Privacy Policy

The Privacy Policy (hereinafter - the Policy) is part of the Terms of Use. By accepting the terms of the Terms of Use (making an acceptance of the offer), you consent to the processing of your personal data on the terms specified in the Policy set out below.

1. General Provisions

1.1. The Privacy Policy (hereinafter - the Policy) is approved by Top Page Limited Liability Company (hereinafter - "Top Page", "We", "Our" in any case and number) in order to establish rules for the processing of personal data of users of the Service.

1.2. Top Page acts as the operator of your personal data. Top Page combines the functions of a controller (“controller”) and a processor (“processor”) of personal data in the sense that is given to these terms in Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of individuals with regard to the processing of personal data and the free movement of such data and the repeal of Directive 95/46 / EC (General Data Protection Rules). ”

1.3. By providing Top Page with their personal data or access to them, the user expresses his full consent to the terms of the Policy.

1.4. The full use of the Service’s functionality (namely, the safety of bookmarks, as well as their synchronization between devices and browsers) requires the user to provide Top Page personal data. In this regard, the use of the full functionality of the Service is possible by the user only subject to prior familiarization with the Policy and expression of consent with it.

1.5. In case of disagreement with the terms of the Policy, the user must stop using the Service.

2. Purpose of using personal data

2.1. User’s personal data may be used by Top Page for the following purposes:

2.1.1. to identify the user when concluding the Terms of Use with him and the execution of these Terms of Use;

2.1.2. to interact with the user, including for sending notifications, requests and other information regarding the use of the Service;

2.1.3. to improve the Service, conduct statistical, marketing and other studies based on anonymized data.

3. Personal data that we use

3.1. Personal data refers to any information related to the user (the subject of personal data), that is, an identified or identifiable natural person.

3.2. Personal data includes: - information, access to which the user provided about himself independently during registration in the Service and its subsequent use; - information that is transmitted automatically, depending on the settings of the Service from other sources.

3.3. Information provided by the user:

3.3.1. when registering with the Top Page Service via e-mail: - email address (e-mail); - password for the personal account on the Service.

3.3.2. when registering in the Top Page Service via social networks: - profile identifier (ID) on the selected resource (VKontakte, Facebook, Google, etc.); - last name and first name (or pseudonym); - email address (e-mail). The administration, assuming the integrity of the user, does not verify the accuracy of the personal data of the user account on the corresponding resource.

3.3.3. when editing (adding) by the user the data of his account on the Service (on your initiative): - new email address (e-mail); - new password on the Service; - phone number. In this case, the phone number is provided by Top Page in encrypted form (for example, + 7 91 * 38 * 6 * 6 *).

3.3.4. when linking an account on the Service (on your initiative) to a profile in the selected social network, the information specified in clause 3.3.2 of the Policy.

3.3.5. when you use the full functionality of the Service, we are also provided with information about the bookmarks you saved in the Service.

3.4. Information we receive from other sources: - IP address; - type of web browser; - operating system; - time and date of visits during registration; - time and date of the last visit; - geography of visitors (country); - cookies; - browser cache.

3.5. When using the Service, such services as Google Analytics, Yandex.Metrica, LiveInternet are used. These services may collect aggregated and anonymized user data. However, we do not supplement our database with this information.

4. Methods of processing personal data

4.1. By providing Top Page with your personal data, you consent to Top Page to process personal data in any way using automation tools or without using such tools, including but not limited to: collection, storage, clarification (updating, changing), retrieval, use, deletion , destruction of the user's personal data.

5. Transmission and dissemination of personal data

5.1. Top Page does not provide the user's personal data or access to them to third parties without the prior consent of the user. The exception is anonymized and aggregated user data that is collected in order to improve the Service, conducting statistical, marketing and other studies.

5.2. Top Page does not control and is not responsible for third-party sites to which the user can go through the bookmarks he has saved. The relationship between the user and third parties to ensure the confidentiality of personal data provided by the user to third parties is independently regulated by the user and such third parties.

6. Measures to ensure the security of personal data

6.1. Top Page takes the necessary and sufficient legal, organizational and technical measures to protect the user's personal data from illegal actions of third parties or accidental leaks.

7. Duration of processing personal data

7.1. Top Page processes the personal data of the user during the term of the user account on the Service. When a user deletes an account on his own or by us at the user's request, personal data is deleted / destroyed by Top Page within 7 (seven) days from the moment the account was deleted. The exception is anonymized and aggregated user data that is collected in order to improve the Service, conducting statistical, marketing and other studies.

8. User rights

8.1. We respect the rights of users regarding personal data and facilitate their implementation. You can contact us with a request to exercise your rights in relation to personal data (for contacts, see Section 10 of the Policy). We ensure that the request is completed within a reasonable time, but no later than 1 (one) month from the receipt of the request. This period may be extended to 3 (three) months due to the complexity of the request or the large number of requests from Top Page clients. We will notify you of such an extension in advance by e-mail specified by you during registration. At your request addressed to us, you can exercise your rights, including the right to access information related to the processing of your personal data; the right to withdraw consent to the processing of personal data; the right to destroy your personal data, etc.

9. Other provisions

9.1. Top Page reserves the right at any time to change, add or delete items of the Policy without notifying the user.

9.2. The new version of the Policy comes into force from the moment it is posted on the Service.

9.3. The user must independently monitor the update of the Policy on the Service.

9.4. Continued use of the Service by the user means acceptance of the changes made to the Policy.

10. Contacts

Top Page Limited Liability Company Legal address: 630126, Russia, Novosibirsk, st.Proletarian 360 Mailing address: 630090, Russia, Novosibirsk, st.Nikolaev, 18, of. 2 PSRN: 1095405011107 e-mail: support@atavi.com

Representative in the European Union: SOFTLAB CORP.LLP Address: LAS SUITE 5 PERCY STREET, FITZROVIA, LONDON, ENGLAND, W1T 1DG Legal entity registration number: OC392736

Last modified: January 2020