Legal documents

Privacy policy and GDPR

Your privacy is important to us. This Consent to Personal Data Processing (hereinafter "the Consent") is meant to help you understand what data we collect, why we collect it, and how we process it when you visit our website https://trafficmanager.com (the "Website") or use our services (the «Services», the "Software" or the "Tracking Platform").

Please take your time to read this document (policy). Your Consent to Personal Data processing is necessary to work with the TrafficManager Tracking Platform.

Traffic Manager Group S.R.L ("TrafficManager", "us", or "we") acts as a controller of your personal data. Traffic Manager Group S.R.L is a corporation registered in Romania (E.U), VIES registration number RO43058081 and is located at the address Ionel Teodoreanu 1, Brasov, Romania. Contact email: [email protected].

TrafficManager processes and stores personal data on secure infrastructure hosted by OVH cloud services, located within the European Union.

By accessing our Website or using our Services, you become subject to this Policy. Your acceptance of the terms of this Policy, in their entirety, shall be effective to you and your employees, if any.

TrafficManager offers a SaaS affiliate tracking platform also known as performance marketing software through his website https://www.trafficmanager.com. Our tracking platform can be used to track, manage and optimize online marketing campaigns or to build affiliate networks for digital or physical products. When used by clients in the iGaming, betting, or online casino sectors, TrafficManager acts solely as a neutral technical service provider for attribution and performance analytics. TrafficManager does not participate in gaming operations, user onboarding, or age-verification processes, which remain the exclusive responsibility of the Client as the Data Controller. Our software allows its clients/consumers/advertisers to upload, download, track, analyze and process data to and from the platform in order to review and optimize results of their marketing campaigns.

The data we process on the clients/consumers/advertiser's behalf relates to their partners with which the clients/consumers/advertisers do business and the end-users who use or interact with the clients/consumers/advertiser's websites, products, services, advertisements campaigns and/or mobile application services. In relation to processing of such personal data, TrafficManager is a data processor. This processing of this data in the free trial period of our tracking platform and the subsequent use of the tracking platform, if the clients/consumers/advertisers choose to continue access and use of the tracking platform, is governed by the data processing agreement executed between TrafficManager and the client/customer/advertiser.

Cash-on-Delivery (COD) Order and Tracking Data. When TrafficManager is used in connection with Cash-on-Delivery (COD) campaigns, the platform may process personal data strictly on behalf of its clients for tracking, attribution, and operational analysis purposes. Depending on the client's integration and configuration, processed data may include customer name, shipping address, phone number, and email address (where available), order identifiers, product information, order value, payment type (COD), delivery status, returns, failed deliveries or cancellations, as well as technical and tracking identifiers such as IP address, device information, timestamps, click IDs, affiliate IDs, and campaign IDs. In these cases, the client acts as the data controller and TrafficManager acts as a data processor in accordance with the Data Processing Agreement.

1. WHAT INFORMATION WE COLLECT AND HOW WE USE IT

"Personal Data" is any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly. We collect the following Personal Data about you:

1.1 INFORMATION WE USE TO PROVIDE SERVICES

Your Contact and Billing Information. When you register or sign up for the TrafficManager Services, we may collect certain contact information from you, such as your first and last name, organization/company name, company number, banking or other payment information, city, state and zip code, country, email address, and phone number or other similar contact details to process your registration request, to contact you regarding it and for finance purposes (invoicing).

We will us this information to provide you access to the Services you have ordered but also for customer support services, technical updates or updates on changes in our usage policies.

IN ADDITION TO THE ABOVE, I CONFIRM THAT FOR THE TIME OF THIS CONSENT I AM ACQUAINTED WITH THE FOLLOWING INFORMATION:

Legal basis for the Personal Data processing: General Data Protection Regulation of April 27, 2016 (GDPR);

Service Usage Information. In order to improve and provide you a better experience using our tracking platform, we may collect information in connection with your use of our Services, including order information, chat logs, email logs, support ticket logs and information about your actions in various client areas on the Website. We may use any information collected from you to improve our user experience and services, especially the customer service and support services, diagnose possible problems or to send you promotions, surveys, periodic emails regarding your order/ registration or system configuration, use of Services or other similar services you might be interested in.

Fraud Prevention and Risk Scoring. TrafficManager may provide fraud prevention and risk-scoring features designed to assist clients in identifying potentially fraudulent or high-risk orders. Fraud scores are generated based on technical and historical indicators, such as patterns associated with IP's, phone numbers, delivery outcomes, or previous order behavior. These scores are provided for advisory and security purposes only.

TrafficManager does not automatically approve, reject, or block orders. Clients may optionally configure automated rules or filters in their own workflows based on fraud scores (for example, applying additional verification steps or redirecting certain orders to alternative payment methods such as credit card instead of cash on delivery). Clients retain full control and responsibility over any decisions taken based on fraud scores.

As these scores are advisory, data subjects retain the right to request human intervention from the Client regarding any decision that significantly affects them. TrafficManager does not perform automated profiling with legal effects.

The legal basis for TrafficManager to use your Contact and Billing Information and the Service Usage Information is the agreements you enter into with us in connection with the Services (the "Services Terms" "TOS" "Terms of Sevice") and performance of these agreements as well as taking steps at your request prior to entering into them.

Third Party. In case of missing information about you or your company we may obtain this information from third party or public sources and add them in your account profile in the contact information section. We may need and use this combined information to provide you our Services and to be sure that we will be paid for the Services provided.

Advertising Platforms and Third-Party Ad Accounts. TrafficManager allows clients and, where applicable, their affiliates to connect third-party advertising platform accounts (including but not limited to Meta Ads, Google Ads, and TikTok Ads) to the TrafficManager platform for the purpose of campaign tracking, attribution, and performance measurement. Such connections are initiated and controlled exclusively by the respective client or affiliate. TrafficManager does not access or control advertising accounts beyond the technical data required to enable tracking, attribution, or reporting as configured by the user.

Data Minimization and S2S Security. In providing API and Server-to-Server (S2S) postback integrations, TrafficManager processes only the minimum data required for accurate attribution and campaign optimization. Where supported by the underlying advertising platform or integration method (e.g., Meta Conversions API), personal identifiers are hashed using industry-standard protocols (such as SHA-256) before transmission to ensure a high level of security and data protection.

Each advertising platform acts as an independent data controller with respect to personal data processed within its own systems. Clients and affiliates are responsible for ensuring that their use of advertising platforms, including the collection of consent and provision of privacy notices, complies with applicable data protection laws and the policies of those platforms.

1.2 USE OF INFORMATION FOR MARKETING PURPOSE

Your Personal Data such as full name, contact email address, country, phone, etc. may be used by Us to send you updates about our Services or marketing offers, even if you are not an active client/customer but you indicated an interest to the TrafficManager services thru our website contact/registration/request form. If you don't want to receive such communications from us please contact us (we will respond your request in a reasonable time period) or press the unsubscribe button you will find at the end of our messages (in case of email messages). Please remember that even if you unsubscribe and you are an active customer/client of our service we will still send you non-marketing communications regarding your account or our ongoing business relations.

1.3 COOKIES AND BROWSING INFORMATION

To facilitate users' navigation on our website, TrafficManager uses cookies and other storage methods with similar functionality (hereinafter "Cookies").

Cookies are small pieces of information that are saved onto the device from which the Service is accessed and which allow TrafficManager to provide certain services such as the ability to recall certain aspects of your most recent content search so that subsequent searches will be faster. Cookies can be removed from your device if you so desire. Most browsers will automatically accept Cookies. However, you can change the settings of your device to prevent Cookies being saved or to remove Cookies which may already be present on your device. Most of the services of our Website can be used without Cookies.

TrafficManager uses its own Cookies and Third party Cookies as follows:

1. Cookies which are strictly necessary to provide a service expressly requested by the user: Specifically, TrafficManager uses the necessary cookies to save a User's login.

2. Session Cookies: These Cookies are saved and valid for a fixed period of time only, that is, until the user quits navigating or using the Service. These Cookies do not permanently save any information onto your device.

3. Navigation Cookies: The primary objective of these Cookies is to avoid offering you recommendations which are unrelated to your areas of interest, as well as to provide you with targeted and personalized commercial offers. Navigation Cookies function by temporarily tracking your Internet navigation. You can remove this type of cookie before starting a navigation session in the Service

Statistical Cookies or Analysis Cookies: These Cookies provide the following information:

1. The dates and times of your visits to the Service

2. Your access to content during your visits to the Service
   
   These Cookies are designed to personalize the Service, improve the user experience, create separate profiles of user activity on the websites, and generate statistics on user activity within the Platform. This allows us to focus our efforts on improving the area's most frequently visited by users as well as help users find what they need more quickly.
   
   TrafficManager may use the information regarding your visit to perform assessments and generate statistics using anonymized data, as well as to ensure uninterrupted service or to make improvements to the Service. This information will not be used for any other purposes whatsoever. All of these purposes are deemed to be non-intrusive of Users' personal and private lives.

3. Cookies from social networks, search engines and other 3rd party tracking technologies: Specifically, Google Analytics, Google AdWords, Baidu, Bing, Yahoo, Twitter and Facebook social plugins or Linkedin button which control interaction with the widgets from these external social networks.
   
   Through the use of Google Analytics, Yahoo, Bing and other 3rd Party tracking technologies we monitor, analyze and improve our Website Search Engine presence (SERP positions). We also use Bing, Yahoo, Baidu, Google Adwords and other similar AD networks for advertising purpose to drive traffic to our website, raise brand awareness, and increase our online sales as a part of our marketing plan.
   
   Through the use of Social Plugins, the Platform interacts with the Twitter, Facebook and Pinterest networks to allow you to share content you find interesting with your social circles. Furthermore, the use of Social Plugins saves you from having to provide the Platform with your personal login information to fetch information already shared within the scope of said social networks. Third party cookies for behavioral marketing/retargeting: these cookies are used by trusted third companies to target registered or unregistered Users who previously have interacted with or visited the Service through any electronic means.

Third party cookies do not obtain any information regarding users' names or the address from where they connect. The information recorded includes for example the users' IP from which they have access, the number of page visits, the language, the city where the user's IP address is assigned, the number of users that visit us, and the frequency or repetition of their visits, which page you are visiting on our website. This enables TrafficManager to advertise its latest offers through the different Affiliate websites, to monitor the advertising campaign, and to show advertisements that are adapted to users' preferences.

You can configure your browser to accept or reject all Cookies by default, or to receive an on-screen notification each time a Cookie request is made at which point you can decide whether or not to allow said cookie to be saved onto your hard drive. To this end, we recommend that you consult the help section of your browser for information on how to change the settings that you currently use or use browsers in "incognito" mode. Should you decide to reject all Cookies, you will continue to be able to navigate the Platform but your access to certain sections may be limited. For more information regarding how to manage cookies, we recommend you visit http://www.aboutcookies.org

Deletion or Return of Data. Upon termination of the Services, the Processor shall, at the choice of the Controller, delete or return all personal data to the Controller and delete existing copies unless applicable European Union or Member State law requires storage of the personal data.

2. THIRD PARTIES, TO WHOM THE CONTROLLER AND/OR THE PROCESSOR MAY TRANSFER THE CLIENT PERSONAL DATA FOR PROCESSING FOR THE PURPOSES AND IN THE WAYS INDICATED IN THIS CONSENT:

2.1. CENTERS FOR PERSONAL DATA PROCESSING AND STORING (DATA PROCESSING CENTERS, DATA CENTERS):

1. Provided Personal Data: All Personal Data listed in this Consent;

2. Personal Data provision purpose: Client/Customer Personal Data safe storage;

Sub-processors. The Controller provides a general authorization for the Processor to engage sub-processors. The Processor shall inform the Controller of any intended changes concerning the addition or replacement of sub-processors, thereby giving the Controller the opportunity to object to such changes.

List of data processing centers:

OVH - 2 rue kellermann BP 80157 59053 ROUBAIX CEDEX 1 - France

2.2. STATE AUTHORITIES AUTHORIZED TO RECEIVE PERSONAL DATA; AUDITORS, CONSULTANTS, ACCOUNTANTS, NOTARIES, LAWYERS (IF NECESSARY):

1. Provided Personal Data: All Personal Data listed in this Consent;

2. Personal Data provision purpose: The Controller provides the Client Personal Data solely in case of the disclosure requirement to authorized official authorities or persons in accordance with the applicable law, order, decree, court decision and in the minimum necessary extent.

2.3. OUR EMPLOYEES WHO ARE IN CONTACT WITH THE CLIENT OR WHO ARE RESPONSIBLE FOR MARKETING, CUSTOMER SUPPORT, IT DEPARTMENT WHO ARE RESPONSIBLE FOR PROVIDING SUPPORT TO OUR CLIENT, ANALYZING AND IMPROVING OUR WEBSITE AND SERVICES.

2.4. AFFILIATED COMPANIES, 3RD PARTY SUPPLIERS/VENDORS SUCH AS DATA STORAGE SERVICES, WEBSITE HOSTING SERVICES, DATABASE MAINTENANCE SERVICES, PAYMENT PROCESSING PROVIDERS, LEGAL CONSULTANTS OR DEBT COLLECTION COMPANIES.

Personal data security ensuring means: specified in the "Policy of processing and safety of personal data" approved by the Controller. The Policy will be available on Privacy policy starting from May 25th, 2018.

Validity period of the consent:

1. If the Client/Customer is a citizen or a company registered in a European Union country or has been verified to work with citizens or companies registered in the European Union countries, this Consent is valid for the minimum required period of the Client/Customer Personal Data processing, namely within 5 (five) years from the date of the termination of interaction between the Client/Customer and TrafficManager. The Personal Data storage period may be extended from 5 (five) to 7 (seven) years from the date of the termination of interaction between the Client/Customer and Trafficmanager;

2. If the Client/Consumer/Advertiser is not a citizen or a company registered in a European Union country, Personal Data is retained for the duration of the contractual relationship and thereafter only for a limited period necessary to (i) comply with applicable laws, (ii) resolve disputes, (iii) enforce agreements, and (iv) maintain backup and system integrity. Unless otherwise required by law or agreed in writing, operational tracking data is retained for a maximum of five (5) years. Backup copies may be retained for a limited additional period not exceeding ninety (90) days before permanent deletion.

Special rules for Client/Customers that are citizens of European Union countries or have been verified to work with citizens of the European Union countries:

1. Consent withdrawal: If the Client/Customer is a citizen or a company registered in a European Union country or has been verified to work with citizens or companies registered in the European Union countries, the Controller is obliged to comply with the GDPR Directive on the specified above minimum period for such Client/Customer Personal Data storage. The Personal data Subject understands, agrees and confirms that the right to withdraw this Consent cannot be applied prior to the mandatory Personal Data storage period expiration in accordance with the provisions of the GDPR Directive;
   
   If the Client/Customer is a citizen or a company registered in a European Union country or has been verified to work with citizens or companies registered in the European Union countries has not withdrawn this Consent after five (5) years following to the termination of interaction between the Client/Customer and TrafficManager. in the Client/Customer Agreement framework, the Controller, provided that the competent authority does not require the extension of the Personal Data processing to 7 (seven) years period, at the end of this five-year period erases the personal data by irrevocable destruction, and also informs all third parties to whom the Controller and/or Processors transferred the Client/Customer Personal Data regarding such erasure, and demands the implementation of similar actions on their part.

2. Client/Customer that is a citizen or a company registered in a European Union country or has been verified to work with citizens or companies registered in the European Union countries is also notified that at any time of the Consent validity period he has the right to:

   1. Access the Personal Data, i.e. has the right to request and obtain from the Controller a confirmation as to whether or not personal data are being processed / access to Personal Data and the following information: the purposes of the processing; the categories of personal data concerned, all possible recipients of the Personal Data, where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;

   2. Obtain from the Controller without undue delay the rectification of inaccurate Personal Data, the completion of Client/Customer's incomplete Personal Data, as well as require the receipt of notifications from the Controller regarding any corrections, additions, erasures or limitations to the Personal Data processing;

   3. Erasure of the Personal Data ("right to be forgotten") if: personal data no longer necessary in relation to the purposes for which they were collected or otherwise processed; the Personal data Subject withdraws the Consent, and there is no other legal ground for the processing; the Personal data Subject objects to the Personal Data processing and there are no overriding legitimate grounds for the processing; Personal Data has been unlawfully processed; Personal Data has to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject; Personal Data has been collected in relation to the offer of information society services to a child (taking into account the provisions of Article 8 (1) of GDPR);

   4. Obtain restriction of Personal data processing if: the accuracy of the personal data is contested by the Client/Customer, for a period enabling the Controller to verify the accuracy of the personal data; the processing is unlawful and the Client/Customer opposes the erasure of the personal data and requests the restriction of their use instead; the Controller no longer needs the personal data for the purposes of the processing, but they are required by the Client/Customer for the establishment, exercise or defense of legal claims; the Client/Customer has objected to processing pending the verification whether the legitimate grounds of the Controller override those of the Client/Customer;

   5. Personal Data portability, i.e. to receive the Personal Data, which Client/Customer has provided to the Controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller;

   6. Object to Personal Data processing, and as result the Controller shall no longer process the personal data unless the Controller demonstrates compelling legitimate grounds for the Personal Data processing which override the interests, rights and freedoms of the Client/Customer or for the establishment, exercise or defense of legal claims (where personal data is processed for direct marketing purposes, the Client/Customer shall have the right to object to processing of personal data for such marketing, and the Controller shall no longer process the Personal Data for such purposes);

   7. File a complaint regarding the Controller/Processors actions to the supervisory authority.

Refusal to grant the Consent: Personal data Subject hereby confirms that he has been notified that the provision of this Consent is not mandatory and the Client/Customer may at any time refuse it. However, the Consent granted by the Client/Customer is a requirement necessary for the conclusion of the Client/Customer Agreement between the Client/Customer and TrafficManager. In the case of absence of the Client/Customer signed Consent, the contractual relationship between the Client/Customer and TrafficManager. does not arise.

3. SECURITY

We have implemented cutting-edge technical and organizational security measures to protect the data in our possession from any kind of unfortunate incidents as accidental data loss, misuse, alteration, disclosure, destruction or unauthorized access, as well, access of your data is limited only to authorized personnel that will process your data subject to a duty of confidentiality. However, no data transmission on the internet can be guaranteed 100% to be safe from intrusion but we have a set of procedures to follow in case we need to deal with any suspected or actual data security breach. In such case, we will notify you right away and the supervisory authority of a suspected breach where we are legally required to do so.

4. DATA COLLECTING FROM MINORS

TrafficManager will never knowingly collect any Personal Data or information about minor age individuals (under eighteen (18) years of age). If we obtain actual knowledge that it has collected personal information about a minor individual, we will delete immediately all this information from our database

5. CLIENT/CUSTOMER RIGHTS, QUESTIONS AND COMPLAINTS

1. You have the right to request any modification/rectification of your personal data saved in our database such as Contact and Billing info by contacting us at [email protected] or by opening a support ticket via your client dashboard.

2. You have the right to restrict, refuse or revoke your consent to the processing of your Personal Data by contacting us at [email protected]. However, it can be difficult or impossible to provide Services to you upon termination of processing of your Personal Data.

3. You can exercise your right to data portability (copy of your Personal Data which you have provided to us in structured, common and machine-readable format if has not been already deleted) or request information about all Personal Data we have stored about you by contacting us at [email protected]

4. If you have any questions, concerns or complaints regarding the way we collect and handle your information, please contact us by email at [email protected] or [email protected]

Date of last revision: 20 January 2026

Terms of use

Welcome to the https://www.trafficmanager.com website (the "Website"). These are the Terms and Conditions ("Terms and Conditions") of use applicable to your access and use of our Website and the services made available through the Website (collectively, the "Services").

These Terms and Conditions must be followed by any individual using the site as a visitor (the "Visitor") without registration, including accessing the platform we have installed online as a product demo ("the Demo") or registered as a User (individuals/businesses) (the "User") and are the Terms and Conditions under which TrafficManager ("TrafficManager," "we," "us," "our") provides you access to the Website or Services.

You must carefully read these Terms and Conditions before registering on our Website or using our Services. By registering to our Website or using the Services you agree to accept and comply the Terms and Conditions, our Privacy policy, Client Agreement or any other rules and conditions provided on our Website and all applicable laws.

TrafficManager may change these Terms and Conditions in whole or in portion at any time without further notice and you agree that you will be bounded by any changes to this Terms and Conditions that will be posted on the Website. The date of the last revision of the Terms and Condition is included at the bottom of this page. Any changes to the Terms and Conditions published on the Site will be immediately applicable to Users and Visitors.

You understand and agree that TrafficManager may discontinue or restrict your use of the Website and/or Service for any reason or no reason with or without notice.

DEFINITIONS

1. TrafficManager: represents the company Traffic Manager Group S.R.L. with registered address in Str. Ionel Teodoreanu no. 1, 500165 Brașov, Romania, VAT(VIES) registration number: RO43058081 ("we," "us," "our");

2. Website: represents the Website located at the address https://www.trafficmanager.com;

3. Demo: is the TrafficManager platform/software technology demonstration, available on our Website as sample for the visitors who might be interested to try the product or see its features before buying.

4. Terms and Conditions: represents the Terms and Conditions on this page with their appendices and all the further and subsequent supplements and amendments.

5. Privacy policy: the document setting out how the data from the User or Visitor is collected, used, retained and transferred. This includes personal data and other important information.

6. Client Agreement: represents the agreement between TrafficManager (or other TrafficManager licensee) and the User / Client / Customer which grand the User right to access and use our Services through the Website;

7. Services: represent all the services we are providing to the clients via our Website, including access to the client dashboard, affiliate tracking platform, and all the upgrades, new features developed, modifications, updates, or personal customization developed in whole or partially by us;

8. Platform: the TrafficManager affiliate tracking software/technology provided to our clients, including all the updates, new features, customizations, server installation and maintenance, updates and monitoring developed in whole or partially by us;

9. Visitor: any person or business/company visiting our Website, subject to our Terms and Conditions and our Privacy policy but not registered in our database;

10. User: any person or business/company who, after accepting our Terms and Conditions, Privacy policy and our Client Agreement, registered and created a user account to use our Services through the Website ("client", "customer", "you", "your");

11. User account: the account resulted after a user registration on our Website that contains personal/company data including payment info with the purpose to use our Services via the Website;

12. Affiliate: represent any private or business/company providing advertisements via their own websites or other promotion channels for a product or service owner ("Advertiser").

13. Advertiser: represents a private or business/company that owns one or multiple products or a service, physical or online, looking for advertisement with the purpose of selling the products or services.

1. REQUIREMENTS

Before you can use our Services, you must agree to this Terms and Conditions and acknowledge that you have read our Privacy Policy, Client Agreement or any other rules and conditions provided on our Website which you will be deemed to have done by utilizing the Services.

In order to access our Services, you will need to register on our Website and provide complete, up-to-date information about you and/or your company. Once your account is created, you will receive a password that you will need to use, together with the email you used to register to access the Services via our Website.

To complete the registration, you will need to electronically accept our Client Agreement so we can continue providing you access to our Services, and at the end of the trial period (if you are eligible to a free trial period) you will need to pay your Pro Forma Invoices, according to the plan you chose as detailed in our Client Agreement.

These requirements may change as the Services evolves.

2. USE OF THE SERVICES AND RESTRICTIONS

1. You will have the right to access our Platform, upload, store, analyze, optimize and download your data from the Software;

2. While using our Platform and Services you agree that you will not violate any applicable law and regulations, and you agree to accept and comply the Terms and Conditions, our Privacy Policy, the Client Agreement and/or any other rules and conditions provided on our Website;

3. You agree not to license, transfer, sell or re-sell any information, content or service obtained from our Website;

4. It is forbidden to make available, through the Website and/or our Services, any material or information that infringes any patent, trade secret, copyright, trademark, or any other right of any party (including the rights of publicity or privacy);

5. Notwithstanding anything to the contrary, you may not: (i) make any misleading, false or deceptive statement representation regarding TrafficManager and/or the Services, (ii) sell, rent, lease, assign, act as a services provider, or grant rights in the Services, including, without limitation sublicense, to any other entity without the prior written consent of TrafficManager, (iii) remove any proprietary notices from the Services, (iv) permit, cause or authorize the modification, creation of derivative works, reverse engineering, translation, decompiling, disassembling or hacking of the Services.

6. You agree that you will not use our Website or the Services for any commercial purpose or the benefit of any 3rd party or charge any person, or receive any compensation for, the use of our Website or Services.

7. You may not connect to or use our Website and/or Services in any way not expressly permitted by this Terms and Conditions, Privacy Policy, Client Agreement, or any other rules and conditions provided on our Website.

3. COMMUNICATIONS

TrafficManager has the right at any time to publish on his Website or Platform any proposal to new services or other offers/proposals or send to the Users messages via email in the email address provided at the time of the registration such offers about our Services or any other relevant matters that could provide a better user experience to the end Clients. These messages may include invitations, suggestions, reminders, or descriptions of future or existing services or other important notices, but also promotional or marketing content.

4. CUSTOMER SUPPORT

The User will receive different type of support level according to the Subscription plan he choose. The most common support offered will be via the support request forms available in the Website, this include any kind of technical support, updates or modifications of the Website or Services, consultation or advise about the use of Website and Services.

5. PAYMENTS OF THE SERVICES

According to the conditions written in the Client Agreement, TrafficManager has the right to collect the fees for the Services from the User / Client. We may use various billing service providers to collect the fees from the User. The User, by using the billing provider service to pay our fee, agrees to be subject to and comply with the terms and conditions, privacy policies or any other other rules and conditions provided by the billing provider service and all applicable laws. All the invoice issuing terms and payment conditions are indicated in the Client Agreement. TrafficManager shall not be responsible and/or liable of any acts of omissions of billing service providers.

6. RIGHTS AND RESPONSIBILITIES OF THE USERS AND VISITORS

1. All the Users / Clients and Visitors of the TrafficManager Website and Services agree and acknowledge that TrafficManager even if it has the right, is not required to verify, so TrafficManager cannot be held responsible for any Visitor or User behaviur, action or inaction related to our Website and/or Services on their compliance with any applicable law.

2. When registering to the Website or Services, the User undertakes to provide only true information about his/her real name and company he/she represent including the contact details and to promptly update (if later needed) any information on the Website that becomes irrelevant, outdated, or inapplicable and to not create more than one Account in our system (One account per user allowed only).

3. The User agrees that he/she is the only responsible for maintaining the confidentiality of their password and account, if any, and is fully responsible for any and all activities that occur under their password or account. The User agrees that he/she needs to ensure that they log out from their account at the end of each session when accessing the Website or Services. In case of any unauthorized use of their password or account or any other breach of security, the User agrees to immediately notify Us. TrafficManager will not be liable for any loss or damage arising from your failure to comply with these obligations.

4. User and Visitor acknowledge and agree that TrafficManager is not responsible for any damage, material or not experienced by legal or natural persons which could arise directly or indirectly because of a User or Visitor actions while using our Website or Services. Every Visitor and User is himself responsible and must comply with all applicable laws related to his/her use of our Website and Services. In particular, but without limitation, Users and Visitors must: (i) NOT infringe any third-party rights; (ii) NOT use the identities of other companies/individuals; (iii) NOT violate any applicable laws or regulations; (iv) NOT infringe personal non-property rights or property rights of TrafficManager and/or any 3rd parties (including intellectual property rights); (v) NOT upload any data that is contrary to any applicable law or contains any viruses or other computer programs or files that may cause damage to TrafficManager or User property, impede the User's computer use, the Website or TrafficManager Services, or interfere with the normal operation of the TrafficManager Website and Services in any way;

5. The User acknowledge and agrees that only himself (including his/her employees, collaborators or any authorized person) is responsible for their actions while using our Website and/or Services and his/her compliance with all the applicable laws and NOT use the Website or Services for any unlawful purpose, in a way prohibited by the Terms and Conditions.

6. When using the Website or Services the User undertakes to not perform any unlawful transactions, actions, or frauds and to not copy or make any illegal use of the information placed by Trafficmanager on the Website / Platform or any other Service Provided (The "Services").

7. When using the Website or Services the User undertakes to not perform any illegal activity including, but not limiting to, (i) not to use the Site and/or the Software for any illegal, offensive, obscene, or immoral purpose; (ii) not to use any automated means (spider, scraper, robot, crawler, iframe , etc.) or interface not provided by us to access the Website and/or the Services, including, without limitation, for the purpose of copying, extracting, aggregating, displaying, publishing or distributing any content or data made available via our Website or Services; (iii) cheating software, hacking tool or any other tools to disrupt, obstruct or interfere with the operation of the Website and/or the Services; (iv) not to obtain or attempt to obtain any information from the Website and/or the Services, including contact details such as but not limited to phone numbers, email addresses, social media profiles or other Instant Messenger details of other account holders or TrafficManager Services;

7. REPRESENTATIONS AND WARRANTIES OF THE USERS AND VISITORS

1. The User or Visitor represents and warrants that when using our Website or Services he/she is 18 years or older, is fully and exclusively responsible for any use of our Website and Services, and complies with all the obligations described in these Terms and Conditions, our Client Agreement, and any other rules and conditions provided on our Website and all applicable laws.

2. The User/Visitor has the right to make payments and represent the legal entity on behalf of which he/she visited or use our Website and Services.

3. As specified in the Client Agreement, the User/Visitor shall pay any and all the fees and taxes related to the use of Trafficmanager Website or Services and understand and agrees that the non-performance of these obligations may result in a Service interruption and obligation to provide the full compensation for any losses incurred by Trafficmanager.

4. The User acknowledges and agrees that she/he (including his/her employees, collaborators or any other authorized person using the Website and/or Services in its behalf) are not entitled to collect or store, or attempt to collect or store, any personal data about third parties without their knowledge and consent and are prohibited from using our Website and Services in violation of any applicable laws and regulations including but not limited to (i) upload in our Website/Platform or Services any information, data or material that is trade libelous, defamatory, obscene or harmful to minors, vulgar, racist, unlawfully threatening or harassing, abusive, promoting hatred, discriminating or displaying prejudice based on ethnic heritage, religion, race, age or sexual orientation or (ii) protected by trademark, copyright, patent, trade secret or any other intellectual property right without authorization or (iii) that violates any law or regulation including without limitation, unfair competition, anti-discrimination, the laws and regulations governing export control, false advertising or (iv) that contains any worms, viruses or any other software intended to damage or alter a computer system or data; (v) upload and process using our Website and Services any material that contains mass mailings or any form of "SPAM".

8. TRAFFICMANAGER RIGHTS AND RESPONSIBILITIES

In case of a breach of these Terms and Conditions, Client Agreement, Privacy Policy or any other rules and conditions provided on our Website and all applicable laws, Trafficmanager at his sole discretion has the right to suspend, limit, partially or fully block or terminate any User or Visitor account or right to use the Website or Services including preventing the User to register again on the Website or a Visitor to re-access the Website without sending a formal notice to the User.

The Visitor/User agrees that TrafficManager, in order to protect Users and Visitors from frauds or any other illegal activities, has the right to observe and collect data about the conduct of Users and Visitors.

TrafficManager has the right at any time to change in part or entirely, stop or terminate the Website or update, rearrange any posted information as long as such modifications don't affect User's data.

TrafficManager is entitled at any time to unilaterally suspend or terminate the transfer to any 3rd party the Website and Services cases in which TrafficManager will make reasonable commercial efforts to provide prior notifications.

As described also in the TrafficManager Privacy Policy, you, as a User or Visitor authorize TrafficManager to process and store data that allow us to identify you, so you acknowledge and Agree that TrafficManager is using its own means to check if you are using our Services or Website in accordance with the Terms and Conditions, Client Agreement, Privacy Policy or any other rules and conditions provided on our Website and all applicable laws.

After the the registration on the Website of the Client/User, TrafficManager or any of its business partners shall be entitled to process, transfer and store any essential data in order to identify you for billing purpose and the performance of the Terms and Conditions, Client Agreement, Privacy Policy or any other rules and conditions provided on our Website so you, as a Client/User issue your agreement to TrafficManager to transfer your data during the communication between our Website or Services and the computer systems of our business partners (es. Our Billing Providers). The purpose of such data transfer is to grant access to our services, ensure the functionality of the Website and/or Services, and to protect TrafficManager rights.

9. USE OF THE PERSONAL DATA

1. All the personal or company data is collected and processed in accordance with the law and our Privacy Policy located at: Privacy policy

2. The User/Client/Customer of TrafficManager (as a controller) acknowledges and agrees that it shall inform its end-users about the processing of their IP addresses or about the use of cookies in their respective privacy policies and provide an opt-out. This requirement applies from the beginning of the free trial period of the TrafficManager Services and the subsequent use of our Services if the client continues to use the TrafficManager Services. The User/Client/Customer also acknowledges and agree that it shall fully comply with Art. 13 of the GDPR and provide the data subjects whose personal data is collected and processed through the TrafficManager Services on behalf of the user/client/customer with all the required information in its privacy policy.

3. TrafficManager at its own discretion may decide to retain and store The User account relevant information like User personal and or corporate data in case of the User account cancellation, especially in case of an investigation or as otherwise required by law or in order to take legal action in consequence of a violation of the Terms and Conditions, Client Agreement, Privacy Policy or any other Website Rules.

10. OTHER LEGAL PROVISIONS

A. WEBSITE CONTENT

All the content included on our Website, such as text, graphics, logos, button icons, images, audio clips, digital downloads, data compilations, and software, is the property of TrafficManager or its content suppliers and protected by international copyright laws and any unauthorized use may violate trademark, copyright, and other laws. The compilation of all the content on this site is the exclusive property of TrafficManager or its licensors with copyright authorship for this collection by TrafficManager, and protected by international copyright laws. Any use, copying, redistribution, or publication by the Visitor or Client without prior authorization from Trafficmanager of any part of the Website or the Platform (the "Services) are strictly prohibited. The Website may contain links to 3rd party sites. TrafficManager is not responsible for the content of any linked third-party sites and doesn't make any representation regarding the accuracy of the content or any other materials on any 3rd party sites. If you decide to access any linked third-party website, you do so at your own risk.

B. LIMITED WARRANTY

The content of our Website, Platform or any other information made available thru the TrafficManager Services may typographically errors or inaccuracies. You agree that TrafficManager (Including his 3rd party Owner's licensees) makes no representations about the reliability, accuracy, completeness, or timeliness of the Content or about the results to be obtained from using Website or Services. The use of the TrafficManager Website, Content or Services is at your own risk. As agreed before in these Terms and Conditions, you acknowledge and Accept that changes are periodically made to the Website and may be made at any time by TrafficManager.

C. LIMITATION OF LIABILITY

D. LIMITATION ON AMOUNT OF LIABILITY

THE AGGREGATE LIABILITY OF OWNER (INCLUDING OTHER OWNER'S LICENSEES) TO YOU FOR ALL CLAIMS ARISING FROM THE WEBSITE AND SERVICES SUCH AS BUT NOT LIMITED TO THE PLATFORM AND THE CONTENT IS LIMITED TO 3 (THREE) MONTHLY FEES FOR THE CHOSEN SUBSCRIPTION PLAN PRECEDING THE DATE OF CLAIM.

CERTAIN STATE LAWS DO NOT ALLOW LIMITATIONS ON IMPLIED WARRANTIES OR THE EXCLUSION OR LIMITATION OF CERTAIN DAMAGES. IF THESE LAWS APPLY TO YOU, SOME OR ALL OF THE ABOVE DISCLAIMERS, EXCLUSIONS, OR LIMITATIONS MAY NOT APPLY TO YOU, AND YOU MIGHT HAVE ADDITIONAL RIGHTS.

E. INDEMNITY

The User/Client/Customer agrees to indemnify, defend and hold harmless TrafficManager, including his 3rd party Owner's licensees, its, directors, officers, employees and agents, from and against any claims, actions or demands, including without limitation reasonable legal and accounting fees, alleging or resulting from your use of the Website and the Services or your breach of these Terms and Conditions. TrafficManager shall provide notice to you promptly of any such claim, suit, or proceeding and shall assist you, at your expense, in defending any such claim suit or proceeding.

F. USER/CLIENT DATA

All the information and data uploaded by the User or retrieved, processed by the TrafficManager Services on behalf of the User shall remain the property of the User. User have the right to copy, download, duplicate, retrieve, any of his data as stored on the Website or in the TrafficManager platform ("Services").

G. THE RIGHT TO USE USERS/CLIENTS NAME AND TRADEMARK

TrafficManager has the right to use the User/Client name or trademark (service mark) or the User logo by posting on the TrafficManager service and in promotional materials during the term of the Client Agreement and for a period of two (2) years after the termination of the Client.

H. THE USE OF VISITOR/USER/CLIENT COMMENTS, REVIEWS, SUGGESTIONS

Visitor and/or User acknowledge and agree that any reviews, suggestions, comments, ideas, questions or feedback related to the Website and our Services provided in the form of email or other submissions to the Website, may shared, used or reused by TrafficManager to better serve you and that all the proposals, feedbacks and ideas made via our email or other submissions on the Website are not an intellectual property of the User and/or Visitor.

TrafficManager shall be entitled to the unrestricted use and dissemination of any idea, suggestion or feedback for any purpose, excepting those uses that violate the Privacy Policy.

I. APPLICABLE LAW AND DISPUTES RESOLUTION

These Terms and Conditions are governed by the laws of Romania, EU, without regard to principles of conflict of laws, will govern this Agreement terms and any dispute of any sort that might arise between you and TrafficManager including his 3rd party Owner's licensees, its, directors, officers, employees, agents, or its associates.

If any provision of these Terms and Conditions is found to be invalid by any court having competent jurisdiction, the invalidity of such provision shall not affect the validity of the remaining provisions of these Terms and Conditions, which shall remain in full force and effect. No waiver of any provision of these Terms and Conditions shall be deemed a further or continuing waiver of such term or any other term. In the event of a legal dispute, it will be resolved according to dispute resolution procedures as provided in the Client Agreement.

In case of any conflict between these Terms and Conditions, Client Agreement and the Data Processing Addendum, the terms of the Data Processing Addendum shall control.

These Terms and Conditions, together with the Client Agreement, Privacy Policy and other Website Rules constitute the entire agreement between you TrafficManager with respect to the use of the Website, the Services and the Content. In case of any conflict between these Terms and Conditions (not including Data Processing Addendum), Client Agreement (not including Data Processing Addendum) and Privacy Policy, the Client Agreement shall prevail.

Date of last revision: January 20, 2026

Client agreement

1. PARTIES

The Service provider, TRAFFIC MANAGER GROUP S.R.L. with registered address Str. Ionel Teodoreanu nr. 1, 500165 Brașov, Romania, VAT (VIES) registration number RO43058081 under the laws of Romania

and

The Client, User of the TrafficManager Tracking platform and all the services provided by Us thru the website TrafficManager.com (the "Website") agreed the following:

By signing up (even on behalf of a Company) to use the Traffic Manager Tracking Platform including any other content or information provided to you as part of our Platform, Website, Software or Services you are entering into a legal agreement with Traffic Manager Limited (the platform Owner) which may conclude this agreement on its own behalf or can also be represented by Traffic Manager Group S.R.L. or other 3rd party entities who have the right to provide our Clients access to the platform via our Website and collect the fees form the Client ("We", "Us", "TrafficManager").

You and we should be known collectively as the "Parties" and individually as a "Party".

This Agreement is accompanied and must be interpreted in conjunction with the Privacy policy and the Terms and conditions located on the Website. In case of any conflict between this Client agreement and the Terms and conditions or the Privacy policy, this Client agreement shall prevail.

TrafficManager reserves the right to modify the present conditions of this Agreement at any time. The applicable version of this agreement is the one you accepted at the time of your registration for our Services.

The acceptance of this Agreement by the Client is made by clicking on the checkbox "I accept the Client agreement" on the registration page.

This contract is concluded for an indefinite period from the date of creation of the account, and the obligations of the parties take effect from that date.

DEFINITIONS

1. TrafficManager: represents the company Traffic Manager Group S.R.L. with registered address in Str. Ionel Teodoreanu nr. 1, 500165 Brașov, Romania, VIES registration number RO43058081, or other 3rd party entities who have the right to provide our clients access to the services via our Website and collect the fees form the Clients ("we," "us," "our");

2. Website: represents the website located at the address https://www.trafficmanager.com;

3. Terms and conditions: represents the Terms and conditions with their appendices and all further and subsequent supplements and amendments located at this page: Terms of use

4. Privacy policy: is the document setting out how the data from the User or Visitor is collected, used, retained and transferred. This includes personal data and other important information about the consent to Personal data Processing ( hereinafter the "GDPR Regulation"). The document is located at this page: Privacy policy

5. Agreement: represents the agreement between TrafficManager (or other TrafficManager licensee) and the User / Client / Customer which grand the User right to access and use our Services through the Website;

6. Services: represent all the services we are providing to the clients via our website including access to the client dashboard, affiliate tracking platform and all the upgrades, new features developed, modifications, updates or personal customization developed in whole or partially by us;

7. Platform: it's the TrafficManager affiliate tracking software/technology provided to our clients, including all the updates, new features, customizations, server installation and maintenance, updates and monitoring developed in whole or partially by us;

8. Visitor: represent any person or business/company visiting our website, subject to our Terms and conditions and our Privacy policy but not registered in our database;

9. User: represent any person or business/company who after accepting our Terms and Conditions, Privacy policy and our Client agreement registered and created a user account in order to use our Services through the Website ("client" "customer" "you" "your");

10. User account: the account resulted after a user registration on our Website that contains personal/company data including payment info with the purpose to use our Services via the Website;

11. Fees: represents the price paid by the Client according to the usage plan chosen on registration and visible in the website pricing page: https://www.trafficmanager.com/pricing

2. SERVICES DESCRIPTION, PRICING, FEES AND PAYMENT

1. TrafficManager, offers a SaaS affiliate tracking solution ("Platform") by registering at the Website www.trafficmanager.com and paying the Fees ("Fees") according to the usage plan you. You agree that TrafficManager has the right to change the fees from the Pricing page at any time, at its sole discretion and you acknowledge that such changes will be available on the Website and all the fees are in EURO, unless otherwise stated;

2. Price: In consideration for the Deliverables, the Client shall pay TrafficManager the fees as set forth on the pricing page or as otherwise agreed upon by the Provider in the event of additional services, such as Custom development, which are tailored to the specific needs of the Client. In the case of custom development requests by clients, the price is set to a minimum of 100 euros for interventions under 1 hour and a maximum of 350 euros per day. A more accurate price will be communicated beforehand through the designated communication channel (ticket or chat), but this price may change if complications arise during the process that were not initially considered or communicated in the initial request. Additionally, if it is necessary to study documentation before providing a price estimate, a cost between 100 and 350 euros will be added to the next proforma invoice. This cost will be incurred even if the feature is not ultimately developed due to the lack of agreement on the price. The price may also vary depending on the chosen payment method and the period for which the Client commits to pay for the Services in advance.

   The chosen method of payment may incur additional fees, as follows:

   • Payments made via Stripe will be subject to an additional fee of 2% of the total proforma invoice amount.

   • Payments made through PayPal will incur an additional fee of 3% of the total proforma invoice amount.

   These fees are meant to cover any potential FX costs that come in addition to the standard processing fees, which are typically covered by TrafficManager. Clients are encouraged to use fee-free payment methods such as SEPA Wire Transfer, Visa, or Mastercard to avoid these additional charges.

   By proceeding with the payment for the services, the Client acknowledges and accepts the pricing terms provided by TrafficManager, including any applicable additional fees.

   All stated fees are exclusive of Value Added Tax (VAT), withholding taxes, and/or any other taxes that may be levied by any jurisdiction. Should VAT, withholding taxes, or any other taxes be imposed on the transactions pursuant to this Agreement, the Client is responsible for paying these taxes in such a way that TrafficManager receives the full amount credited to the Client without offset or deduction.

3. The duration of the billing period is 1Month / 3 Months / 6 Months or 1 Year on prepaid basis and the payment period is set to NET 5 days. In case you decide to change your subscription plan (Upgrade or Downgrade) you agree that the changes will take effect starting from the next month billing period but not less than 7 days since TrafficManager was notified about these changes;

4. We offer a 30-day free trial period to all our new clients, but please note that the decision to provide you with a Trial period or NOT is made at our sole discretion;

   For any other info about Billing and Refund Policy please refer to this page: https://www.trafficmanager.com/legal/?section=billing-refund-policy

   TrafficManager and its associates attempt to be as accurate as possible. However, TrafficManager does not warrant that product descriptions or other content of this site is accurate, complete, reliable, current, or error-free. If a service offered by TrafficManager itself is not as described, your sole remedy is to cease using it.

5. Late Payment Penalties and Recovery Costs

   The Client agrees to pay the fees within the stipulated payment period, set to NET 5 days from the issuance of the proforma invoice. If the proforma invoice remains unpaid after the due date, it becomes overdue. TrafficManager may send a late payment warning 9 days after the due date and may add a fixed sum of €40 as late payment penalty compensation 11 days after the due date in line with the European Late Payment Directive (2011/7/EU).

   This fixed sum is intended to cover the administrative effort and resources used to manage late payments.

   The Client acknowledges that these recovery costs are to ensure timely payments, compensate TrafficManager for late payment handling, and not as punitive measures. If late payment persists, the related platform may move through the billing lifecycle from expired to suspended and, if it remains suspended without payment, to canceled.

3. GRANT OF LIMITED RIGHTS

TrafficManager grants you a non-exclusive, revocable, limited and non-transferable right ("Client agreement") to access our Website and use our Tracking Platform through our Website for a fee as indicated above in the point 1 "Platform Description" in accordance with the terms and conditions of this Client agreement, The Website TOS, Privacy policy and other terms that will be displayed to you from time to time while accessing different areas from the Website or Platform for the first time. The Client agreement, if not terminated earlier under the Terms of this Agreement is granted for the whole period of the Trial or during which the Platform fee is paid for. We reserve our right to choose the customers of our Platform and the right to refuse access to our platform to anyone for any reason.

This Client agreement grants you these limited rights:

1. To use our Platform and all the features you paid for according to the plan you choose by accessing it via our Website or a White label installed on your own web domain;

2. To gather or upload your data, process, review, analyze, optimize and download the data from the Platform;

3. All your data shall be collected and processed in accordance with the GDPR, Privacy policy, Terms and Conditions of use and in accordance with the Law. You as the platform Client and final user of this data you acknowledge and agree that you are prohibited from using the Platform in violation of any applicable laws and regulations and you shall be retained fully responsible for any illegal activity you did using this data;

4. PLATFORM ACCOUNT AND AGREEMENT TERMINATION

1. You, as the Client agree to assume the whole responsibility for maintaining confidential your account login details (user and password) and the whole responsibility for all the actions that occur under your account or by using your user and password. If you notice or become aware of any suspect activity on your account or unauthorized access you agree to notify Us immediately.

2. You are considered to start using our Tracking Platform as of the date the Free Trial period has begun (if you received a Free trial period) and you will receive access to the Tracking Platform and to your account until the termination of this Agreement, subject to monthly payments of the Platform Fees. This Agreement will automatically renew on a month-to-month basis until you cancel your subscription from your account settings page, or you provide us with a notice via email or by opening a support ticket in our system at least 30 days before the cancelation date. On the account termination you lose your right to access and use the Platform.

   If a recurrent or renewal proforma invoice remains unpaid after its due date, the related platform may be marked as expired. If it remains unpaid for 14 days after expiration, the platform may be suspended. If it remains suspended for 7 more days without payment, the platform may be canceled. If the overdue proforma invoice is paid before cancellation, access may be restored.

3. For any breach of this Agreement or any Terms and conditions of use, TrafficManager may end this agreement without any notice with immediate effect;

4. In case of account termination for any reason we shall keep: our rights to use and disclose your feedback about our service and Platform and the right to recover from you any amounts you owe us before the service termination.

5. DISCLAIMER OF WARRANTIES AND LIMITATION

6. TRACKING PLATFORM AND WEBSITE USE

1. Beside the responsibilities and obligations you agree with upon registration and provided in our Terms and conditions, You as the Platform Client agree that you shall never try to reverse engineer any part of the TrafficManager Platform, reproduce, copy, trade or sell any part of our Website or Platform and that you will use our Website and our Platform for lawful uses only. Any violation of this section will be considered as a breach of this client agreement.

2. You agree that TrafficManager has the right to make any kind of modifications or updates to the Website and the Tracking Platform at any time in order to provide a better service to you as a Client (for example: Bug fixes, new features release, etc.) and in case of such event cause you a service disruption you agree that you will notify our support team immediately and we shall not be retain responsible for any kind of data or material loss.

3. You will have access to our Support service just as provided in our Terms and conditions or in the package you choose from the pricing page: https://www.trafficmanager.com/pricing

4. You declare that you acknowledge and agree that all the data, material or information uploaded, gained or retrieved by you and processed with the TrafficManager Platform on your behalf shall not contain any form of "SPAM", is protected by copyright or any trademark, patent, trade secret or any other intellectual property (without authorization).

5. You declare that you acknowledge and agree that all the data, material or information uploaded, gained or retrieved by you and processed with the TrafficManager Platform on your behalf is not false advertising, contains any viruses, worms or any other software intended to damage or alter a computer system or data, is not defamatory, unlawfully threatening or harassing, obscene or harmful to minors, abusive, pornographic, trade libelous, vulgar, racist, discriminating or displaying prejudice based on religion, promoting hatred, ethnic heritage, race, sexual orientation or age, or (c) that violates any law or regulation, including without limitation, the laws and regulations governing export control, unfair competition, anti-discrimination;

6. As the Platform Client you authorize TrafficManager to process, transfer and store the data enabling to identify you and using its own system to check if you are using the TrafficManager tracking platform in accordance with this agreement;

7. As the Platform Client you authorize TrafficManager to transfer your data during any kind of communication between our Website/Platform and any other computer systems of TrafficManager and his partners for the purpose to ensure the full functionality of the Platform and the Authorization to use the Website/Platform and protect the TrafficManager rights. You acknowledge and agree also that after the effective date of your registration you accepted this agreement and TrafficManager or any of its business partners are entitled to process, store and transfer any data in order to identify you for billing purposes or performance of this Agreement;

7. COPYRIGHT AND OWNERSHIP

1. All content included on our Website and Platform, such as text, graphics, logos, button icons, images, audio clips, digital downloads, data compilations, and software, is the property of TrafficManager or its content suppliers and protected by international copyright laws. The compilation of all content on this site is the exclusive property of TrafficManager or its licensors with copyright authorship for this collection by TrafficManager, and protected by international copyright laws. Any use, copying, redistribution or publication by the Client of any part of the Website or the Platform are strictly prohibited.

2. The Client does not acquire the ownership on the Platform, the Website or any other material made available by TrafficManager through his Website or Platform excluding all the data and information retrieved, uploaded, acquired and processed by the TrafficManager Platform on your behalf that shall remain your property and you shall have the right to copy, duplicate, retrieve, download the data or information but without disclosing it to third parties. Any other use of information or materials (except your information) contained in the Platform or Website without the written permission of TrafficManager or unauthorized use that may violate any applicable communications regulations and statutes or laws including but without limitation copyright and trademark laws is strictly prohibited and will terminate this Agreement. This Platform Client agreement can be revoked at any time at the sole discretion of TrafficManager.

8. APPLICABLE LAW AND DISPUTES RESOLUTION

1. This Platform - Client agreement is governed by the laws of Romania, EU, without regard to principles of conflict of laws, will govern this Agreement terms and any dispute of any sort that might arise between you and TrafficManager or its associates.

2. Any dispute relating in any way to your visit to TrafficManager or to products you purchase through TrafficManager shall be solved in max. 30 (thirty) days by negociation between the Parties before submitting the dispute to any court in Romania and you consent to exclusive jurisdiction and venue in such courts except that, to the extent you have in any manner violated or threatened to violate TrafficManagers intellectual property rights, TrafficManager may seek injunctive or other appropriate relief in any state or court in Romania, EU;

9. FORCE MAJEURE

1. Neither party shall be held liable or responsible to the other party nor be deemed to have defaulted under or breached this Agreement for failure or delay in fulfilling or performing any obligation under this Agreement when such failure or delay is caused by or results from causes beyond the reasonable control of the affected party, including but not limited to acts of God, explosions, fires, Internet or network failure, telecommunications failure, vandalism, lack of access or breakdown of IT systems, computer hacking or damage to the data or information maintained in these systems, a power supply failure or failure in TrafficManagers's systems, administrative or legislative interventions, storms or other natural disasters, national emergencies, riots, insurrections, wars, strikes or other labor difficulties, any act or omission of any other person, entity or any governmental authority; provided, however, that the party so affected shall use reasonable commercial efforts to avoid or remove such causes of nonperformance, and shall continue performance hereunder with reasonable dispatch whenever such causes are removed. Either party shall provide the other party with prompt written notice of any delay or failure to perform that occurs by reason of force majeure. The parties shall mutually seek a resolution of the delay or the failure to perform as noted above.

10. MISCELLANEOUS

1. If any provision of this Platform – Client agreement is found as invalid by any court with competent jurisdiction, the invalidity of this Agreement shall not affect the validity of the remaining provisions of the Terms and conditions of this Agreement. All the provisions of this Agreement shall continue and survive termination, including the terms that relates to limitations and exclusions of Trafficmanager's restrictions, liability, limitations, intellectual property and reimbursement of any damages. No waiver of any provision of this Agreement shall be deemed a further or continuing waiver of such term or any other term.

2. The parties of this Agreement are independent entities, and this agreement will not create any joint venture, partnership, franchise, agency, sales representative or employment relationship between the Parties, so the Client has no authority to accept or make any kind of offers or to represent in any way or make statements on behalf of TrafficManager.

3. TrafficManager shall be entitled to assign this Agreement to any 3rd party, in whole or in part without your consent, cases in which this Client – Platform Agreement shall continue in force, without any changes, with the new entity or person entering into Trafficmanager's place as the contracting party.

4. The Client shall not be entitled to in any way transfer or assign this Client agreement to a 3rd, in whole or in part, without TrafficManagers's prior written consent.

5. This Client agreement ("Agreement") together with our Terms and conditions, Privacy policy and other terms that will be displayed to you from time to time when you will visit for the first-time certain sections of our Website or Platform represent the entire agreement between you and TrafficManager. In case of any conflict between this Client agreement and other Terms and conditions this Client Agreement shall prevail.

6. The parties declare that they have negotiated all the terms of this Agreement and they expressly accepted them by signing the contract, any prior agreement between the parties will not product any legal effects between them.

7. TrafficManager reserves the right to periodically update and modify the terms of this Agreement. In such cases, we will inform the Client in advance, by posting the modifications on the website 15 days before its entry into force, which is why we ask the Client to periodically check the content of this Agreement.

8. Any notification to TrafficManager must be sent electronically to the email address [email protected]

The present Agreement is located in this page: https://www.trafficmanager.com/clientagreement

Annex 1 - processing of personal data by TrafficManager according to GDPR

Contract for personal data processing between the Client and TrafficManager

This annex is accompanied and must be interpreted in conjunction with the Privacy policy and sets out the specific rules regarding the processing of personal data submitted by the Beneficiary, as Client or Customer, to TrafficManager, as a controller of your personal data in accordance with Regulation (EU) 2016/679 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (hereinafter referred to as "GDPR"), as well as any subsequent national legislation on the protection of personal data.

By accessing our Website or using our Services, you become subject to this Contract. Your acceptance of the terms of this Contract, in their entirety, shall be effective to you and your employees, if any.

1. TERMS

In this annex the terms used will be interpreted in accordance with the GDPR, and where applicable, the terms used will have the definitions stipulated by art. 4 of the GDPR.

2. CONTRACT OBJECT

The object of personal data processing is the processing by TrafficManager of personal data sent by the Customer in order to provide the services stipulated in the main Customer Agreement but also for customer support services, technical updates or updates on changes in our usage policies.

3. DATA COLLECTED

Your Contact and Billing Information. When you register or sign up for the TrafficManager Services, we may collect certain contact information from you, such as your first and last name, organization/company name, company number, banking or other payment information, city, state and zip code, country, email address, and phone number or other similar contact details to process your registration request, to contact you regarding it and for finance purposes (invoicing). More details about how we process the data can be found in the Privacy policy document located at this page: Privacy policy

4. SPECIFIC INSTRUCTIONS

Under this contract, the Client gives the following specific instructions to the controller:

• To collect and process personal data received from the Client directly for the purpose provided in the article 1 from the Privacy policy page (Privacy policy)

• To send messages by email on behalf of the Client, for the service of sending notifications or documents by email (if this service is used by the Client);

• To collect and process the information sent by the Client to the TrafficManager Servers via the Website or Platform

5. DURATION OF DATA PROCESSING

The duration of the processing of personal data is identical to the duration of the main Client agreement.

6. NATURE AND PURPOSE OF DATA PROCESSING

The nature and purpose of the data processing are those established by the Client under the main Client Agreement, namely the provision of TrafficManager services, depending on the usage plan or package of services chosen.

7. THIRD PARTIES

All the Third parties, to whom TrafficManager may transfer the Client Data for processing are listed under the article 2 from the Privacy policy page (Privacy policy)

• Pursuant to this Article, the Client understands to authorize TrafficManager to process his data thru his third-party partners as listed in the Article 2 from the Privacy policy Page.

• For all the future Third Parties that TrafficManager may use to process the Client data, TrafficManager receives a general authorization to subcontract to any other provider in the EU, EEA or country with an adequate level of protection recognized by a decision of the European Commission, which is necessary for certain parts of the data processing under this contract. an adequate level of security, at least at the level of this contract. This authorization includes the obligation to inform the Client, through a message through the account on the TrafficManager Website or by email. The operator has the possibility to object within 2 working days.

8. RIGHTS AND OBLIGATIONS OF THE CLIENT

• The right to receive information from TrafficManager or to verify through a mandated auditor whether TrafficManager has and implements appropriate technical and organizational measures so that the processing complies with the requirements of the GDPR; the verification will take place on the basis of a prior written notification, sent at least 14 working days before the verification;

• The right to receive assistance from the Controller, in particular to fulfill his obligation to respond to the requests of data subjects regarding the exercise of their rights under the GDPR;

• The right to object to other third parties specified to the article 7.2

• To comply with its obligations under the GDPR as Client with regard to personal data collected or processed by TrafficManager, on its behalf.

• Obligation to inform data subjects under the GDPR, including information on the processing of data by TrafficManager under this contract

• Obligation to be solely responsible for establishing the legal basis for the processing of personal data covered by this contract

• The obligation to implement appropriate technical and organizational measures under the GDPR, including securing the transfer of data from data subjects to TrafficManager;

• The Client understands that from the moment of deleting the data after the end of the provision of services by TrafficManager according to the obligations of GDPR and art. 9 of this contract, the data can no longer be recovered, and it is the entire responsibility of the Client to ensure that it has made a complete copy of them.

• In all situations where the Client is the one who has to perform an obligation, such as, for example, informing the data subject about the breach of personal data security, TrafficManager cannot be held liable by the Client's inactions within the scope of that obligation.

9. RIGHTS AND OBLIGATIONS OF TRAFFICMANAGER

• The obligation to inform the Customer within a maximum of 10 days, if, in the opinion of TrafficManager, an instruction violates GDPR and / or other legal provision regarding the processing of personal data;

• The obligation to ensure the security of personal data processed on behalf of the Client in accordance with Article 32 of the GDPR and Article 10 of this Annex;

• Obligation to inform the Client without undue delay of a breach of the security of the Client's personal data during the processing performed by TrafficManager;

• Obligation to assist the Client with all information necessary for the notification, if any, to the Competent Authority for Data Security Infringement, but without substituting for the Client his obligation to notify;

• Obligation to assist the Client in ensuring compliance with the obligations set out in Articles 32-36 of the GDPR;

• The obligation to assist the Client in solving the requests of the data subjects or to send to the Client any request received from the data subjects, in connection with the personal data that have been collected and processed by TrafficManager, within maximum 5 calendar days from its receipt. This assistance does not apply if the Customer already has in the technical tools provided by TrafficManager the possibility to directly solve the request of the data subject (eg the platform Account access - where the Customer already has all the information about what data he collects);

• Obligation not to transmit personal data and / or confidential information, which may be personal data, of which he became aware during the performance of the contract

• The obligation to provide training to authorized personnel to process personal data, regarding the confidentiality of such data;

• The obligation to include confidentiality obligations towards employees and third parties;

• The right to disclose certain personal data by virtue of a legal obligation or other condition provided by law at the request of an authority, public institution or court.

• The right to recruit third parties according to article 7 of this Contract;

• The right to cover the costs generated by ensuring the assistance of the Client, by the Client, in the situations provided by GDPR according to art. 9, if they exceed the monthly cost of the services provided by TrafficManager;

• The right to use anonymized statistical information as a result of activities performed as a result of this contract or its entire activity;

• TrafficManager cannot establish purposes or means of processing personal data, these being established exclusively by the Client.

10. SECURITY

TrafficManager must comply with appropriate technical and organizational measures to ensure appropriate risk-related security measures in line with good industry practice. In determining the appropriate level of security, TrafficManager must take into account the current state of development, implementation costs and the nature, scope, context and purposes of the processing, as well as the risk with varying degrees of probability and seriousness to the rights and freedoms of individuals. and the risks that arise as a result of the processing, in particular those that may lead to, accidentally or illegally, the destruction, loss, alteration, or unauthorized disclosure of personal data transmitted, stored or processed in a otherwise, or to unauthorized access to them.

In this context, TrafficManager has established the internal application of the following organizational and technical security measures for the security of personal data, taking into account the type of activity performed:

• implementation of ISO27001 / ISO27017 / ISO27018 security standards

• periodic security audit performed by cybersecurity experts

• limited access to the database for a very small number of employees of TrafficManager

• permanent monitoring of access to the database

• encryption of the connection used by the Client to access the service using SSL

• encrypted client passwords

• regular backups

Voluntarily, TrafficManager may send summaries of the conclusions of security auditors (after deletion of commercial or confidential information) made periodically to Customers to demonstrate its ongoing activities on this subject.

11. LIMITATION OF LIABILITY

The Client agrees to exonerate TrafficManager from any liability for damages that may arise from:

• non-compliance with the contract due to events that exceed any responsibility of TrafficManager;

• compliance with the Client's instructions or non-compliance with the Client's instructions justified in advance by a notification regarding its illegality;

• the lack or vitiation of the consent of the data subjects or of the use of a wrong legal basis by the Client;

• non-compliance with the contract due to some actions of the Client.

12. DELIMITATION OF LIABILITY

The Customer and TrafficManager define their responsibilities for ensuring the protection of personal data (e.g. ensuring the confidentiality or security of processing), depending on the access and effective control exercised over the data, both contractually and technically.

13. ENTRY INTO FORCE AND AMENDMENTS

This annex enters into force on May 20, 2018 and is valid until modified by TrafficManager and informing the Clients accordingly. Using the Account, Platform and/or our Services after the Clients informing means their consent to this document.

Last edit: January 20, 2026

Processing of personal data by TrafficManager according to GDPR

Contract for personal data processing between the Client and TrafficManager

This annex is accompanied and must be interpreted in conjunction with the Privacy Policy and sets out the specific rules regarding the processing of personal data submitted by the Beneficiary, as Client or Customer, to TrafficManager, as a Data Processor on behalf of the Client (the Data Controller) in accordance with Regulation (EU) 2016/679 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (hereinafter referred to as "GDPR"), as well as any subsequent national legislation on the protection of personal data.

By accessing our Website or using our Services, you become subject to this Contract. Your acceptance of the terms of this Contract, in their entirety, shall be effective to you and your employees, if any.

1. Terms

In this annex the terms used will be interpreted in accordance with the GDPR, and where applicable, the terms used will have the definitions stipulated by art. 4 of the GDPR.

2. Contract Object

The object of personal data processing is the processing by TrafficManager of personal data sent by the Customer in order to provide the services stipulated in the main Business Agreement (the "Agreement") but also for customer support services, technical updates or updates on changes in our usage policies.

3. Data Collected

Your Contact and Billing Information. When you register or sign up for the TrafficManager Services, we may collect certain contact information from you, such as your first and last name, organization/company name, company number, banking or other payment information, city, state and zip code, country, email address, and phone number or other similar contact details to process your registration request, to contact you regarding it and for finance purposes (invoicing). More details about how we process the data can be found in the Privacy policy document located at this page: Privacy policy

4. Specific instructions

Under this contract, the Client gives the following specific instructions to the Processor:

• To collect and process personal data received from the Client directly for the purpose provided in the article 1 from the Privacy policy page (Privacy policy)

• To send messages by email on behalf of the Client, for the service of sending notifications or documents by email (if this service is used by the Client);

• To collect and process the information sent by the Client to the TrafficManager Servers via the Website or Platform

• To facilitate the transmission of data to third-party advertising platforms (e.g., Meta, Google, TikTok) via API or S2S integrations as requested by the Client's use of the Platform features.

5. Duration of data processing

The duration of the processing of personal data is identical to the duration of the main Client Agreement.

6. Nature and purpose of data processing

The nature and purpose of the data processing are those established by the Client under the main Client Agreement, namely the provision of TrafficManager services, depending on the usage plan or package of services chosen.

7. Third Parties

All the Third parties, to whom TrafficManager may transfer the Client Data for processing are listed under the article 2 from the Privacy policy page (Privacy policy)

• Pursuant to this Article, the Client understands to authorize TrafficManager to process his data thru his third-party partners as listed in the Article 2 from the Privacy policy page.

• For all the future Third Parties that TrafficManager may use to process the Client data, TrafficManager receives a general authorization to subcontract to any other provider in the EU, EEA or country with an adequate level of protection recognized by a decision of the European Commission, which is necessary for certain parts of the data processing under this contract. an adequate level of security, at least at the level of this contract. This authorization includes the obligation to inform the Client, through a message through the account on the TrafficManager Website or by email. The client (the Data Controller) has the possibility to object within 10 working days.

8. Rights and Obligations of the Client

• The right to receive information from TrafficManager or to verify through a mandated auditor whether TrafficManager has and implements appropriate technical and organizational measures so that the processing complies with the requirements of the GDPR; the verification will take place on the basis of a prior written notification, sent at least 14 working days before the verification;

• The right to receive assistance from the Controller, in particular to fulfill his obligation to respond to the requests of data subjects regarding the exercise of their rights under the GDPR;

• The right to object to other third parties specified to the article 7.2

• To comply with its obligations under the GDPR as Client with regard to personal data collected or processed by TrafficManager, on its behalf.

• Obligation to inform data subjects under the GDPR, including information on the processing of data by TrafficManager under this contract

• Obligation to be solely responsible for establishing the legal basis for the processing of personal data covered by this contract

• The obligation to implement appropriate technical and organizational measures under the GDPR, including securing the transfer of data from data subjects to TrafficManager;

• The Client understands that from the moment of deleting the data after the end of the provision of services by TrafficManager according to the obligations of GDPR and art. 9 of this contract, the data can no longer be recovered, and it is the entire responsibility of the Client to ensure that it has made a complete copy of them.

• In all situations where the Client is the one who has to perform an obligation, such as, for example, informing the data subject about the breach of personal data security, TrafficManager cannot be held liable by the Client's inactions within the scope of that obligation.

9. Rights and Obligations of TrafficManager

• The obligation to inform the Customer immediately, if, in the opinion of TrafficManager, an instruction violates GDPR and / or other legal provision regarding the processing of personal data;

• The obligation to ensure the security of personal data processed on behalf of the Client in accordance with Article 32 of the GDPR and Article 10 of this Annex;

• Obligation to inform the Client without undue delay of a breach of the security of the Client's personal data during the processing performed by TrafficManager;

• Obligation to assist the Client with all information necessary for the notification, if any, to the Competent Authority for Data Security Infringement, but without substituting for the Client his obligation to notify;

• Obligation to assist the Client in ensuring compliance with the obligations set out in Articles 32-36 of the GDPR;

• The obligation to assist the Client in solving the requests of the data subjects or to send to the Client any request received from the data subjects, in connection with the personal data that have been collected and processed by TrafficManager, within maximum 5 calendar days from its receipt. This assistance does not apply if the Customer already has in the technical tools provided by TrafficManager the possibility to directly solve the request of the data subject (eg the platform Account access - where the Customer already has all the information about what data he collects);

• Obligation not to transmit personal data and / or confidential information, which may be personal data, of which he became aware during the performance of the contract

• The obligation to provide training to authorized personnel to process personal data, regarding the confidentiality of such data;

• The obligation to include confidentiality obligations towards employees and third parties;

• The right to disclose certain personal data by virtue of a legal obligation or other condition provided by law at the request of an authority, public institution or court.

• The right to recruit third parties according to article 7 of this Contract;

• The right to cover the costs generated by ensuring the assistance of the Client, by the Client, in the situations provided by GDPR according to art. 9, if they exceed the monthly cost of the services provided by TrafficManager;

• The right to use anonymized statistical information as a result of activities performed as a result of this contract or its entire activity;

• TrafficManager cannot establish purposes or means of processing personal data, these being established exclusively by the Client. The Client, as Data Controller, acknowledges that it has the sole responsibility for the accuracy, quality, and legality of the personal data and the means by which it acquired the personal data. TrafficManager, as Data Processor, provides the technical infrastructure to process such data solely according to the Client's configuration. The Client shall indemnify and hold TrafficManager harmless against any claims, damages, or fines arising from the Client's failure to correctly identify TrafficManager as a Data Processor (and not a Joint Controller) in its agreements with Affiliates or other third parties. Regarding any antifraud or fraud-scoring features provided by the Platform, the Client acknowledges that these are advisory risk indicators only. The Client remains the sole decision-maker regarding any actions taken (such as lead rejection) based on these scores, ensuring a path for human review as required by law.

10. Security

TrafficManager must comply with appropriate technical and organizational measures to ensure appropriate risk-related security measures in line with good industry practice. In determining the appropriate level of security, TrafficManager must take into account the current state of development, implementation costs and the nature, scope, context and purposes of the processing, as well as the risk with varying degrees of probability and seriousness to the rights and freedoms of individuals. and the risks that arise as a result of the processing, in particular those that may lead to, accidentally or illegally, the destruction, loss, alteration, or unauthorized disclosure of personal data transmitted, stored or processed in a otherwise, or to unauthorized access to them.

In this context, TrafficManager has established the internal application of the following organizational and technical security measures for the security of personal data, taking into account the type of activity performed:

• implementation of ISO27001 / ISO27017 / ISO27018 security standards

• periodic security audit performed by cybersecurity experts

• limited access to the database for a very small number of employees of TrafficManager

• permanent monitoring of access to the database

• encryption of the connection used by the Client to access the service using SSL

• encrypted client passwords

• regular backups

• data hosting exclusively on EU-based infrastructure (OVH Cloud)

• industry-standard hashing (SHA-256) for PII during API and S2S transmissions

Voluntarily, TrafficManager may send summaries of the conclusions of security auditors (after deletion of commercial or confidential information) made periodically to Customers to demonstrate its ongoing activities on this subject.

11. Limitation of liability

The Client agrees to exonerate TrafficManager from any liability for damages that may arise from:

• non-compliance with the contract due to events that exceed any responsibility of TrafficManager;

• compliance with the Client's instructions or non-compliance with the Client's instructions justified in advance by a notification regarding its illegality;

• the lack or vitiation of the consent of the data subjects or of the use of a wrong legal basis by the Client;

• non-compliance with the contract due to some actions of the Client.

12. Delimitation of liability

The Customer and TrafficManager define their responsibilities for ensuring the protection of personal data (e.g. ensuring the confidentiality or security of processing), depending on the access and effective control exercised over the data, both contractually and technically.

13. Entry into force and amendments

Precedence. In the event of any conflict or inconsistency between the terms of this GDPR Agreement and the terms of any Affiliate Agreement or other commercial contract between the Client and third parties, the terms of this Agreement shall prevail specifically regarding the data processing obligations and liabilities of TrafficManager.

This annex enters into force on May 20, 2018 and is valid until modified by TrafficManager and informing the Clients accordingly. Using the Account, Platform and/or our Services after the Clients informing means their consent to this document.

Date of last revision: 20 January 2026