PRIVACY POLICY


Last Update: May 18, 2018

This Privacy Policy describes privacy rights of, without limitation, Publishers and Advertisers (hereinafter referred to as “you” or “your”) who use http://revtop.com/ website (hereinafter referred to as the “Website”) and all related applications, services and tools. It applies to collection, use, storage, sharing and protection of your personal and non-personal information by Revenue Digital Ltd (hereinafter referred to as the “Company”, “us”, “we” or “our”).

We are providing you with this Privacy Policy to help you make an informed decision as to whether to use or continue using the website. The Company reserves the right to update this Privacy Policy periodically, and these updates are effective upon posting. It is imperative that this Privacy Policy is read thoroughly and often.


COLLECTION OF INFORMATION


We collect both Personally Identifiable Information (PII) and Non-Personally Related Information (NRPI).

Personally Identifiable Information (PII) is information that may include your name, email address, zip code/postal code, telephone numbers (including wireless phone numbers), birth date, gender, salary range, education and marital status, occupation, social security number, employment information, personal and online interests, and any other additional information that may be requested from time to time.

Non-Personally Related Information (NPRI) is information, without limitation, concerning the computer system that the individuals are using to access the Website such as IP address, date and time of visit, domain type, and their activity etc.

Cookies, Web Beacons and Similar Technologies. When you access the Website and/or use our services, we may place small data files on your computer or other device. These data files may be Cookies, Web Beacons or other local storages provided by your browser or associated applications. We use these technologies to recognize you as a Publisher or an Advertiser, to measure promotional effectiveness, to help ensure that your account security is not compromised, to mitigate risk and prevent fraud and to promote trust and safety across the Website and our services.

A Cookie is a small piece of data sent from the Website and stored in your web browser while you are browsing the Website. Every time you load the Website, the browser sends the cookie back to the server to notify the Website of your previous activity.

A Web beacon is typically a transparent graphic image (usually, 1 pixel x 1 pixel) that is placed on the Website. The use of a web beacon allows the Website to record the simple actions of your opening the page that contains the beacon.

We reserve the right to utilize the other Similar Technologies which may have the analogous functional concept and/or lead to the similar results.

You are free to decline our Cookies, Web Beacons and Similar Technologies if your browser or browser add-on permits, unless our Cookies, Web Beacons and Similar Technologies are required to prevent fraud or ensure the security of the Website. However, declining our Cookies may interfere with your use of our website and our services.


USE OF INFORMATION


The Company uses the collected information, prima facie, for providing our services. We may also use this information for contacting you for marketing purposes and share it with the third parties solely to perform services on behalf of the Website, such as providing support to our internal operations.

Your PII will be used, without limitation, to establish your account, to communicate with you and for ongoing record keeping, required by the Company.

Your NPRI will be used, without limitation, for system administration and for improvement of our services. Your log information is necessary to validate and authorize your entry and activity on the Website.

Your Credit Card Information which includes credit card numbers, the expiration date of the card etc., is collected for purposes of processing and completing financial transactions. Credit Card Information is disclosed to the third parties involved in the transactions only.


DISCLOSURE OF INFORMATION


Your PII will not be shared unless we have first given you notice that we might share your data, and you have authorized us to do so.

We may disclose any information we have about you (including your identity) if we determine that such disclosure is necessary in connection with any investigation or complaint regarding your use of the Website, or to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, or the rights or property of visitors to or users of the Website. We reserve the right at all times to disclose any information that we deems necessary to comply with any applicable law, regulation, legal process or governmental request. We also may disclose your information when we determines that applicable law requires or permits such disclosure, including exchanging information with other companies and organizations for fraud protection purposes.

We may share the data which is collected using Cookies, Web Beacons and Similar Technologies to the third parties only in the form of anonymous statistics so that it contains no PII.


GENERAL DATA PROTECTION REGULATION


On May 25, 2018, the European Union’s General Data Protection Regulation (GDPR) becomes officially operative. We maintain our commitment to protect the privacy of its users and abide by the legislation of all regions we operate. We are willing to deliver the best experience to our end-users.

Taking into account of the above, personal data (if any) of our users is processed under the “purposes of legitimate interests” as outlined in GDPR Article 6(1)(f). Such an approach also helps us to fight against fraud and reimburse our contractors and agents.

General Data Protection Regulation (EU) 2016/679, is a European Union law governing privacy and data protection for all residents of the EU. The provisions of GDPR can be also applied to how data is processed and verified (more on that later) outside the European Union.

GDPR is a new set of rules intended to empower the citizens of the European Union to control their personal information. In accordance with the applicable laws, users are authorized to access and modify their own data held by the companies, which includes data collection, ad tracking, surveys, cookies, location data, and every other bit of a user’s “digital footprint”. Users are also entitled to transmit their personal details to other organizations. The GDPR also enforces companies to determine their in-house data security policies.

We will comply with all the GDPR requirements worldwide for all our users by the 25th of May 2018. We will (i) streamline the data handling controls, (ii) specify our relationships with data partners, and (iii) provide the data subjects with an understanding and direct management of the way their personal information is used.


GDPR measures


We cooperate with our partners to determine the way data is handled under the agreed terms.

We have assigned a Data Protection Officer (DPO). You may reach him via dpo@revtop.com

Personal information will be pseudonymized and encrypted to ensure the user privacy. The collected information will be handled for standard cases of use described in this Privacy Policy.

We will retain the gathered data for no longer as 24 months.


The retention policy of company’s data


Company processes and for about 24 months stores the pseudonymized data, let alone special requirement provided by GDPR (fraud, legal claim, etc.). Other than that, all personal data is deleted once the 24-month period is over.


Requests and removal of the data


You (data subject) may send official requests to us via email at the following address: dpo@revtop.com

At any time, you have the right:

  • To access your personal information that we hold;
  • To request the rectification of your personal information that we hold;
  • To request the erasure of your personal information that we hold;
  • To request to restrict processing of your personal information;
  • To object to processing of your personal information by us;
  • To request to transfer your personal information that we hold (e.g. data portability);
  • To file a complaint to a supervisory authority in your jurisdiction; and
  • To withdraw any consent related to your personal information given by you.

Your request will be observed within a 30-day period from the initial request receipt.

We will also notify you and a relevant supervisory authority within 72 hours from a breach in a case of such breach related to your personal information that we hold.


SECURITY OF INFORMATION

Security of your information is our utmost priority. We follow generally accepted industry standards to protect against the unauthorized access to, retention of, and disclosure of data. This includes undertaking necessary physical, electronic, and management activities required to protect data integrity, access, and use. Any data that are stored on our servers is treated as confidential information. Please keep in mind, however, that despite these reasonable efforts to protect data on our servers, no method of transmission over the Internet is guaranteed to be secure. Therefore, while we strive to protect your data at all times, we cannot guarantee its absolute security and shall not be liable for any breach of security by an outside party. Only authorized employees have access to the information you provide us.


CHILDREN’S PRIVACY

We are sensitive to the issue of children’s privacy. Therefore, the Website and our services are neither developed for, nor directed at, children. If you believe your child has provided us with personally identifiable data, and you would like to have the data removed, please contact us.


THIRD-PARTY SITES

A link from the Website to another website does not imply our endorsement of that site. We do not control the websites to which we link and assume no responsibility for their content or privacy policies. Therefore, you should carefully review the privacy policies that apply to any sites you access from our site.


TRANSFER OF DATA UPON CHANGE OF CONTROL

In the event that another company acquires all or substantially all of the assets of our business through a consolidation, merger and asset purchase, or other transaction, we reserve the right to transfer all data (including any PII a user may have provided to us) that is in our possession or under our control to such acquiring party.


CONSENT

By visiting the Website, you consent to the collection and use of any PII and/or NPRI as outlined above. If you do not agree to this Privacy Policy, please do not access or use the Website.


CONTACTS

Do not hesitate to contact us at contact@revtop.com if you have questions about this policy.