of ad services, and interactions with these ad impressions and ad services that are related to visits to your site.

Our Company may implement Google Analytics Demographics and Interest Reporting: The data from Google's Interest-based advertising or 3rd-party audience data (such as age, gender, and interests) with Google Analytics allows us to serve ads to you based on this data.

Opting-out of Google Analytics' For The Web and Google Analytics for Display
Users can opt-out of Google Analytics' currently available opt-outs for the web at https://tools.google.com/dlpage/gaoptout/
Using the Ads Settings, users can opt-out of Google Analytics for Display Advertising and customize Google Display Network ads at https://www.google.com/settings/personalinfo

Retargeting Ad Campaigns and Persistent Identifiers
Our Company may utilize various types of advertising that appear on our Company sites and services including ads on third party sites and services. Our Company may utilize categories of information, including names and email addresses, collected from users on our sites and services, as well as third party sites and services, in connection with the ads that are served. This advertising may include, but not limited to, contextual advertising, cookies, anonymous cookies, pixels, persistent identifiers, geolocation information, email opt in, search engine terms, behavioral advertising and/or retargeting advertising.

This type of advertising is a form of targeted advertising, to the specific individual who is visiting the Web site. These advertisements appear on websites or other media, including display ads, pop up ads and ads displayed in mobile browsers. Those advertisements are selected and served by automated systems based on the interests relevant to the user from the content displayed to the user, based on what the user is viewing.
Our Company does not conduct inquiries into the information collection practices of third parties that may collect information from users that leave our Web site.
Our Company may share customer information with third parties to process orders, for third party analytics and for marketing and advertising purposes. Responses to Email Inquiries: When Visitors or Members send email inquiries to our company, the return email address is used to answer the email inquiry we receive.

Special Cases
It is our company's policy to use or share the personal information about Visitors or Members in ways described herein without additional notice or means to opt out except as noted herein, or otherwise prohibit such unrelated uses.

Also, we may disclose personal information about Visitors or Members, or information regarding your use of the Services or Web sites accessible through our Services, for any reason if, in our sole discretion, we believe that it is reasonable to do so, including: credit agencies, collection agencies, merchant database agencies, law enforcement, or to satisfy laws, such as the Electronic Communications Privacy Act, the Child Online Privacy Act, regulations, or governmental or legal requests for such information; to disclose information that is necessary to identify, contact, or bring legal action against someone who may be violating our Acceptable Use Policy or Terms Of Service, or other user policies; to operate the Services properly; or to protect our company and our Members.

Affiliates
We may share some or all of your personal information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates would include a parent or any subsidiaries, joint venture partners, or other companies that we control or that is under common control with us.

Third Party Service Providers
We may share your Personally-Identifying Information, which may include your name and contact information (including email address) with our authorized service providers that perform certain services on our behalf. These services may include fulfilling orders, providing customer service and marketing assistance, performing business and sales analysis, supporting our website functionality, and supporting contests, sweepstakes, surveys and other features offered through our Website. We may also share your name, contact information and credit card information with our authorized service providers who process credit card payments. 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 purpose.

Business Transfers; Bankruptcy
Trafficola reserves the right to transfer all Personally-Identifying Information in its possession to a successor organization in the event of a merger, acquisition, or bankruptcy or other sale of all or a portion of Trafficola's assets. Other than to the extent ordered by a bankruptcy or other court, the use and disclosure of all transferred Personally-Identifying Information will be subject to this Privacy Policy, or to a new privacy policy if you are given notice of that new privacy policy and are given an opportunity to affirmatively opt-out of it. Personally-Identifying Information submitted or collected after a transfer, however, may be subject to a new privacy policy adopted by the successor organization.

Changing Personally-Identifying Information; Account Termination
You may at any time review or change your Personally-Identifying Information by going to your account settings (if applicable) or contacting us using the contact information below. Upon your request, we will deactivate or delete your account and contact information from our active databases. Such information will be deactivated or deleted as soon as practicable based on your account activity and accordance with our deactivation policy and applicable law.

To make this request, either go to your account settings (if applicable) or contact us as provided below. We will retain in our files some personal information to prevent fraud, to troubleshoot problems, to assist with any investigations, to enforce our Terms of Use and to comply with legal requirements as is permitted by law. Therefore, you should not expect that all your personal information will be completely removed from our databases in response to your requests. Additionally, we keep a history of changed information to investigate suspected fraud with your account.

General Use
We use the Personally-Identifiable Information in the file we maintain about you, and other information we obtain from your current and past activities on the Website to: deliver the products and services that you have requested, manage your account and provide you with customer support, communicate with you by email, postal mail, telephone and/or mobile devices about products or services that may be of interest to you either from us, our affiliate companies or other third parties, develop and display content and advertising tailored to your interests on our Website and other sites, resolve disputes, troubleshoot problems, measure consumer interest in our services, inform you of updates, customize your experience, detect and protect us against error, fraud and other criminal activity, enforce our Terms of Use, and as otherwise described to you at the time of collection.

At times, we may look across multiple users to identify problems. In particular, we may examine your Personally-Identifiable Information to identify users using multiple user IDs or aliases. We may compare and review your Personally-Identifiable Information for accuracy and to detect errors and omissions. We may use financial information or payment method to process payment for any purchases made on our Website, enroll you in the discount, rebate, and other programs in which you elect to participate, to protect against or identify possible fraudulent transactions, and otherwise as needed to manage our business.

Voluntary contests, giveaways and surveys
From time to time, Trafficola may offer Website users the opportunity to participate in contests, giveaways and other promotions. Any information submitted in connection with such activities will be treated in accordance with this Privacy Policy. From time to time, Trafficola may also ask Website users to participate in surveys designed to help Trafficola improve the Website. Any Personally-Identifying Information provided to Trafficola in connection with any survey will be used only in relation to that survey, and will be disclosed to third parties not bound by this Privacy Policy only in non-personally-identifying, aggregated form.

Collection and use of information by third parties generally
Trafficola contractually prohibits its contractors, affiliates, vendors and suppliers from disclosing Personally-Identifying Information received from Trafficola, other than in accordance with this Privacy Policy. Third parties are under no obligation to comply with this Privacy Policy, however, with respect to Personally-Identifying Information that users provide directly to those third parties or that those third parties collect for themselves. These third parties include advertisers, providers of games, utilities, widgets and a variety of other third party applications accessible through the Website.
Trafficola neither owns nor controls the third-party websites and applications accessible through the Website. Thus, this Privacy Policy does not apply to information provided to or gathered by the third parties that operate them. Before visiting a third-party, or using a third party application, whether by means of a link on the Website, directly through the Website, or otherwise, and before providing any Personally-Identifying Information to any such third party, users should inform themselves of the privacy policies and practices (if any) of the third party responsible for that website or application, and should take those steps necessary to, in those users' discretion, protect their privacy.

Security
We take security of your Personally-Identifying Information seriously and use reasonable electronic, personnel, and physical measures to protect it from loss, theft, alteration, or misuse. However, please be advised that even the best security measures cannot fully eliminate all risks. We cannot guarantee that only authorized persons will view your information. We are not responsible for third party circumvention of any privacy settings or security measures.

Privacy policy changes
Trafficola may, in its sole discretion, change this Privacy Policy from time to time. Any and all changes to Trafficola's Privacy Policy will be reflected on this page and the date new versions are posted will be stated at the top of this Privacy Policy. Unless stated otherwise, our current Privacy Policy applies to all information that we have about you and your account. Users should regularly check this page for any changes to its Privacy Policy. Trafficola will always post new versions of the Privacy Policy on the Website. However, Trafficola may, as determined in its discretion, decide to notify users of changes made to this Privacy Policy via email or otherwise. Accordingly, it is important that users always maintain and update their contact information.

California privacy rights
California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us once a year, free of charge, information about the personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request to the contact address below.

Contact
If you have any questions regarding our Privacy Policy, please contact us at: support  @ trafficola.com

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