Privacy policy
This Privacy policy shall be applicable exclusively in cooperation with Terms of Service and Terms and conditions of site content using

This Privacy policy (hereinafter referred to as the "Policy"/ "Privacy policy") shall be applicable to the information, including personal data in interpretation of applicable legislation (hereinafter referred to as the "Personal information"), which TopHit LLC (hereinafter referred to as the "Administration" / "we") and/or affiliated companies may get about individuals or legal entities visiting site of Administration (hereinafter referred to as the "Site"), as well as about persons, registering on the Site (hereinafter referred to as the "User"/ "Users"/ "you"), including in the course of execution by Administration/ its affiliated persons of any agreements and contracts on the Site using, entered into by and between the User and Administration.

In applying this Policy Administration shall be guided by the legislation of the Russian Federation. Taking into consideration the fact Administration may provide its services to Users of the European Union, as well as Users of the European Union may use the Site and/or services of Administration, Administration shall adhere to provisions of European Union Regulations on protection of individuals and free personal data transaction at the course of processing the Personal information.

Registration on the Site is unconditional consent of the User to this Policy, as well as authorization of the User to record, store, reproduce, process and in any other way use the Personal information of the User throughout the term of registration of the User on the Site and within Five (5) years after deletion of the User Account from the Site. Should the User have any objections to these terms it shall refrain from using the Site.

Administration takes all commercially feasible measures in order to keep all Personal information disclosed by the User. Information collected by Administration at the moment of registration, as well as information which is required to enable the Users use the Site, shall not be provided to third persons for any purposes without express consent of the User, except for cases set forth in this Policy, Terms of services, Terms and conditions of site content using, or envisaged by applicable legislation, including the law of the Russian Federation.

If you have any questions or concerns about this Privacy Policy, do not hesitate to contact us through help@tophit.ru и help@tophit.ua.
Information we collect and process

Administration may collect and process the following information about the User at the process of their using the Site:

1) the Personal information provided by the User at the moment of registration (creation of Account), including name, phone number, address and age;
2) electronic data (HTTP-highlights. IP-address, cookies, identification browser data, information on hardware and software);
3) data and time of access to the Site;
4) information of User's activity at the time of using the Site (search requests, electronic mail addresses, content of electronic mail and enclosures);
5) information on geolocation;
6) payment information, such as payment address and number of credit card;
7) other information about the User, required for processing pursuant to the terms and conditions regulating the Site using.

Administration uses cookies to collect the Personal information and connection of such information with a device and web-browser of the User pursuant to the terms and conditions set forth herein.

Administration shall not process the information disclosing racial or ethnic origin, political and religious views, membership to professional association, as well as processing of genetic and biometrical data for unique identification of individual, data in respect to health, sexual activity, as well as sexual orientation of individual. Processing of set category of data may be completed only with reasons set forth by applicable legislation (particularly with the consent of the User to processing of its Personal information, protection of vital interests of the User, and the like).

By continuing using the Site the User agrees that the Personal information of the User collected by Administration on the Site, may be transferred through national boundaries, to the territory of foreign state, to a foreign individual and foreign legal entity (cross-border transfer).
Who else could have access to your Personal information

Administration is entitled to outsource third parties such as companies performing credit cards turnover, for issuing invoices for services to Users, providers of electronic mail services to send Users electronic messages from the name of Administration. Should the User subscribes to the services of Administration, Administration is entitled to transfer Personal information for such third parties solely to provide Users with services under agreements concluded by Administration with such third parties.

In all cases Personal information shall be processed solely for the purposes set forth in this Policy, except as otherwise provided by terms of site and/or services using, set forth by corresponding companies, as follows:

Yandex https://yandex.ru/legal/confidential/300120;
Google https://policies.google.com/privacy?hl=en-US
Purposes of processing of Personal information of the User

Administration shall not process Personal information without sufficient legal grounds therefor. This is why Administration processes Personal information of the Users only, if:

1) the User gives the consent for processing its Personal information to complete concrete processing purposes;
2) processing is required to complete contractual obligations of Administration, including work of the Site;
3) processing of Personal information of the User is completed in connection with fulfillment of conditions of a contract to which the User concerned is a party;
4) processing is required for compliance of obligations set forth by the applicable legislation;
5) processing is required for protection of the life, health and other vital interests of the Users;
6) processing is required for execution of legal orders, orders of other institutes or officials, which are to be executed pursuant to the applicable law;
7) processing is required for execution of rights and legal interests of Administration in the course of completing activity, set forth by a charter or other local legal acts of Administration or achievement of public goals.
8) for other legal purposes.

Processing the Personal information of the User is limited by purposes for which such Personal information is processed, as follows:
1) granting the Users access to the Site and User's Account;
2) cooperation of User and Administration, and cooperation of Users between each other;
3) comfort increase in using the Site, upgrading service quality by Administration;
4) protection of legal rights and interests of Users and Administration.
Information Security

Keeping Personal information secure is one of the most significant responsibilities of Administration.

In most cases the Personal information of the Users are processed automatically, without granting access to Administration employees thereto. As it is necessary Administration shall grant access to the Personal information about the User to those employees and others who need to know that information to assist Administration in its activity, or to provide products or services to the Users. Administration shall safeguard the Personal information, according to the established security standards and procedures, by maintaining physical, electronic, and procedural safeguards to the Personal information.

Security

The servers where the Personal information is kept are in a highly secure server environment, with surveillance and support to prevent unauthorized access and data security.

Administration cannot guarantee the security of the User's data while it is being transmitted over the Internet and through servers that are out of the control of Administration. Administration cannot ensure or warrant the security of any information the User transmits to the Site or at the process of services rendered by the Administration. Any data transmissions the User makes over the Internet are done so at its own risk.
Sharing Personal information

Administration shall not share, sell, rent or trade the User's Personal information other than as established pursuant to this Privacy policy.

Administration reserves the right to disclosure the Personal information of the Users as required by the law of the Russian Federation or by the applicable law and when the disclosure of the Personal information is necessary to protect the rights of Administration and/or comply with a judicial proceeding or court orders, served to the Administration.

Administration is entitled to process the Personal information without the consent of the User in the following cases:

- the Personal information processing is required to exercise and fulfill functions, powers and obligations imposed by the applicable law;

- the Personal information is processed subject to publication or compulsory disclosure in accordance with the applicable law;

- processing of the Personal information is required for realization of the rights and legitimate interests of the Administration or third parties or for the achievement of socially significant goals, provided that this not cause the rights and freedoms of the User to be violated;

- public access to the Personal information being processed has been granted by or at the request of the User;

- the Personal information processing is required for performance of an agreement to which the User is a party or under which the User is a beneficiary or surety, including in case of realization by the Administration of its right to assign rights (requests) thereunder, or for conclusion of an agreement on the initiative of the User or an agreement under which the User shall be a beneficiary or surety;

- in any cases directly prescribed by the applicable law.
Mailing Policy

In case of sending an electronic mail by the User to Administration, Administration uses email address for comments and/or reply to question, and stores an electronic mail of the User and its own reply for any future correspondence. Administration will never use email address of the User to send any unsolicited message or information, nor will share it with or sell it to anyone else for such use

With an express consent of the User to receive information about services rendered by Administration, promotions, newsletters, press releases, and/or new offers, Administration shall use email address of the User solely to provide with the information or other services, until the User asks to stop such sending (using the 'unsubscribe' instructions provided with each email communication).
Passwords

Account information of the User, username and profile are password-protected so the User has secure access to entering and editing its Personal information. It is the Users' responsibility to protect the security of its password. Access to Account is protected by a unique username and password that is known to the User only. The Site uses internal security processes that encrypt the User's password to protect it from being divulged or accessed by any third party. Neither employees of the Administration, nor any of its contractors can obtain or access the User's password.
Storing of User's personal information

Personal information of the User shall be stored on servers physically located in Russian Federation. Administration shall record, arrange, accumulate, store, specify (updating, changing), extract of personal data of the Russian Federation citizens by using databases in the territory of the Russian Federation.

By processing the Personal information Administration shall adhere to Standard contractual clauses, approved by the European commission in order to ensure an adequate level of protection of the Personal information transferred to Russia.

In case of leakage of User's Personal information Administration shall notify corresponding authoritative body thereof (excluding the cases when such leakage of the User's Personal information shall not result in risk for rights and freedoms of individuals). When leakage of the User's Personal information may cause high risk for rights and freedoms of individuals Administration shall immediately notify the User of such leakage of Personal information.
Users' rights

When it is required by the applicable law the User is entitled to access to its Personal information, processed by Administration pursuant to this Policy.

The User may in any time amend or delete its private information by contacting its Account. Should you need our assistance in updating or reviewing your Personal information, do not hesitate to contact us help@tophit.ru. Help desk will answer within 24 hours.

The User has the right to ask for deleting its Account by contacting Administration via electronic mail address help@tophit.ru и help@tophit.ua. In so doing the User understands and agrees that it will not be able to enter the Site and use the Site services with deleted Account. At the same time the User has the right to create new Account. Administration reserves the right to keep information connected to the User's Account (including deleted) in its database.

If provided by the applicable legislation the User shall have the right to:

- obtain full data on its Personal information processed by the Administration;

- access to its Personal information, including the right to receive a copy of any record, except for cases stipulated by the applicable law;

- specify its Personal information, amend and/or correct mistakes therein, block or erase thereof in case the Personal information appears to be incomplete, outdated, inexact, illegally obtained or is not necessary for declared processing purposes;

- revoke its consent for Personal information processing;

- take legally provided measures for protection of its rights;

- to contest Administration's actions or failure to act in violation of personal data legislation of the Russian Federation with the authorized protection body or in court;

- limit its Personal information processing in case Personal information is illegally processed;

- object to its Personal information processing completed for certain purposes (for example, for purposes of direct marketing).

The User is also entitled not to come within the purview of decision, based on automatic processing of its Personal information, that results in legal consequences for such User.
Other terms and conditions

Administration has the right to change this Privacy policy at any time. Unless stated otherwise, the current Privacy policy shall be applicable to all information that we have about the User and the User's Account. If Administration makes changes to this Privacy policy the corresponding notification will be placed on the Site.

If Administration makes material changes or is going to use the Personal information in a manner different from that stated at the time of collection Administration will notify Users via the Site prior to the change becoming effective. The Users in this case will have a choice as to whether or not give Administration the right to use their information in this different manner.
SPECIAL NOTE ABOUT UNDERAGE CHILDREN (PG-16)

This Site is not intended for use for children aged 16 and under. Children may use this Site only with the direct supervision of their parents, guardians or foster parents. User discretion is advised.
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