Privacy and Cookie Policy

Introduction

This Privacy & Cookie Policy applies to our product TraffiqX. This policy describes how we may collect and process your personal data, when you register in this program. Through this policy you will also know when collection takes place, the purpose of such collection and how we process information which may relate to you (‘personal data’), among others. It also provides important information on your statutory rights and how to exercise them. This policy is not intended to override the terms of any contract you have with us or to override any rights that you may have under data protection laws.

TraffiqX is a product managed by Catena Media. Catena Media as a Data Controller will collect and process your personal information in accordance with this policy, and in observance of the relevant and applicable Data Privacy Regulations.

Who are we?

Catena Media is a company incorporated under Maltese Law, which is engaged in performance marketing and lead generation online. The headquarter office is located at Quantum Place, Triq ix-Xatt Ta’ Xbiex, GZR 105, Gzira. Malta, having subsidiaries in other countries.

Who is responsible for looking after your data?

Catena Operations Limited (‘Catena Media”, “we’, ‘us’), is principally responsible for looking after your personal data, where collected. We can be categorized as a Data Controller, being able to determine the means and purposes of processing personal data.

You should be aware that although we are principally responsible as a Controller, for looking after your personal data, information may be shared with other third parties ("processors" and/or "sub processors"), we contract with, in order to supply the services to you. Please rest assured that when accessing your personal data, all third party processors engaged by our company, and/or "sub processors" used by our authorised processors, will comply with the standards set out in our Privacy Policy.

What personal data we may process?

We may collect the following categories of personal data: (1) Identity and contact information; (2) Communications; (3) Marketing data and preferences; (4) Location data; (5) Technical and performance data. Particularly, we may collect the following:

• Username
• Email address
• Password
• Date of registration
• Name and last name
• Phone number
• IP address
• State
• Posts, comments, personal preferences, selection, opinions, complaints, reviews, ratings, interaction
• Location Data
• Time spent, clicks
• Website usage
• Cookie and other online identifiers

How do we collect data?

(1) Directly from you: when you register voluntarily in this program and provide us of your personal data.You may choose to provide (voluntarily) other information directly to us or we may require other information from you, as part of this program. For example, to complete your profile, for identity verification purposes, among others.We may also collect other information should you decide to get in touch with us or connect with us through social media or another third-party application (your social media service provider or third-party application may allow you to share information with us. If you choose to share, your social media provider will generally tell you which information will be shared). (2) Automatically: via the cookies, analytics tools and similar technologies; (3) Where required for identification and verification purposes.

We do not collect personal data on people under the age of 18 (or the age of legal consent per the laws of any jurisdiction, whichever is higher). If personal data on minors is collected without our knowledge, please contact us at privacy@catenamedia.com and report the issue.

We do not collect special categories of personal data like sensitive personal data (for example: political views, religion, trade union membership, health information, among others).

When do we process your personal Data?

We will collect information from you directly when you register in this program.This information is provided by you on a voluntary basis for registration purposes. Later on, we may also collect data when you interact with our website, or when verification is required. Where we process your personal data to create and administer your account, verify your identity, or provide the services you have registered for, we do so because it is necessary for the performance of our contract with you, or to take steps at your request before entering into a contract.

For what purposes we process your personal data?

We may use your personal data for the following purposes:

Account registration and verification

We will collect your username and email, name and last name, state, among others, to create your account in the program and manage it. We may require further documents at a later stage in order to verify legal age.

Providing the services of this program

we may collect data which is essential for the performance of the contract with you. In this regard we will be able to enhance and personalize the services related to this program.

Fraud and Abusive Behaviour Prevention

monitoring account activity will allow us to determine if there was a fraud or abusive behaviour from the side of the user.

Marketing

this program may imply the provision of communications, newsletters, among others to the users. Our intention is to enhance and improve our communications and offerings towards you. We may use a similar technology to cookies to confirm whether you have opened a marketing email or clicked on a link in the email.

Customer support and communications

users can come to us making queries, complaints, requesting assistance. To manage the relationship with our user, we analyze information in our systems and databases to improve the way we run our business and websites according to user preferences, to provide a better service and user experience.

Legal

we may process data to establish, exercise or defend legal claims.

Personalized Experience and Profiling

personalize, customize, target and improve the content delivered to you based on your preferences and the data we collect. Data you provide when completing the tasks suggested in this program may also be linked to your cookie data to personalize future content and communications. This profiling helps us tailor communication based on your likely interests, without producing legal or similarly significant effects. You can object to profiling at any time by contacting us at privacy@catenamedia.com, and we will stop using your data for segmentation unless we can demonstrate compelling legitimate grounds.

Cookies

We may also use data collected via cookies and your interaction with marketing emails (e.g., whether you opened or clicked) to personalize the content and timing of the emails we send you

Technical

understand, diagnose, troubleshoot and fix issues with our services under this program.

Who do we share your personal data with?

We work with many third parties to help deliver of services related to this program. These platforms act on our behalf and are subject to appropriate contractual, organizational and technical safeguards. From time to time, these third parties processors and/or subprocessors may require access to your personal data. These third parties can include:

• mailing application providers,
• plugin providers and hosts,
• marketing automation platforms such as Customer.io, which we use to trigger communications based on behavioral data.
• form and lead capture providers (e.g., ConvertFlow), which we use to collect your details when you sign up for newsletters or offers. These platforms act on our behalf and transmit your data securely to our internal systems and marketing automation tools;
• chatbot platforms and providers,
• other service providers (e.g., cloud services providers, hosting providers, authentication providers, etc.),
• analytics, tracking, and cookies (and similar technologies) service providers, who also process personal data for their own purposes as Data Controllers. Should you have any questions please contact us at privacy@catenamedia.com

Among these third party suppliers which whom we may share information for the provision of services we have the following:

Our subsidiaries in the Catena Media Group, located inside or outside the EU/EEA, for internal administrative and marketing purposes. Personal data transfers will be subject to Catena Media intra-group data transfer agreements, on the basis of our legitimate interest and your consent when transferred to another Catena Media Group subsidiary for its own marketing purposes;

Some of the providers, as described before, including our analytics, advertising, and customer communication providers, are located outside the European Economic Area (EEA), including in the United States. Where we transfer personal data outside the EEA, we rely on the European Commission's Standard Contractual Clauses, an adequacy decision, the recipient's certification under the EU-U.S. Data Privacy Framework , or another legally recognised safeguard, as applicable to each recipient. More details are available on request by contacting privacy@catenamedia.com

Law enforcement and data protection authorities, if we are under a duty to disclose to and comply with a legal obligation or protect our interests or security;

In the event that we sell, buy or reorganize any business or assets, or if our assets are acquired by a third party, including prospective sellers or buyers.

Direct Marketing

We may use your personal data to send you direct marketing communications regarding products and services offered by the Catena Media Group and its advertising partners, for example in relation to online casino and sports betting. This may be in the form of emails, SMS, WhatsApp, Facebook or Telegram messenger, or targeted online advertisements. By subscribing to our marketing communications, you agree to receive promotional material from this website and from Catena Media associated brands and products, including but not limited to PlayUSA, Bonus.com, Legal Sports Report, Lineups, Gaming Today.

Where you have subscribed to receive marketing communications, we may use marketing automation platforms (e.g., Customer.io) to create behavioral segments and trigger automated campaigns based on your interactions with our website or emails.

We may also use tracking technologies (such as tracking pixels) in our marketing emails to determine whether emails are opened, or links are clicked. This helps us personalize follow-up content, improve relevance, and measure engagement. This tracking is only used if you have provided consent.

The use and processing of your personal data for the purpose of sending you electronic marketing messages will be based on your consent to receive such messages. Provided that we have received your consent, we may use third parties to help us to process your personal data for marketing purposes.

You retain the right to unsubscribe from any further electronic marketing communications at any time after giving us your consent to send such messages. You can use the opt-out link included in all direct electronic marketing communications or contact us at privacy@catenamedia.com.

We take steps to limit direct marketing to a reasonable and proportionate level and to send you communications that we believe may be of interest or relevance to you, based on the information you had provided us.

From time to time, Catena Media may restructure or consolidate its websites, services, or communication channels across its group brands. If this involves transferring a newsletter subscription or other marketing communication from one brand to another (for example, due to a site closure or consolidation), we will notify you in advance and give you the opportunity to opt out. This is done in line with Catena Media’s legitimate interest in ensuring service continuity and providing users with consistent and relevant content. Your data will continue to be processed in accordance with this policy and applicable data protection laws.

We may update this Privacy Policy from time to time. If we make a material change — for example, a new purpose for processing your data, or a new category of recipient — we will post the updated policy on this page, update the date at the top, and, where required by law, provide additional notice or seek your renewed consent before the change takes effect. We encourage you to review this page periodically

Why do we use Cookies?

We use cookies to remember your preferences, provide you with a complete range of functions on our website, and make our website more enjoyable and convenient to use, to deliver relevant content.

What are Cookies?

Cookies are small text files stored on your device to help websites function efficiently and provide a better user experience. This means the website can remember your preferences (such as login, language, font size and other display settings) and actions over a period of time, so you don’t have to enter them again whenever you return to the site or move from one page to another.

We have in place first party cookies, which are placed on your device directly by our website, in this case in the TraffiqX website. But we also make use of third party cookies that are place on your device, not by the website but by a third party (like an analytic systems). We will explain later in this policy who are these third party cookies.

You have control at all times over cookies. In order for us to implement these cookies you have to consent to them when registering in the TraffiqX program.

If you are a California resident, you may opt out of the use of cookies that result in the “sharing” of your personal information under California law. You can do this via our “Do Not Sell or Share My Personal Information” link or by contacting us at privacy@catenamedia.com

In general, you can view our website without cookies, however disabling cookies may affect site functionality.

What categories of cookies we use?

What cookie providers do we use?

We make use of third party cookie providers, and their use is only allowed as per your consent, as obtained in the registration process.Some of these third parties collect data directly from your browser, and their processing is governed by their own privacy policies.Please find below a list of cookie providers we may use. In case you have any questions or you would like to withdraw your consent you can by writing to privacy@catenamedia.com

• Google Analytics, a Web analytics service from Google Inc. (“Google”). Google Analytics uses cookies to identify how frequently certain areas of our website are used and to identify preferences and transmits this information about your use of this website (including your truncated IP address) to a Google server in the United States and stores it there. Google will use this data to analyze your use of the website, create reports on website activity for us, and carry out further services regarding website and Internet usage. Google may also send this information to third parties where required by law or to the extent third parties process these data on behalf of Google.
• Facebook Pixel – Facebook: This Cookie is placed by Facebook. It allows our website to measure, optimize and build audiences for Facebook advertising campaigns by tracking users’ interactions with our site after viewing or clicking on a Facebook ad.
• Customer.io – Customer.io: This Cookie is placed by Customer.io. It allows us to personalize our emails and messages based on how users interact with our website and previous communications.
• app.convertflow.com – ConvertFlow: These Cookies are placed by ConvertFlow. They help us display relevant messages or forms based on your site behavior and remember what you have interacted with.
• Nexus (linkengine.io) – Catena Media: This Cookie is placed by our internal tool LinkEngine.io. It tracks which affiliate links are clicked so we can monitor performance and make sure links are working correctly.
• Double Click – Double Click: Double Click is used for advertisers and to advertise on multiple ad servers.
• Cloudflare – Cloudflare: Cloudflare cookies are used on the website to apply security settings on a per-client basis.

Please note that we may add or remove these cookies, but will inform you via this policy. If you have any question about these cookies please contact us at privacy@catenamedia.com

Which are the rights you have?

You have a number of rights in relation to your personal data.

To exercise your rights, you may contact us at any time by sending an email to privacy@catenamedia.com

Right to access

You can ask us to:

• confirm whether we are processing your personal data;
• give you a copy of that data;
• provide you with other information on your personal data, for example, what data we have, what we use it for, who we disclose it to, whether we transfer it outside the EU and how we protect it, how long we keep it for, what rights you have, how you can make a complaint, where we got your data from, and whether we have carried out any Automated Decision Making or Profiling, to the extent that information has not already been provided to you in this Policy.

We aim to respond to any request within one month of receipt. Where a request is complex or we have received a high number of requests, we may extend this period by a further two months; if so, we will tell you about the extension, and why it is necessary, within the first month.

Right to correct

You can ask us to rectify or correct inaccurate personal data. We may seek to verify the accuracy of the data before rectifying it.

Right to erasure

You can ask us to erase your personal data but only where:

• it is no longer required for the purposes for which it was collected after the retention period had ended; or
• you have withdrawn your consent (where processing was based on consent); or
• following a successful right to object (see ‘Objection’ below); or
• it has been processed unlawfully; or
• to comply with a legal obligation.

We are not required to comply with your request to erase your personal data if the processing of your personal data is necessary:

• for compliance with a legal obligation; or
• for the establishment, exercise or defense of legal claims.

Right to restrict

You can ask us to restrict (i.e., keep but not use) your personal data but only where:

• its accuracy is contested, to allow us to verify its accuracy; or
• the processing is unlawful but you do not want it to be erased; or
• it is no longer required for the purposes for which it was collected but we still need it to establish, exercise or defend legal claims; or
• you have exercised the right to object, and verification of overriding grounds is pending.

Portability

You can ask us to provide your personal data to you in a structured, commonly used, machine-readable format or you can ask to have it ‘ported’ directly to another Data Controller – but in each case, only where:

• the processing is based on your consent or on the performance of a contract with you; and
• the processing is carried out by automated means.

Right to object

You can object to any processing of your personal data which you believe that your fundamental rights and freedoms outweigh our legitimate interests. Except when

• We have an opportunity to demonstrate that we have compelling legitimate interests that override your rights and freedoms.

You can ask to obtain a copy of – or reference to – the safeguards under which your personal data is transferred outside of the European Economic Area.

We may redact data transfer agreements or related documents (i.e., obscure certain information contained within these documents) for commercial sensitivity reasons.

We kindly ask that you attempt to resolve any issues with us first via our complaints procedure as set in the Terms and Conditions of this Program. However, you can also contact us at privacy@catenamedia.com

Right to no discrimination

You cannot be discriminated against for exercising these rights.

For how long do we keep your data?

We will retain your personal data for as long as reasonably necessary for the purposes listed in this Policy.

In some circumstances, we keep your personal data for a certain period of time in order to meet legal, tax or accounting requirements for example. Otherwise, we keep it for as long as we have a contractual obligation with you (e.g., if you are a registered user).

In terms of our marketing and targeting activities, we will collect and process your data until you have withdrawn your consent for collection or until you close your account with the company.

Where your personal data is no longer required, we will ensure that it is either securely deleted or made anonymous.

The right to withdraw your consent

You are in control of your personal information, therefore you have the right to withdraw your consent at any time by contacting us at privacy@catenamedia.com

The right to not to be subject to solely automated decision -making including profiling

Where applicable you have the right not to agree with the profiling where it produces legal effects (like financial or lending, employment, housing or insurance, or healthcare decision) or significantly affects you. In this regard the user will have the right to object and request human intervention, and will be able to challenge such decision. Should you have any questions in this regard, kindly contact us at privacy@catenamedia.com

Data Security

We have implemented technical and organizational measures to protect your personal data, so please rest assured that we are properly handling the security of the data collected. Should you have any questions on this matter kindly contact us at privacy@catenamedia.com

California residents

If you are a resident of California, you have additional rights under the CCPA, as amended by the CPRA. These include:

We do not sell your personal information for monetary consideration. However, we may share your data with advertising or analytics partners for targeted advertising purposes, which may be considered “sharing” under California law.

You may opt out by clicking the “Do Not Sell or Share My Personal Information” link on our website or by contacting us at privacy@catenamedia.com

If we disclose your personal information to third parties for those third parties' own direct marketing purposes, you can request a list of the categories of personal information disclosed and the names of those third parties. To make such a request, contact us at privacy@catenamedia.com

Do Not Sell or Share My Personal Information

Changes to this policy

We may update this policy from time to time, so kindly review it. If material changes take place we will do our best in communicating this to you. We will provide you of information in advance in order for you to take an informed decision, and accept or not the changes, and if you would continue your subscription with us or not.

Contact us

For more information on the Privacy & Cookie Policy or would like to exercise any of your rights kindly contact us at privacy@catenamedia.com