PRIVACY POLICY
Updated and Effective as of February 26, 2025
To use some of our Services (apps, websites, and others), we may ask you to provide specific information such as your name (or nickname), email address, date of birth, information about your feelings and mental well-being, and other onboarding details. Depending on the app or web product you choose within our ecosystem, additional data—such as your pulse, heart rate, a photo of your hand, or other information—may be required (please refer to Section 2.1 of this Policy). In some of the cases, you have the option to skip certain onboarding questions by selecting "Skip" or a similar feature.
Additionally, we may automatically collect information from your device, including language settings, IP address, time zone, device type and model, and other data points. This data enables us to provide Services (e.g., rendering product features), analyze app usage (e.g., feature popularity), and enhance specific experiences like refund processing.
To improve subscription management and engagement tracking, we integrate with Apple’s App Store Server API. This includes using the consumptionRequestReason feature, which collects data about your interactions with subscription content. Certain event data (Customer Account Age, User Account Details, Content Consumption Level, Platform Information, Total In-App Purchase Amount, App Usage Time, and Account Status) may also be shared with Apple to enhance subscription management in line with Apple’s guidelines. Apple uses and protects this data per its Privacy Policy, retaining it only as necessary to fulfill its purpose, such as improving the refund process by reviewing refund requests more effectively. For further details on how Apple protects data, see the Apple Platform Security Guide or the App Store & Privacy documentation. Apple may share this data with service providers acting on its behalf, partners, or others at your direction but will not use it for marketing purposes. You may opt out of transferring this event data to Apple by contacting us.
We encourage you to read this Privacy Policy to better understand how we handle your data (Section 2), your data privacy rights (Section 7), and the privacy control features available to you.
If you have any unanswered questions or wish to exercise your privacy rights, please contact us at gototop@support-team.app.
In this privacy policy, the following definitions are used:
«Services» refers to our Apps, Websites, and any related services or properties we control;
«Apps» refers to games, applications, and other products produced by us on any and all platforms;
«Websites» refers to websites and other online properties we control;
«Personal Data» refers to data that relates to you as an identified or identifiable individual;
«Anonymous data» does not include data where the identity has been removed;
«User, consumer, you» is any third party that uses our Services.
WE HOPE YOU TAKE SOME TIME TO READ THROUGH IT CAREFULLY, AS IT IS IMPORTANT.
PLEASE DO NOT PROVIDE ANY SENSITIVE INFORMATION UNLESS YOU ARE CERTAIN ABOUT ITS NECESSITY AND HAVE GIVEN YOUR EXPLICIT CONSENT.
Thank you for choosing to be part of our community!
This privacy policy describes how we at GOTOTOP LTD, the legal entity incorporated in accordance with the laws of the Republic of Cyprus (collectively, “we,” “us,” or “our”), collect, use, store, transfer, and disclose personal information from our Users in connection with our Services. One way to protect your privacy is to learn how your personal information will be used before you give it out. We attach great importance to your privacy rights and truthfully explain why and how we use your information.
For the purpose of the General Data Protection Regulation 2016/679 and any implementing legislation (the "GDPR"), GOTOTOP LTD will be the data controller responsible for any personal data we process.
We reserve the right to update this Privacy Policy from time to time so please be sure to check regularly.
Please read this Policy carefully and do not hesitate to contact us if you have any questions at gototop@support-team.app. Where applicable, if you do not provide us with the relevant Personal Data, you may not be able to use our Services completely.
We may change this Privacy Policy from time to time. If the changes are material, we will notify you. If permitted by law, your continued use of the Services after this policy has been updated indicates your acceptance of changes made. You should not use the Services if you do not agree with this Policy and our Terms of Use.
How to contact us:
Name: GOTOTOP LTD
Address:14 Panagioti Tsangari, 1st Floor, Office 1E, 4047, Limassol, Cyprus
E-mail: gototop@support-team.app
When you use our Services, we can collect, use, receive, process, transfer, and share some of your Personal Data for different legitimate purposes. You will find below explanations regarding what Personal Data we may collect, the reasons why we may collect this data and the legal bases relied on in each case. Please, note that the types of information that we may collect depend on how you use the Services and interact with us. We may anonymize your Personal Data (so that it can no longer be associated with you) for research or statistical purposes. In such cases we may use anonymous information without further notice to you since such information is not considered as Personal Data and cannot be connected with you.
2.1. User-provided information - In certain cases, we may require certain personal data, and in other cases, we may simply ask that you voluntarily provide such personal data:
A. When you register for the Services or contact us you provide some Registration Information: (your name (or nickname); login/e-mail address; password or passcode, age (year of birth), gender, content of your question or request, telephone number).
B. When you go through the onboarding process, you provide Quiz Data: pulse and heart rate, photo of your hand, Information about your feelings and emotional situation, mental well-being, common information about your health condition (not specific, in general), relationship status (married, difficult, engaged, soulmate, single); The area of life that the user wants to develop (Self-care & Personal Growth, Health & Well-being, Career, Business & Work, Friends & Relationships); place of birth; time of birth.
C. Our Services allow in-app purchases. In-app purchases are not mandatory and it is up to you whether to pay for accessing such functionality or not. You should know that payments are processed via the Apple App Store (Apple, https://www.apple.com/legal/privacy/en-ww/), the Google Play Store (Google, https://policies.google.com/privacy), or other payment processors. Payment processing takes place through a payment system, integrated into the app store, appropriate for your platform. We may receive the billing and payment information that you provide when your purchase is processed by someone else (like, Apple or Google, Etc.), such as when you purchase a subscription. If you purchase subscriptions in our apps, our third-party payment processor will collect the billing and financial information it needs to process your charges. This may include your postal address, e-mail address, and financial information. We don’t collect or store payment data, details, or payments-related personal data. However, our payment processors may share information with us related to your purchases. We may use this information for purposes as described in this Privacy Policy.
D. Location Data - we do not collect the User’s precise location: country, state, or coarse location such as Approximate Location Services (general - non-precise location).
2.2. Automatically collected information - When you use our Services we automatically collect certain personal data about you:
A. Device Info: type and model; operating system and version number (ex.: ios 7.1.3, android), hardware type, connection type (for example, WiFi, 3G, 4G), network service provider, device motion parameters and carrier, Platform; Device Locale; App Version.
B. Identity Data (only identify a computer, device, browser, or Application): IP Address; ID for advertisers (IDFA) (iOS only); Google Advertising ID, or GPS ADID (ID Device) if Google Advertising ID is empty; API level (Android only); Firebase ID.
C. Usage Data (Events): Indicates if the activity happened on mobile or web; Length of user's last session; Length of user's current session; Number of sessions recorded; Push notification token, i.e., registration token (Android), device token (iOS); clicks on User’s ads; the type of ads and the webpage or Application from which such ads were displayed; downloads and installations of applications.
D. Diagnostic information: for example, logs, error reports, and events and the type, number, date, and page relating to this information.
E. Location information: (IP address; Time zone; Information about your mobile service provider).
F. Our app integrates with Apple’s App Store Server API to manage in-app subscriptions and improve your experience by accurately tracking engagement with subscription content. We use the consumptionRequestReason feature, which enables us to collect specific data about your interactions with subscription content. Certain data collected may also be shared with Apple to enhance subscription management in line with Apple’s guidelines:
Apple uses and protects the data you share through the Send Consumption Information API in accordance with Apple’s Privacy Policy. For additional information about how Apple protects data, see the Apple Platform Security Guide. Apple retains the data you provide through the Send Consumption Information API for the period necessary to fulfill the purpose for which the data was collected, which is to improve the refund process by obtaining data that assists with reviewing the customer’s refund request. Apple may share the data you provide through the Send Consumption Information API with service providers who act on our behalf, our partners, or others at your direction. Apple will not share the data with third parties for their own marketing purposes. For more information, see App Store & Privacy.
2.3. Information received from third parties
A. Third-party log-in data: If you sign into the Services with Facebook Connect (Instagram), Google Connect, or Apple, we will collect information that is visible via your Facebook or Google account, such as (1) your first and last name, (2) Facebook ID/Google ID/Apple ID (3) Profile Picture/URL, city-level location.
B. Analytics information: we integrate certain analytics software, a third-party analytics provider in some of our Apps. (user ID, in-Apps activity data, advertising ID, IP address, location).
C. Apple Health Kit or Google Fit: Please be kindly note that we may ask your permission to connect to Apple HealthKit and Google Fit to import Personal Data about your health and activities into the App. This imported data may include calories burned, heart rate, and other data about your health. When you choose to have this data imported, you are subject to the Google Fit and Apple HealthKit privacy policies and practices.
2.4. Cookies and Other Tracking Technologies
Cookies, web beacons (also known as "tracking pixels"), embedded scripts, location-identifying technologies, fingerprinting, device recognition technologies, in-app tracking methods, and other tracking technologies now and hereafter developed ("Tracking Technologies") may be used to collect information about interactions with the Service or e-mails, including information about your browsing and purchasing behavior. We may use Automatically Collected Information and Cookies information to maintain and improve our Services, including doing the following things: (a) automatically update the applications on your system; (b) remember your information so that you will not have to re-enter it during your visit or the next time you access our Services; (c) provide customized third-party advertisements, content, and information, unless it will include instructions on how to opt out of receiving these advertisements, content, and information in the future; (d) monitor the effectiveness of third-party marketing campaigns; (e) monitor aggregate site usage metrics such as total number of visitors and pages accessed.
2.5. Access to your library or Microphone
The app requires your permission to access your microphone recordings and your photo and video library when you use the app to activate voice commands and to enable you to share your achievements on your social media accounts. However, we do not collect or have access to such data. We may send push notifications to the User to send you app updates, high scores, and other service-related notifications that may be of importance to you (You can disable this anytime in your phone settings).
The purpose of this Privacy Policy is the fulfillment of the provisions of the Terms of Service (“Contract”) concluded between the User and GOTOTOP LTD. We collect user’s personal data when user starts using our Services. Our main aim is to perform our contractual obligation towards the User and make our Service available to the User. We use information that you submit and information that is processed automatically to provide you with all requested services.
We generally process your personal data on the following legal bases:
Contract. You have entered a contract with us and we need to use some of your personal data to provide services you have requested or take steps that you request prior to providing services. For example, we cannot create an account for you if you do not provide the required information like your email address. If you do not provide information indicated as required or mandatory within our service, it will not be available to you.
Legal obligations. We may have to process or share your personal data to comply with legal obligations, such as to comply with a subpoena or legal process.
Legitimate interests. We process your personal data for purposes that constitute our legitimate interests, such as fraud prevention and safety; protecting our, your, or others’ property rights; exercising or defending legal claims; investigating violations of and enforcing our Terms of Use; and analyzing and improving our services.
Consent. In some cases, we may process your personal data based on your consent, such as when we request access to data on your mobile device through the prompts in your device’s operating system. You have the right to withdraw your consent anytime in the manner indicated at the time consent is requested with no impact on the validity and lawfulness of collection or processing based on the consent made before its withdrawal.
PURPOSE OF PROCESSING | LAWFUL BASIS |
We collect Registration Data if you wish to register for the Services (to create an account) – only if it is applicable to the App, a device to set up and administer your account, provide technical and customer support and training, verify your identity, and send important account, subscription, and Service information. | Contract (art. 6(1)(b) of the GDPR) |
We collect almost all data to provide and deliver the Services and all features, to show information about the app and your progress, to customize your experience, to enable your access, and to address technical issues. | Contract (art. 6(1)(b) of the GDPR) or Contract (art. 6(1)(b) of the GDPR) if the data relates to a special category of personal data in a covered jurisdiction. |
To communicate with us (for example: to answer your questions and requests) To provide you with feedback and information about your progress. | Legitimate interest ((art. 6(1)(f) of GDPR) |
For billing (invoicing), account management, and other administrative purposes, if applicable | Contract (art. 6(1)(b) of the GDPR) |
To provide features of the Services, make recommendations for you. | Consent (art. 6(1)(a) of GDPR) |
To provide you with Services, we may ask for your Camera permission; Health Data read permission; Health Data update permission; and Motion sensors permission. | Consent (art. 6(1)(a) of GDPR) |
To determine the sign of the zodiac and make your horoscope, make a natal map, you can voluntarily provide it to us to receive Services | Contract (art. 6(1)(b) of the GDPR) |
To analyze, operate, and improve our Services, to customize our Services, to support the existing functions of the Services, to conduct research and create reports for internal use; To understand you and your preferences to enhance your experience and enjoyment using our Services; To store your App Data and App progress; To connect to our Services; To comply with legal obligations and law enforcement requests. To monitor and analyze trends, usage, and activities in connection with our Services. | Legitimate interest (art. 6(1)(f) of GDPR) |
We collect and process automatically collected information data to improve content accessibility, manage subscriptions effectively, and ensure compliance with Apple’s App Store policies. By analyzing engagement metrics, we aim to deliver a customized and seamless in-app experience. | Legitimate Interest (Article 6(1)(f) GDPR) |
We will use emails and push notifications to send you information and marketing communications about our services, such as tips, offers, and newsletters. | Consent (art. 6(1)(a) of GDPR) |
An alternative way to register (only for voluntary users' desires) | Contract (art. 6(1)(b) of the GDPR) |
To help us optimize our app features and events for each User. To allow us to track the performance of our marketing campaigns To recognize that you as an existing User | Legitimate interest (art. 6(1)(f) of GDPR) |
Any information that may be required by law - Legal obligations: We may be required to use and retain Personal Data for legal and compliance reasons, such as the prevention, detection, or investigation of a crime; loss prevention; or fraud. For example, when we use your date of birth when required for age verification purposes. | The legal basis (art. 6(1)(c) of the GDPR) |
To provide you with interest-based (behavioral) advertising or other targeted content. We store Advertising ID to track the success of our advertising and marketing programs. We may use information that is processed automatically for marketing purposes (to show ads that may be of interest to you based on your preferences). We provide personalized content and information to you, which can include online ads or other forms of marketing. To make choices about Interest-Based Ads from participating third parties, including opt-out of receiving behaviorally targeted advertisements from participating organizations, please visit the Digital Advertising Alliance or Network Advertising Initiative consumer opt-out pages, which are located at http://www.networkadvertising.org/choices/ or http://www.aboutads.info/choices. Users in the European Union should visit the European Interactive Digital Advertising Alliance’s user information website https://www.youronlinechoices.eu/. | Consent (art. 6(1)(a) of GDPR) or Legitimate interest (unless it requires consent, for example, when covered under certain e-privacy regulations) |
For the customization of product and service offerings and making our recommendations to you, for example through emails or push notifications, including for third-party products and offerings (excluding data from Apple HealthKit and Google Health Connect). | Consent (art. 6(1)(a) of GDPR) |
We use Personal Data to personalize your experience with our Services. Some of our Services will ask you to share your geolocation so we can customize your experience and increase the accuracy of the Service. If you agree to share your geolocation with us, you will be able to turn it off at any time by going to the privacy settings on your mobile device or online. | Contract (art. 6(1)(b) of the GDPR) or Consent (art. 6(1)(a) of GDPR) |
To fulfill contractual obligations with third parties. For example, when we provide pseudonymized data to our partners in analytics matters or process your payment. | Legitimate interest (art. 6(1)(f) of GDPR) |
AI Feature
In our app, we may use AI technologies. For example, if you choose to engage in a conversation with the Advisor, your conversations will be transmitted to OpenAI's servers via an API connection. However, we will not transfer any data from your conversations that would enable OpenAI to identify you unless you explicitly provide such information within your conversations. We do share your nickname with OpenAI to ensure proper addressing by the Advisor, which is essential for delivering the user experience we aim to provide. It's important to note that we do not permit OpenAI to utilize your information for training or enhancing its models.
Please be aware that some of the information you may disclose during your conversations could be sensitive. We kindly request that you refrain from providing such sensitive information, and we assure you that we will not process such data unless we obtain your explicit consent. When we do process such information, it will solely be for the purpose of delivering our service to you.
The data transfer between our platform and OpenAI occurs through a SOC 2 Type 2 compliant API connection, which has been independently audited by a third-party auditor in accordance with the 2017 Trust Services Criteria for Security. You can find more information about this audit from publicly available sources on OpenAI's website (https://openai.com/policies/api-data-usage-policies).
OpenAI will retain the information you send via the API for a maximum of thirty (30) days, after which it will be deleted, except when OpenAI is required to retain copies under applicable laws. In such cases, OpenAI will isolate and protect that information from any further processing except as mandated by applicable laws.
For additional details regarding OpenAI's API data usage policies, please consult https://openai.com/policies/api-data-usage-policies
We may share your information with third-party companies to perform certain services, including but not limited to hosting services, payment processing, analytics, and customer service, and to assist us in our marketing efforts. We share your Personal Data with certain third parties as part of our operation of the Service, whether shared by us or gathered directly by third parties through SDKs integrated into the Service. This data sharing enables us to provide you with the Service in an optimal way, such as serving you personalized, relevant advertisements within the Service. The following companies are the Processors of the Personal Data of the Services (In case you want to learn more about the services and privacy options, please consult their websites and privacy policies):
PROCESSOR | PURPOSE | POLICY AND OPT-OUT |
Customer support: help us to communicate with you simple and fast | ||
HelpDesk (Text, Inc.) | Customer support (Email address Content of the emails) | https://www.helpdesk.com/legal/privacy-policy/ |
Ad Partners: usually collect data via their own tools (Software Development Kits or “SDK”), help us to find new users | ||
AppLovin Corp | Advertising service. Personal Data collected: Cookies and Usage Data. You may opt out of certain features through your mobile device settings, such as your device advertising settings, or by following the instructions provided in their Privacy Policy. You may visit www.aboutads.info/choices or www.youronlinechoices.eu (for individuals in the EU) to learn more about interest-based advertising and how to opt-out of this form of advertising on your web browser by companies participating in the Digital Advertising Alliance (“DAA”) self-regulatory program. Personal data is collected to find you and people like you and share our services with them. Ads Services show relevant information to potential users. | https://www.applovin.com/privacy/ |
AdColony, Inc | https://www.adcolony.com/privacy-policy/ | |
TikTok (Bytedance, Ltd) | https://www.tiktok.com/legal/page/row/privacy-policy/en | |
Сhartboost | https://answers.chartboost.com/en-us/articles/200780269 | |
IronSource Mobile Ltd. | https://ironsource.mobi/privacypolicy.html | |
Unity Technologies | https://unity3d.com/legal/privacy-policy | |
https://policy.pinterest.com/en/privacy-policy | ||
Snap Inc. | https://www.snap.com/en-US/privacy/privacy-policy/ | |
Analytic companies: provide us with tools and technologies that allow us to better understand how users interact with our services, usually collect data via their own SDKs | ||
Adjust, Ltd. | Mobile attribution and analytics. Personal Data collected: Cookies and Usage Data. AppsFlyer, a mobile marketing platform, helps App-Developers, Brands, and ad agencies attribute installs to campaigns and optimize their users’ acquisition funnel. Personal Data collected: Device Info, Identity Data. | https://www.adjust.com/terms/privacy-policy/ |
Other partners | ||
Apple, Inc. | To collect and process payments for subscription to the App. Personal Data collected: Payment and banking information and Usage Data. To manage in-app subscriptions, certain user interaction data, as outlined above, is shared with Apple through the consumptionRequestReason feature to facilitate accurate and secure subscription management. | https://support.apple.com/en-us/HT210584 |
Amazon Web Services, Inc. | Hosting and backend service Personal Data collected: various types of Data as specified in the privacy policy of the service. | https://aws.amazon.com/privacy/ |
BunnyWay d.o.o. | CDN Personal Data collected: various types of Data as specified in the privacy policy of the service. | https://bunnycdn.com/privacy |
Hetzner Online GmbH | Internet hosting. Personal Data collected: Cookies and Usage Data | https://www.hetzner.com/rechtliches/datenschutz/ |
Facebook Ireland Ltd. | Our Services measure conversions using visitor action pixels from Facebook. This allows an analysis of the effectiveness of Facebook advertisements for statistical and market research purposes and their future optimization. Facebook Analytics is an analytics tool provided by Facebook, Inc. (US) that may collect or receive information from our Services. You can manage your personalized ad preferences in relation to Facebook directly from your Facebook account. Personal Data collected: Cookies, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example) and Usage Data. | https://www.facebook.com/policy.php |
Google Inc. | To collect and process payments for subscriptions to the App; AdMob Google Inc. is an advertising service. Personal Data collected: Cookies, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example), and Usage Data. | https://policies.google.com/terms?hl=ru , https://firebase.google.com/terms/analytics/ |
Solid | To collect and process payments for subscriptions to the App and certain web services (Payment and Banking information) | https://solidgate.com/privacypolicy |
OpenAI, L.L.C. | AI-generated content provider | |
Competent Authorities | To comply with a legal obligation, process, or request. If we are bound to disclose your personal data by a judicial order or by a governmental or regulatory authority, we will comply and share the personal data with that body. | |
We will keep your Personal Information for the length of time required to provide you with the Service and for the reasons described in this privacy policy unless a longer retention period is required or permitted by law. Afterward, we will delete all aforementioned data from our possession within a reasonable timeframe. We do not verify the correctness of the personal data that we collect or that you provide. In all cases, we do not retain such data for more than 5 years. If you no longer want us to use the information that we physically access and store, you can request that we erase your personal information and close your account. Except for any legal obligation that sets a longer data retention period, at the end of these periods, the processed personal data will be deleted or anonymized.
6.1. Personal data may be processed by both automated and non-automated means and may be stored at our premises and on our service provider’s servers. We understand that, unfortunately, the transmission of Information via the Internet is not completely secure. We do our best to maintain the privacy and integrity of your Information. We have implemented industry-standard security measures, which include encryption to protect your personal information, including all information you input into your habit data or share in Services, and this information is not available to third parties. Our measures include Pseudonymization and tokenization; Encryption, Protection of data integrity and etc. However, transmissions over the Internet are never 100% secure, and you should not provide any personal data if you want to avoid any risk. We will also not use information received through your use of the HealthKit and Google Fit framework for advertising or similar services, nor will we sell it.
6.2. We work in the international space and provide our Services to our Users around the world. We and third-party organizations that provide automatic data processing technologies for the App or our third-party advertising partners may transfer the automatically processed information across borders and from your country or jurisdiction to other countries or jurisdictions around the world. You acknowledge and agree that The locations of servers for the services include:
(1) Cyprus and
(2) Germany (The European Union) - the servers located in the European Union that automatically process your personal data and obtain access to your personal data for the purposes of manual processing;
Your data will be processed on our servers, which may not be located in your country of residence. No matter where our servers are located, we will make great efforts to take the appropriate safeguards to guarantee your rights in conformity with this Privacy Policy and any applicable laws. This means that your personal information can be transferred to a third country, a territory, or one or more specified sectors within that third country or to an international organization where data protection and confidentiality regulations may not provide the same level of protection of personal data as your country does. Your consent to this Privacy Policy, followed by your submission of such information, represents your agreement to that transfer.
We attach great importance to user privacy and would like to explain your data protection rights.
(i) The right to withdrawal. It’s important to remember that if we process your data based on your consent, you have the right to withdraw your consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. Withdrawal is made by the mere notification of GOTOTOP LTD via its Support service, i.e., by sending an e-mail to the address gototop@support-team.app with the topic «Consent withdrawal» or in the Settings menu of the application.
(ii) The right to know what Personal Data we hold and how and why we handle your Personal Data. You can ask us for a copy of your Personal Data. If you would like to exercise your right of access, please contact us as described below and let us know what information you would like to receive.
(iii) The right to opt-out of direct or target interest advertising on mobile applications by checking the privacy settings on your device settings menu. Please note that even if you use your right to opt-out, you will still receive advertising, but not direct or target interest. On Apple, you can opt out of this by going to Settings > Privacy > Advertising and turning on “Limit Ad Tracking”. On Android, you can opt-out by going to Settings > Google Services> Ads and choosing “Opt out of Ads Personalization.”
(iv) The right to request an update or correction (rectify) to any of your Personal Data that is out of date, incomplete, or incorrect (according to Article 16 of the GDPR). In certain specific circumstances, you have the right to ask us to delete your Personal Data which we are holding about you.
(v) The right to delete your personal data. (Right to be forgotten). You have the right to request that we delete certain of your personal data.
(vi) The right to object. You have the right to object to our processing of your personal data under certain conditions. Object to us processing your personal data at any time on grounds relating to your particular situation. Object to your personal data being processed for direct marketing purposes.
(vii) The right to restrict the processing of your personal data under the conditions set out in Article 18 of the GDPR or any other applicable laws in your country of residence.
(viii) The right to portability of your personal data. In some circumstances, you may have the right to request that the data that you have provided to us be provided to you so you can transfer this to another data controller.
(ix) The right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority. Please see this directory for contact details: https://edpb.europa.eu/about-edpb/board/members_en. If you are in Switzerland, please visit this FDPIC site for contact details: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html.
(x) The right to Data portability. You have the right to Request a copy of your personal data in electronic format and the right to transmit that personal data for use in another party’s service.
(xi) The right to request access to the personal information we collect from you, change that information or delete it in some circumstances. You have the right to request us for copies of your personal data. To request to review, update, or delete your personal information, please submit a request. We will respond to your request within 30 business days. The User is empowered to request one copy of the personal data undergoing processing free of charge. Any additional copies are provided on a reimbursement basis.
You may send the request aimed at exercising your rights provided herein to our email or to our business address: 28 Oktovriou 367, MEDITERRANEAN COURT, 1st Floor, Flat/Office A5, 3107, Limassol, Cyprus. If you make a request, we have one month to respond to you.
Our services usually have a minimum age requirement for users and are not directed to children. We do not knowingly collect personal data relating to children. Children should never disclose their name, address, phone number, or any personal information without their parents’ prior permission. We consider a user to be a child if they are under the age of 13 unless more stringent regulation applies in their country of residence. In EU countries, users under the age of 16 are considered children unless the data protection regulation of their country of residence specifies another age. If you become aware that your child has provided us with Personal information without your consent, please contact us, and we will take the required steps to delete such information. Moreover, some of the apps are limited to users younger than 18.
This is additional information about how we collect, use, disclose, and otherwise process personal information of individual residents of the State of California within the scope of the California Consumer Privacy Act of 2018 (“CCPA”). We adopted this paragraph to comply with the CCPA, and any terms defined in the CCPA have the same meaning when used in this notice.
California law requires us to disclose information about the categories of personal information we collect and how we use it, the categories of sources from which we collect personal information, and the third parties with whom we share personal information. We have provided detailed descriptions above in this policy. In particular, our Services have collected the following categories of personal information from its consumers within the last twelve (12) months:
Category | Examples | Collected | We sell | Sources of Collection | Categories of Third Parties with Whom We Share Personal Information |
A. Identifiers. | A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, and Social Security number. | YES | NO | User, their Devices | Advertisers, Analytics Providers, and Third Parties as Legally required |
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). | A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal data in this category may overlap with those from other categories. | NO | NO | N/A | N/A |
C. Protected classification characteristics under California or federal law. | Race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth, and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information), driver’s license number, passport number, or other similar identifiers. | NO | NO | N/A | N/A |
D. Commercial information. | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | YES | NO | User | Payment Service Providers |
E. Biometric information. | Genetic, physiological, behavioral, and biological characteristics or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data (Hair color, eye color, fingerprints, height, retina scans, facial recognition, voice, and other biometric data). | NO | NO | N/A | N/A |
F. Internet or other similar network activity. | Browsing history, search history, and information on a consumer’s interaction with a website, application, or advertisement. | YES | NO | User, their Devices | Advertisers, Analytics Providers, and Third Parties as Legally required |
G. Geolocation data. | Physical location or movements. | NO | NO | N/A | N/A |
H. Sensory data. | Audio, electronic, visual, thermal, olfactory, or similar information. | NO | NO | N/A | N/A |
I. Professional or employment-related information. | Current or past job history or performance evaluations. | NO | NO | N/A | N/A |
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). | Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. | NO | NO | N/A | N/A |
K. Inferences are drawn from other personal information. | The profile reflects a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | YES | NO | Users, their Devices, Partners | Advertisers, Analytics Providers, and Third Parties as Legally required |
As a California resident, you have the rights listed below:
Other Rights. The User can request certain information about our disclosure of your information to third parties for their direct marketing purposes during the preceding calendar year (to the extent we have shared information for such purposes within the given period). This request is free and may be made once a year. You also have the right not to be discriminated against for exercising the above-mentioned rights.
The User may exercise your California privacy rights described above by emailing us at gototop@support-team.app. We must confirm your identity (e.g., first name, last name, account name, email address, state of residence, Etc.) and California residency to process your requests to exercise your information, access, or deletion rights. We aim to respond to a consumer request for access or deletion within 45 days of receiving that request. We will inform you of the reason and extension period in writing if we require more time.
The California Consumer Privacy Act ("CCPA") provides California residents with the additional rights listed here. To exercise these rights, see the "Exercising Your California Privacy Rights" subsection below.
Social sharing features
User has the right to know and see what information we have collected about you over the past 12 months, including:
Right to Delete
The User has the right to request that we delete the information we have collected from you (and direct our service providers to do the same). There are several exceptions, however, that include, but are not limited to, when the information is necessary for us or a third party to do any of the following:
Right to Opt-out
The User has the right to "opt-out" or direct us to stop "selling" or otherwise sharing your information with third parties in exchange for monetary or other valuable consideration. To submit an opt-out request, please follow the instructions under the 'Opt-out of targeted advertising' paragraph above to configure the Privacy Setting in any of our apps or by checking your device's privacy settings.
Other Rights
Users can request certain information about our disclosure of your information to third parties for their direct marketing purposes during the preceding calendar year (to the extent we have shared information for such purposes within the given period). This request is free and may be made once a year. You also have the right not to be discriminated against for exercising the above-mentioned rights.
If you have any questions or comments about this policy, you may contact us:
Via email at gototop@support-team.app.
Via post to:
The Company name: GOTOTOP LTD
Address: 14 Panagioti Tsangari, 1st Floor, Office 1E, 4047, Limassol, Cyprus