Privacy Policy
This Privacy Policy (hereinafter the "Policy") applies to the platform (including any applicable websites and interfaces for accessing it, collectively referred to as the "Platform") provided by "TOP GROUP" (the "Company") and is an additional agreement to the Terms of Use Agreement. This Policy describes how the Company collects, uses, and discloses Personal Information received from Users of the website www.1TOP.GROUP and any Account Services provided through the "TOP GROUP" Platform.
1. General Provisions
1.1 Definition of Personal Information: For the purposes of this Policy, "Personal Information" refers to the information provided by the User, through which the User of the website can be identified and/or their identity can be directly or indirectly established.
1.2 User Consent: By registering on the Platform and using it, the User of the website agrees that their Personal Information will be processed in accordance with this Policy and the Terms of Use of the Platform ("Terms of Use"). Capitalized terms used herein shall have the same meaning as in the Terms of Use Agreement.
1.3 Collection and Processing of Information: The Company collects and processes Personal Information about the User of the website directly from them during registration and use of the website, as well as automatically when using the Platform.
1.4 Purpose of the Policy: The purpose of this Policy is to provide the User of the website with information about the purposes of collection and processing of Personal Information, legal grounds, scope of processing, protection, and processing periods of Personal Information.
2. Information the Company Collects Directly About Website Users
2.1 Personal Account and Profile Information:
Email address, username, and other personal data: This information is used to communicate with the Website User.
Name and address: Provided during registration and when purchasing discount certificates.
2.2 Financial Information:
Crypto wallet addresses, transaction data, and balances: Available during interaction with the Platform.
Banking details, including bank card data and transfers through banks: This information is processed exclusively for the purposes of conducting payments and refunds, as well as complying with legal requirements related to financial monitoring and anti-money laundering.
2.3 Additional Information:
The Company may collect additional information to comply with legal requirements, such as checking against restricted persons lists. The Company processes Users’ Personal Information on the following legal bases (in accordance with applicable laws, including GDPR):
User consent – when the User voluntarily provides data.
Contract performance – when processing is necessary for the provision of Services.
Legal obligations – when the Company must process data to comply with legal requirements (e.g., accounting, tax obligations).
Company’s legitimate interests – when processing is necessary to develop and protect Services, marketing, or fraud prevention.
2.4 Communication with the Company:
The Company collects information provided by the Website User during support and feedback, to respond to inquiries, provide assistance, and improve the Platform.
2.5 Authorized Persons:
If a User acts as an authorized representative of another User and provides their Personal Information, they are responsible for having all necessary permissions and consents to provide such information to the Company.
3. Information Automatically Collected by the Company
3.1 Log Data: When using the Platform, the Company’s servers automatically record information using cookies and other tracking technologies, including IP address, webpage address, browser type and settings, date and time of the request, browser configuration information, language preferences, and cookie data.
3.2 Device Information: The Company may collect information about the device type, operating system, device settings, unique device identifiers, and crash data.
3.3 Combination of Information: The Company may combine this information with other collected data, including the User’s name, email address, and other Personal Information.
4. How the Company Uses User Information
4.1 Purposes of Using Information: The Company uses User information, including Personal Information, for the following purposes:
Providing the Platform: To provide the Platform to the User, facilitate communications and transactions on the Platform, communicate with the User about Platform usage, respond to User inquiries, fulfill orders, and for other customer service purposes.
Content Personalization: To customize the content and information the Company may send or display to the User, offer personalized assistance and guidance, and otherwise personalize the user experience when using the Platform.
Usage Analysis: To better understand how Users access and use the Platform, both in aggregate and individually, to improve the Platform and respond to User preferences, as well as for other research and analytical purposes.
Marketing and Advertising: For marketing and advertising purposes. For example, the Company may use information such as the User’s email address to send newsletters, special offers, and promotional campaigns, conduct contests, or otherwise contact the User regarding Services, products, or information. The Company may also use collected information to target Platform advertisements on third-party websites.
Processing Bank Payments: To enable payment for Services via bank transfers and credit/debit cards, as well as to process refunds if necessary. The Company uses this information solely to fulfill payment obligations and maintain accounting records.
The Company does not process biometric data, health information, racial or ethnic origin, religious beliefs, or other special categories of data without obtaining separate consent from the User.
If the User provides such data (e.g., passport photo for verification), the Company uses it solely for identification purposes and compliance with legal requirements.
5. How We Transfer User Information
5.1 Information Transfer: The Company may transfer User information, including Personal Information:
To affiliates and subsidiaries: solely for the purpose of providing the Platform; however, if the Company does so, the use and disclosure of User Personal Information will be maintained by such affiliates and subsidiaries in accordance with this Policy.
To third-party service providers: to vendors, contractors, or agents performing functions on behalf of the Company, provided such third parties agree to use such information only to provide services.
In connection with negotiations or sale: if the Company is negotiating with another company or organization, or the Company is acquired or merged with another company or organization, or if substantially all assets of the Company are transferred to another company or organization, or in a bankruptcy procedure.
By law: in accordance with the law, litigation, court order, or other legal process, for example, in response to a subpoena.
To protect rights and safety: if the Company believes it is necessary to investigate, prevent, or take action regarding illegal activity, suspected fraud, situations involving potential threats to any person’s safety, violations of our Terms of Use or this Policy, or as evidence in a judicial proceeding in which the Company is involved.
Aggregated or anonymized information: the Company may collect, process, analyze, and provide aggregated or anonymized user information to third parties and publicly for product development, marketing, advertising, research, or similar purposes.
Banks and payment organizations: for processing payments, refunds, and transaction verification. Such organizations are required to ensure the protection of Personal Information in accordance with applicable law and agreements with the Company.
5.1.1 When transferring Personal Information outside the User’s country of residence, the Company applies the following measures:
Use of EU Standard Contractual Clauses (SCCs) for transfers of data of EEA citizens;
Concluding contracts with data recipients providing adequate protection;
Applying technical and organizational measures to protect data during cross-border transfers.
5.1.2 Special provisions for users from the European Economic Area (EEA)
Data Controller: www.1TOP.GROUP .
Users have the right to file a complaint with the data protection authority of their country or the European Data Protection Board.
Contact for GDPR questions:support@1TOP.GROUP.
5.1.3 Special provisions for users from the USA (CCPA/CPRA)
Users have the right to request a list of categories of Personal Information collected by the Company.
Users have the right to request deletion of data, except where retention is required by law.
Users have the right to opt out of the sale of their personal information (“Do Not Sell My Personal Information”). The Company does not sell User Personal Information to third parties in the direct sense of this term.
5.2 Cookies and other tracking mechanisms:
The Company and third-party service providers use cookies and other tracking mechanisms to track information about User use of the Platform. The Company may combine this information with other Personal Information collected from Users (and third-party service providers may do so on its behalf).
6. Profiling and Automated Decision-Making
6.1 Profiling refers to the automated processing of Personal Information, manifested as the use of Personal Information to evaluate certain personal aspects of the User, in particular, to analyze or predict matters related to the User’s personal preferences, interests, behavior, and location.
6.2 The Company conducts profiling in accordance with its legitimate interests, based on personal offers and marketing, as well as for awarding the User rewards for participation in the Partner Program. The Company provides Users with options and convenient tools to manage their privacy settings.
6.3 The Company may carry out automated decision-making for the User. The User must be informed about such Company activities separately in accordance with the Terms of Use.
6.4 The making of automated decisions that create legal consequences for the User may only occur in connection with the conclusion or execution of the Agreement between the Company and the User, or based on the User’s full acceptance of the Agreement’s terms.
7. Cookie
7.1 Cookies are alphanumeric identifiers that the Company transfers to the hard drive of a computer, tablet, phone, or other device that the User uses to visit the site via a web browser for record-keeping purposes. Some cookies allow the Company to simplify the User's navigation of the Platform, while others are used to speed up the login process or track the User's actions on the Platform. Cookies are widely used by site owners to ensure the operation of sites or improve performance, as well as to obtain analytical information.
7.2 The site www.1TOP.GROUP uses its own and third-party cookies and similar technologies to store information on the User's computer. This is done to ensure maximum convenience for Users, providing personalized information, remembering preferences regarding marketing, Services, and products, as well as helping to obtain the correct information. By continuing to use the Platform, the User confirms their consent to the use and placement of cookies.
7.3 The Company and service providers may use different types of cookies on the Site:
Strictly necessary cookies. These cookies are necessary to give the User the ability to navigate the Site and use its features, such as accessing protected sections of the Platform.
Cookies for improving the Site’s operation. These cookies collect information about the use of the Site by visitors, such as which pages are viewed most often and whether visitors receive error messages on web pages. These cookies do not collect information that directly identifies the visitor. All information collected by these cookies is combined, remaining anonymous. Such information is used only to improve the operation of the Site. These cookies collect information about Site usage solely in the interest of the Site operator. By using the Site, the User agrees that the Company may place such cookies on their device.
Functional cookies. These cookies allow the Site to remember the User's selected response options (for example, User's name, language, or region) and provide enhanced capabilities according to individual preferences or needs. For example, the Site may provide the User with information about Services and products offered in a specific city or region by storing the region where the User is currently located in a cookie. These cookies may be used to remember changes made by the User regarding text size, fonts used, and other customizable web page settings. They may also be used to provide requested User services, such as viewing videos or commenting on blogs. Information collected by these cookies may be anonymous, and these cookies cannot track User activity on other sites. By using the Platform to set personal settings, the User agrees that the Company may place such cookies on their device, used to remember preferences.
Targeting or advertising cookies. These cookies are used to show advertisements that best match the User’s needs and interests based on the analysis of the User’s movements on the network. They are also used to limit the number of ad impressions and help the Company evaluate the effectiveness of an advertising campaign. They are usually placed on the User’s device by third-party advertising networks but with the Company’s permission. Such cookies remember the User’s visit to our Site. This information is used jointly with other organizations, such as third-party advertisers, and will be linked to Site functions provided by other organizations. In other words, these cookies collect the most information about users.
7.4 The Company and service providers may use cookies for various purposes, including:
Systems of the Company can uniquely identify the User during a session or while logging into the Platform. This allows the Company to process the User’s online transactions, orders, and requests and verify their identity after the User has logged in while navigating the Platform.
Facilitate obtaining information about the User’s Site visits;
Analyze information about page visits by the User to improve our Site;
Provide advertising, messages, and content created by the Company and third parties on this Site and other sites, considering the User’s interests;
Help the User obtain the necessary information;
Determine the number of visitors and how they use our Site to improve the efficiency of the Site and best understand their audience’s interests;
Track aggregate and statistical information about User activity.
7.5 Disabling cookies. Most web browsers automatically accept cookies, but if desired, the User can change their browser settings to block them in the future. General settings of most browsers will explain how to prevent the computer from accepting new cookies, how to make the browser notify about a new cookie, or how to disable cookies entirely. Users of the Platform who have disabled cookies will not be able to view certain areas of the Platform.
8.Third-Party Analytics
8.1 The Company uses automated devices and applications such as Google Analytics and Yandex Metrica to assess the use of the Platform. The Company may also use other analytical tools to evaluate the Platform. The Company uses these tools to improve the Platform, performance, and user experience. These organizations may use cookies and other tracking technologies to perform their services. The Company does not share the User’s Personal Information with these third parties.
Links to Third-Party Websites
9.1 The Platform may contain links to third-party websites. Any access to and use of such linked websites is not governed by this Policy but instead is governed by the privacy policies of those third-party websites. The Company is not responsible for the information practices of such third-party websites.
10. Security of User’s Personal Information
10.1 The Company has taken reasonable precautions in accordance with applicable laws and regulations to protect the Personal Information that the Company collects from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. The User agrees that no data security measures can guarantee 100% security. Therefore, all Users (including their Authorized persons) of the Platform must comply with the security requirements set forth in the Terms of Use and take the following additional steps to help ensure the security of their Personal Information and access to their Account:
ensure the security of private keys and passwords for accessing the Crypto Wallet and keep them safe and confidential, and not disclose this data to third parties.
beware of fake resources and phishing websites. The Platform has only one website address – www.1TOP.GROUP
install antivirus, antispyware, and firewall software on their personal computers and mobile devices.
regularly update operating systems, antivirus, and firewall products with security patches or newer versions.
disable file and printer sharing on computers, especially if they are connected to the Internet.
regularly create backups of their critical data.
consider using encryption technology to protect highly sensitive or confidential information.
completely log out and clear the browser cache after completing each online session with the Platform.
do not install software or run programs of unknown origin.
delete unwanted email.
do not open email attachments from unknown people.
do not disclose personal and financial information to little-known or suspicious websites.
do not use a computer or device that cannot be trusted.
do not use public computers or internet cafés to access online services or perform financial transactions.
10.2 The User must immediately notify the Company at support@1TOP.GROUP if they become aware of any unauthorized use or access to the User’s Account or User credentials. The Company is not responsible for any lost, stolen, or compromised User credentials or for any activity in the User’s Account as a result of unauthorized use of the User’s credentials.
10.3 The Company applies safeguards when processing banking transactions, including encryption of bank card data and compliance with payment industry security standards (e.g., PCI DSS). The User agrees that when paying by banking methods, the data may be processed in encrypted form by payment operators and banks with which the Company has agreements.
11. Access, Correction, and Deletion Rights
11.1 The User may access, edit, update, or delete their Account or Personal Information collected by the Company at any time by entering their account settings or by sending us an email at support@1TOP.GROUP. The Company will respond to the User’s requests within a reasonable time, but no later than the period required by law.
Right to restriction of processing – The User may request to temporarily suspend the processing of their data.
Right to data portability – The User may request their data in a structured, machine-readable format and transfer it to another operator.
Right to object – The User may object to the processing of data for marketing, profiling, or other purposes based on the legitimate interests of the Company.
Right to withdraw consent – The User may withdraw previously given consent to processing at any time.
11.2 Notwithstanding the foregoing, there may be circumstances in which the Company cannot fulfill a request to edit, update, access, or delete an Account profile or Personal Information. This includes, but is not limited to:
any ground on which such a request may be denied under applicable law;
where it is necessary to retain information in accordance with federal, state, or local laws, as well as for accounting or taxation purposes;
when it is necessary to carry out a civil, criminal, or regulatory investigation, or a subpoena from federal, state, or local authorities;
when it is necessary to cooperate with law enforcement authorities regarding behavior or activities that, in the reasonable and good faith opinion of the business, service provider, or third party, may violate federal, state, or local law;
where it is necessary to retain information for the establishment or defense of legal claims;
if the information contains legal privileges or information belonging to another party; or
in cases where fulfilling the request would compromise the privacy of others or other legal rights.
11.3 If the Company decides that it cannot respond to any request in a particular case, it will provide an explanation of why such a decision was made and a contact point for any further inquiries. To protect the User’s privacy, the Company will take commercially reasonable steps to verify identity before responding to any request under this provision, including compliance with any applicable legal requirements for verifying the User’s identity.
12. Information Transfer
12.1 The Company may store the User's Personal Information on servers located in the countries where the Company's main offices are located. If such jurisdiction is outside the User's country of residence, the User agrees to the transfer of Personal Information to such jurisdiction for the purpose of providing the User with the Platform, even if such other jurisdiction provides a lower level of Personal Information protection than the User's country of residence.
13. Information Storage
13.1 The Company retains the User's Personal Information as long as the Account is used on the Platform. We will cease to store the User's Personal Information or remove means by which Personal Information can be associated with specific individuals as soon as it is reasonably assumed that:
the purpose for which this Personal Information was collected is no longer served by its retention; and
the retention is no longer necessary for legal, accounting, or business purposes.
The User agrees that some laws may require us to keep records of transactions or accounts for a certain period of time.
Bank transactions and documents related to payments may be stored by the Company for the period established by tax and financial legislation, even if the User's Account is deleted.
14. Children's Privacy
14.1 The Platform is not intended for children under 18 years of age. If the Company discovers that a child under the age of 18 has provided Personal Information to the Company, the Company will delete such information from all systems.
15. Contacting the Company
15.1 If the User has questions regarding aspects of the Platform's privacy, the User may contact the Company through the internal services of the Site or via email at support@1TOP.GROUP
16. Changes to this Policy
16.1 This Policy comes into effect from the moment of its publication. The Company may make changes to the Policy. The new version of the Policy comes into effect from the moment it is published on the Site; for this reason, the User should regularly check the Site for changes.
In case of discrepancies between translations of the Privacy Policy and the English version, the English version shall prevail.