Legal Documents

Cookie Policy

Thank you for using our services! All legal information related to Cointraffic website, platform and services can be found on this page.

In case you have any questions, or require additional support, please contact us by e-mail at [email protected], by phone +372 640 1051, or at: Cointraffic OÜ, Liivalaia 45, 10145, Tallinn, Estonia. Our support team will get back to you within 48 working hours. If your inquiry requires a more detailed answer, it might take up to 7 working days for processing your request.

By using our website, platform or services, you are agreeing to the below terms and policies, so please read them carefully.

This page was last updated on 29.07.2022.

This cookie policy ( “Cookie Policy”) provides information about how and when Cointraffic OÜ, registry code 14112292, address Liivalaia 45, 10145, Tallinn, Estonia ( “we” or “us”) use cookies when you visit the website https://cointraffic.com/ ( “Website”) or access the services provided on the Website. For additional details about the collection and use of personal data, please check our Privacy Policy. If you do not accept this Cookie Policy, please do not use our Website.

1. What Cookies are?

For almost any modern website to work properly, it needs to collect certain basic information on its users. Cookies are small text files placed on the browser or hard drive of your computer, mobile, or other device when you visit a website. Cookies are widely used when providing online services and help to make websites work, or work more efficiently as well as to provide information to the website owners.

Cookies do lots of different things, for example, remembering user preferences, letting users navigate between pages efficiently and generally improving the user experience. Cookies are not used to personally identify you in any way, nor will they damage your system or files.

Some websites may also contain images called ‘web beacons’ (also known as ‘clear gifs’). Web beacons only collect limited information, including a cookie number, a timestamp, and a record of the page on which they are placed. Websites may also carry web beacons placed by third party advertisers. These beacons do not carry any personally identifiable information and are only used to track the effectiveness of a particular campaign (for example by counting the number of visitors).

To find out more about cookies, visit this site.

2. Use of Cookies?

Like most Internet sites, our Website may use cookies and similar technologies like single-pixel gifs and web beacons. We may use on our Website the following cookies:

1. persistent cookies that last until you or your browser delete them or until they expire. Persistent cookies are used to create a database of your previous choices and preferences;
2. session cookies that last only while your browser is open and are automatically deleted when you close your browser. Session cookies are used to support functionality of the Website and understand your use thereof;
3. strictly necessary cookies that enable services you have specifically requested for, including to log into secure areas of Website;
4. functionality cookies that allow us to remember the choices that you make (e.g. user name or language) and provide you with more personal features;
5. analytical cookies that allow us to recognize and count the number of visitors to our Website, to see how visitors move around the Website when they are using it and to record which content viewers view and are interested in. This helps us to improve the service which we offer to you by helping us make sure our users are finding the information they are looking for; and
6. targeting or advertising cookies that allow us to deliver advertisements more relevant to you, but can also limit the number of times you see an advertisement, and be used to chart the effectiveness of an ad campaign by tracking users’ clicks.

Currently, we use the following cookies:

Cookie	Purpose
Session tracking cookies	These are first party cookies, which are both strictly necessary and functional. They gather information to maintain your login details throughout the session, avoiding re-authentication.
Site setting cookies	These are first party cookies, which store temporary information to enable site functionality and collect and hold certain information which improves your experience on the Website, e.g. by setting you the appropriate language.
Analytical cookies	These are third party analytical cookies which are offered by Google, that tracks and reports Website traffic. Google Analytics are used to collect information about how visitors use the Website, including details in respect of the number of visitors to the Website, where visitors have come to the Website from and the pages they visited. We use the information to compile reports about how visitors use Website and to help us improve the site. The cookies collect information in an anonymous form, (none of these cookies collect and/or store any personally identifiable information). In addition to ourselves, Google accesses the information collected by these cookies. Further details in respect of Google Analytics Cookie Usage can be found by here.
Advertising cookies	This Website uses the following third-party cookies for remarketing:Google Ads, an online advertising service offered by Google Inc. For more information on the Google privacy and cookie policy, please click here.Facebook Ads an online advertising service offered by Facebook Inc. For more information on the Facebook privacy and cookie policy, please click here.Linkedin Ads, an online advertising service offered by Linkedin Inc. For more information on the LinkedIn privacy and cookie policy, please click here.Adform Audience, an online advertising service offered by Adform A/S. For more information on the Adform privacy and cookie policy, please click here.

3. Control of Cookies

It is possible to tell your browser to reject cookies for all sites or specific sites. However, rejecting cookies is not recommended, as cookies are intended to improve your browsing experience. If you limit the ability of websites and applications to set cookies, you may worsen your overall user experience and/or lose the ability to access the services, since it will no longer be personalized to you. It may also stop you from saving customized settings, like login information.

If you do want to reject or opt out of cookies you can either manually delete them or set most browsers to prevent them from being placed. Browser manufacturers provide help pages relating to cookie management in their products. Please see below for more information:

1. Google Chrome
2. Mozilla Firefox
3. Opera

For other browsers, please consult the documentation that your browser manufacturer provides.

You may opt-out of third party cookies from Google Analytics on its website. You can opt out of interest-based targeting provided by participating ad servers through the Digital Advertising Alliance ( http://youradchoices.com ). In addition, on your iPhone, iPad or Android, you can change your device settings to control whether you see online interest-based ads.

Terms for Advertiser

Thank you for using our services! All legal information related to Cointraffic website, platform and services can be found on this page.

In case you have any questions, or require additional support, please contact us by e-mail at [email protected], by phone +372 640 1051, or at: Cointraffic OÜ, Liivalaia 45, 10145, Tallinn, Estonia. Our support team will get back to you within 48 working hours. If your inquiry requires a more detailed answer, it might take up to 7 working days for processing your request.

By using our website, platform or services, you are agreeing to the below terms and policies, so please read them carefully.

This page was last updated on 24.09.2025.

1. Applicability

These Terms of Service ( “Terms”) shall govern the commercial relationship between you and us. Where used in this Agreement, references to: (a) “we”, “our”, “us” means Cointraffic OÜ, registry code 14112292 and, as applicable, any of its directors, shareholders, employees and contractors, being a digital advertising network that provide services for products monetization and promotion, connecting advertisers and publishers through such service globally ( “Services”) and (b) “you” and/or “your” mean the individual or entity who wishes to use our Services as an advertiser through the platform available at https://cointraffic.com/ website ( “Website”).

By checking the box and clicking “I have read and accepted the Terms of Service” button, or by continuing to use any of our Services, you (a) confirm that you are aware and agree to be bound by the present Terms and other policies established by us, including Website Usage Policy, Cookie Policy and Privacy Policy, (b) represent and warrant that you are duly authorized and lawfully able to enter into the Agreement, and (c) that you are and will remain in compliance with these Terms.

Additional terms or service conditions may apply and be shown separately. These additional terms become part of your Agreement with us and all the policies made available to you therein must be followed.

If you do not agree to all the provisions of these Terms, then you may not use any of our Services.

2. Definitions and interpretation

For the purposes of the Terms, the following terms shall have the meaning as specified below:

Account: an account on the Platform, which is created through the Website and used to access your Wallet, payment details and other information.

Ads or Advertisement: any type of content (such as text messaging, audio and video files, rich media, content, text, and graphic text), including but not limited to, banners, buttons, pop-ups, pop-unders, lightbox interstitial and text links that are generally used as an advertisements, licensed and provided to us by you.

Agreement: any standard terms imposed by us to regulate the commercial relationship between you and us, including these Terms and Policies.

Banner: any banner, logo, Ad or other marketing material designed or created by us at your request.

Campaign: a “marketing operation” designating the operations set up with the aim, notably, of increasing traffic to your Site or other product linked with you.

Crowdsale: a public sale of Tokens organized and/or managed by you.

IPR: all patents, rights to inventions, utility models, copyright and related rights, trade marks, service marks, trade, business and domain names, rights in trade dress or get-up, rights in goodwill or to sue for passing off, unfair competition rights, rights in designs, rights in computer software, database right, topography rights, moral rights, rights in confidential information (including know-how and trade secrets) and any other intellectual property rights, in each case whether registered or unregistered and including all applications for and renewals or extensions of such rights, and all similar or equivalent rights or forms of protection in any part of the world.

Minimum Deposit: a minimum amount of payment that is allowed to be credited to the Account as prepayment for the Services. Such an amount is shown in the Account under “Add funds” tab and acts as the technical basis for the payment possibility.

Platform: a technological solution offered by us and available at the Website, enabling the presentation of Ads and publishing Press-Releases on Publisher Site(s).

Policies: Website Usage Policy , Cookie Policy, Privacy Policy and other policies imposed by us and published on the Website.

Press-Release: a written communication that reports specific but brief information about you, your Site or other product or service linked to you.

Publisher Site: a website of a publisher with whom we have entered into contract in order to display your Campaign Ads and/or publish your Press-Release(s).

Services: services we will provide to you via the Platform based on your insertion orders and in accordance with these Terms.

Site: a website or other product linked with you to which an Internet user may be directed through the Campaign Ads placed and/o Press-Release(s) published on the Publisher Site(s).

Terms: these terms of service imposed by us.

Token: a cryptographic token generated or to be generated and offered for sale by you.

VAT: a value added tax chargeable under Estonian law for the time being.

Wallet: a set of billing details and financial information associated with your Account.

Website: website located at https://cointraffic.com/ and all subdomains of such website.

References to the word “include” or “including” (or any similar term) are not to be construed as implying any limitation and general words introduced by the word “other” (or any similar term) shall not be given a restrictive meaning because they are preceded or followed by words indicating a particular class of acts, matters or things.

References to “persons” include private individuals, legal entities, unincorporated associations and partnerships and any other organisations, whether or not having separate legal personality.

Except where the context specifically requires otherwise, words importing one gender shall be treated as importing any gender, words importing individuals shall be treated as importing legal persons and vice versa, words importing the singular shall be treated as importing the plural and vice versa, and words importing the whole shall be treated as including a reference to any part thereof.

3. Account

3.1. Registration

In order to become an advertiser and start using the Services, you must first register an Account on the Platform and be in compliance with present Agreement (in case of using self-service) or register as an advertiser by contacting us directly for acceptance (in case you wish our management-service).

Self-service assumes that access to the Services shall be provided through your Account. Management-service assumes that assistance in using the Services and the Platform shall be provided by or with the assistance of our team

Any natural person older than 18 years with full active legal capacity or any legal person may apply for an Account. You must provide your real name(s) and full personal and/or company registration information including payment data, if required. All information you provide upon registration must be accurate and up-to-date. You may not provide any false information or create an Account for anyone other than yourself without respective authorization. The representative of a legal person making the Account on behalf of the legal person must ensure that he has all the necessary rights and powers to do that. In order to verify your Account, we may request additional verification information, such as a copy / scan of your passport, ID card, driver’s license, utilities bills and payment method details.

We reserve the right to accept or reject your Account registration request without additional explanation. Further, we reserve the right to define the scope of features, Services and tools available for your Account. Registering an Account on the Platform implies full and total acceptance of all our policies, including these Terms.

You are entirely responsible for maintaining the confidentiality of the information you hold for your Account, including your password, and for any and all activity that occurs under your Account as a result of you failing to keep this information secure and confidential. You have to notify us immediately, in case of any unauthorized use of your Account.

You may not transfer your Account to anyone without our explicit written permission and you may not use anyone else’s Account or password at any time without the express permission and consent of the holder of that Account. We cannot and will not be liable for any loss or damage arising from your failure to comply with these obligations. You will be held liable for losses due to someone else using your account or password as a result of your failing to keep your account information secure and confidential.

In case we find at our sole discretion that there is a threat that you are engaging in any suspicious activity, you have violated the Agreement or it is necessary for security reasons, we may temporarily suspend your Account until the cause for suspending your Account has been eliminated; or if that cannot be eliminated or you refuse or fail to eliminate it, block your Account and terminate the Agreement. For security reasons we may in addition block your access to the entire Website. You agree that we will not be liable to you or to any third party for termination of your access to your Account and/or the Website as a result of any violation of the Agreement by you. If your Account has been previously suspended or blocked, or during the time your Account has been temporarily blocked, for any of the above reasons, you may not create another Account without our prior express permission.

3.2. Inactive account

To use our Services, you must keep your Account active. If it is inactive for a period of 150 consecutive calendar days (i.e. you have left your Account balance unused during that time), we may deem your Account inactive. If your account is flagged as inactive, you will get a respective notification by email.

Inactive accounts will be charged an inactive account fee to preserve your data. If on the last day of the month your Account is marked inactive, an inactive account fee in the amount of EUR 50 will be deducted from your Account balance on the first day of the following month. In case of continuing inactivity after each following 3 months, a multiplier of 1.5 to the previous month’s inactive account fee amount will be applied.

If you re-start using our Services during this process, your Account will be immediately marked as active. You understand and agree that all fees already deducted during the inactive account process will not be returned even if your Account status becomes active again. All deducted fees will be displayed in your Account for your overview.

If your Account balance is below EUR 50 or below any amount that will as a result of multiplying the previous inactive account fee amount by 1.5, you will receive a deactivation warning email informing you that your Account will be deactivated after 30 calendar days because of: “Inactive account” status. If your account is not activated within 30 calendar days, it will be deleted without the option to restore it and all statistical data and other information will be completely removed.

In case you are no longer interested in using our Services and you wish to avoid the inactive account process, you must duly terminate your Agreement with us in accordance with these Terms.

4. Services

We shall provide the Services based on the insertion orders submitted via the Platform using reasonable care and skill. We shall use current Internet ad serving industry-standard security measures in connection with the provision of the Services.

Any Campaign is published under your responsibility. You declare and guarantee that any Campaign is in accordance with the laws and regulations in force, especially internet and advertising laws and does not infringe any third party’s intellectual property rights or privacy. We reserve the right to refuse to publish or to delete any Campaign which does not comply with laws and regulations in force. In this case no indemnity shall be claimed by you to us.

You acknowledge that we may reject any of your Campaigns at any time for whatever reason. We cannot bear any responsibility in case of illegal Campaign(s).

All statistics for the purposes of calculation of impressions and general delivery reporting are based on the statistical data in our reporting system. You fully acknowledge the trustworthiness of such data, which will prevail in the event of a dispute, with regard to the measurement of all impressions. Your Account statistics are available for the last 6-month period only. For getting statistics for more than 6-month range, you should do written request to us. Unless there any technical issues, the statistics on your Account are updated live. However, you agree that provided statistics are subject to validation by us, and are subject to change without prior notice.

We reserve the right to modify or discontinue, temporarily or permanently, the Services with or without notice to you and we shall not be liable to you or any third party for any modification to or discontinuance of these Services save for the return of any prepaid sums in connection with the provision of the Services which are subsequently not provided. We shall also have the right to make any changes to the Services which are necessary to comply with any applicable law.

4.1. Campaign Ads

We shall promote and display your Campaign Ads on the Publisher Sites and, at your request, create and design a Banner for your Campaign(s). We reserve the right to add, edit, or remove any Campaign settings or characteristics. Currently, we provide CPM (cost per mile: advertiser pays for each 1000 impressions delivered to it) pricing model. Each advertising format might have minimum and maximum prices, whereby we reserve the right to update minimum and maximum prices at any given time.

You must ensure that your servers support the traffic directed to your Site through the Ads we are serving. You acknowledge that we take in no way responsibility for the consequences in case your servers cannot support the traffic directed to your Site through the Campaign Ads. However, if such kind of failure happens, please send us an e-mail to [email protected]. Upon receipt of such e-mail we shall make our best reasonable efforts to resolve the failure, inter alia we have the right to suspend your Campaign.

4.2. Banner Creation

If you insert an order for design of a Banner for your Campaign, you shall provide us with all the information and content necessary for the creation of a Banner. You shall procure such content shall not include any of the following:

1. inappropriate content, including (i) content that incites hatred against, promotes discrimination of, or disparages an individual or group on the basis of their race or ethnic origin, religion, disability, age, nationality, veteran status, sexual orientation, gender, gender identity, or other characteristic that is associated with systemic discrimination or marginalization; (ii) content harasses, intimidates, or bullies an individual or group of individuals; (iii) content that threatens or advocates for harm on oneself or others or seeks to exploit others; (iv) promotions containing violent language, gruesome or disgusting imagery, or graphic images or accounts of physical trauma and/or (v) promotions containing obscene or profane language or that are likely to shock or scare;
2. misleading or unclear content, including (i) promotions of services or products that cannot be found from your Site; (ii) advertising that is not relevant to the Site; and/or (iii) any misleading and/or false information;
3. prohibited adult content, including (i) text, image, audio, or video of graphic sexual acts intended to arouse; (ii) content promoting underage, non-consensual, or other illegal sexual themes, whether simulated or real; and/or (iii) content that may be interpreted as promoting a sexual act in exchange for compensation, sexual exploitation of minors or marriage to a foreigner; and/or
4. deceptive investment content, including (i) promotions guarantying returns, if an opportunity sounds too good to be true; (ii) promotions offering to use retirement or pension funds for investment purposes; (iii) content that pressures to act quickly; (iv) promotions placing bonuses or discounts as a main massage of ad or offering bonuses higher than 50% in case of pre-sale of Tokens and higher than 30% in case of sale of Tokens; (v) promotions using words such as “invest” and “buy” in connection with a timer or bonuses / discounts; (vi) statements that the Client’s project is not scam; (vii) content promoting that the investment is no-risk investment and (viii) other deceptive investment advice and money-making opportunities.

You shall be obliged to approve any Banner before launching the Campaign and shall bear full responsibility for the information contained in the Banner, including regarding you, your Site and/or other product or service linked to you. You acknowledge and agree that Campaign shall not be launched until the relevant Banner is approved by you.

4.3. Press-Releases

We shall draft a Press-Release based on the content provided by you and publish it on the Publisher Sites. You shall procure such content shall not include any of the listed in section 4.2 and shall bear full responsibility for the information contained in the Press-Release regarding you, your Site and/or other product or service mentioned in the Press-Release. Upon your request, we shall make one round amendments to the Press-Release. We shall start publishing the Press-Release after receipt of your final approval. You shall be obliged to approve the Press-Release and/or any amendment thereof within five (5) business days as of receipt of the relevant draft.

We shall put the best efforts while providing our Services, but we do not guarantee the amount of interest given to your product or service, social media sharing of the Press-Release, traffic to the Publisher Site(s) or your Site or any other results that are not directly dependent on our efforts.

5. Your obligations and warranties

You shall have sole responsibility for ensuring the accuracy of all information provided to us and warrant and undertake to us that your employees and representatives assisting in the execution of the Agreement have the necessary skills and authority.

You represent and warrant that you comply with all applicable rules, regulations, codes of practice and laws relating to its use of the Services, including without limitation its obligations under the data protection, competition, e-commerce and equivalent legislation and hereby agree to indemnify and to keep us indemnified in respect of any and all costs, claims or proceedings whatsoever brought against us by any third party in connection with any breach of the same by you.

You represent and warrant that:

1. in case of being a legal entity, you are duly organized and validly existing under the laws of its country of incorporation; no actions for the dissolution, merger, division or transformation of you have been taken, no interim trustee has been appointed, no bankruptcy or reorganisation proceedings have been commenced and no bankruptcy petitions have been submitted with respect to you;
2. you have full authority and power to enter into this Agreement and perform your obligations hereunder;
3. the entry into and performance of this Agreement and the consummation of the transactions contemplated herein will not result in a breach of (i), in case of being a legal entity, the articles of association or any other constitutional documents, (ii) any judgement, decree or order of any court or any administrative act of any public body, (iii) any applicable law or permit, or (iv) any agreement or other undertaking binding on you;
4. you are not purchasing the Services for any illegal purposes and have all necessary permits and licenses for the display of the Campaign Ads, publishing Press-Releases and carrying out business activities in the relevant countries;
5. any information provided to us under this Agreement (including regarding your Campaigns) is true, accurate, correct and current;
6. you are the owner of each material and/or content or that you are legally authorized to act on behalf of the owner of such for the purposes of this Agreement;
7. all materials and/or content provided to us comply with all applicable laws, statutes, ordinances, and regulations and do not breach any rights of any person or entity including, without limitation, rights of intellectual property, publicity or privacy, or rights or duties under consumer protection, product liability, tort, or contract theories;
8. you have reviewed the Policies and will regularly check the Policies for updates and shall comply with such Policies, as well as updates to the same.

If your Campaign concerns the Crowdsale and/or otherwise relates to Tokens, you represent and warrant that:

1. you are not selling Tokens for any illegal purposes and have all necessary permits and licenses for the display of the Campaign Ads, publishing Press-Releases and carrying out Crowdsale and business activities in the relevant countries, including, but not limited to, (i) comply with all foreign exchange, anti-money laundering or regulatory restrictions applicable to the sale of Tokens and (ii) have all governmental or other consents that may need to be obtained; and
2. you shall make all the required actions in order to restrict the sale of the Tokens to citizens or residents of a geographic areas in which sale or use of the Tokens is prohibited by applicable law, decree, regulation or treaty.

You declare and guarantee that Campaigns, including your Site(s), do not:

1. promote goods, services or activities which are prohibited and promoting activity itself is in accordance with all applicable laws of jurisdictions to which your Site and/or Campaign is concerned (e.g. laws regulating services and products with special regulations);
2. contain malware, automatically downloaded content, malicious scripts or password phishing scams;
3. contain material that infringes the rights of any third parties (including but not limited to copyright and other intellectual property rights and personal rights) or which promotes copyright piracy (e.g. unauthorized MP3s, roms, ‘warez’, emulators, or cracks, etc);
4. contain material that infringes the rights of any third parties (including but not limited to copyright and other intellectual property rights and personal rights) or which promotes copyright piracy (e.g. unauthorized MP3s, roms, ‘warez’, emulators, or cracks, etc);
5. promote any type of hate-mongering (i.e., racial, political, ethnic, religious, gender-based, sexuality-based or personal, etc.);
6. contain inappropriate newsgroup postings or unsolicited e-mail (spam);
7. contain fraudulent or misleading material, false representations or notifications, including misleading information about products, services, or businesses;
8. contain false statements about your identity or qualifications;
9. promise products, services, or promotional offers that aren’t easily found from your Site and/or landing page;
10. impersonate entity, company or organization of a third person, and mimic functionality or warnings from the operating system, software or other content of a third person;
11. disclose personal or confidential information that is not publicly accessible, lacks required consent(s) or which disclosure is illegal due to other circumstances;
12. contain illegal, false or deceptive investment advice and money-making opportunities;
13. provide incentives of any nature to require or encourage users to click on advertisement banners (i.e., charity, sweepstakes, etc.);
14. contain material which reasonable public consensus deem to be indecent, immoral or other ways inappropriate;
15. direct to or be a site which is under construction or incomplete or a site with extremely limited audiences or viewership;
16. make use of suspicious campaign settings;
17. contain links to other sites, applications or any other type of content presenting the characteristics detailed above.

You shall be obliged as quickly as possible and within the agreed deadline to comment on and or approve materials under the Services, submitted by us. In addition, you undertake, as quickly as possible and within the agreed deadline to, implement changes on your Site or where it may otherwise be required by us, to comply with the terms of this Agreement.

You shall be obliged to inform us immediately of changes of your Site’s domain name, look or content of the Site and any other material information which may affect the Services delivered by us.

You shall not, and shall not assist or permit any third party, to: (a) use the Services to collect or store personally identifiable information; (b) misappropriate any part of the Services; and (c) breach any Company’s security measures.

You shall not and shall not attempt to: (a) resell, sublicense, lease, time-share, distribute or otherwise transfer to any third party its right to access and use the Platform or the Services; (b) reverse engineer, decompile or dissemble the Platform or any part thereof; (c) modify, copy or create derivative works of the Services or the Platform or any our graphics, creative, copy or other materials owned by, or licensed to us in any way, or (d) access the Platform or any part thereof for the purpose of building a competitive product or service or copying its features or user interface or authorize or permit a direct competitor to do so.

You shall ensure that each of your Sites contains a privacy policy that:

1. discloses (i) the usage of third-party technology, (ii) the data collection and usage resulting from the Services; and (iii) that third parties may be placing and reading cookies on end users’ browsers, or using web beacons to collect information in the course of Ads being served on your Sites;
2. includes information about end users’ options for cookie management; and
3. complies with all applicable privacy laws, rules and regulations.

You oblige to take all reasonable steps to ensure that an end user is provided with clear and comprehensive information about, and consents to, the storing and accessing of cookies or other information on the end user’s device where such activity occurs in connection with the Services and where providing such information and obtaining such consent is required by law.

It is your responsibility to ensure that your Campaign, including your Site, Ads and Press-Releases, always met the above requirements. We have the right to check your compliance with these Terms at any point during the time your Agreement with us is valid.

6. Fees, refunds and taxation

6.1. Fees and payment terms

You shall pay fees for the Services based on the invoices submitted by us. Unless agreed differently, you must load funds to your Wallet in advance. The funds from your Wallet may be spent on any Campaign type set up by you. If your Account balance becomes zero, all your Campaigns related with your Wallet will be immediately paused.

The fees for the Services provided by us are calculated based on the pricing model of the Campaign type chosen by you and, if applicable, statistics gathered by us. Amount of daily Campaign Ads spendings will be deducted from your Wallet balance on daily basis automatically. Amount payable for Banner creation and Press-Releases will be deducted from your Wallet automatically after ordering the relevant Service. All invoices generated by us shall be under automatic approval and must be paid in full by you. You agree that you are entitled to a refund for delivered Services only in cases explicitly set out in these Terms.

When you make a purchase, you agree to provide a valid funding account to proceed with payment. When you have successfully completed the funding transaction, we will then transfer that value to your Wallet balance and create an invoice. Pay attention to the details of the transaction, because your total price may include taxes and fees, all of which you are responsible for funding. Upon payment we may charge you with a processing fee or any other fee applicable by third party payment service provider.

You have the right to select any payment service provider available provided your transaction meets all of the criteria set in the terms and conditions for each payment method. You agree that we are not responsible for any actions applied by the payment service provider including but not limited to any additional transaction fees applied to your Account. We have the right to switch payment service provider(s) at any time without notifying you. For each payment method, there are different account thresholds for receiving and sending money that might be changed at any moment by us. We reserve the right to reject a financial operation or change the list of available payment options.

You are responsible for maintaining the security of your Account, and you understand that you will be charged for any orders placed on or through your account.

We have the right make adjustments to your Account balance due to technical reasons and/or fraudulent activity.

6.2. Bonuses

All bonuses earned or granted to you are not eligible for refund. Bonuses can be used for Campaigns only and are the last to be used.

6.3. Refunds

You are entitled to request for a refund in the following cases:

1. if there has been an incorrect payment transaction;
2. if you have made a prepayment and you prove that the actions forming the basis of the pricing model of your Campaign are based on a publisher’s fraudulent activities (i.e. the artificial increase of actions). In order to detect and prove publisher’s fraudulent activities you undertake to send to us a detailed report of sources/websites you consider to be fraudulent. In case the publisher’s fraudulent activities cannot be clearly identified based on your report, we are entitled to request additional proof from you. If you fail to submit a report or additional proof regarding the publisher’s fraudulent activities, we may refuse to give a refund and adjust your Account balance accordingly.
3. if at the end of the validity of the Agreement it appears that you have spent for the Services less than you have prepaid. In such a case you are entitled to ask for a refund within 30 days after the termination of the Agreement, provided that the amount of your unused Account balance is at least EUR 50. Before refunding, we will have to finalize all not invoiced spending and make necessary adjustments where needed. After finalizing all current statistics, your unused Account balance will be refunded to you at your request, minus an administrative fee of 15% (fifteen per cent) to cover our costs and fees related with the management of giving a refund, within 30 working days. Your refund will be created back to the same payment method and same payment account that you used to make your last payment. You may be required to provide additional information or documentation in order for us to confirm your identity, before any refund request is processed. Please be aware that if your Agreement with us is terminated due to the violation of the Agreement by you, we are entitled to a contractual penalty in the amount of your unused Account balance and therefore, we may refuse to make you a refund by way of set-off of the claims.

Please note that, in an attempt to fulfill clients’ expectations of services provided, the funds in the amount of the Minimum Deposit, which were paid for the first time to the account, are considered non-refundable and subject to being spent in full on the Platform.

You agree that transaction fees could be applied to refunded payment(s), so we reserve the right to deduct all transaction fees from your Account balance.

6.4. Taxation

If according to applicable law it is your responsibility to declare, pay or withhold taxes on or from your transactions with us, you agree to indemnify and hold us harmless from and against any claim arising out of your failure to do so. We perform our tax obligations according to the tax laws of the Republic of Estonia. All payments to you from us in relation to our Services will be treated as inclusive of tax (if applicable) and will not be adjusted.

6.5. Additional Actions

We may cancel any transaction if we believe the transaction violates the Agreement, or if we believe doing so may prevent financial loss. We may also cancel any income, bonuses, prepayment, and adjustments as a result of fraudulent or illegal activity. In order to prevent financial loss to you or to us, we may at our sole discretion and without incurring any liability, place a delay on a payment for a period of time, or limit funding instruments for a transaction, or limit your ability to request a payment, or suspend/block your Account. In order to prevent financial loss to you or to us, we may contact your funding instrument issuer, law enforcement, or affected third parties (including other users) and share details of any payments you are associated with, if we believe doing so may prevent financial loss or a violation of law.

If you leave your Account balance unused for 150 consecutive days, or if you delete your account and leave a balance, or if we suspend your Account and you do not meet any conditions necessary to reinstate it within 150 days, we may process your Account balance to zero in accordance with these Terms. If your Agreement with is terminated due to the violation of the Agreement by you, we are entitled to a contractual penalty in the amount of the balance of your blocked Account and therefore, we may refuse to make any payments to you by way of set-off of the claims.

7. Delays and complaints

In the event that you prove that the Services are delayed or not in accordance with the Agreement, we shall be obliged to remedy or redeliver, at our own discretion, without undue delay. In the event that the Services continue to be not in accordance with the Agreement after reasonable attempts have been made to remedy this, you shall be entitled to cancel the relevant order in accordance with section 13, provided that the breach is material.

Complaints concerning delays or breach of the Agreement shall be submitted immediately after the time when you became or should have become aware of the matter. If you fail to bring the breach (unless by its very nature it is impossible to ascertain within such a period) to our attention within 48 hours you shall be deemed to have accepted the Services and shall not be entitled to assert remedies based on delays or breach of Agreement.

Your exclusive remedies for late delivery or Services not conforming with the Agreement are as specified in this section 7 and, if the remedies set out in this Agreement have been exhausted, your final remedy is limited to cancellation of the Agreement and our sole liability is to refund any payments for Services not conforming with the Agreement, subject to the limitations set out in sections 10 and 11 below.

8. Intellectual property

It is your responsibility to ensure that you have the right to use any IPR when you provide any text, image or representation ( “Materials”) to us for incorporation into the Services (including content of Ads, banners and information for Press-Releases) and you hereby grant or agree to procure the grant of (as applicable) an irrevocable, unconditional and fully paid-up licence to us, our affiliates and publishers to use such Materials and your trademarks for the purposes of providing the Services.

You shall be responsible for ensuring that the contents of Materials which you have contributed or approved are not in contravention of legislation, decency, marketing rules or any other third-party rights. We shall be entitled to reject and delete such material without incurring any liability. In addition, we shall be entitled to cancel the relevant order.

You shall indemnify us against all damages, losses and expenses suffered or incurred by us as a result of the Materials which you have contributed or approved being in contravention of legislation, decency, marketing rules or any action that any such Materials infringe any IPR of a third party.

All IPR, both economic and moral, in (a) the Services and the Platform, (b) our trademarks and (c) any goodwill, derivative works, improvements and/or intellectual property associated with the foregoing, are owned by us. Unless expressly stated otherwise in this Agreement, the IPR created, developed, subsisting or used in connection with the Services and whether in existence at the date hereof or created in the future shall vest in us and be our property or the relevant third party from whom we have acquired a right of use with a view to executing the Agreement. You agree to execute and deliver such documents and perform such acts as may be necessary from time to time to ensure such IPR vest in us.

If we make Banners, draft Press-Releases or create other materials available to you as part of the execution of the Agreement, you shall only acquire a non-exclusive personal non-transferable license to use such material until the Services under this Agreement cease. Except as expressly stated herein, nothing in this Agreement is intended to grant you any rights to any of our trademarks, service marks, copyrights, patents or trade secrets. All rights not expressly granted in this Agreement are reserved by us.

9. Liability, indemnity

You are fully responsible for the due performance of your obligations under the Agreement and must compensate to us any and all damages caused by the non-performance or unsatisfactory performance of your obligations.

You agree to indemnify, hold and defend us, our officers, directors, shareholders, predecessors, successors in interest, employees, agents, clients and partners, harmless from any demands, loss, liability, claims or expenses, made against us by any and all third-party claims and liabilities arising out of or related to or in connection with: (a) your sale of Tokens; (b) actions taken by legislatures or regulatory agencies in any jurisdiction affecting the Tokens; (c) purchase and use of the Services and/or the Platform; (d) any content or materials provided by you to us; (e) any breach or alleged breach of any of the representations, warranties, declarations, undertakings or statements made by you; (f) violation of these Terms and/or Policies and/or other mutual agreement between you and us; and/or (g) violation of any law, rule or regulation, or any rights of any other person or entity. You shall notify us immediately of any matter which could result in any loss, claim, damage, expense or liability subject to indemnification under this section. Such notification will not release you from your indemnification duty. We reserve the right to exercise sole control over the defence, at your expense, of any claim subject to indemnification under this section.

In case of delay with any payments you will pay us a penalty for late payment in the amount of zero point five percent (0,5%) of the outstanding amount per day.

You agree that we are entitled to demand you to pay a contractual penalty and/or cancel the provision of the relevant Service in the following cases:

1. if you fail to undertake those acts or provide those materials or approvals required under these Terms within any specified or agreed deadline, we may demand from you a contractual penalty in the amount of 30% (thirty per cent) of price of the relevant Service ordered by you;
2. If your Agreement with us is terminated due to the violation of Agreement by you (e.g. due to your fraudulent activity), we may demand from you a contractual penalty in the amount of your unused balance and set-off our claim for the contractual penalty against your claim for payment; and
3. If you do not have any of the necessary rights, permits or licenses required for the display of the Campaign ads, or publisher Press-Release or the operation of your Site(s) and/or business activities in the selected countries and you have not notified us thereof, we may demand from you a contractual penalty in the amount of EUR 10 000 for each breach.

In case the contractual penalty does not cover our actual damages, we may also demand for compensation for damages exceeding the penalty.

10. Disclaimer of warranty

SUBJECT TO WARRANTIES GIVEN BY US UNDER SECTION 4, NEITHER WE NOR ANY PERSON ASSOCIATED WITH US MAKE OR GIVE, NEITHER EXPRESSLY NOR IMPLIED, ANY PROMISE, WARRANTY OR REPRESENTATION AS TO, AND DOES NOT ACCEPT ANY LIABILITY IN RESPECT OF THE ACCURACY, COMPLETENESS, RELIABILITY, TIMELINESS, QUALITY OF THE SERVICES OR THEIR CORRESPONDENCE WITH DESCRIPTION OR AS TO THEIR FITNESS FOR A PARTICULAR PURPOSE OR AS TO THE TITLE AND NON-INFRINGEMENT (INCLUDING WITHOUT LIMITATION NON-INFRINGEMENT OF THIRD PARTY RIGHTS), PRODUCTIVENESS OR CAPACITY. THE PLATFORM AND THE SERVICES ARE PROVIDED ON AN “AS IS” AND “AS AVAILABLE” BASIS.

NEITHER WE NOR ANY PERSON ASSOCIATED WITH US MAKE ANY PROMISE, WARRANTY OR REPRESENTATION THAT THE FUNCTIONS CONTAINED IN THE PLATFORM AND/OR THE SERVICES WILL BE CORRECT, UNINTERRUPTED OR ERROR-FREE, THAT ANY DEFECTS WILL BE CORRECTED. WE CANNOT ENSURE THAT ANY FILES OR OTHER DATA YOU DOWNLOAD FROM THE WEBSITE WILL BE FREE OF VIRUSES OR OTHER HARMFUL COMPONENTS, OR THAT THE PLATFORM AND THE SERVICES WILL OTHERWISE MEET YOUR NEEDS OR EXPECTATIONS.

WE DISCLAIM ANY AND ALL LIABILITY FOR THE ACTS, OMISSIONS AND CONDUCT OF ANY THIRD PARTIES (INCLUDNIG PUBLISHERS) IN CONNECTION WITH OR RELATED TO YOUR USE OF THE PLATFORM AND/OR ANY SERVICES. WE DO NOT BEAR ANY RESPONSIBILITY IN CASE OF ILLEGAL ADVERTISEMENT OR ILLEGAL CONTENT PUBLISHED ON THE PUBLISHER’S SITE(S).

YOU UNDERSTAND AND ACKNOWLEDGE THAT THERE IS NO GUARANTEE THAT ANY MINIMUM LEVEL OF INTEREST (INCLUDING A CERTAIN NUMBER OF CLICKS, REGISTRATIONS, PURCHASES OR THE LIKE) WILL BE GENERATED AS A RESULT OF PROVISION OF THE SERVICES, OR THAT USE OF THE SERVICES WILL PROVIDE ANY SPECIFIC RESULTS. YOUR SOLE REMEDY AGAINST US FOR DISSATISFACTION WITH ANY SERVICES IS TO STOP USING ANY SUCH SERVICES.

THE FOREGOING DISCLAIMER OF WARRANTY IS MADE TO THE FULLEST EXTENT PERMITTED BY LAW AND IS A FUNDAMENTAL PART OF THE BASIS OF OUR BARGAIN HEREUNDER, AND THAT WE WOULD NOT ENTER INTO THIS AGREEMENT ABSENT SUCH DISCLAIMER.

11. Limitation of Liability

No claim for a breach of any our representation or warranty shall be actionable or payable if the breach in question results from or is based on a condition, state of facts or other matter which was disclosed to you and/or actually known by you.

We reserve the right to do any of the following, at any time, without notice, to: modify, suspend or terminate operation or access to the Website, the Platform or the Services for any reason; modify or change the Website, the Platform or the Services and any applicable policies or terms; and/or interrupt the operation of the Website, the Platform or the Services as necessary to perform routine or non-routine maintenance, error correction, or other changes.

We shall not be liable for downtimes, interference in the form of hacking, virus, disruptions, interruptions, faulty third-party software, search engines or websites on which a Service is dependent or other deliveries from a third party.

To the fullest extent permitted by applicable law, you release us from responsibility, liability, claims, demands and/or damages (actual and consequential) of every kind and nature, known and unknown, arising out of or related to the acts or omissions of publishers or any third parties, including in connection with illegal advertisement or illegal content published on the Publisher Site(s).

TO THE MAXIMUM EXTENT PERMITTED BY LAW, (A) IN NO EVENT SHALL WE, OUR LICENSORS, AFFILIATES, EMPLOYEES, AGENTS, OFFICERS OR DIRECTORS BE LIABLE TO YOU OR ANY THIRD-PARTY FOR ANY SPECIAL, PUNITIVE, INCIDENTAL, INDIRECT OR CONSEQUENTIAL DAMAGES OF ANY KIND, OR ANY DAMAGES WHATSOEVER, INCLUDING, WITHOUT LIMITATION, THOSE RESULTING FROM LOSS OF USE, LOSS OF DATA, LOSS OF REVENUE, LOSS OF PROFITS OR DAMAGES FOR BUSINESS INTERRUPTION, WHETHER OR NOT WE HAVE BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES, AND ON ANY THEORY OF LIABILITY, ARISING OUT OF OR IN CONNECTION WITH THE USE OF THE PLATFORM OR OF ANY SERVICES, AND (B) OUR AGGREGATE LIABILITY UNDER THIS AGREEMENT OR IN ANY OTHER WAY SHALL ONLY BE FOR DIRECT DAMAGES AND SHALL NOT EXCEED THE LOWER OF EUR 5,000 OR THE NET AMOUNT RECEIVED AND RETAINED BY US IN CONNECTION WITH THIS AGREEMENT WITH YOU DURING THE THREE MONTH PERIOD IMMEDIATELY PRECEDING THE DATE OF THE CLAIM.

Any claim under the Agreement must be brought within six (6) months after the cause of action arises, or such claim or cause of action is barred.

The provision of this section 11 determine the allocation of risks between you and us, and you agree and acknowledge that such allocation of risks and the limitations of liability specified herein are an essential basis of the bargain between you and us.

12. Force majeure

We shall not be liable for delays, failure in performance or interruption of the Services which result directly or indirectly from any cause or condition beyond its reasonable control, including but not limited to, any delay or failure due to any act of God, act of civil or military authorities, act of terrorists, civil disturbance, war, strike or other labour dispute, fire, interruption in telecommunications or Internet services or network provider services, failure of equipment and/or software, other catastrophe or any other occurrence which is beyond its reasonable control ( “Force Majeure Event”).

If a party believes that a Force Majeure Event has occurred, such party shall immediately inform the other party of the start and end of the Force Majeure Event.

Notwithstanding the other provisions of this Agreement, each party shall be entitled to terminate the Agreement without liability to the other by written notice to the other party in the event that the performance of the Agreement is impeded for more than thirty (30) days due to a Force Majeure Event.

13. Duration and termination

Your Agreement with us becomes effective upon registration of your Account or upon signing any additional agreement with us and is valid for unspecified period.

Each party is within its rights entitled to terminate the Agreement, for any reason, by registered mail (with notice of delivery) or by e-mail, sent by you to [email protected] or by e-mail from us to the e-mail address you have previously provided, giving at least 24 hours prior notice.

Provided that we have made available such a possibility, you may also terminate the Agreement by deleting your Account from the Platform. You as an advertiser may be given such an option only if your Account has no un-invoiced spending and/or unpaid invoices. You can delete your Account by way of pressing the delete button on your Account. After that we will send you an e-mail with confirmation link. If you confirm your wish to delete your account, the Agreement will be deemed terminated, your access to your Account will be closed and the provision of all our Services to you stops.

Provided there is a good reason, both you and us may terminate the Agreement also immediately without prior notice. We may do so inter alia if:

1. we are required so by a facially valid subpoena, court order, or binding order of a governmental authority;
2. you have delayed your payment under the Agreement by more than ten (10) days;
3. you have failed to comply with any applicable laws, directives, rules and/or regulations;
4. we reasonably suspect that you are in breach of any of your warranties and representations given under these Terms;
5. you materially breach any other obligation under these Terms or Policies and fail to remedy such breach within a reasonable time granted by us;
6. in respect of you, a liquidator, receiver or administrative receiver is appointed, you are adjudicated as bankrupt, or declared as insolvent;
7. this opportunity is set forth in any other provision of these Terms.

Upon termination of the Agreement your Account is immediately archived. If there was an unused balance on your Account, you are entitled to a refund in accordance with this Agreement.

All provisions of the Agreement which by their nature extend beyond the expiration or termination of this Agreement shall survive the termination of this Agreement. Termination of this Agreement will not prejudice any right of action or remedy which may have accrued to you or us prior to termination (as the case may be).

14. Confidentiality

You agree to keep all details of the contractual relationship between you and us confidential (including but not limited to information about our Services, technology, software, statistics, price rates and all info explicitly marked as confidential), and not to disclose information of any nature exchanged (including communication sent to you by us) before or during the term of the Agreement to any third parties. You shall use the same degree of care to protect the confidential information as you use to protect your own most highly confidential information, but in no circumstances less than reasonable care, and shall not disclose confidential information to any person or entity other than your officers, employees and consultants who need access to such confidential information in order to effect the intent of this Agreement and who have entered into written confidentiality agreements with you consistent with this section 14.

You as an advertiser undertake not to use the information about our publishers directly or indirectly for your own or third party’s commercial benefit or in order to compete or cause prejudice to our activities in any manner whatsoever.

The duty of confidentiality does not apply to any use or disclosure authorised by us or as required by law or any information which is already in or becomes available to the general public other than through your unauthorised disclosure. In addition, you may disclose relevant information to your auditors, attorneys, credit and financial institutions, provided that the latter are also bound by a duty of confidentiality.

You agree that we may disclose the fact that we have promoted your Campaigns and include your name, logo and other brand features in our presentations, marketing materials, customer lists, financial reports and on our Website. You grant us an irrevocably licence to use and display your name, figure, logo etc. as a reference on the Website, other marketing materials or types of media.

15. Notices

You agree that we may communicate with you electronically any finance information related to your Account. We may also provide notices to you by posting them in your Account on the Website, or by sending them to an email address that you have previously provided to us. Website and email notices shall be considered received by you within 24 hours of the time posted or sent.

16. Changes

We reserve the right, at our sole discretion, to change, modify, add or remove any part of these Terms, at any time. We will notify you about the changes to the Terms either by e-mail, your Account (if any) or through the Website. Your continued use of our Services or the Platform means that you accept and agree to the changes.

This version was last updated on 07.06.2019 and historic versions can be obtained by contacting us.

17. Governing law and jurisdiction

The Agreement shall be governed by and construed in accordance with the laws of the Republic of Estonia without regard to its principles and rules on conflict of laws.

Any dispute arising out or in connection with the Agreement will be finally settled by the Arbitration Court of the Estonian Chamber of Commerce and Industry in Tallinn on the basis of the regulation of the aforementioned Arbitration Court. The arbitral tribunal proceedings will be conducted in English. The arbitration will be held by one arbitrator mutually agreed upon by the Parties, and if no agreement can be reached, then by one arbitrator who is chosen by the Council of the Arbitration Court of the Estonian Chamber of Commerce and Industry.

18. Miscellaneous

There is no relationship of exclusivity, partnership, joint venture, employment, agency or franchise between you and us under this Agreement. None of us has the authority to bind the each other (including the making of any representation or warranty, the assumption of any obligation or liability and/or the exercise of any right or power), except as expressly provided in this Agreement.

Whenever possible, each provision of this Agreement will be interpreted in such a manner as to be effective and valid under applicable law but, if any provision of this Agreement is held to be invalid, illegal or unenforceable in any respect, such provision will be ineffective only to the extent of such invalidity, or unenforceability, without invalidating the remainder of this Agreement or any other provision hereof.

This Agreement constitutes the full and entire understanding and agreement between you and us regarding the subjects hereof and supersedes any agreement or understanding between you and us prior to signing of this Agreement.

Our failure to insist on or enforce strict performance of the terms and conditions of the Agreement shall not be construed as a waiver by us of any provision or any right it has to enforce the Agreement, nor shall any course of conduct between us and you or any other party be deemed to modify any provision of the terms and conditions of the Agreement.

This Agreement, and any rights and obligations hereunder, may not be transferred or assigned by you, but may be assigned by us without restriction, including without limitation to any third party. Any attempted transfer or assignment in violation hereof shall be null and void. Subject to the foregoing, this Agreement will bind and inure to the benefit of us and you, respective successors and permitted assigns.

A person who is not a party to this Agreement has no right to rely upon or enforce any term of this Agreement.

19. Contact and complaints

In case you have any complaints, or require additional support, please contact us by e-mail at [email protected] or at: Cointraffic OÜ, Liivalaia 45, 10145, Tallinn, Estonia or by phone +372 6401051. Our support team will get back to you within 48 working hours. If your inquiry requires a more detailed answer, it might take up to 7 working days for processing your request.

Terms for Publisher

Thank you for using our services! All legal information related to Cointraffic website, platform and services can be found on this page.

In case you have any questions, or require additional support, please contact us by e-mail at [email protected], by phone +372 640 1051, or at: Cointraffic OÜ, Liivalaia 45, 10145, Tallinn, Estonia. Our support team will get back to you within 48 working hours. If your inquiry requires a more detailed answer, it might take up to 7 working days for processing your request.

By using our website, platform or services, you are agreeing to the below terms and policies, so please read them carefully.

This page was last updated on 29.07.2022.

1. Applicability

These Terms of Service ( “Terms”) shall govern the commercial relationship between you and us. Where used in this Agreement, references to: (a) “we”, “our”, “us” means Cointraffic OÜ, registry code 14112292 and, as applicable, any of its directors, shareholders, employees and contractors, being a digital advertising network that provide services for products monetization and promotion, connecting advertisers and publishers through such service globally ( “Services”) and (b) “you” and/or “your” mean the individual or entity who wishes to use our Services as a publisher through the platform available at https://cointraffic.com/ website ( “Website”).

By checking the box and clicking “I have read and accepted the Terms of Service” button, or by continuing to use any of our Services, you (a) confirm that you are aware and agree to be bound by the present Terms and other policies established by us, including Website Usage Policy, Cookie Policy and Privacy Policy, (b) represent and warrant that you are duly authorized and lawfully able to enter into the Agreement, and (c) that you are and will remain in compliance with these Terms.

Additional terms or service conditions may apply and be shown separately. These additional terms become part of your Agreement with us and all the policies made available to you therein must be followed.

If you do not agree to all the provisions of these Terms, then you may not use any of our Services.

2. Definitions and interpretation

For the purposes of the Terms, the following terms shall have the meaning as specified below:

Account: an account on the Platform, which is created through the Website and used to access your payment details, financial data and other information.

Ads or Advertisement: any type of content (such as text messaging, audio and video files, rich media, content, text, and graphic text), including but not limited to, banners, buttons, pop-ups, pop-unders, lightbox interstitial, Press-Releases and text links that are generally used as advertisements, licensed and provided to us by Advertisers.

Advertiser: any individual or entity with whom we have entered into agreement for promoting such person’s website, services and/or products through the Platform.

Advertising Format: a position and way of appearance of an Advertisement on the Publisher Site.

Advertisement Code: line or lines of code inserted within the source code of the Publisher Site that are designed to instruct the Internet user’s browser to make a request to the ad server in order to display an Advertisement.

Agreement: any standard terms imposed by us to regulate the commercial relationship between you and us, including these Terms.

Artificial Traffic: Impressions that result from a fault or whose origin is automatic operations not resulting from Internet user actions, or resulting from the intervention of elements including, but not limited to, bots, robots, requests emanating from electronic mail and chat rooms, script generators and links placed on sites unknown to us, Publisher or Advertiser, and any other click of unclear origin.

CPM or Cost per mille: the amount payable by us to Publisher for each 1,000 Impressions delivered to us.

Commission: designates the remuneration due to the Publisher within the terms of this Agreement.

Impressions: a measure of the number of times an Advertisement has been rendered on a user’s screen.

Platform: a technological solution offered by us and available at the Website, connecting Advertisers and Publishers using Services and enabling the presentation of Ads and publishing Press-Releases on Publisher Site(s).

Policies: Website Usage Policy, Cookie Policy, Privacy Policy and other policies imposed by us and published on the Website.

Press-Release: a written communication that reports specific but brief information about the Advertiser, its website or other product or service linked to the Advertiser.

Publisher: any individual or entity who has entered into this Agreement, in order to commercialize all or part of the advertising space on the Site(s) that it publishes.

Publisher Site or Site: any website owned and/or managed by Publisher containing places for displaying advertisements.

Terms: these terms of service imposed by us.

VAT: a value added tax chargeable under Estonian law for the time being.

Website: website located at https://cointraffic.com/ and all subdomains of such website.

References to the word “include” or “including” (or any similar term) are not to be construed as implying any limitation and general words introduced by the word “other” (or any similar term) shall not be given a restrictive meaning because they are preceded or followed by words indicating a particular class of acts, matters or things-

References to “persons” include private individuals, legal entities, unincorporated associations and partnerships and any other organisations, whether or not having separate legal personality.

Except where the context specifically requires otherwise, words importing one gender shall be treated as importing any gender, words importing individuals shall be treated as importing legal persons and vice versa, words importing the singular shall be treated as importing the plural and vice versa, and words importing the whole shall be treated as including a reference to any part thereof.

3. Account

3.1. Registration

In order to become a Publisher, you must first register an Account on the Platform and be in compliance with present Agreement (in case of using self-service) or register as a Publisher by contacting us directly for acceptance (in case you wish our management-service).

Self-service assumes that access to the Services shall be provided through your Account. Management-service assumes that assistance in using the Services and the Platform shall be provided by or with the assistance of our team.

Any natural person older than 18 years with full active legal capacity or any legal person may apply for an Account. You must provide your real name(s) and full personal and/or company registration information including payment data, if required. All information you provide upon registration must be accurate and up-to-date. You may not provide any false information or create an Account for anyone other than yourself without respective authorization. The representative of a legal person making the Account on behalf of the legal person must ensure that he has all the necessary rights and powers to do that. In order to verify your Account, we may request additional verification information, such as a copy / scan of your passport, ID card, driver’s license, utilities bills and payment method details.

We reserve the right to accept or reject your Account registration request without additional explanation. Further, we reserve the right to define the scope of features, Services and tools available for your Account. Registering an Account on the Platform implies full and total acceptance of all our policies, including these Terms.

You are entirely responsible for maintaining the confidentiality of the information you hold for your Account, including your password, and for any and all activity that occurs under your Account as a result of you failing to keep this information secure and confidential. You have to notify us immediately, in case of any unauthorized use of your Account.

You may not transfer your Account to anyone without our explicit written permission and you may not use anyone else’s Account or password at any time without the express permission and consent of the holder of that Account. We cannot and will not be liable for any loss or damage arising from your failure to comply with these obligations. You will be held liable for losses due to someone else using your account or password as a result of your failing to keep your account information secure and confidential.

In case we find at our sole discretion that there is a threat that you are engaging in any suspicious activity, you have violated the Agreement or it is necessary for security reasons, we may temporarily suspend your Account until the cause for suspending your Account has been eliminated; or if that cannot be eliminated or you refuse or fail to eliminate it, block your Account and terminate the Agreement. For security reasons we may in addition block your access to the entire Website. You agree that we will not be liable to you or to any third party for termination of your access to your Account and/or the Website as a result of any violation of the Agreement by you. If your Account has been previously suspended or blocked, or during the time your Account has been temporarily blocked, for any of the above reasons, you may not create another Account without our prior express permission.

3.2. Inactive account

To use our Services, you must keep your Account active. If it is inactive for a period of 150 consecutive calendar days (i.e. you have left your Account balance unused during that time), we may deem your Account inactive. If your account is flagged as inactive, you will get a respective notification by email.

Inactive accounts will be charged an inactive account fee to preserve your data. If on the last day of the month your Account is marked inactive, an inactive account fee in the amount of EUR 50 will be deducted from your Account balance on the first day of the following month. In case of continuing inactivity after each following 3 months, a multiplier of 1.5 to the previous month’s inactive account fee amount will be applied.

If you re-start using our Services during this process, your Account will be immediately marked as active. You understand and agree that all fees already deducted during the inactive account process will not be returned even if your Account status becomes active again. All deducted fees will be displayed in your Account for your overview.

If your Account balance is below EUR 50 or below any amount that will as a result of multiplying the previous inactive account fee amount by 1.5, you will receive a deactivation warning email informing you that your Account will be deactivated after 30 calendar days because of: “Inactive account” status. If your account is not activated within 30 calendar days, it will be deleted without the option to restore it and all statistical data and other information will be completely removed.

In case you are no longer interested in using our Services and you wish to avoid the inactive account process, you must duly terminate your Agreement with us in accordance with these Terms.

4. Site eligibility and approval

We, prior to you placing Ads on any Sites, must approve each Site. We reserve the right to deny, refuse, or revoke your participation, or the inclusion of any Site, on the Platform at any time in our sole discretion. To be eligible to participate, the Site must, at all times during the term of the Agreement comply with our policies provided herein. In addition, you grant us the right to access, index and cache your Site, or any portion thereof by automated means, including but not limited to web spiders or crawlers.

You represent and warrant that you are the owner of each Site or you are legally authorized to act on behalf of the owner of such Sites for the purposes of this Agreement. You further represent and warrant that you are not (a) engaged in money laundering or terrorist financing, (b) subject to any EU sanctions measures; (c) publisher of racist/pornographic/pressure group material or extreme political propaganda and (d) extreme political and/or charitable organization.

You represent and warrant that you obey the laws regarding copyright ownership and use of intellectual property. You declare and guarantee that you have the necessary legal rights to display that content protected by copyright law, if any, on your Site. This includes displaying copyrighted material, hosting copyrighted files, or providing links driving users to sites that contain copyrighted material. You declare and guarantee that you do not upload, download, display, perform, transmit, or otherwise distribute any content in violation of any third party’s copyrights, trademarks, or other intellectual property or proprietary rights. You declare and guarantee that you abide by laws regarding copyright ownership and use of intellectual property, and you shall be solely responsible for any violations of any relevant laws and for any infringements of third-party rights caused by any content you provide or transmit, or that is provided or transmitted using your Account. The burden of proving that any content does not violate any laws or third-party rights rests solely with you.

You shall inform our team at [email protected] prior to sending any traffic to us if your Site has ever been suspended and/or terminated for invalid traffic, spam, fraud, compliance issues or any breach of terms by a monetization provider, failing which, if brought to our notice, we reserve the right to suspend your Account, withhold any payments due to you and/or recover monies already paid.

On each Site approved by us, you agree (a) to comply with all applicable laws, corresponding to the place of collection of user data, and the place of residence of the user whose personal data is collected; (b) to get affirmative consent prior to the first occurrence that third parties may be placing and reading cookies on end users’ browsers to collect information in the course of the advertising or content being served; (c) to conspicuously display, maintain, and make readily accessible to end users, a privacy and cookie policies that complies with applicable law (including EU General Data Protection Regulation, if applicable) and provides information on end user’s data collection practices, including information on the kind of data collected, the purposes for which the data will be processed, any disclosures that will be made of the data and use of any tracking mechanism, information on how to disable those tracking mechanisms; and (d) to provide end users with the opt-out for receiving Ads.

In any event, you acknowledge yourself to be completely independent from us. Consequently, you state and guarantee to us that you have proceeded with, or will proceed with, at your own cost and as your sole responsibility, all the required administrative obligations (e.g. obligations related with social security, taxes and any other applied obligations) concerning the activities you perform via Website or Platform.

Furthermore, you agree to conform to all laws and regulations, decrees, orders and standard practice concerning the exercise of your activity or activities, whatever you may be, and to make sure personally that you have obtained all the relative authorizations, administrative or otherwise, required for this. You, as head of publication for your Site, carry the sole responsibility for its editorial content.

5. Advertisement placement

If your Site has been approved, you are entitled to install Advertising Code(s) within the source code of your Site and place the Ads and publish Press-Releases of Advertisers on your Site in compliance with these Terms. You agree that installation of the Advertisement Codes required to display the Advertisements on your Site is fully under your responsibility. You further agree and confirm that the Advertising Code may be placed only on Sites that have been approved by us. If you place the Advertising Code on a Site that has not been approved by us, we may void the Impressions related to such Site.

After placing the Advertising Code on the Site, we will perform an initial check of your submission regarding technical quality and determine if Ads can be displayed on your Site according to our advertisement placement policy.

Your Account identifies one or several unique Sites. If you wish to display Ads on several Sites (different names) you should register all of them in order to have a correct overview of your incomes. You may add and edit any Site from your Account at any time.

After publishing a Press-Release on your Site, you will have to add a link in the Platform to the published Press-Release and we will perform an initial check thereof. If Press-Release is published in compliance with these Terms, we will mark the publication as approved.

Visitors of your Site may not be misled in any way and should be able to easily distinguish content from Ads. You are prohibited from placing Ads under misleading headings or titles.

If pop-ups are displayed on your Site, they may not interfere with the site navigation, change user preferences, initiate downloads or distribute viruses. You must ensure that no ad network or affiliate or any other user uses such methods to direct users to pages that contain Advertising Code.

If you place third party ads on your Site, it should always be clear to Internet user that these ads are served by different advertising networks and that such ads have no association with us. Please also be aware that competitor ads are considered to be part of your Site content and must follow our quality and advertisement placement policies.

You may place Ads on password-protected pages as long as those pages comply with these Terms. When submitting application Site, please make sure to provide us with a non-password-protected page for review. If your pages require a login and irrelevant ads are appearing, we may ask you to provide us a demo account to access protected pages.

In addition, you agree not to place Advertisements on: (a) a page that contains only or principally advertising messages, (b) on any non-content-based page, (c) a page under construction or personal home pages; (d) on a free hosted page; or (e) pages where the bulk of the content is user-generated.

We shall have the right to place certain tracking technology in the Ads (such as tracking pixel(s) or any mechanism(s)) for observing, recording, analyzing and optimizing the performance of the Ads and the Site.

You may not, without our prior consent, change the agreed location of Advertising Formats or way of their appearance and, in case the Advertising Format includes static banners, not to place any new and/or additional advertising formats to your Site above our static banners or so that such new and/or additional advertising formats would negatively affect the visibility and/or effectiveness of our static banners. In case of publishing a Press-Release, if you may not, without our prior consent, change the content of the Press-Release and/or its visuals.

You are strictly prohibited from altering, changing or amending the Advertising Code and/or using a third party’s ad platform with the aim to alter, change or amend the Advertising Code, without our prior written consent. Further, using the Advertising Code inside the banner tags of other networks, ad servers or any other ad exchange system is strictly prohibited.

If an Advertisement is not in compliance with these Terms, you may remove the Advertising Code from your Site only after your have notified us thereof and we have failed to bring the Advertisement into compliance with the Agreement within 24 hours after receipt of the notice from you.

You acknowledge and agree that we have the right to request you to stop displaying Ads on all or some of your Site(s), irrespective whether that particular Site has been previously registered and validated or not. Should you refuse to comply with our request, we have the right to immediately terminate your Agreement with us.

6. Quality policy

You are responsible for keeping your Site always online, functional and reachable by the users from all over the world. You should always test your Site to make sure that it appears correctly in different browsers and monitor your Site’s performance and optimize load times. You must monitor your Site for hacking and remove hacked content as soon as it appears.

You must create a useful, information-rich Site with clearly and accurately described content. You are not allowed to create multiple pages, sub-domains, or domains with substantially duplicate content. You should avoid “doorway” pages created just for search engines, or other “cookie cutter” approaches such as affiliate programs with little or no original content.

You must provide unique and relevant content that gives Internet users a reason to visit your Site. Your Site should have a clear hierarchy and working text links. Every page should be reachable from at least one static text link.

You declare and guarantee that your Site is not and does not contain: (a) fully or partly not working Site; (b) Site without content; (c) violent content; (d) racial, ethnic, political, hate-mongering or otherwise objectionable content; (e) hate speech, harassment, bullying, or similar content that advocates harm against an individual or group; (d) excessive profanity; (f) hacking or cracking content; (g) illicit drugs and drug paraphernalia content; (h) content that promotes, sells, or advertises products obtained from endangered or threatened species; (i) software pirating; (j) investment, money-making opportunities or advice not permitted under law; (k) sales of illegal substances or activities (e.g. illegal online gambling, counterfiing money, etc); (l) content regarding programs which compensate users for clicking ads or offers, performing searches, surfing websites or reading emails; (m) content promoting underage, non-consensual, or other illegal sexual themes, whether simulated or real; (o) content that may be interpreted as promoting a sexual act in exchange for compensation, sexual exploitation of minors or marriage to a foreigner; (p) sales of illegal alcohol, tobacco or tobacco-related products, weapons or ammunition; and/or (q) any other content that is illegal, promotes illegal activity or infringes on the legal rights of others.

Publisher Site may not be loaded by anything that: triggers pop-ups automatically; modifies browser settings; redirects users to unwanted websites; and/or otherwise interferes with normal site navigation.

Although we do not have any obligation to monitor any materials or content available through the Site, we have the right to check your compliance with this Agreement at any point during the Agreement is valid. Failure to meet the conditions set forward (including engagement in fraudulent or illegal activity) may result in suspension or termination of the Agreement, blocking your Account and/or withholding any Account balance.

7. Prohibited activity

You are expressly prohibited from using any means, devices or arrangements to commit fraud, violate an applicable law, interfere with other affiliates or falsify information in connection with the Services or generating of remuneration or exceed your permitted access to our Services. Further, you are expressly prohibited from taking any of the following actions: (a) excessive page refreshes, generated either manually or automatically; (b) third-party programs with user incentives, such as spam email marketing, click-exchange programs, paid-to-surf or auto-surf programs; (c) using one or several maneuvers that give rise to Commission and/or (d) using automated online robots, or other deceptive software that are programmed to interact with Ads.

Besides artificial activity you must avoid the following techniques: automatically generated content; participating in link schemes; ad cloaking and sneaky redirects; hidden text or links or doorway pages; creating pages with malicious behavior, such as phishing or installing viruses, trojans, or other bad ware; make any modifications to the Advertising Code; generating Artificial Traffic by an Advertising Code; and/or intentional deception involving financial transactions.

You are prohibited from using deceptive implementation methods to obtain interaction with the Advertising Code, including offering compensation to Internet users for viewing Ads or performing searches, promising to raise money for third parties for such behavior. You shall not provide any text in or around the Ad units or include phrases that may mislead users or encourage them to click the Ads. Any ads that are disguised within the content and/or placed in a manner which cannot be distinguished from content are prohibited.

You represent and warrant that you will not (a) take any action that imposes, or may impose, in our sole discretion, an unreasonable or disproportionately large load on our Platform or otherwise make excessive demands on it and (b) disable, circumvent or otherwise interfere with security related features of our Services or features that prevent or restrict use or copying of any part of our Services, or which enforce limitations on the use of our Services.

You declare and guarantee that your Site does not offer for sale or promote the sale of counterfeit goods.

We actively monitor the quality of traffic coming to your Sites for continued compliance with our policies and maintenance of our quality standards. If we suspend you in any fraudulent activity we shall have the right, at our sole discretion, to ban your Account, suspend delivery of Ads to your Sites, withhold all payments due to you and take all necessary legal actions to restore the damage caused by such violation. All Advertisements carried out on your Site with fraudulent activities are not subject for payment.

Either direct or indirect, real or potential, the generation of Artificial Traffic by an Advertisement Code that belongs to your Account will entail the immediate termination of your Agreement and your disconnection from Platform, and the immediate, justified deletion of your Account with no liability for compensation due from us.

You must compensate to us any loss incurred to us with your fraudulent or other illegal activity. For compensation we may use any of your funds accessible to us by making settlements and deductions. We shall also be entitled to a refund of monies already paid to you with respect to Commission earned as a result of any non-compliance of these Terms.

8. Intellectual property

All intellectual property rights, both economic and moral, in (i) the Services and the Platform, (ii) our trademarks and (iii) any goodwill, derivative works, improvements and/or intellectual property associated with the foregoing, are owned by us. During the term of this Agreement, we grant you a non-exclusive, non-transferable, non-sublicensable license to use the Services and the Platform, solely as described this Agreement.

You shall not and shall not attempt to: (a) resell, sublicense, lease, time-share, distribute or otherwise transfer to any third party its right to access and use the Platform or the Services; (b) reverse engineer, decompile or dissemble the Platform or any part thereof; (c) modify, copy or create derivative works of the Services or the Platform or any our graphics, creative, copy or other materials owned by, or licensed to us in any way, or (d) access the Platform or any part thereof for the purpose of building a competitive product or service or copying its features or user interface or authorize or permit a direct competitor to do so. Except as expressly stated herein, nothing in this Agreement is intended to grant you any rights to any of our trademarks, service marks, copyrights, patents or trade secrets. All rights not expressly granted in this Agreement are reserved by us.

You represent and warrant that you maintain adequate rights in and to the Sites (including without limitation under the intellectual property rights in and to any third party content contained therein) in order to engage in the Platform, including without limitation the right to modify and create derivative works of any materials on your Sites.

The fact that you display on your Site the visuals and brand of an Advertiser gives you no intellectual property rights over the elements that constitute the brand or the products and services of the Advertiser.

9. Commission

You will receive from us Commission for displaying Ads and publishing Press-Releases on your Site. The amount of Commission for displaying Ads shall be based on the CPM applicable to a specific geo, demand and the price that the Advertiser sets in the campaign, whereby the maximum CPM shall be agreed with you. The amount of Commission for publishing a Press-Release shall be based on the prices set out in the Platform. All statistical data for the purposes of billing and general delivery reporting are based on our reporting system only.

Your daily Commission that you have earned based on the statistical data shall be added to your Account on the following day. You fully acknowledge the trustworthiness of such data, which will prevail in the event of a dispute, with regard to the measurement of all Impressions. Your Account statistics are available for the last 6-month period only. For getting statistics for more than 6-month range, you should do written request to us. Unless there any technical issues, the statistics on your Account are updated live. However, you agree that provided statistics are subject to validation by us, and are subject to change without prior notice.

If at the end of the validity of the Agreement it appears that you have on your Account balance un-invoiced Commission, you may request for the payment thereof within 30 days after the termination of the Agreement, provided that the amount of your un-invoiced Commission meet the payment threshold. However, if your Agreement with us is terminated due to the violation of the Agreement by you, we are entitled to a contractual penalty in the amount of your un-invoiced Commission and therefore, we may refuse to pay for you un-invoiced Commission by way of set-off of the claims.

We have the right to make adjustments to your balance in one of the following cases: (a) deduct transaction and payment fees, (b) due to technical reasons, (c) due to fraudulent activity, (d) due to Advertiser’s complaints or refunds and/or (e) on the basis of additional agreements with you.

10. Payment Terms

Minimum payment threshold for Publishers is EUR 25, before tax each month. Daily balance reports can be found in the Account. If your Account reaches the payment threshold, you will be able to submit a payment request, selecting a payment method available on the Website and specifying your payment details. You will bear the transaction, payment and currency exchange fees, if applicable.

When you request your payment, we will have up to 10 calendar days starting from the date of payment request to validate your request and up to 5 calendar days to proceed with the payment for validated requests. Each request is validated by us only after your Commission has been checked for any fraudulent activity.

We shall not be liable for any payment based on (a) any fraudulent impressions generated by any person, bot, automated program or similar device, as reasonably determined by us; (b) Ads delivered to end users whose browsers have the ads disabled; or (c) impressions co-mingled with a significant number of fraudulent impressions described in (a) above, or as a result of other breach of this Agreement by you. If your request is refused due to fraud, we have the right to apply all sanctions stipulated in the Agreement.

If the Commission is payable in bitcoins (BTC), the EUR/BTC exchange rate shall be fixed by us as at the moment of making the payment on the basis of rate determined by the relevant payment service provider (including BTC processing service provider).

As a Publisher you must ensure your capability to receive payments from us and submit valid payments details in the Account. If the receipt of Commission or any other payment from us fails or is delayed due to your failure to comply with this obligation (including if you have provided incorrect or wrong payment details), we shall not be liable for such failure or delay. In any event, all payments will be made at the payment details specified in your Account. If you believe that any fault in transaction has taken place, you agree to notify us immediately and, we will make all possible efforts to eliminate delays or errors in payment processing.

You agree that we are not responsible for any actions applied by the payment service provider including but not limited to any additional transaction fees applied to your account. We have the right to switch payment service provider(s) at any time without notifying you. For each payment method, there are different account thresholds for receiving and sending money that might be changed at any moment by us. We reserve the right to reject a financial operation or change the list of available payment options.

If a payment is aborted by a third-party payment provider and is returned to our account, we commit to return those funds to your Account. You agree that transaction fees could be applied to refunded payment(s), so we reserve the right to deduct all transaction fees from your Commission.

Unless expressly authorized in writing by us, you may not require us to transfer your Commission or any other payment you are entitled to under the Agreement to a third person.

We may, in our sole discretion, refuse to process a payment (and may place a payment hold) on any part of your Account, block your Account and terminate this Agreement, if we have a reasonable suspicion that you have breached any provision of this Agreement. We also reserve the right to set-off any amount you owe us, including for breaches of this Agreement.

Hereby you represent and warrant to provide us with all the documentation or its equivalents, needed for your identification, ascertainment of the legal fact and fulfillment of our obligations under this Agreement, within 5 business days from the date of request. In certain cases, we may withhold all payments until we will receive relevant documentation from you.

Any dispute regarding a payment of Commission must be submitted within sixty (60) calendar days of the date on which you were given the right to request the Commission, otherwise, it shall be deemed waived.

11. Self-billing, taxes

You as a Publisher order us to generate and issue you invoices on behalf of you. Following validation of your payment request and prior to making any payment to you as a Publisher, we will generate automatically through the Platform the invoice on behalf of you. Furthermore, you as a Publisher agree that the Platform will generate the said invoices based on the data provided to us and available from Account and agree that such date is accurate, fully and legally compliant for the purposes of invoicing and taxation. All of your paid invoices will be available to download in PDF format from your Account.

Any Publisher being a legal person and residing in the European Union who has provided a VAT number expressly warrants that such VAT number is, in its own country, valid for the issuance of invoices to us. You accept to be solely liable for any error, direct or indirect loss or damage arising from the inaccuracy or non-compliance of such data or the breach of any of the aforementioned warranties and, accordingly, you will hold us harmless from any of the direct or indirect loss or damages. You hereby confirm that another VAT invoice won’t be issued. You hereby agree to notify us if you (a) change your VAT registration number; (b) cease to be VAT registered; or (c) change your payment details.

In case there is any claim, administrative proceeding from any authority, dispute or conflict, in any way due to the inaccuracy or non-compliance of such data provided by you, we are expressly authorized to retain any payments due to you until such incident has been resolved.

We perform our tax obligations according to the tax laws of the Republic of Estonia. All payments to you from us in relation to our services will be treated as inclusive of tax (if applicable) and will not be adjusted. If according to applicable law it is your responsibility to declare, pay or withhold taxes on or from your transactions with us, you agree to indemnify and hold us harmless from and against any claim arising out of your failure to do so.

According to the Estonian Income Tax Act, upon making a payment to any Publisher being a legal person residing at low tax rate territory, an income tax at the rate of 20% shall be withheld by us from the amount of requested Commission. An income tax shall not be withheld by us if you provide us with documentation proving that more than 50 per cent of your annual income is derived from actual economic activity.

12. Liability, indemnity

You are fully responsible for the due performance of your obligations under the Agreement and must compensate to us any and all damages caused by the non-performance or unsatisfactory performance of your obligations.

You agree to indemnify, hold and defend us, our officers, directors, shareholders, predecessors, successors in interest, employees, agents, clients and partners, harmless from any demands, loss, liability, claims or expenses, made against us by any and all third-party claims and liabilities arising out of or related to or in connection with your use of the Website, including any served content that is not provided by us, your use of our Services and/or the Platform, or your breach of any term of these Terms, Website Usage Policy or other mutual agreement between you and us. You shall notify us immediately of any matter which could result in any loss, claim, damage, expense or liability subject to indemnification under this section. Such notification will not release you from your indemnification duty. We reserve the right to exercise sole control over the defence, at your expense, of any claim subject to indemnification under this section.

If your Agreement with us is terminated due to the violation of Agreement by you (e.g. due to your fraudulent activity), we may demand from you a contractual penalty in the amount of your un-invoiced Commission and set-off our claim for the contractual penalty against your claim for payment.

13. Disclaimer of warranty

THE PLATFORM AND THE SERVICES ARE PROVIDED ON AN “AS IS” AND “AS AVAILABLE” BASIS AND WITHOUT REPRESENTATIONS, WARRANTIES OR CONDITIONS, WHETHER EXPRESS, IMPLIED, STATUTORY OR OUT OF A COURSE OF DEALING OR USAGE OF TRADE, INCLUDING BUT NOT LIMITED TO IMPLIED WARRANTIES OR CONDITIONS OF MERCHANTABILITY, MERCHANTABLE QUALITY, FITNESS FOR ANY PARTICULAR PURPOSE OR USE, NONINFRINGEMENT (INCLUDING WITHOUT LIMITATION NONINFRINGEMENT OF THIRD PARTY RIGHTS), QUALITY, PRODUCTIVENESS OR CAPACITY, AND ALL SUCH WARRANTIES ARE HEREBY DISCLAIMED.

NEITHER WE NOR ANY PERSON ASSOCIATED WITH US MAKE ANY PROMISE, WARRANTY OR REPRESENTATION THAT THE FUNCTIONS CONTAINED IN THE PLATFORM AND/OR THE SERVICES WILL BE CORRECT, UNINTERRUPTED OR ERROR-FREE, THAT ANY DEFECTS WILL BE CORRECTED. WE CANNOT ENSURE THAT ANY FILES OR OTHER DATA YOU DOWNLOAD FROM THE WEBSITE WILL BE FREE OF VIRUSES OR OTHER HARMFUL COMPONENTS, OR THAT THE PLATFORM AND THE SERVICES WILL OTHERWISE MEET YOUR NEEDS OR EXPECTATIONS.

WE MAKE NO GUARANTEE REGARDING THE NUMBER, QUALITY, OR CONTENT OF ANY ADVERTISEMENTS OR THE TIMING OF DELIVERY OF SUCH ADVERTISEMENTS. WE SHALL NOT BE RESPONSIBLE FOR ANY ADS OR WEBSITES THAT ARE SERVED THROUGH OR LINKED FROM THE PLATFORM. WE DISCLAIM ANY AND ALL LIABILITY FOR THE ACTS, OMISSIONS AND CONDUCT OF ANY THIRD PARTIES IN CONNECTION WITH OR RELATED TO YOUR USE OF THE PLATFORM AND/OR ANY SERVICES, INCLUDING ANY ACTS OR OMISSIONS OF ANY ADVERTISER. WE CANNOT BEAR ANY RESPONSIBILITY IN CASE ILLEGAL ADVERTISEMENT OR ILLEGAL CONTENT PUBLISHED ON YOUR SITE.

YOU UNDERSTAND AND ACKNOWLEDGE THAT THERE IS NO GUARANTEE THAT ANY MINIMUM LEVEL OF IMPRESSIONS OR REVENUE, OR ANY IMPRESSIONS OR REVENUE, WILL BE GENERATED AS A RESULT OF THIS AGREEMENT, OR THAT USE OF THE SERVICES OR THE PLATFORM WILL PROVIDE SPECIFIC RESULTS. YOUR SOLE REMEDY AGAINST US FOR DISSATISFACTION WITH OUR PLATFORM OR ANY SERVICES IS TO STOP USING THE PLATFORM OR ANY SUCH SERVICES.

THE FOREGOING DISCLAIMER OF WARRANTY IS MADE TO THE FULLEST EXTENT PERMITTED BY LAW AND IS A FUNDAMENTAL PART OF THE BASIS OF OUR BARGAIN HEREUNDER, AND THAT WE WOULD NOT ENTER INTO THIS AGREEMENT ABSENT SUCH DISCLAIMER.

14. Limitation of liability

No claim for a breach of any our representation or warranty shall be actionable or payable if the breach in question results from or is based on a condition, state of facts or other matter which was disclosed to you and/or actually known by you.

We reserve the right to do any of the following, at any time, without notice, to: modify, suspend or terminate operation or access to the Website, the Platform or the Services for any reason; modify or change the Website, the Platform or the Services and any applicable policies or terms; and/or interrupt the operation of the Website, the Platform or the Services as necessary to perform routine or non-routine maintenance, error correction, or other changes.

TO THE MAXIMUM EXTENT PERMITTED BY LAW, (A) IN NO EVENT SHALL WE, OUR LICENSORS, AFFILIATES, EMPLOYEES, AGENTS, OFFICERS OR DIRECTORS BE LIABLE TO YOU OR ANY THIRD-PARTY FOR ANY SPECIAL, PUNITIVE, INCIDENTAL, INDIRECT OR CONSEQUENTIAL DAMAGES OF ANY KIND, OR ANY DAMAGES WHATSOEVER, INCLUDING, WITHOUT LIMITATION, THOSE RESULTING FROM LOSS OF USE, LOSS OF DATA, LOSS OF REVENUE, LOSS OF PROFITS OR DAMAGES FOR BUSINESS INTERRUPTION, WHETHER OR NOT WE HAVE BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES, AND ON ANY THEORY OF LIABILITY, ARISING OUT OF OR IN CONNECTION WITH THE USE OF THE PLATFORM OR OF ANY SERVICES, AND (B) OUR AGGREGATE LIABILITY UNDER THIS AGREEMENT OR IN ANY OTHER WAY SHALL ONLY BE FOR DIRECT DAMAGES AND SHALL NOT EXCEED THE LOWER OF EUR 5,000 OR THE COMMISSION PAYABLE BY US TO YOU OVER THE THREE MONTH PERIOD IMMEDIATELY PRECEDING THE DATE THE CAUSE OF CLAIM AROUSE.

Any claim under the Agreement must be brought within six (6) months after the cause of action arises, or such claim or cause of action is barred.

The provision of this section 14 determine the allocation of risks between you and us, and you agree and acknowledge that such allocation of risks and the limitations of liability specified herein are an essential basis of the bargain between you and us.

15. Force Majeure

You and us shall not be liable for delays or failure to perform under the Agreement which result directly or indirectly from any cause or condition beyond its reasonable control, including but not limited to, any delay or failure due to any act of God, act of civil or military authorities, act of terrorists, civil disturbance, war, strike or other labour dispute, fire, interruption in telecommunications or Internet services or network provider services, failure of equipment and/or software, other catastrophe or any other occurrence which is beyond its reasonable control and shall not affect the validity and enforceability of any remaining provisions (force majeure).

The party in default of force majeure shall immediately notify the other party of the occurrence of force majeure, shall make reasonable efforts to remove or overcome the effects of such occurrence or event; and shall resume performance of its obligations hereunder immediately after cessation of such occurrence or event.

16. Duration and termination

Your Agreement with us becomes effective upon registration of your Account or upon signing any additional agreement with us and is valid for unspecified period.

Each party is within its rights entitled to terminate the Agreement, for any reason, by registered mail (with notice of delivery) or by e-mail, sent by you to [email protected] or by e-mail from us to the e-mail address you have previously provided, giving at least 24 hours prior notice.

Provided that we have made available such a possibility, you may also terminate the Agreement by deleting your Account from the Platform by way of pressing the delete button on your Account. After that we will send you an e-mail with confirmation link. If you confirm your wish to delete your account, the Agreement will be deemed terminated, your access to your Account will be closed and the provision of all our Services to you stops.

Provided there is a good reason, both you and us may terminate the Agreement also immediately without prior notice. We may do so inter alia if:

1. we are required so by a facially valid subpoena, court order, or binding order of a governmental authority;
2. you fail to comply with any applicable laws, directives, rules and/or regulations;
3. you fail to comply with any of the requirements of our quality, advertisement placement or anti-fraud policies and/or Policies;
4. we reasonably suspect that you are in breach of any of your warranties and representations given under this Agreement;
5. you materially breach any other obligation of the Agreement and fail to remedy such breach within a reasonable time granted by us;
6. in respect of you, a liquidator, receiver or administrative receiver is appointed, you are adjudicated as bankrupt, or declared as insolvent;
7. this opportunity is set forth in any other provision of these Terms.

Upon termination of the Agreement your Account is immediately archived and you are required to remove promptly the Advertising Code installed on the pages of your Site(s).

All provisions of the Agreement which by their nature extend beyond the expiration or termination of this Agreement shall survive the termination of this Agreement. Termination of this Agreement will not prejudice any right of action or remedy which may have accrued to you or us prior to termination (as the case may be).

17. Confidentiality

You agree to keep all details of the contractual relationship between you and us confidential (including but not limited to information about our customers and business partners and their contact details, our products and services, technology, software, statistics, price rates and all info explicitly marked as confidential), and not to disclose information of any nature exchanged (including communication sent to you by us) before or during the term of the Agreement to any third parties. You shall use the same degree of care to protect the confidential information as you use to protect your own most highly confidential information, but in no circumstances less than reasonable care, and shall not disclose confidential information to any person or entity other than your officers, employees and consultants who need access to such confidential information in order to effect the intent of this Agreement and who have entered into written confidentiality agreements with you consistent with this section 17.

You specifically undertake not to use the information about Advertisers directly or indirectly for your own or third party’s commercial benefit or in order to compete or cause prejudice to our activities in any manner whatsoever.

The duty of confidentiality does not apply to any use or disclosure authorised by us or as required by law or any information which is already in or becomes available to the general public other than through your unauthorised disclosure. In addition, you may disclose (a) relevant information to your auditors, attorneys, credit and financial institutions, provided that the latter are also bound by a duty of confidentiality and (b) the amount of gross payments you have received from the use of our Services.

You agree that we may include your name, logo and other brand features in our presentations, marketing materials, customer lists, financial reports and on our Website. You also agree that we may use our Advertisement Code to enable third parties to collect information about the use of Site through use of cookies, web beacons and other similar technologies, including but not limited to third parties that collect statistical information in order to provide analytical services and third parties that collect non-personal identifiable information in order to provide targeted Advertisements.

18. Notices

You agree that we may communicate with you electronically any finance information related to your Account. We may also provide notices to you by posting them in your Account on the Website, or by sending them to an email address that you have previously provided to us. Website and email notices shall be considered received by you within 24 hours of the time posted or sent.

19. Changes

We reserve the right, at our sole discretion, to change, modify, add or remove any part of these Terms, at any time. We will notify you about the changes to the Terms either by e-mail, your Account (if any) or through the Website. Your continued use of our Services or the Platform means that you accept and agree to the changes.

This version was last updated on 26.11.2018 and historic versions can be obtained by contacting us.

20. Governing law and jurisdiction

The Agreement shall be governed by and construed in accordance with the laws of the Republic of Estonia without regard to its principles and rules on conflict of laws.

Any dispute arising out or in connection with the Agreement will be finally settled by the Arbitration Court of the Estonian Chamber of Commerce and Industry in Tallinn on the basis of the regulation of the aforementioned Arbitration Court. The arbitral tribunal proceedings will be conducted in English. The arbitration will be held by one arbitrator mutually agreed upon by the Parties, and if no agreement can be reached, then by one arbitrator who is chosen by the Council of the Arbitration Court of the Estonian Chamber of Commerce and Industry.

21. Miscellaneous

There is no relationship of exclusivity, partnership, joint venture, employment, agency or franchise between you and us under this Agreement. None of us has the authority to bind the each other (including the making of any representation or warranty, the assumption of any obligation or liability and/or the exercise of any right or power), except as expressly provided in this Agreement.

Whenever possible, each provision of this Agreement will be interpreted in such a manner as to be effective and valid under applicable law but, if any provision of this Agreement is held to be invalid, illegal or unenforceable in any respect, such provision will be ineffective only to the extent of such invalidity, or unenforceability, without invalidating the remainder of this Agreement or any other provision hereof.

This Agreement constitutes the full and entire understanding and agreement between you and us regarding the subjects hereof and supersedes any agreement or understanding between you and us prior to signing of this Agreement.

Our failure to insist on or enforce strict performance of the terms and conditions of the Agreement shall not be construed as a waiver by us of any provision or any right it has to enforce the Agreement, nor shall any course of conduct between us and you or any other party be deemed to modify any provision of the terms and conditions of the Agreement.

This Agreement, and any rights and obligations hereunder, may not be transferred or assigned by you, but may be assigned by us without restriction, including without limitation to any third party. Any attempted transfer or assignment in violation hereof shall be null and void. Subject to the foregoing, this Agreement will bind and inure to the benefit of us and you, respective successors and permitted assigns.

A person who is not a party to this Agreement has no right to rely upon or enforce any term of this Agreement.

22. Contact and complaints

In case you have any complaints, or require additional support, please contact us by e-mail at [email protected] or at: Cointraffic OÜ, Liivalaia 45, 10145, Tallinn, Estonia. Our support team will get back to you within 48 working hours. If your inquiry requires a more detailed answer, it might take up to 7 working days for processing your request.

Privacy Policy

Thank you for using our services! All legal information related to Cointraffic website, platform and services can be found on this page.

In case you have any questions, or require additional support, please contact us by e-mail at [email protected], by phone +372 640 1051, or at: Cointraffic OÜ, Liivalaia 45, 10145, Tallinn, Estonia. Our support team will get back to you within 48 working hours. If your inquiry requires a more detailed answer, it might take up to 7 working days for processing your request.

By using our website, platform or services, you are agreeing to the below terms and policies, so please read them carefully.

This page was last updated on 29.07.2022.

This privacy policy ( “Privacy Policy”) describes how Cointraffic OÜ, registry code 14112292, address Liivalaia 45, 10145, Tallinn, Estonia ( “we” or “us”), as a data controller, collect, use and disclose personal data, and the steps we take to protect such personal data, provided by you or collected by us either on the website https://cointraffic.com/ ( “Website”) or when you use the services or products that we provide or may provide in the future ( “Services”).

1. Data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

1. identity data, such as, first name, last name and date of birth;
2. contact data, such as, email address, mailing address and phone number;
3. financial data, such as, bank account, payment card details and billing address;
4. transaction data, such as, details about payments to and from you and other details of the Services you have purchased from us;
5. profile data, such as, username, account number or password;
6. technical data, such as, the Internet Protocol (IP) address used to connect your computer to the Internet, your login information (if applicable), browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our Website (including date and time), page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouseovers), methods used to browse away from the page and any information of yours related to contact our customer service team;
7. usage data, such as, information you viewed or searched for and information about how you use our Website and Services; and
8. marketing and communications data, such as, your preferences in receiving marketing from us and our third parties and your communication responses.

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

2. Methods of data collection

We use different methods to collect data from and about you including through:

1. direct interactions. You may give us your identity, contact and financial data by filling in forms or by corresponding with us by post, phone, email, skype and other messenger or otherwise. This includes personal data you provide when you apply for our Services, create an account on our Website, subscribe to our Service or publications, request marketing to be sent to you, enter a competition, promotion or survey, or give us some feedback, including report a problem with our Website;
2. automated technologies or interactions. As you interact with our Website, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive technical data about you if you visit other websites employing our cookies.
3. third parties or publicly available sources. We may receive personal data about you from public domain, third parties (such as, analytics providers, advertising networks, search information providers and providers of technical, payment and delivery services) or other websites we operate or the other services we provide.

Where we need to collect personal data by law, or under the terms of an agreement we have with you and you fail to provide that data when requested, we may not be able to perform the agreement we have or are trying to enter into with you, including to provide you with the Services. In this case, we may have to cancel the Services you have with us but we will notify you if this is the case at the time.

3. Use of your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

1. where we need to perform the agreement, we are about to enter into or have entered into with you;
2. where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
3. where we need to comply with a legal or regulatory obligation.

Legitimate interest means the interest of our business in conducting and managing our business to enable us to provide you with the best Services and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

Purpose or Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as our client and decide whether and on what terms to provide the Services	Identity, Contact and Financial	Performance of an agreement with you
To process and deliver the Services including, to (a) provide customer support and communicate with you, (b) manage payments and fees and verify transactions, (c) collect and recover fees owed to us, and (d) resolve disputes and enforce agreements entered between us	Identity, Contact, Financial, Transaction, Marketing and Communications	Performance of an agreement with you; Necessary for our legitimate interests
To prevent and investigate prohibited or illegal activities or fraud, including, prevent money laundering and terrorist financing	Identity, Contact, Financial, Transaction	Performance of an agreement with you; Necessary for our legitimate interests
To manage our relationship with you, including: (a) notifying you about changes to our Services, Website, general terms or this Privacy Policy and (b) asking you to leave a review or take a survey	Identity, Contact, Profile, Marketing and Communications	Performance of an agreement with you; Necessary to comply with a legal obligation; Necessary for our legitimate interests (to keep our records updated and to study how you use our Services)
To enable you to partake in a competition or complete a survey	Identity, Contact, Profile, Usage, Marketing and Communications	Performance of an agreement with you; Necessary for our legitimate interests (to study how you use our Services, to develop them and grow our business)
To administer, customize, update, maintain, protect and improve the Website and the Services (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Identity, Contact, Technical and Usage	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation); Necessary to comply with a legal obligation
To deliver relevant Website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	Identity, Contact, Profile, Technical, Usage, Marketing and Communications	Necessary for our legitimate interests (to study how you use our Services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our Website, Services, marketing, customer relationships and experiences	Technical and Usage	Necessary for our legitimate interests (to define types of clients for our Services, to keep our Website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about Services that may be of interest to you	Identity, Contact, Technical and Usage, Profile	Necessary for our legitimate interests (to develop our Services and grow our business)

We may use your identity, contact, profile, technical and usage data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which Services and offers may be relevant for you (we call this marketing). You may receive marketing communications from us if you have requested information from us or purchased Services from us and, in each case, you have not opted out of receiving that marketing.

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contact us at any time.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

4. Cookies and similar technologies

Like most Internet sites, our Website may use cookies and similar technologies to enhance your user experience and provide customization and useful features to our Website and Services. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this Website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

5. Disclosure of your personal data

Except as outlined in this Privacy Policy, your personal data will never be sold or disclosed with other companies or organizations for commercial purposes or otherwise.

We reserve the right at all times to disclose any personal data that we have collected when: (a) permitted or required by law; or, (b) trying to protect against, prevent, investigate actual or potential fraud, security issues, technical issues, unauthorized transactions or other violations; or (c) trying to enforce the applicable terms of service or other agreements; or (d) protecting against violations to the rights, property or safety of us, our users or the public as required or permitted by applicable laws; or (e) you have given your consent to do so. Finally, we may transfer personal data to a successor entity in connection with a corporate merger, consolidation, partial or total sale of assets, bankruptcy, or other corporate change.

We may disclose your personal data to our contractors (who may be located outside of the European Economic Area (“EEA”)) to process it for us, for the purposes of processing transactions, collecting fees, identifying you, but also for improving your user experience, performing business support functions or other related tasks, based on our instructions and in compliance with the Privacy Policy and any other applicable confidentiality and security requirements. In addition, transfers to our contractors are covered by the service agreements with such contractors. Such contractors, with whom we may have to share your personal data for the purposes set out above, currently include Freshdesk, Intercom, Adform, Google Analytics and Bitpay.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

1. we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries ;
2. where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries ;
3. where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

6. Data security

We adhere to the generally accepted industry standards to protect your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Only our authorized employees, agents and contractors (who have agreed to keep personal data secure and confidential) have access to the personal data on a need to know basis.

We store and process data, including personal data, in the EEA and possibly in other countries through third parties that we use to operate and manage the Services. When you access or use our Websites or the Services, or otherwise provide personal data to us, you are consenting, on behalf of you and your authorized agents, (and representing that you have the authority to provide such consent) to the processing and transfer of personal data in and to the other countries which may have different privacy laws from your or their country of residence. We will take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this Privacy Policy.

Any payment transactions will be encrypted. Where we have given you (or where you have chosen) a password, which enables you to access certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

You agree and acknowledge that the Internet may be subject to breaches of security and that the submission of data over the Internet may not be secure. We strive to use acceptable means to protect any personal data you share with us, however we cannot guarantee its absolute security.

7. Data retention

We will retain your personal data only for so long as it is required for the purposes for which it was collected. This period may extend beyond the end of your relationship with us, but only for so long as is reasonably necessary for us to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations (e.g. taxation purposes), resolve disputes and enforce our agreements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

When your personal data is no longer required, we will destroy, delete or convert it into an anonymous form.

8. Third-party links

The privacy practices set forth in this Privacy Policy apply to the Website and Services only. If you link to other web sites (including sites that offer or use the Services or are promoted by us) or use the services of other service providers, please review the privacy policies posted at those web sites or by the relevant service providers.

9. Age limitations

We do not allow use of our Services and the Website by anyone younger than 18 years old. If you learn that anyone younger than 18 has unlawfully provided us with personal data, please contact us and we will take steps to delete such information.

10. Your rights

Under certain circumstances, you have following rights under data protection laws in relation to your personal data:

1. right to request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it;
2. right to request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us;
3. right to request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request;
4. right to object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms;
5. right to request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it;
6. right to request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform an agreement with you; and
7. right to withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain Services to you. We will advise you if this is the case at the time you withdraw your consent.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

11. Changes to this privacy policy

We may change this Privacy Policy unilaterally and without prior notice, but any changes will be posted on the Website. If we make changes that materially alter your privacy rights, we will provide additional notice, such as via email or through the Services. If you disagree with the changes to this Privacy Policy, you should stop using our Services, the Website or any other aspect of our business. Your continued use of the Website or our Services constitutes your agreement to all such changes.

This version was last updated on 11.05.2018 and historic versions can be obtained by contacting us.

12. Contact and complaints

For further information regarding the Privacy Policy and related practices or in case of any suspected infringement of your privacy, please contact us at [email protected] or by post: Cointraffic OÜ, Liivalaia 45, 10145, Tallinn, Estonia.

If you reside in the EEA, we will be the controller of your personal data provided to, or collected by, or processed in connection with our Services. You have the right to make a complaint at any time to the Estonian Data Protection Inspectorate (address 19 Väike-Ameerika St., 10129 Tallinn, Estonia, e-mail address [email protected], phone +372 627 4135). We would, however, appreciate the change to deal with your concerns before you approach the Data Protection Inspectorate, so please contact us in the first instance.