Privacy Policy top-contacts.com
Media Buy Services Ltd. takes your privacy very seriously, treats all your personal information with great care, and assures you that your data will only be used by this Privacy Policy. This Privacy Policy sets out how Media Buy Services Ltd. uses and protects any information that you provide Media Buy Services Ltd. when you use our website and our services. In short, we use your data to offer you our services, to get in touch with you, inform you about our service, and be able to make your offers.
Questions Related to Data Protection and Exercising your Rights
If you have any questions related to data protection, or if you wish to exercise your rights, please contact supp23@top-contacts.com or the address stated above, adding the keyword “Data Protection”.
Support requests via supp23@top-contacts.com as well as email attachments will not be opened/considered due to security regulations.
Who is Media Buy Services Ltd.?
Media Buy Services Ltd. provides a service using a platform (“Platform”) where users can get in touch and communicate with each other through messages. The services of Media Buy Services Ltd. are provided by: Media Buy Services Ltd., Arh. Georgi Nenov 25 str. office 1; 1324, Sofia, .
Media Buy Services Ltd. is responsible for the manner in which your personal data is being collected, used and stored.
In which cases will we process personal data
We will process personal data which you transfer to us actively by your entries. Additionally, we will process personal data in an automated way, based on the use of our service. Particularly in the cases stated below your personal data may be processed.
- Visiting our website
- Creating a customer account
- Purchase of Coins
- Contacting other users or us
- Email Newsletters
- Approaches to us
- Chats, approaches to other users
- Analyzes of the users‘ motivations for visiting our website and how they use it
- Analyzes of our advertising measures‘ success
- Personalization of advertisement measures
- Defense against attacks on our technical infrastructure
For details, please refer to the following explanations.
Visiting our Website
As soon as you visit our website, the company we have entrusted with the website’s operation will store the public IP address of the computer you are using to visit our website. This includes the access date and time. The IP address is a unique numeric address, through which your computer sends and receives data via the internet.
Usually, neither we nor our service provider will know whom the IP address belongs to, unless you provide us with any data permitting us to identify you while using our website. Also, a user can be identified if we take legal action (in cases of cyber-attacks on our website, for instance) and are informed of the user’s identity during the process of investigation. So as a general rule, you will not have to worry we will be able to draw a connection between you and your IP address.
Our service provider is using the IP address to enable you to visit and use our website and to discover and prevent attacks on our websites. Unfortunately, websites are attacked frequently, to harm the operators and users (for example blocking access, spying on data, distributing malware like viruses, or other illegal purposes). Such attacks would adversely affect our website’s intended use as well as the security of our website’s visitors.
The IP address, along with the visit’s time, is being processed to prevent such attacks and potential dangers resulting from them for ourselves and our website’s users. Via our service provider we are pursuing the justified interests of maintaining our business operations as well as of preventing unlawful interference affecting ourselves or our website’s visitors.
The legal basis of this processing activity is article 6 paragraph 1 f) of the General Data Protection Regulation (GDPR). The stored IP data will be deleted by depersonalization, provided they are no longer necessary for identifying or preventing attacks.
Ways of Contact
Whenever you contact us via one of the ways of contact provided, we will make use of the data provided by you to process your inquiry. You can contact us by using the contact form on the Platform. In this contact form, we ask you to provide us with the following information: name, email address, and message. We use this information to reply to your questions, request, and complaints.
The legal basis for this is our justified interest in replying to your request according to article 6 paragraph 1 f of the General Data Protection Regulation (GDPR). If your request is serving the purpose of concluding or processing a contract with us, the additional basis of the processing activity is article 6 paragraph 1 b of the General Data Protection Regulation (GDPR). The data will be deleted after your request has been completed. In cases in which we are obligated by law to store the data for a longer period, they will be deleted after the expiry of this period.
Creating a Customer Account
To make use of our Platform, you need to create an account. To create your account we ask you to provide us with your name, email address, and password. This information is mandatory. You can also add extra information, such as your profile picture, telephone number, location, gender, age, date of birth, physical characteristics, relationship status and sexual orientation or flirt preferences. Your extra information is saved in your account and you can update or delete this information at all times. Furthermore, this extra information may qualify as special category of personal data which we only process based on your consent. You are at all times entitled to withdraw your consent by sending an email to supp23@top-contacts.com. Please be advised that if your messages to users of the Platform contain (special) personal data, we process that data to provide you the service.
To use all of our offer’s functionalities, you need to create a customer account. Apart from the information required during the registration process, all other personal information will be provided voluntarily. You alone decide what information you would like to include in your user profile. You can edit or delete your data at any time. The more information you provide, the higher the chances for other users to find you and recognize the mutual interests you share with them. As our website is accessible for everyone via the internet, all the information provided by you will be public.
If you do not provide any data permitting us to identify you (such as your mobile number), you can use our service without us knowing who you are. If you buy coins, you will have to provide your name and your address, but only our payment service provider will receive this data, which they will not forward to us. Accordingly, you will be able to use our service anonymously.
If you create a customer account and add information to your profile, we are processing the data provided by you for this purpose, to create and administrate your customer account, as well as to enable you to make use of the services related to your customer account. Additionally, the data will be used for our service and made accessible to other users, following their intended purpose (for example searching for specific inclinations and interests, match checks to identify mutual interests and preferences). The legal basis of this processing activity is article 6 paragraph 1 b) of the General Data Protection Regulation (GDPR).
During the process of creating a user account, we will be able to identify your approximate location, based on your IP address. We will use this to pre-enter this location in your user profile, which you can change. This is done to ensure that the members of our service will use the correct location for local searches and thereby – unless they adapt the location – will find other members. The legal basis of this processing activity is article 6 paragraph 1 f) of the General Data Protection Regulation (GDPR).
The data will be stored until the customer account is deleted. In cases in which we are obligated by law to store the data beyond this event (to fulfill accounting obligations, for instance), or if we are legally entitled to store the data beyond this event (in case of a current lawsuit against the user account owner, for instance), the data will be deleted as soon as the obligation or the legal authorization to store the data ceases to exist.
Signup via Google and Facebook
For easier signup to our service you can use the corresponding services by Google and Facebook. In this case, your account with the respective provider will also serve as access to our service. For the use of these services, the data privacy policy of the corresponding provider applies in the first instance (data privacy policy Google as well as Facebook) as well as any additional agreements you have consented to as a customer of Google or Facebook. Regarding this, please refer to the corresponding data privacy policies of Google or Facebook and check the agreements you have consented to in connection with these contracts or separately.
The corresponding provider will transfer the following personal data regarding you, which we will store in your customer account and process as stated under „Customer Account“.
Google:
- First Name and Last Name
- Email Address
- Gender
- Profile Picture
- Language
Facebook:
- First Name and Last Name
- Email Address
- Gender
- Date of Birth
- Profile Picture (we will only use the first profile picture)
- Facebook-Sites you have liked (Likes)
- Location
- Language
The legal basis of this processing activity is article 6 paragraph 1 a) of the General Data Protection Regulation (GDPR), as you are agreeing to the data transfer by using the corresponding service.
The processing of special categories of personal data in accordance to article 9 of the General Data Protection Regulation (GDPR)
If you add any data to your profile, or otherwise communicate any data to us for processing, which could be considered to be data of special categories within the meaning of article 9 of the General Data Protection Regulation (GDPR) (for example ethnic origin, religious or ideological conviction, data referring to sexual life or sexual orientation), we will process them on the sole basis of your voluntary indications and use them for no other purpose than providing the functionalities of our service, for which these data will be accessed and used.
This involves the public indication of these data to your customer account for other users of our service, public search functions for users, match checks, and all other functionalities of which it is recognizable to you as a user that these data are being used for them. If you do not wish this to be done, please do not add any data of the nature defined in article 9 of the General Data Protection Regulation (GDPR) to your user profile and do not communicate any such data to us or to other users.
Chat between Users
As a part of our contractual services we are offering our users the option of sending and receiving chat messages. The legal basis of the corresponding processing of personal data is article 6 paragraph 1 b) of the General Data Protection Regulation (GDPR). The corresponding messages will be saved until you have them deleted, provided we are neither legally obligated nor entitled to continue the storing.
Calculating your Position
To be able to suggest other users of our service in your neighborhood, we will calculate your position via your browser. To enable this, you need to share your position on your browser's corresponding question. The legal basis of this processing activity is article 6 paragraph 1 a) of the General Data Protection Regulation (GDPR). You can disable the sharing of your position at any time by adapting your browser settings accordingly.
We are using Google Maps, a service by Google LLC („Google“), Amphitheater Parkway, Mountain View, CA 94043, the USA to auto-complete your search for a city as well as to localize your position, if you have agreed to this in your browser. When this function is called, your IP address will be transferred to Google. The IP address is a unique numeric address, by which the respective computer sends and fetches data via the internet. For this, Google’s data privacy policy applies, which can be accessed at .
Our justified interest in using Google Maps is supporting our website’s visitors in entering a desired city name (The legal basis of this processing activity is article 6 paragraph 1 f) of the General Data Protection Regulation (GDPR)) as well as your constantly revocable consent to the localization serving the purpose to suggest users in your area (The legal basis for this processing activity is article 6 paragraph 1 a) of the General Data Protection Regulation (GDPR)).
Payment details
To gain full access to the Platform, which among other things includes the option of sending and receiving messages, you need to buy credits. For this purchase, we process your payment details which include your phone number. To process your payment, you will be transmitted to the website of your bank, credit card company, or another payment provider. You will be transferred back to the Platform once you have completed your payment.
We will also process these data in connection with your IP address to identify and prevent fraud attempts, based on article 6 paragraph 1 f) of the General Data Protection Regulation (GDPR). Thus, we are pursuing the aim to protect ourselves from fraudulent transactions.
Data stored in connection with the conclusion of a contract concerning the purchase of a product will be deleted on expiration of the legal retention obligation. In cases in which legal record keeping requirements and retention obligations exist (for example retention of invoices according to tax legislation), the legal basis for this processing activity is article 1 paragraph 1 c) of the General Data Protection Regulation (GDPR). We will delete or de-personalize the data as soon as they are no longer necessary for the processing of the respective contract and any legal retention obligation has ceased to exist.
Newsletter
On your registration for our offer, we have informed you that we will make use of your e-mail address to send out our newsletter. You can object to this use at any time, which will result in you being deleted from our email list. You will find a corresponding link at the end of each newsletter.
We are using cookies for the purposes stated below:
- Technically necessary cookies, which are indispensable for the use of our website’s functions (for example to identify whether you have logged in). Certain functionalities could not be provided without these cookies.
- Functional cookies that are being used to technically process certain functionalities, which you would like to use.
- Analyzing cookies serving the purpose of analyzing user behavior.
- Cookies of third party providers. Cookies of third-party providers are stored by third parties, whose functionalities we are integrating into our website, to enable certain functionalities. They can also be used to analyze user behavior.
Most of the browsers employed by our users permit their settings to be adapted, concerning which cookies are to be saved. They also permit the deletion of (specific) cookies. If you are restricting cookies to be saved on specific websites, or if you are declining cookies from third-party websites, you might not be able to make use of our website to its full extent. Below please find some information concerning how to adapt the cookie settings with the most frequently used browsers:
Google Analytics Data Protection Declaration
This website is using Google Analytics, a service by Google LLC („Google“). The use is based on article 6 paragraph 1 subparagraph 1 letter f) of the General Data Protection Regulation (GDPR). .
Google Analytics is making use of so-called „Cookies”, which are small text files, which are stored on your computer, and which permit an analysis of your use of the website. The information regarding your use of the website created by the cookie, such as
- Browser type / version
- Operating system
- Referrer URL (the website you have been visiting before)
- Hostname of the accessing computer (IP address)
- Time of server request
will usually be transferred to one of Google’s servers within the USA and stored there. The IP address transferred via your browser within the framework of Google Analytics will not be brought together with any other data by Google. The way we use Google Analytics ensures that your IP address will be used in a de-personalized way only. According to Google’s statement, this de-personalization will be done within the European Union or a member state of the European Economic Area. It will only be in exceptional cases in which the complete IP address shall be transferred to one of Google’s servers within the USA and only be abbreviated at that point. According to Google’s statement the de-personalization will be done before the IP address will be stored initially on a permanent data medium. For details, please refer to Google’s privacy policy, accessible via .
On behalf of this website’s operator Google will make use of this data to analyze the website’s use, create reports about the website activities, and perform other services related to the website’s and the internet’s use for the website’s provider. You can prevent the saving of cookies by adapting your browser software settings. We would like to point out that in this case you may not be able to make full use of all the functionalities of this website.
Additionally, you can prevent the registration of data created by cookies and related to your use of the website (including your IP address) by Google as well as the processing of these data by Google by downloading and installing the browser plugin available via this link: .
Google is a member of the PrivacyShield Agreement and has concluded an order management contract with us for Google Analytics.
Additionally, we are using Google Analytics to evaluate data from double-click cookies and AdWords for statistical purposes. If you do not wish this to be done, you can deactivate it via the ads preferences manager ( ).
Please refer to Google Analytics Help for further information related to Google Analytics ( ).
Personal offers
On the basis of the personal information collected by Media Buy Services Ltd. a profile is created. Based on this profile, we try to tailor our offers to you as well as possible. These offers are sent to you by email.
For this we use:
- The functionalities that you use
- Your surfing behavior on the website
- The amount that you spent on credits
- Your flirt preferences
- Data collected by using cookies
This use of your personal data is based on your consent. If you no longer wish your information to be used for this purpose, you can withdraw your consent by sending an email to supp23@top-contacts.com
Statistical research
Media Buy Services Ltd. wishes to deliver services of the highest quality. To accomplish this Media Buy Services Ltd. needs to perform statistical research. Based on the outcome of the research we can make adjustments to our services and/or the Platform. Media Buy Services Ltd. uses your personal data for this statistical research. The results of the research are always aggregated. This means that the data in the research results can no longer be traced back to you.
Automatically generated data
Media Buy Services Ltd. requires certain information for the Platform to work as optimally as possible (for example, to display content correctly and to keep the Platform secure). That is why we collect automatically generated data on your use of the Platform. This information consists of:
- the device type (i.e. tablet or smartphone) you use;
- the IP address (and geolocation) of your device
- operating system of your device
- browser software you use
- web pages you visit
- The internet service provider that you use
Third party disclosure
We will not provide your data to third parties without your consent unless the following cases apply:
We provide your personal data to (sub)processors (inter alia the hosting party and entities that employ the people that reply to your messages) which may process personal data under the responsibility of Media Buy Services Ltd.. Media Buy Services Ltd. assures that it has contractually guaranteed that these (sub)processors will not process data outside the scope of this Privacy Policy, and that technical and organizational measures are taken to safeguard your personal data against (inter alia) unintentional loss or destruction or damage of your personal data.
We may provide your personal data to any third parties if you have explicitly consented to the transfer for these parties to process your personal data, and/or insofar as this information cannot be traced back to you.
We may provide your personal data to third parties in case we are obligated to do so under applicable law and/or regulations, as a result of a lawsuit and/or if we believe that this is necessary to protect our rights.
What we do with your information?
We will process your personal data for the following purposes and on the basis of the following legal grounds:
| Purpose | Legal basis | |
|---|---|---|
| Account & Message | To provide the Platform and its functionalities to you and to bring you in contact with profiles that match your preferences. | The processing is necessary for the performance of a contract to which you are a party. In case special categories of personal data are being processed, the processing is based on your consent. |
| Contact form | To answer any questions and / or to be able to contact you. | The processing is necessary for the legitimate interests pursued by Media Buy Services Ltd.. to provide its (customer) services to you. |
| Newsletter | To subscribe you to our mailing list and send you updates on our service. | The processing is necessary for the legitimate interests pursued by Media Buy Services Ltd. to send you the newsletter to which you subscribed. |
| Personal offer | To send you personal offers | The processing is based on your consent. |
| Statistical research | to generate statistical data and to (anonymously) use this data for research purposes. | The processing is necessary for the legitimate interests pursued by Media Buy Services Ltd. to provide the website as user-friendly as possible and to improve our services. |
| Automatically generated information | To secure, adjust and improve the Platform. | The processing is necessary for the purposes of the legitimate interests pursued by Media Buy Services Ltd. namely for information security. |
| Third party disclosure | To provide information about you to third parties and/or to give access to third parties to information about you, providing, this is necessary for the execution of the services; you have given your consent; or this is necessary based on law and/or regulations, as a result of a lawsuit and/or if it is necessary to protect our rights. | The processing is necessary for the performance of a contract to which you are a party; you have given consent to the processing of your data for this purpose; the processing is necessary for compliance with a legal obligation to which Media Buy Services Ltd. is subject. |
Security
Media Buy Services Ltd. is committed to ensuring that your personal data is secure. To prevent unauthorized access or disclosure, Media Buy Services Ltd. takes appropriate technical and organizational measures to protect your data against loss or any form of unlawful processing.
Furthermore, if personal data is stored outside the EEA, Media Buy Services Ltd. ensures that this storage is under the law and that an adequate level of protection is guaranteed. Media Buy Services Ltd. has signed the EU Model Clauses with these parties and/or the transfer of data is based on the EU-US Privacy Shield.
Links to other websites
The Platform may contain hyperlinks that take you to the website or application of a third party, such as social media sites. Media Buy Services Ltd. has no authority over those third-party services and/or websites. For the use of those services and/or websites of third parties, a separate privacy statement might be applicable. This Privacy Policy is exclusively applicable to personal data that is obtained through the Platform. Media Buy Services Ltd. does not accept any responsibility or liability for the (use and/or content of the) services and/or websites of third parties.
Storage term
Media Buy Services Ltd. will store your personal data as long as necessary to perform the purposes of processing as stated in this Privacy Policy.
Controlling your personal information
Under the privacy legislation, you have several rights as a data subject. This chapter of the Privacy Policy states these rights and how you can invoke these rights.
Response
Media Buy Services Ltd. will try to respond to your request as soon as possible, but in any case within four (4) weeks. If Media Buy Services Ltd. needs more time, Media Buy Services Ltd. will inform you of this. In no case Media Buy Services Ltd. will respond to you later than two months.
Your requests can be sent to supp23@top-contacts.com. Please use the email address known to us so we can identify you. To ensure that the information you request is yours, we may ask you to send a valid proof of identity.
If Media Buy Services Ltd. cannot (fully) determine to which personal data your request relates, Media Buy Services Ltd. can ask you to (further) specify your request. The possibility exists that Media Buy Services Ltd. rejects a request from you, for example because your request is unfounded or excessive or because Media Buy Services Ltd. (legally) cannot or does not have to comply with your request. Media Buy Services Ltd. will also notify you of a rejection. Media Buy Services Ltd. informs you that you can, in case Media Buy Services Ltd. rejects your request, file a complaint with the Competent Data Protection Authority.
Right of access
According to article 15 of the General Data Protection Regulation (GDPR) you have the right to demand a confirmation from our side, stating whether we are processing personal data concerning you. If that is the case, you are entitled to intelligence about these personal data and further information, as stated in article 15 of the General Data Protection Regulation (GDPR).
Right to Rectify
According to article 16 of the General Data Protection Regulation (GDPR) you are entitled to demand us rectify any incorrect personal data concerning you with no delay. Concerning the processing purposes, you are also entitled to demand incomplete personal data to be completed – also by an additional statement.
Right to be forgotten
You have the right to demand us to delete your data with no delay. We are obligated to delete any personal data immediately, if the relevant conditions according to article 17 of the General Data Protection Regulation (GDPR) are met. For details, we would like to refer you to article 17 of the General Data Protection Regulation (GDPR).
Right to restrict the processing
According to article 18 of the General Data Protection Regulation (GDPR) you are entitled to demand of us to limit the processing of your personal data, provided certain pre-conditions are met.
Right of Data Portability
According to article 20 of the General Data Protection Regulation (GDPR) you are entitled to receive the personal data you have provided to us in a structured, established, and machine-readable format. You are also entitled to transfer the data to another responsible party without any hindrance from our side, provided the processing is based on any agreement based on article 6 paragraph 1 letter a, or article 9 paragraph 2 letter a, or on a contract according to article 6 paragraph 1 letter b, and the transfer is done via automated tools.
Right to Object
According to article 21 of the General Data Protection Regulation (GDPR) you are entitled to object to your personal data’s processing based on article 6 paragraph e or f of the General Data Protection Regulation (GDPR). This does also apply for profiling based on these regulations.
If we are processing your personal data for direct advertisement, you have the right to object to the processing of your personal data for the use of such advertisement at any time. This does also apply to profiling, if it is connected to such advertisement.
If you would like to exercise any of the rights you are entitled to, please contact us as the responsible party via the contact data given above, or use any of the other ways of contact provided to notify us. If you have any questions regarding this, please contact us.
Existence of a Right of Appeal to the Supervisory Authority
According to article 77 of the General Data Protection Regulation (GDPR) you are entitled to the right of appeal to the supervisory authority without prejudice to any wider administrative or judicial remedy. This right applies particularly within the member state of your abode, of your working place, or the suspected contravention, if you consider the processing of your data to be a violation of the General Data Protection Regulation (GDPR).
Can this privacy statement be amended?
This Privacy Policy may be amended from time to time. The amendments will be published on the Platform. Should any material change be executed, you will be informed of such change.
Complaints or questions?
In case you have any complaints or questions about this Privacy Policy and how Media Buy Services Ltd. processes your data, you have the right to report this via supp23@top-contacts.com. In case you and Media Buy Services Ltd. are not able to resolve your complaint(s) about the aforementioned data processing, you also have the right to file a complaint to the competent Data Protection Authority.
18 U.S.C 2257 Record-Keeping Requirements Compliance Statement
All models who appear in any visual depiction of actual or simulated sexually explicit conduct contained in this website were required to be eighteen years of age or older at the time of the creation of such depictions. Records required by Section 2257 of Title 18 of the United States Code and associated regulations with respect to visual depictions of actual sexually explicit conduct are kept by the custodian of records listed below.
The legal relationship between Media Buy Services Ltd. and the user shall be governed by the laws of the Bulgaria, subject to any mandatory provisions.
Media Buy Services Ltd.
Updated: 01/2024
Media Buy Services Ltd. © 2024.
Arh. Georgi Nenov 25 str. office 1; 1324, Sofia