Privacy and Cookie Policy

TrafficStars Network Ltd (TSN Ltd)
Last Updated: April 2026

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1. Introduction

This Privacy and Cookie Policy explains how TrafficStars Network Ltd (“TSN”, “we”, “us”, “our”) collects, uses, and protects personal data when you interact with our websites, platforms, and services.

This Policy is issued in accordance with:

• UK GDPR
• Data Protection Act 2018
• Data Use and Access Act 2025
• Privacy and Electronic Communications Regulations 2003

By using our website or services, you acknowledge this Policy.

2. Data Controller and Role Clarification

TrafficStars Network Ltd (ICO Registration: ZB013860) acts as a data controller only in respect of personal data processed through its own websites, platforms, and direct services.

Important – Advertising and Third-Party Marketing

TSN operates a digital advertising and affiliate platform.

• We do not send unsolicited marketing emails
• We do not control third-party marketing lists or databases
• Advertisers, affiliates, and marketing partners using our platform act as independent data controllers in respect of their own marketing activities

Where you receive marketing communications from third parties that link to our platform:

• The sender of the communication is the data controller for that activity
• TSN does not have access to or visibility of the personal data used to send such communications
• TSN only processes personal data if and when you directly engage with our services

3. Contact Details

TrafficStars Network Ltd
27 Old Gloucester Street
London, WC1N 3AX

Email: help@tsnsupport.com

You have the right to lodge a complaint with the UK supervisory authority, the Information Commissioner’s Office (ICO). We encourage you to contact us first so we can resolve any concerns.

4. What Personal Data We Collect

We may collect and process the following categories of personal data:

• Identity Data: name, username, title, date of birth
• Contact Data: email address, postal address, telephone number
• Financial Data: payment details (where applicable)
• Transaction Data: purchases, subscriptions, service usage
• Technical Data: IP address, browser type, device information
• Usage Data: interaction with our website or services
• Profile Data: preferences, feedback, survey responses
• Marketing Data: communication preferences

Sensitive Data

We do not intentionally collect special category data as defined under UK GDPR Article 9.

5. How We Collect Your Data

We collect data through:

a. Direct Interactions

When you:

• Register for services
• Enter competitions or promotions
• Contact us directly

b. Automated Technologies

Including:

• Cookies
• Server logs
• Analytics tools

c. Third Parties

We may receive data from:

• Payment providers
• Service providers
• Advertising partners (limited to aggregated or non-identifiable data unless you engage directly)

6. How We Use Your Personal Data

We process personal data only where lawful under UK GDPR Article 6.

Lawful Bases

• Contractual necessity – to provide services
• Legitimate interests – to operate and improve our platform
• Legal obligation – regulatory compliance
• Consent – where required (e.g. cookies, direct marketing)

7. Advertising and Platform Functionality

TSN provides infrastructure enabling third parties to promote offers, services, and advertising content.

In this context:

• TSN may process technical routing data (e.g. IP address, click data)
• Such processing is typically transient and limited
• TSN does not receive marketing lists or personal datasets from advertisers unless a user directly engages

We do not:

• Build profiles of individuals from third-party email campaigns
• Determine targeting criteria used by advertisers
• Control how third parties collect or use personal data

8. Marketing Communications

We will only send marketing communications where:

• You have opted in; or
• You are an existing customer and soft opt-in applies under PECR

You can opt out at any time.

9. Data Sharing

We may share data with:

• IT and hosting providers
• Payment processors
• Professional advisers
• Regulators and authorities

All third parties are required to comply with applicable data protection laws.

10. International Transfers

Where data is transferred outside the UK:

We rely on:

• UK adequacy regulations
• International Data Transfer Agreements (IDTA)
• Standard Contractual Clauses (SCCs)

We no longer rely on the EU-US Privacy Shield framework.

11. Data Security

We implement appropriate technical and organisational measures in accordance with UK GDPR Article 32, including:

• Access controls
• Encryption where appropriate
• Monitoring and breach response procedures

12. Data Retention

We retain personal data only as long as necessary.

Typical retention periods include:

• Customer data: up to 6 years (legal/tax requirements)
• Marketing data: until withdrawal of consent
• Technical data: short-term operational retention

We may retain minimal data to maintain suppression lists where required.

13. Your Legal Rights

You have rights under UK GDPR including:

• Access (Article 15)
• Rectification (Article 16)
• Erasure (Article 17)
• Restriction (Article 18)
• Objection (Article 21)
• Data portability (Article 20)

We may request identity verification under Article 12(6).

14. Third-Party Links

Our website may contain links to third-party sites. We are not responsible for their privacy practices.

COOKIE POLICY

15. What Are Cookies

Cookies are small text files placed on your device to improve website functionality and user experience.

16. Types of Cookies We Use

Strictly Necessary Cookies
Required for website operation.

Analytics Cookies
Help us understand usage patterns.

Functionality Cookies
Remember user preferences.

Targeting/Advertising Cookies
Used to deliver relevant advertising.

17. Legal Basis for Cookies

We use cookies in accordance with PECR:

• Strictly necessary cookies – no consent required
• All other cookies – require user consent

Consent is obtained via our cookie banner and can be withdrawn at any time.

18. Third-Party Cookies

Third parties (e.g. analytics providers, advertising networks) may set cookies.

We do not control these cookies.

19. Managing Cookies

You can manage cookies via:

• Browser settings
• Cookie consent banner

20. Changes to This Policy

We may update this Policy periodically. The latest version will always be available on our website.

21. Contact

For all data protection enquiries:

Email: help@tsnsupport.com