Privacy Policy

PRIVACY POLICY

EFFECTIVE DATE: OCTOBER, 2025

LAST MODIFIED: OCTOBER, 2025

WEBSITE(S) COVERED: REDTRAFFIC.COM

This Privacy Policy explains how we collect, use, and process your personal data, how we comply with applicable legal obligations, and informs you about your privacy rights under the laws that may apply to you (including, where relevant, the EU General Data Protection Regulation (“GDPR”) and similar data protection laws in other jurisdictions).

Certain personal data is necessary to provide our services. If you choose not to provide such required information, we may not be able to deliver the requested services, or the functionality of the Website may be limited.

2. Who we are

XXX LLC is a company duly registered in the State of Colorado, United States of America, having its principal office at Address of LLC, Broomfield, CO 80023, United States. The “Redtraffic” brand is a trademark of REDTRAFFICMEDIA LLC and is used under authorization. XXX LLC is authorized to operate under and provide services using this brand. Any questions, concerns, or requests regarding this Privacy Policy or the exercise of your legal rights should be addressed to our Privacy Officer using the contact details below: Email address: help@redtraffic.com Postal address: Address of LLC, Broomfield, CO 80023, United States

3. Definitions and interpretation

In this Privacy Policy, the following definitions are used:

Cookies means a small text file placed on your computer by this Website when you visit certain parts of the Website and/or when you use certain features of the Website. Details of the cookies used by this Website are set out in our Cookies Policy.

Member means a person who creates an account on this Website and signs up to access any of the Website’s content or Company’s services.

Personal Data means any information relating to you that identifies you or could reasonably be used to identify you, and that is recorded in any form.

Sensitive Data means as per Article 9 of the GDPR, Personal Data revealing:

a) racial or ethnic origin, political opinions, religious or philosophical beliefs;

b) trade-union membership;

c) genetic data, biometric data processed solely to identify a human being;

d) health-related data;

e) data concerning a person’s sex life or sexual orientation.

User or You means any third party that accesses the Website and is not either (i) employed by us and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to us and accessing the Website in connection with the provision of such services.

Website means the website that you are currently using, redtraffic.com, and any sub-domains of this website, unless expressly excluded by their own terms and conditions.

4. Scope of this privacy policy

This Privacy Policy applies only to the actions of Redtraffic and Users/Members with respect to this Website. It does not extend to any websites that can be accessed from this Website including, but not limited to, any links we may provide to social media websites.

5. Collection and Use of Your Personal Data

If you are a User, we may collect the following personal data:

· IP (Internet Protocol) address

· Location data to deliver targeted advertisement to you

If you are a Member, we may collect the following personal data:

· Full name;

· Governmental issued identification documents such as national ID, passport or driver’s license;

· Email address;

· Residential address;

· Billing address;

· Financial data such as bank account and payment card details (where applicable)

· Ad interactions with advertisements, including ad clicks and views to evaluate the effectiveness of ads and optimize campaigns.

· Phone number;

· Communication identifiers (such as Skype, Telegram, or similar platforms);

· IP (Internet Protocol) address

We use ZenPayments, Bitpay, and PayPal as payments methods. If you choose to use our services and make a payment through our website, these payment processors may collect and process your personal data, including payment details and other identifying information. By proceeding with a payment, you acknowledge and agree that your personal data will be processed by the respective payment processor in accordance with its privacy policy. For more information on how your data is handled, please refer to the respective privacy policies of these payment processors.

6. Purposes of Processing Your Personal Data

We will use your personal data for one or more of the following purposes:

a) To perform the contract we are about to enter into or have entered into with you.

b) For our legitimate business purposes (such as fraud prevention, network security, analytics, and service improvement), where permitted by applicable law.

c) To comply with legal or regulatory obligations.

d) Where disclosure is required by courts, regulators, law enforcement, or other competent authorities.

e) Where you have provided your consent. Please note that you may revoke your consent at any time by contacting us at help@redtraffic.com

(for example, to withdraw consent for the use of non-essential cookies).

When you use our Website, we automatically log information such as IP address, browser type, referrer, and other technical data. This information is used to optimize our Website’s technical performance, enhance security, and for internal analytics and research purposes.

If you provide consent, we may also send you promotional or service-related communications, which may include, where legally permitted, marketing of adult-oriented content. You can opt out at any time by using the unsubscribe link in emails or by contacting us at help@redtraffic.com

We may use your data to provide information about products or services you have shown interest in, to distribute opt-in newsletters, and to conduct market research (by email, or by phone where legally permitted and with your prior authorization).

Redtraffic, directly or through authorized third parties, may make inquiries to verify your identity. This may include requesting additional information, requiring you to confirm ownership of your email address or financial instruments, or verifying your information against third-party databases or other sources. We may also request government-issued identification (such as a driver’s license or passport) solely for verification purposes. Redtraffic reserves the right to suspend or restrict access to your account if we are unable to obtain or verify this information.

We do not intentionally collect or process special categories of personal data (such as health data, biometric data, or political opinions).

Eligibility: Our services are intended for use only by individuals who are at least 18 years of age, whether acting on their own behalf or on behalf of a business entity. We do not knowingly collect or process personal data from anyone under the age of 18. If we become aware that we have collected personal data from a minor, we will delete such information promptly.

7. Transfer of Your Personal Data and Personal Data Recipients

In the course of performing our contractual and legal obligations, your personal data may be shared with different departments within Redtraffic and/or with carefully selected third-party service providers. Where we share personal data with such third parties, we require them—through written agreements—to (i) comply with applicable data protection laws, (ii) maintain confidentiality and appropriate security measures, and (iii) process the data only on our documented instructions and solely for the specified purposes.

Your personal data may be transferred to and stored in countries outside your country of residence, including the United States. Such transfers will occur only where necessary for the performance of our contract with you, compliance with a legal obligation, or for other legitimate business purposes permitted by law.

If you are located in the European Economic Area (EEA), the United Kingdom, or Switzerland, we will ensure that any international transfer of your personal data complies with applicable data protection law, for example by relying on:

the EU Standard Contractual Clauses (Commission Implementing Decision (EU) 2021/914) with any required supplementary technical and organizational measures;

UK safeguards such as the International Data Transfer Agreement (IDTA) or the UK Addendum to the EU Standard Contractual Clauses;

Swiss-compliant contractual clauses as recognized by the FDPIC, and/or adequacy decisions (where available).

Recipients of personal data may include, for example: government authorities and regulators (where required by law), auditors and accountants, legal advisors, payment processors and financial institutions, IT and cloud hosting providers, security/anti-fraud and analytics vendors, customer support and communications tools, file storage and archiving providers, business partners and other suppliers that support our operations. We only provide the minimum necessary information for the relevant purpose, prohibit recipients from using personal data for their own purposes, and require deletion or return of the data once services are completed, unless retention is mandated by law. Where required by applicable U.S. state privacy laws, we contract with recipients as service providers/contractors. If you are not located in these regions, transfers will be handled in accordance with applicable local law.

8. No Automated decision-making

We do not use fully automated decision-making processes, including profiling, that produce legal or similarly significant effects on individuals. While we utilize automated tools to assist in detecting fraudulent activity, ad targeting optimization and screening of ad campaigns, these tools serve only as a preliminary screening mechanism. Any decision that may impact users—such as suspending an account, rejecting an ad, or flagging a payment—undergoes human review before being finalized. This ensures that our decisions are fair, transparent, and consider all relevant factors beyond what an automated system can assess.

9. Security for Your Personal Data

Redtraffic uses appropriate administrative, technical, and physical measures to protect your personal data. Authorised personnel and third parties service providers may have limited access to your personal data, and they will only process your data according to our instructions. We have implemented mechanisms to:

· Ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services.

· Restore the availability and access to personal data in a timely manner in the event of a physical or technical incident.

· Regularly test, assess and evaluate the effectiveness of technical and organisational measures for ensuring the security of the data.

We have also established a policy for data breach, and we commit to notifying you and the competent authority for any breach or any suspected personal data breach where we are obliged by the law to do so.

10. Data Retention

We will retain your personal data for as long as necessary to fulfill the purposes for which it was collected, and to comply with applicable regulatory or statutory obligations. Once the required legal period has elapsed, these data will be definitively erased.

The criteria used to determine our retention periods include:

• The length of time we have an ongoing relationship with you and provide the services to you.
• Whether there is a legal obligation to which we are subject.
• Whether retention is advisable considering our legal position (such as litigation or regulatory investigations).

You have the right to request deletion of your personal data, subject to applicable legal requirements and legitimate business needs (for example, fraud prevention, compliance with tax or regulatory obligations, or dispute resolution). If you are located in the European Economic Area (EEA), the United Kingdom, or Switzerland, this includes the right commonly referred to as the “right to be forgotten” under the GDPR.

11. Your Legal Rights

You have the right to: (i) Request access to your personal data; (ii) Request correction of your personal data; (iii) Request deletion of your personal data; (iv) Object to the processing of your personal data; (v) Request restriction of the processing of your personal data; (vi) Where applicable under relevant law, request transfer of your personal data; (vii) Withdraw the consent that you have previously given us.

If you would like to exercise any of your rights, please contact our Privacy Officer by sending an email to help@redtraffic.com or by writing to us at Address of LLC, Broomfield, CO 80023, United States, and submit the relevant request. For verification purposes, you may be asked to provide a copy of a government-issued identification document or other proof of identity.

If you are a resident of the European Economic Area (EEA), the United Kingdom, or Switzerland, you also have the right to lodge a complaint with your local supervisory authority. If you are a resident of California, you may have additional rights under the California Consumer Privacy Act (CCPA), as amended by the CPRA, which you can exercise by contacting us using the details above.

We would appreciate the opportunity to address your concerns directly before you contact a supervisory authority.

12. Functionality of the website

To use all features and functions available on the Website, you may be required to submit certain Personal Data.

You may restrict your internet browser’s use of Cookies. For more information see the below clause.

13. Cookies

This Website may place and access certain Cookies on your computer. Redtraffic uses Cookies to improve your experience of using the Website and to improve our range of services. Redtraffic has carefully chosen these Cookies and has taken steps to ensure that your privacy is protected and respected at all times.

All Cookies used by this Website are used in accordance with current applicable laws.

Before the Website places Cookies on your computer, you will be presented with a message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling Redtraffic to provide a better experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Website may not function fully or as intended.

For more information about Cookies, please check our Cookies Policy available at.

14. 14. California Consumer Privacy Act (CCPA/CPRA) Notice

We do not specifically target California residents; however, if you are a California resident, you are entitled to certain rights under the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA). If you voluntarily register and use our platform, we may process your personal information as part of our standard data processing practices.

To the extent that the CCPA/CPRA applies, California residents may exercise the following rights regarding their personal information:

· Right to opt-out of sale or sharing: You may request us to stop selling or sharing your personal information. We do not sell or share personal information as those terms are defined under the CCPA/CPRA.

· Right to know: You may request disclosure of the categories and specific pieces of personal information we have collected, used, shared, or disclosed about you, and the purposes for which we did so.

· Right to delete: Subject to applicable exceptions, you may request deletion of personal information we have collected from you.

· Right to non-discrimination: We will not deny goods or services, charge different prices, or provide different levels or quality of goods or services for exercising your CCPA/CPRA rights. However, if you refuse to provide certain personal information that is necessary for us to provide services, we may be unable to complete that transaction.

Only you, or someone legally authorized to act on your behalf (for example, an authorized agent with a duly executed power of attorney), may make a verifiable consumer request related to your personal information. We may require you or your agent to provide sufficient information to allow us to reasonably verify your identity.

To submit a request, please contact us by email at help@redtraffic.com

We will respond to verifiable consumer requests as required by law.

15. General

If any court or competent authority finds that any provision of this privacy policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this privacy policy will not be affected.

Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.

16. Changes to this privacy policy

We may change this policy as new services are added or old ones are changed. Please check this Privacy Policy from time to time for updates on our Website. We may e-mail periodic reminders of our policies and terms of use, but you should check our Website frequently to see recent changes. Unless stated otherwise, our current Privacy Policy applies to all information that we have about you and your account. As we continue to develop our business, we might reorganize or transfer our business units or assets. In such transactions, user information generally is one of the transferred business assets but remains subject to the promises made in any pre-existing Privacy Policy unless the user consents otherwise. Also, in the unlikely event that Redtraffic or substantially all of its assets are acquired, user information may be one of the transferred assets, without prejudice to applicable data protection requirements.