1. Introduction
Welcome to Mtraf Affiliate Network ("we," "our," "us," "Company," or "Mtraf"). We are
committed to protecting your privacy and ensuring the security of your personal
information. This comprehensive Privacy Policy explains how we collect, use, disclose,
transfer, store, and safeguard your information when you visit our website, use our
services, interact with our affiliate network, or engage with any of our digital
properties.
Company Information:
- Company Name: Nutu Affiliate Network SRL
- Registered Address: Suite 101, 1st Floor, Eden Plaza, Eden Island,
Mahe, Seychelles
- Business Registration: Registered under Seychelles law
- Contact Email: [email protected]
- Website: mtraf.io
2. Scope and Application
This Privacy Policy applies to all users, visitors, affiliates, partners, customers, and
any individuals who interact with our services, including but not limited to:
- Website visitors and users
- Affiliate partners and publishers
- Advertisers and merchants
- Business partners and collaborators
- Job applicants and employees
- Service providers and contractors
3. Information We Collect
3.1 Information You Voluntarily Provide
We may collect personal information that you voluntarily provide to us through various
channels, including but not limited to:
- Personal Identification: Name, email address, phone number, postal
address
- Business Information: Company name, business registration details,
tax identification numbers
- Financial Information: Bank account details, payment card
information, transaction history
- Professional Information: Job title, work experience, professional
credentials
- Communication Preferences: Language preferences, marketing opt-ins,
notification settings
- Account Information: Username, password, security questions,
profile information
- Content and Communications: Messages, feedback, reviews, comments,
submissions
3.2 Automatically Collected Information
We automatically collect certain information when you visit our website, use our
services, or interact with our digital properties:
- Device Information: IP address, device type, operating system,
browser type and version
- Usage Data: Pages visited, time spent, click patterns, navigation
paths
- Technical Data: Server logs, error reports, performance metrics,
system information
- Location Data: General geographic location (country, city, time
zone)
- Network Information: Internet service provider, connection type,
bandwidth
- Referral Information: Source website, search terms, campaign
identifiers
3.3 Information from Third Parties
We may receive information about you from various third-party sources, including but not
limited to:
- Business Partners: Advertisers, merchants, affiliate networks,
marketing partners
- Service Providers: Payment processors, analytics providers, hosting
services
- Social Media Platforms: Facebook, Twitter, LinkedIn, Instagram, and
other social networks
- Public Sources: Public records, business directories, social media
profiles
- Data Brokers: Legitimate data providers and aggregators
- Government Sources: Public registries, regulatory databases
3.4 Special Categories of Information
In certain circumstances, we may collect sensitive information, including:
- Financial Data: Income information, credit history, payment
behavior
- Behavioral Data: Online activity, preferences, interests, browsing
patterns
- Technical Data: Device fingerprints, cookie data, tracking pixels
- Marketing Data: Campaign responses, conversion data, engagement
metrics
4. How We Use Your Information
We use the collected information for various purposes, which may include but are not
limited to:
4.1 Service Provision and Operations
- Processing affiliate applications, registrations, and account management
- Managing affiliate relationships, commissions, and performance tracking
- Providing customer support, technical assistance, and account services
- Processing payments, transactions, and financial operations
- Maintaining account security, fraud prevention, and risk management
- Delivering personalized content, recommendations, and experiences
- Optimizing website performance, functionality, and user experience
4.2 Business Development and Analytics
- Analyzing website performance, user behavior, and market trends
- Conducting market research, competitive analysis, and business intelligence
- Developing new products, services, and features
- Improving existing services, processes, and systems
- Identifying business opportunities and growth strategies
- Measuring campaign effectiveness and return on investment
4.3 Marketing and Communications
- Sending promotional materials, newsletters, and marketing communications
- Providing updates about our services, features, and company news
- Conducting targeted advertising and marketing campaigns
- Personalizing content, advertisements, and user experiences
- Managing email lists, subscription preferences, and communication channels
- Running contests, surveys, and promotional activities
4.4 Legal and Compliance
- Complying with applicable laws, regulations, and legal obligations
- Responding to legal requests, subpoenas, and court orders
- Protecting against fraud, abuse, and security threats
- Enforcing our terms of service, policies, and agreements
- Resolving disputes, claims, and legal proceedings
- Maintaining records for regulatory and audit purposes
4.5 Research and Development
- Conducting research studies and data analysis
- Developing algorithms, models, and predictive analytics
- Testing new technologies, features, and methodologies
- Improving artificial intelligence and machine learning systems
- Creating industry reports, whitepapers, and thought leadership content
5. Information Sharing and Disclosure
We may share your information with various parties as described below, always in
accordance with this Privacy Policy and applicable laws:
5.1 Service Providers and Vendors
We share information with trusted third-party service providers who assist us in various
business operations:
- Technology Providers: Website hosting, cloud services, software
platforms
- Payment Processors: Credit card processors, banking services,
financial institutions
- Marketing Services: Email marketing, advertising platforms,
analytics tools
- Customer Support: Help desk systems, communication platforms,
support tools
- Security Services: Fraud detection, threat prevention, security
monitoring
- Data Storage: Cloud storage, backup services, data centers
5.2 Business Partners and Networks
We may share information with our business partners and network participants:
- Advertisers and Merchants: For campaign management and performance
tracking
- Affiliate Networks: For cross-network collaboration and
optimization
- Marketing Partners: For joint campaigns and promotional activities
- Technology Partners: For integration and platform development
- Strategic Partners: For business development and market expansion
5.3 Legal and Regulatory Requirements
We may disclose your information when required or permitted by law:
- Government Authorities: Law enforcement, regulatory bodies, tax
authorities
- Legal Proceedings: Court orders, subpoenas, legal discovery
- Regulatory Compliance: Industry regulations, licensing requirements
- Public Safety: Emergency situations, threat prevention, public
health
- Intellectual Property: Copyright protection, trademark enforcement
5.4 Business Transfers and Corporate Events
In the event of business changes, your information may be transferred:
- Mergers and Acquisitions: Company sales, mergers, or acquisitions
- Asset Sales: Sale of business units, divisions, or assets
- Bankruptcy: Insolvency proceedings or business restructuring
- Corporate Reorganization: Internal restructuring or reorganization
5.5 Aggregated and Anonymized Data
We may share aggregated, anonymized, or de-identified information that cannot reasonably
be used to identify you for:
- Research Purposes: Industry studies, market analysis, academic
research
- Business Intelligence: Performance metrics, trend analysis,
benchmarking
- Public Reporting: Company statistics, industry insights, public
disclosures
6. Cookies and Tracking Technologies
6.1 Types of Cookies and Tracking
We use various types of cookies and tracking technologies to enhance your experience:
- Essential Cookies:
- Session management and authentication
- Security and fraud prevention
- Basic website functionality
- Shopping cart and checkout processes
- Analytics Cookies:
- Website usage analysis and statistics
- Performance monitoring and optimization
- User behavior tracking and insights
- Conversion rate analysis
- Marketing and Advertising Cookies:
- Targeted advertising and retargeting
- Campaign performance measurement
- Cross-site tracking and attribution
- Personalized content delivery
- Social Media Cookies:
- Social media integration and sharing
- Social login and authentication
- Social media advertising
- Community features and engagement
- Third-Party Cookies:
- Google Analytics and similar tools
- Advertising networks and platforms
- Social media platforms
- Payment processors and security services
6.2 Cookie Management and Control
You have several options for managing cookies and tracking:
- Browser Settings:
- Enable or disable cookies through browser preferences
- Delete existing cookies and browsing data
- Set cookie preferences for different websites
- Use private or incognito browsing modes
- Third-Party Opt-Outs:
- Digital Advertising Alliance (DAA) opt-out
- Network Advertising Initiative (NAI) opt-out
- Google Analytics opt-out browser add-on
- Social media platform privacy settings
- Company Controls:
- Cookie consent management tools
- Preference centers and settings
- Marketing opt-out mechanisms
- Account privacy controls
7. Data Security and Protection
7.1 Security Measures
We implement comprehensive security measures to protect your information:
- Technical Safeguards:
- Encryption of data in transit and at rest
- Secure socket layer (SSL) and transport layer security (TLS)
- Firewalls, intrusion detection, and prevention systems
- Regular security audits and vulnerability assessments
- Multi-factor authentication and access controls
- Data backup and disaster recovery systems
- Organizational Safeguards:
- Employee training and security awareness programs
- Access controls and role-based permissions
- Incident response and breach notification procedures
- Vendor security assessments and monitoring
- Regular security policy reviews and updates
- Compliance monitoring and reporting
- Physical Safeguards:
- Secure data center facilities
- Environmental controls and monitoring
- Physical access controls and surveillance
- Equipment security and maintenance
- Document and media destruction procedures
7.2 Data Breach Response
In the event of a data breach or security incident:
- Immediate incident assessment and containment
- Notification to affected individuals and authorities
- Investigation and root cause analysis
- Remediation and security improvements
- Legal and regulatory compliance
- Communication and transparency
8. Data Retention and Storage
8.1 Retention Periods
We retain your information for various periods depending on the type and purpose:
- Active Accounts: For the duration of your account plus additional
periods for legal and business purposes
- Inactive Accounts: For a reasonable period after account
deactivation
- Transaction Data: For periods required by law and business needs
- Marketing Data: Until you opt out or request deletion
- Legal Records: For periods required by applicable laws and
regulations
- Analytics Data: For business analysis and improvement purposes
8.2 Storage Locations
Your information may be stored and processed in various locations:
- Primary Storage: Seychelles and European Union
- Backup Storage: Multiple secure locations worldwide
- Cloud Services: Various cloud providers and data centers
- Service Providers: Third-party storage and processing facilities
8.3 Data Deletion and Destruction
When information is no longer needed:
- Secure deletion from active systems
- Removal from backup and archive systems
- Physical destruction of media and documents
- Verification of complete data removal
- Documentation of deletion processes
9. International Data Transfers
9.1 Cross-Border Transfers
Your information may be transferred to and processed in countries other than your own:
- European Union: Adequacy decisions and standard contractual clauses
- United States: Privacy Shield framework and contractual safeguards
- Other Countries: Appropriate safeguards and legal mechanisms
- Cloud Services: Global data center networks and CDN services
9.2 Transfer Safeguards
We ensure appropriate safeguards for international transfers:
- Legal Frameworks: GDPR, CCPA, and other applicable laws
- Contractual Clauses: Standard contractual clauses and data
processing agreements
- Certification Programs: Privacy Shield, ISO 27001, and other
certifications
- Technical Measures: Encryption, access controls, and security
protocols
10. Your Rights and Choices
Depending on your location and applicable laws, you may have various rights regarding
your personal information:
10.1 Access and Portability
- Right to Access: Request information about what data we hold about
you
- Right to Portability: Receive your data in a structured,
machine-readable format
- Right to Know: Understand how your data is collected, used, and
shared
- Right to Verification: Confirm the accuracy and completeness of
your data
10.2 Correction and Update
- Right to Rectification: Request correction of inaccurate or
incomplete information
- Right to Update: Modify your personal information and preferences
- Right to Supplement: Add missing information to your profile
- Right to Verification: Confirm that corrections have been made
10.3 Deletion and Erasure
- Right to Deletion: Request removal of your personal information
- Right to Erasure: Complete removal from all systems and backups
- Right to Anonymization: Convert personal data to anonymous form
- Right to Confirmation: Verify that deletion has been completed
10.4 Objection and Restriction
- Right to Object: Object to certain processing activities
- Right to Restriction: Limit how your data is processed
- Right to Withdraw Consent: Revoke previously given consent
- Right to Opt-Out: Decline certain data collection and use
10.5 Marketing and Communications
- Marketing Opt-Out: Unsubscribe from marketing communications
- Communication Preferences: Choose how and when we contact you
- Channel Preferences: Select preferred communication methods
- Frequency Controls: Manage the frequency of communications
10.6 Automated Decision Making
- Right to Human Review: Request human review of automated decisions
- Right to Explanation: Understand how automated decisions are made
- Right to Appeal: Challenge automated decision outcomes
- Right to Alternative Processing: Request non-automated alternatives
11. Children's Privacy and Protection
11.1 Age Restrictions
Our services are not intended for children under the age of 16:
- Minimum Age: We do not knowingly collect data from children under
16
- Age Verification: We may implement age verification measures
- Parental Consent: We may require parental consent for users under
18
- Educational Content: We may provide educational resources about
online safety
11.2 Protection Measures
We implement various measures to protect children's privacy:
- Content Filtering: Age-appropriate content and advertising
- Parental Controls: Tools for parents to manage children's accounts
- Educational Resources: Information about online safety and privacy
- Reporting Mechanisms: Ways to report inappropriate content or
behavior
12. Third-Party Services and Links
12.1 Third-Party Services
Our website and services may integrate with third-party services:
- Social Media: Facebook, Twitter, LinkedIn, Instagram, and others
- Payment Processors: Stripe, PayPal, and other payment services
- Analytics Tools: Google Analytics, Facebook Pixel, and similar
services
- Advertising Networks: Google Ads, Facebook Ads, and other ad
platforms
12.2 External Links
Our website may contain links to external websites:
- Partner Websites: Affiliate and business partner sites
- Resource Links: Educational and informational resources
- Social Media: Links to our social media profiles
- Third-Party Services: Links to integrated services and tools
12.3 Third-Party Privacy
We are not responsible for the privacy practices of third-party services:
- Independent Policies: Each third party has its own privacy policy
- User Responsibility: Users should review third-party privacy
practices
- Limited Control: We have limited control over third-party data
practices
- Recommendation: We recommend reviewing all third-party privacy
policies
13. Changes and Updates to This Privacy Policy
13.1 Policy Updates
This Privacy Policy may be updated from time to time to reflect:
- Legal Changes: New laws, regulations, or legal requirements
- Business Changes: New services, features, or business practices
- Technology Changes: New technologies, platforms, or tools
- User Feedback: User requests, concerns, or suggestions
- Industry Standards: Best practices and industry developments
13.2 Notification Methods
We will notify you of material changes through various methods:
- Website Updates: Posting updated policy on our website
- Email Notifications: Sending emails to registered users
- Account Notifications: In-app or account-based notifications
- Public Announcements: Press releases or public statements
- Social Media: Updates through our social media channels
13.3 Effective Date
Changes to this policy will be effective:
- Immediate Effect: For new users and new data collection
- Notice Period: With advance notice for existing users
- Grace Period: Reasonable time for users to review and respond
- Retroactive Application: May apply to previously collected data
13.4 Continued Use
Your continued use of our services after policy changes constitutes:
- Acceptance: Agreement to the updated privacy policy
- Consent: Consent to new data practices and procedures
- Acknowledgment: Understanding of your rights and choices
- Compliance: Agreement to comply with updated terms
14. Contact Information and Support
14.1 Primary Contact
For privacy-related questions, concerns, or requests:
- Email: [email protected]
- Address: Mtraf Affiliate Network SRL, Suite 101, 1st Floor, Eden
Plaza, Eden Island, Mahe, Seychelles
- Response Time: We aim to respond within 30 days of receiving your
request
14.2 Additional Support
For general inquiries and support:
- Customer Support: [Support email/phone]
- Technical Support: [Technical support contact]
- Business Inquiries: [Business development contact]
- Legal Inquiries: [Legal department contact]
14.3 Regulatory Authorities
You may also contact relevant data protection authorities:
- Seychelles: National Center for Personal Data Protection
- European Union: Your local data protection authority
- United States: Federal Trade Commission or state attorneys general
- Other Jurisdictions: Local privacy and data protection regulators
15. Governing Law and Dispute Resolution
15.1 Applicable Law
This Privacy Policy is governed by:
- Primary Law: Laws of Seychelles
- Secondary Law: European Union data protection laws (where
applicable)
- International Law: Applicable international privacy frameworks
- Industry Standards: Relevant industry best practices and guidelines
15.2 Dispute Resolution
Any disputes arising from this Privacy Policy will be resolved through:
- Primary Method: Negotiation and good faith discussions
- Secondary Method: Mediation or alternative dispute resolution
- Final Method: Legal proceedings in Seychelles courts
- Arbitration: Binding arbitration if mutually agreed upon
15.3 Jurisdiction
Legal proceedings will be subject to:
- Primary Jurisdiction: Courts of Seychelles
- Alternative Jurisdiction: As required by applicable law
- International Jurisdiction: Where international law applies
- Forum Selection: As specified in our terms of service
16. Additional Provisions
16.1 Severability
If any provision of this Privacy Policy is found to be invalid or unenforceable:
- Remaining Provisions: Other provisions remain in full force and
effect
- Reformation: Invalid provisions may be reformed to the extent
possible
- Enforcement: Valid portions will be enforced to the maximum extent
- Interpretation: Provisions will be interpreted to maintain validity
16.2 Entire Agreement
This Privacy Policy constitutes:
- Complete Agreement: The entire agreement regarding privacy
practices
- Supersession: Supersedes all prior privacy policies and agreements
- Integration: Integrated with our terms of service and other
policies
- Amendment: May only be amended in writing by authorized
representatives
16.3 Waiver
No waiver of any provision of this Privacy Policy:
- Effectiveness: Will be effective unless in writing
- Scope: Will apply only to the specific provision waived
- Duration: Will continue in effect unless revoked in writing
- Precedent: Will not create a precedent for future waivers
Last Updated: January 1, 2024
Version: 2.0
