The following Confidentiality Policy (from here on – “Policy”) is an official document that establishes the procedure of processing information and of implementation of privacy rights of individuals who use the Topface dating service – www.topface.com (from here on – “Service”) – with the help of the Internet web page, mobile version apps, social networks apps, as well as through other methods that are specified in the User Agreement http://topface.com/agreement/.
The present Policy was developed by the Service Administration (from here on – “Administration”.) The goal of the present Police is to provide the necessary privacy rights to the users, which includes their personal data, from unauthorized access and disclosure.
1. Personal data of the users that is received and processed by the Administration
1.1 According to the present Policy, under the term “Personal data of the users” the following is implied:
1.1.1. Personal information that a User provides independently during the registration process (name, date of birth, email, phone number, place of residence, personal photos) or during the further use of the Service, which includes the User’s personal data.
1.1.2. Data that automatically transfers to the Administration during the use of the Service with the help of the software that is installed on a User’s device, which includes IP-address, cookie information, User’s browser information (or the other program that is being used to access the Service), access time, the requested page address, and User’s location coordinates (if the User has allowed that during the mobile app setup.)
1.2. The present Policy is applicable to the Service only. The Administration does not control and is not responsible for the use of third parties’ websites that a User can access through the links that are available at the Service websites. Third parties’ websites and indirect systems, such as pop-up windows, can ask Users for additional personal information or execute any other actions.
1.3 Except for the instances of identification of a User on the basis of and in the manner, specified by the User Agreement http://topface.com/agreement/, the Administration does not verify the authenticity of the personal information that is provided by the Clients, as well as it does not control their competence. In such instances the Administration assumes that Users provide authentic and necessary personal information to the questions that are asked in the registration form and keep that information up to date.
2. The purpose of acquiring and processing personal data
2.1. The website Administration processes personal data for the purpose of discharging the liability that concerns the use of the Service and that exists between the website Administration and its users.
The Administration acquires and processes on the personal information that is necessary for the Service and its features to be provided in accordance with the User Agreement.
2.2. The Administration may also use a User’s personal information in the following instances:
2.2.1. User Identification;
2.2.2. Service quality improvement, convenience of its use, new features development;
2.2.3. Statistical or other kind of research;
2.2.4. Targeted advertising.
3. Processing of the Users’ personal data
3.1. The processing of personal data is based on the following principles:
3.1.1. legality of the purposes and methods of processing of personal data;
3.1.3. accordance of the purposes of processing personal data with the purposes that were determined and declared prior to acquiring personal data, and accordance with the website Administration’s credentials;
3.1.4. accordance of volume with nature of the personal data being processed, and accordance of methods with the purposes of personal data processing;
3.1.5. inadmissibility of merging the databases that were created for incompatible purposes and which contain personal data.
3.2. The Service Administration processes users personal data for the purpose of discharging the liability that exists between the Administration and a User of the Service.
According to the article 6 № 152 “Personally identifiable information” of the Russian Federal Law from 27.07.2006, where additional consent of the user to his or her personal data processing is not required. On account of section 2 of the article 22 of the aforementioned law the Website Administration has the right to process personal data without a notification to the representative committee that protects the privacy rights of the subjects.
3.3. Personal data is acquired during the registration process, and, later on, during the corrections to the personal information that are made by a user of their own accord using the Service’s tools. Users’ Personal data is stored electronically only and is processed with the use of automatized systems.
According to section 7 of the article 5 “Personally identifiable information” of the Russian Federal law from 27.07.2006, the processed personal data is subjected to deletion after is has served the purposes of the processing or in case it no longer helps to serve such purposes.
4. Measures taken to protect the Users’ personal data
4.1. According to section 2 of the article 18.1 № 152 “Personally identifiable information” of the Russian Federal law from 27.07.2006, Administration takes technical, organizational and legal measures to protect the privacy of a User from unauthorized or accidental access, deletion, alteration, blocking, copying, distribution, or any other illegal actions.
4.2. To access the Service, a User needs a login (email address or a mobile phone number) and a password. The responsibility on the safety of this information lies on the User. User cannot share their login and password information with third parties and is fully responsible for its safety by choosing the method of its storage.
4.2.1. In case of registration and entering with the help of the social networks, the social network account data is used.
4.3 To protect the information privacy, Administration provides the Users with the ability to protect their own page with a password that can be restored with the help of the email that was used during the registration.
For additional protection, Administration allows the Users to use the system that links the page with a mobile phone number. To use the system a User has to provide the Website Administration with their mobile phone number. In case that a User lost their login or password information, the access to their page can be restored with the help of the restoration code that is given in a text message that the User gets.
5. Concluding regulations
5.1. Administration has the right to make changes to the present Confidentiality Policy. A new version of the Policy comes into effect after it has been posted, if it is not provided otherwise by the new version of the Policy. The current version is always located under the following link http://topface.com/privacy/.
5.2. The law of the Russian Federation is applicable to the present Policy and to the relations between a user and the Administration that concern the application of the Confidentiality Policy.
5.3. The present Confidentiality Policy has been created in Russian and English languages, and in case of contradictions (conflicts) between the Russian and English versions of the present Confidentiality Policy, the Russian version is predominant.