PRIVACY POLICY

Last update on December 15th, 2020.

Thank you for deciding to become a part of our community at Top Kartinki («we», «us» or «our»). We strive to protect your personal data and your right to privacy. If you have any questions or concerns regarding our policy or our actions regarding your personal information, please contact us at [email protected].

When you visit our website https://topkartinki.ru, a mobile application (Android: https://play.google.com/store/apps/details?id=ru.otkritki.greetingcard ) and use our services, you trust us your personal information. We are very serious about your privacy. In this Privacy Policy, we strive to explain to you as clearly as possible what information we collect, how we use it and what rights are with regard to it. We hope you take some time to read it carefully, as this is important information for you. If there are any conditions in this Privacy Policy that you do not agree with, please stop using our Sites or Applications and our services.

This Privacy Policy applies to all information collected through our website (for example, https://topkartinki.ru), the mobile application and/or any related services, sales, marketing or events (we refer to them in this Privacy Policy as "Services", "Service" or "Application").

Please read this Privacy Policy carefully, as it will help you to make informed decisions about providing us your personal information.

CONTENTS

WHAT DATA DO WE COLLECT?

Personal data that you disclose to us

Briefly: we collect personal data that you provide us.

We collect personal information that you voluntary provide to us when registering in the Services or Applications, by expressing your interest in receiving information about us or our products and services, by interacting with Services or Applications (such as posting cards through our application) or by contacting us otherwise.

The personal information we collect depends on the context of your interaction with us and the Services or Applications, the choices you make, and the products and functions that you use. The personal information we collect may include the following:

Personal information you provide. We collect the first name, last name and nickname (nickname); e-mail address; social networks; and other similar data.

Billing information. All billing information is stored on Google Play. You can find links to their privacy policy here: https://payments.google.com/payments/apis-secure/u/0/get_legal_document?ldo=0&ldt=privacynotice&ldl=en-GB

Login data for social networks. We can give you the opportunity to register using your social media account information, such as your Facebook, Twitter, or other social media account. If you decide to register in this way, we will collect the information described in the section “How we process your social logins” below.

All personal information that you provide to us must be true, complete and accurate, and you should notify us of any changes to such personal information.

Data collected automatically

Briefly: some information, such as the IP address and / or characteristics of the browser and device, is collected automatically when you visit our Services or Applications.

We automatically collect certain information when you visit, use or navigate in the Services or Applications. This information does not reveal your specific identity (for example, your name or contact information), however it may include information about the device used, such as your IP address, browser and device characteristics, operating system, language settings, URL links, device name, country, location information about how and when you use our Services or Applications, and other technical information. This information is primarily necessary to ensure the security and operation of our Services or Applications, as well as for internal analytics and reporting.

Like many other companies, we also collect information using cookies and similar technologies. Information about what cookies do we use and how to refuse them can be found in the section “Do we use cookies and other tracking technologies?”.

Internet identifiers. We collect the information about your device; applications tools and protocols, such as IP (Internet Protocol) addresses; cookie identifiers or others, such as those used for analytics and marketing; and other similar data.

Data collected through our applications

Briefly: we can collect information about your mobile device, push notifications when you use our applications.

If you use our Applications, we may also collect the following information:

Mobile device data. We can automatically collect device information (for example, your mobile device’s identifier, model and manufacturer), operating system version information and IP address.
Pop-up reminders. We may request sending push notifications about your account or mobile application. If you want to refuse to receive these types of messages, you can disable them in your device’s settings.

HOW WE USE YOUR INFORMATION?

Briefly: we process your information for purposes based on legitimate business interests, fulfilment of our contract with you, compliance with our legal obligations and / or your consent.

We use personal information collected through our Services or Applications for various business purposes described below. We process your personal information for these purposes, based on our legitimate business interests, to enter into or execute an agreement with you with your consent and / or to comply with our legal obligations. We indicate the specific processing bases on which we rely, next to each goal listed below.

We use the information we collect or receive:

To facilitate account creation and login process. If you decide to link your account with us with a third-party account (for example, with your Google or Facebook account), we use the information that you have allowed us to collect from these third parties in order to simplify the creation of the account and the login process for interaction with the Service. See below the section “How do we process your social logins?” for more information.
To send your marketing and promotional messages. We and / or our third-party marketing partners may use the personal information you send to us for our marketing purposes, if this is appropriate for your marketing preferences. You can opt out of our marketing communications at any time (see below “What are your privacy rights”).
To send you administrative information. We may use your personal information to send you information about a product, service and new feature and / or information about changes to our conditions, rules and policies.
To complete your orders and purchases. We can use your information to execute and manage your orders, payments, returns and exchanges through our Services or Applications.
To post reviews. We publish reviews about our Services or Applications, which may contain personal information. Before publishing a review, we will get your consent to use your name and review. If you want to update or delete your review, please contact us at [email protected] and be sure to include your name, location and contact information.
To deliver targeted ads to you. We can use your information to develop and display content and advertising (and to work with third parties who do this) based on your interests and / or location, and to measure its effectiveness.
To manage prize draws and contests. We may use your information to conduct prize draws and contests when you decide to participate in such promotions.
To request your feedback. We may use your information to request feedback and contact you regarding your use of our Services or Applications.
To protect our Services. We may use your information as part of our efforts to ensure the security and protection of our Services or Applications (for example, to monitor and prevent hacker attacks, fraud, etc.).
To provide connectivity between users. We can use your information to enable the exchange of data between users with the consent of each user.
To ensure compliance with our terms, conditions, and policies regarding business objectives, legal obligations, and contractual relationships.
To respond to legal inquiries and suppress illegal activities. If we receive a subpoena or other legitimate request, we may need to check our data to determine how to respond to it.
To manage user accounts. We may use your information to manage and maintain our account..
To provide services to the user. We may use your information to provide you with the requested service..
To respond to user requests / provide user support. We can use your information to answer your requests and solve any potential problems that you may encounter when using our Services.
For other business purposes. We may use your information for other business purposes, such as data analysis, identifying trends in the use of our Services, determining the effectiveness of our advertising campaigns, and also to evaluate and improve our Services or Applications, products, marketing and your experience. We will use and store this information in aggregated and anonymous form so that it is not associated with individual end users and does not include personal information. We will not use identifiable personal information without your consent.

WILL YOUR INFORMATION BE TRANSMITTED TO ANYONE?

Briefly: we transmit information only with your consent in order to comply with the laws of the countries in which we operate, provide you services, protect your rights or fulfill business obligations.

We may process or transmit data based on the following legal bases:

Consent. We may process your data if you have consented to the use of your personal data for certain purposes.
Legitimate interests: we can process your data when reasonably necessary to achieve our legitimate business interests.
Contract execution. If we have a contract with you, we may process your personal information to fulfil the terms of our contract.
Legal obligations. We may disclose your information if required by law to comply with applicable law, government requests, litigation, court order or trial, for example, in response to a court order or subpoena (including in response to government agencies to satisfy national security or law enforcement requirements).
Vital interests: We may disclose your information in cases where we believe it is necessary to investigate, prevent or take action regarding possible violations of our policies, alleged fraud, situations involving potential threats to the security of any person and illegal activities, or as evidence in the lawsuit in which we participate.

In particular, we may need to process your data or transfer your personal information in the following situations:

Providers, Consultants, and Other Third Party Service Providers. We may transfer your data to third-party providers, service providers, contractors or agents who provide services for us or on our behalf and require access to such information in order to carry out this work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing tasks. We may allow certain third-party organizations to use the tracking technology in the Services or Applications, which will allow them to collect data about how you interact with the Services or Applications over time. This information can be used, among other things, to analyze and track data, determine the popularity of certain content, and better understand online activity. Unless otherwise specified in this Policy, we do not transfer, sell, rent or transfer any of your information to third parties for advertising purposes. We have contracts with our data processors. This means that they cannot do anything with your personal information unless we have instructed them to do so. They will not transfer your personal information to any organization other than us. They will hold it securely and store it for the period that we instruct..
Third Party Advertisers. We may use the products of third-party advertising companies to display ads when you visit our Services or Applications. These companies may use information about your visits to our website and other websites contained in cookies and other tracking technologies to provide advertisements for goods and services that interest you.
Offer wall. Our applications can display third-party advertisements in the form of an “offer wall”. Such advertising allows third-party advertisers to offer users virtual currency, gifts or other items in exchange for accepting and completing the advertising offer. Such advertisements may appear on our mobile application and be displayed to you based on certain data, such as a geographic region or demographic information. When you click on the offer wall, you leave our mobile application. A unique identifier, such as your user ID, will be provided to the provider to prevent fraud and correctly credited to your account..

WHO YOUR INFORMATION WILL BE TRANSMITTED TO?

Briefly: we only share information with the following third parties.

We transfer and disclose your information only to third parties specified in this section (service providers). We have classified each side and provided links to their privacy policies so that you can easily understand the purpose of their data collection and processing methods, as well as change the settings for collecting your data by these providers.

Advertising, direct marketing and lead generation in
Google AdSense https://policies.google.com/technologies/partner-sites

Appodeal https://www.appodeal.com/home/privacy-policy/

MyTarget https://legal.my.com/us/mytarget/privacy/

AdMob https://policies.google.com/technologies/partner-sites

Yandex https://yandex.ru/legal/confidential/

Allow users to connect to third-party accounts
Google Account https://policies.google.com/privacy,

Facebook Login https://www.facebook.com/policy.php

Odnoklassniki https://ok.ru/privacy

Vkontakte https://vk.com/privacy

Cloud computing services
Amazon Web Services (AWS) https://aws.amazon.com/privacy/
Data backup and security
Google Drive Backup https://policies.google.com/privacy

Providing access to our applications

Google Play Services https://play.google.com/intl/en-us_us/about/play-terms/index.html

Analytics of the use of our mobile and web applications

Firebase Analytics & Crashlytics https://firebase.google.com/support/privacy

DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

Briefly: we may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (e.g. web beacons and pixels) to access or store information. Specific information about how we use these technologies and how you can refuse certain cookies is set out in our Cookie Policy.

Cookie files - these are tiny text files that are stored in the user's browser. Most cookies contain a unique identifier called a cookie identifier: a string of characters that websites and servers associate with the browser in which the cookies are stored. This allows websites and servers to distinguish the browser from other browsers that store different cookies, and recognize each browser by a unique cookie ID.

Cookies are widely used by websites and servers to provide many basic services on the Internet. If you make purchases on a website, a cookie allows the website to remember which products you added to your virtual basket. If you set preferences on a website, a cookie allows the website to remember your preferences on your next visit. Or, if you log in to the website, the website may use a cookie to subsequently recognize your browser so that you do not have to log in again. Cookies also allow websites to collect data about user activity, such as the number of unique page visitors per month. All these applications depend on the information stored in cookies..

Below is a list of cookies used by our website and Services:

Google Advertising Cookies

Google AdSense Policies for Your Data:

https://policies.google.com/technologies/partner-sites

You can opt out of personalized advertising by visiting:

https://www.google.com/settings/ads

Appodeal Promotional Cookies

https://www.appodeal.com/home/privacy-policy/

MyTarget Promotional Cookies

https://legal.my.com/us/mytarget/privacy/

AdMob Promotional Cookies

https://policies.google.com/technologies/partner-sites

Yandex Advertising Cookies

https://yandex.ru/legal/confidential/

HOW DO WE PROCESS YOUR SOCIAL LOGINS?

Briefly: if you decide to register or enter our services using an account on a social network, we may have access to certain information about you.

Our Services or Applications offer you the opportunity to register and log in using your social network account information (for example, your Facebook or Vkontakte logins). If you decide to do this, we will receive certain information about you from your social network service provider. The profile information we receive may vary depending on the respective social network service provider, but will often include your name, email address, friends list, profile photo, as well as other information that you decide to make public.

We will use the information we receive only for the purposes described in this privacy policy or otherwise explained to you in the Services or Applications. Please note that we do not control and are not responsible for the other use of your personal information by your third-party social network provider. We recommend that you read their privacy policy to understand how they collect, use and share your personal information, as well as how you can set your privacy preferences on their websites and applications.

FOR HOW LONG WE KEEP YOUR INFORMATION?

Briefly: we store your information for as long as necessary to achieve the goals set out in this privacy policy, unless otherwise required by law.

We will store your personal information for the entire time necessary for the purposes set out in this privacy policy, unless the law requires or permits a longer storage period (for example, tax, accounting or other legal requirements). No purpose in this policy will require us to store your personal information longer than the period during which users have an account with us.

When we do not have a legitimate business need to process your personal information, we will delete it or anonymize it, or if this is not possible (for example, due to the fact that your personal information has been stored in backup archives), we will securely store your personal information and isolate it from further processing until removal becomes possible.

HOW DO WE KEEP YOUR INFORMATION SECURE?

Briefly: We strive to protect your personal information through organizational and technical security measures.

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information that we process. However, please also remember that we cannot guarantee that the Internet itself is 100% secure. Despite the fact that we will do our best to protect your personal information, the transfer of personal information to our Services or Applications is at your own risk. You must connect to our Services using only secure telecommunication channels.

WHAT ARE YOUR PRIVACY RIGHTS?

Briefly: You can view, change or delete your account at any time.

In accordance with international best practices, our users have the following rights:

The right to be informed
Right of access
Right to Correction (data correction)
Right to delete (to be forgotten)
Right to restrict processing
Right to data portability
Right to object
Right not to be subject to automated decision-making

If you have questions or comments about your privacy rights, you can write to us at [email protected].

Account Information

If at any time you want to view or change the information in your account or close your account:

■ Go into your account settings and update your account.

Upon your request to delete your account, we will disable or delete your account and information from our active databases. However, some information may be stored in our files to prevent fraud, troubleshoot, assist in any investigations, enforce our Terms of Use and / or comply with legal requirements.

Cookies and Similar Technologies. Most web browsers are set to accept cookies by default. If you prefer, you can choose to delete cookies and reject cookies in your browser. If you decide to delete cookies or reject cookies, this may affect certain functions or services of our Services or Applications. To opt out of advertising based on the interests of advertisers in our Services or Applications, visit the website: https://optout.aboutads.info/?c=2&lang=EN.

E-mail opt-out. You can unsubscribe at any time by clicking on the unsubscribe link in the letters we send to you, or by contacting us using the information below. After that, you will be removed from the list of marketing email addresses, however we will still need to send you emails related to the services that are necessary for the administration and use of your account.

DATA LEAKAGE

Confidentiality violation occurs when there is unauthorized access or collection, use, disclosure or disposal of personal information. You will be notified of data breaches when the Top Kartinki considers that you are likely to be at risk or seriously harm the protection of personal data. For example, a data leak can lead to serious financial damage or to your mental or physical well-being. In the event that the Top Kartinki finds out about a security breach that has led or could lead to unauthorized access, use or disclosure of personal information, the Top Kartinki will immediately consider the matter and notify the appropriate supervisory authority no later than 72 hours after we become aware about this, unless the leak of personal data is unlikely to lead to a risk to the rights and freedoms of individuals.

CONTROL OVER DO-NOT-TRACK FUNCTIONS

Most web browsers, as well as some mobile operating systems and mobile applications, include a Do Not Track (“DNT”) feature or an option that you can activate to indicate that you prefer privacy, so as not to track or collect data about your online activities. A single technology standard for the recognition and implementation of DNT signals has not been agreed. Thus, at present, we are not responding to DNT browser signals or any other mechanism that automatically informs you of your choice not to be tracked on the Internet. If we adopt a standard for online tracking that we must follow in the future, we will notify you of this practice in a revised version of this privacy policy.

DO WE LOCALIZE YOUR PERSONAL DATA?

Briefly: yes, if you are a resident of the Russian Federation, we comply with the requirements for the localization of personal data in databases located in the territories of this country.

In accordance with the current legislation of the Russian Federation, when collecting personal data, we are obliged to ensure the recording, systematization, accumulation, storage, updating (updating, changing), extraction of personal data of citizens of the Russian Federation using databases located on the territory of the Russian Federation.

Also, we will comply with other localization requirements of these countries in which we operate.

DO WE UPDATE THIS POLICY?

Briefly: yes, we will update this policy as necessary to comply with relevant laws.

We may update this privacy policy from time to time. The updated version will be marked with the updated date “Revised”, and the updated version will take effect as soon as it becomes available. If we make significant changes to this privacy policy, we may notify you by posting a notice of such changes or by sending you a notification directly. We encourage you to review this privacy policy often to keep abreast of how we protect your information.

HOW CAN YOU CONTACT US REGARDING THIS POLICY?

If you have questions or comments about this policy, you can send us an email at [email protected]

HOW CAN YOU VIEW, UPDATE OR DELETE DATA ABOUT YOU THAT WE COLLECT?

In accordance with the laws of certain countries, you may be entitled to request access to the personal information we receive from you, change this information or delete it in certain circumstances. To request viewing, updating or deleting your personal information, please contact us at the following email address: [email protected]. We will respond to your request within 30 days.