Privacy Policy

In cases where you call TopHostingTech or schedule an appointment for a meeting, such conversations will be recorded by TopHostingTech International Ltd. for quality management purposes. As a result, we will be able to maintain and improve the quality of TopHostingTech services based on TopHostingTech quality standards and policies. For this purpose we will process the following data: email address, date and time of conversation, its duration, audio and/or video recording, any other personal data provided by you voluntarily during the conversation. Also, provided email address and / or phone No. may be used for the purposes of allowing you to reach us or contacting you regarding your matter. In such cases processing is necessary for the purpose of the legitimate interests pursued by TopHostingTech (under Article 6(1)( f) of GDPR) or is based on your consent, when you consent to video recording by turning video on, or provide certain data voluntary (under Article 6(1)(a) of GDPR). The recordings will be kept up to for 30 days and deleted thereafter as soon as technically feasible.

3.2. Information We Collect when You use the Platform

When you use the TopHostingTech Platform or contact us directly by any communication channel, we may collect information, including personal information, about the services you use and how you use them.

This information is necessary for the adequate performance of the contract between you and us, to enable us to comply with legal obligations and given our legitimate interest in being able to provide and improve the functionalities and security of the TopHostingTech Platform. Automatic collection of data

• Log data and Device information. We automatically collect log data and device information when you access and use the TopHostingTech Platform, even if you have not created a TopHostingTech Account or logged in. That information includes, among other things: Internet protocol (IP) addresses, browser information, including its type, Internet service provider (ISP), referring/exit pages, device properties, including its operating system, date/time stamp and/or clickstream data.
• Tracking technologies and Cookies. We use cookies, beacons, tags, scripts, and other similar technologies, such as CI codes (click tracking), ISC (source tracking), and ITC (item tracking codes). We also automatically collect information about the device's operating system, phone model, device ID, and customer number. For more detailed information on the use of these technologies, see our Cookies Policy.
• Usage information. We use a tool called "Google Analytics" to collect information about your interactions with the TopHostingTech Platform (e.g., what pages you visit, such as the pages or content you view, your searches for Listings, bookings you have made, and other actions on the TopHostingTech Platform). Consequently, Google, Inc. plants a permanent cookie on your web browser to identify you as a unique user the next time you visit this Site. For more information, please visit Google.
• Geo-location data. We collect information about your approximate location as determined by data such as your IP address to offer you an improved user experience and comply with applicable legal requirements, such as taxes, pricing, etc. Such data may be collected only when you access the TopHostingTech platform using your device.

TopHostingTech processes this information on the legal basis of:

• Your consent;
• Conclusion and performance of contractual arrangements and obligations between TopHostingTech and the User;
• Pursuance of legitimate interests of TopHostingTech, as Data Controller and manager of the TopHostingTech platform.

4. HOW WE USE YOUR DATA?

We use, store, combine, and process information, including personal information, about you to provide, understand, improve, and develop the TopHostingTech Platform, create and maintain a trusted and safer environment, and comply with our legal obligations.

• To Identify: Personal identification information is collected and processed for the purposes of User identification, use of services, and domain name registration. Additionally, this information may be used to provide Users with support, notify them about updates or improvements, and inform them of changes to any Terms of Use (including changes to this Policy).
• To Create and Maintain a Trusted Environment: We verify or authenticate information or identifications provided by you (such as ID number, email, or phone numbers). We also use collected information to detect and prevent fraud, spam, abuse, security incidents, and other illegal activities.
• To Create Aggregated Statistical Data: We carry out market research and analysis necessary for running our business. Aggregated or inferred non-personal information helps us evaluate customer needs, sales trends, and other activities.
• To Stay Connected: We use information about data usage, devices, and operating systems to diagnose problems, optimize applications and services, and enhance your browsing and purchasing experience.
• To Customize Marketing: We may analyze the data you provide and your interactions with the TopHostingTech Platform to offer more customized services and recommendations.
• To Send Service and Billing Messages: TopHostingTech may contact you with essential updates, such as service maintenance notifications, support responses, payment reminders, and abuse complaint notices. These communications are mandatory and cannot be opted out unless you deactivate your account.
• To Register Domains: In certain jurisdictions, domain name registration information must be publicly available through WHOIS searches as required by ICANN rules. TopHostingTech stores and shares this information as required.
• To Contact You: We may notify you regarding your account, troubleshoot issues, resolve disputes, collect fees, or send updates. This may be done via email, telephone, text messages, or portal communication.
• To Handle Sales-Related Inquiries: If you contact us with questions about our services or potential purchases, we will use the data you provide to assist you and follow up on your inquiries.
• To Get Feedback: We may contact you to review our services or products. We might use an external company to collect feedback, sharing minimal data (e.g., name, email, and reference number) for this purpose.
• To Provide, Operate, and Improve the Services: This includes ensuring a smooth and efficient user experience.
• To Enhance Data Security and Prevent Fraud: We process data to maintain the integrity and security of our platform.
• To Comply with Applicable Laws and Regulations: We ensure our practices align with legal and regulatory standards.

5. JOB APPLICATIONS

We understand that privacy and discreteness are crucial to our Applicants and are committed to keep Applicants Information private and use it solely for TopHostingTech's internal and group companies’ recruitment purposes (including for identifying Applicants, evaluating their applications, making hiring and employment decisions, and contacting Applicants by phone or in writing). TopHostingTech may retain Applicants Information submitted to it for no longer than one year after the applied position has been filled or closed. We collect this information to re-consider Applicants for other positions and opportunities at TopHostingTech; we can use their Applicants Information as reference for future applications submitted by them; and if the Applicant is hired, for additional employment and business purposes related to his/her work at TopHostingTech. If you previously submitted your Applicants Information to TopHostingTech, but now wish to access it, update it or have it deleted from our systems, please contact us at tophostingtech@gmail.com .

6. INFORMATION PERTAINING TO VISITORS AND USERS OF OUR USER’S WEBSITES OR SERVICES

We may collect, store and process certain information pertaining to visitors and users of our User’s websites or services, solely on our Users’ behalf and at their direction. Each of our Users is able to collect and manage information, including personal data, via their website. Such information and personal data are then stored with TopHostingTech. For such purposes, within the meaning of the GDPR, TopHostingTech may in certain limited cases, as specified in the Terms of Service, be considered as a “data processor” of such information pertaining to visitors and users of their websites or services. The Users controlling and operating such User websites, shall be considered as the “data controllers” of such information, and shall be solely, completely and fully responsible and liable for complying with all laws and regulations that may apply to the collection and control thereof, including all privacy and data protection laws of all relevant jurisdictions.User shall be solely, completely and fully responsible for the security, integrity and authorized usage of information related to visitors and users of their websites or services, and for obtaining consents, permissions and providing any fair processing notices required for the collection and usage of such information.

TopHostingTech has no direct relationship with the individual visitors and users of our User’s websites or services whose personal data it processes. If you are a customer of any of our Users, and would like to make any requests regarding your personal data, please contact such User(s) directly. For more information about data processing arrangement between us and our Users, please see our Terms of Service.

7. DIRECT MARKETING AND SERVICE EXPIRATION NOTICES/RENEWAL REMINDERS

When creating an Account at our Platform, subject to the available preferences, you are free to give consent and/or opt-out from receiving various offers and/or notices directly to your e-mail, phone (SMS and/or Whatsapp messages) or in your Account. We use provided contact details and your preferences for direct marketing (by sending various offers or newsletters) and/or Service expiration notices / renewal reminders.

This communication, depending on your preferences, may be personalized taking into account any other information which you have provided to us (e.g. location, social media profile information, purchase history etc.) or we have collected or generated from other sources as described below. Please note that in case you subscribe to service expiration notices / renewal reminders via SMS/WhatsApp, it is our right, but not an obligation, to send such notices / reminders for each Service.

Right to object / revoke consent

If a User wishes to change their preferences communication (revoke consent or object), they are free to exercise such option at any time they wish by (1) following the instructions to unsubscribe in the received email (usually, by clicking on a link for that purpose at the bottom of our e-mail) / text message; (2) visiting and adjusting User’s personal account settings (communication preferences). You may also at any time refuse to receive information from us by sending an email to tophostingtech@gmail.com.

8. OTHER USES OF YOUR PERSONAL DATA

• Developing the Platform: We use data, including public feedback, to conduct research and development for the further enhancement of our platform, aiming to provide you and others with a better, more intuitive, and personalized experience, as well as to drive membership growth.
• Customer Support: We use data to assist you and fix problems. This data (which may include your communications) helps us investigate, respond to, and resolve complaints and issues (e.g., bugs).
• Aggregate Insights: We use data to generate aggregated insights. This data helps us produce and share insights that do not identify you personally.
• Security and Investigations: We use data for security purposes, fraud prevention, and investigations. We may use your data (including your communications) if necessary for security purposes or to investigate possible fraud, violations of our Terms of Use, this Policy, or attempts to harm our users.

9. SOURCES OF PERSONAL DATA

We collect and receive your Personal data from yourself (including your device) as well as from the following sources:

• Social network operators (such as Facebook, Google, etc.);
• Third-party service providers, suppliers and our partners;
• Other legal sources.

10. RETENTION AND DELETION

We generally retain your personal information for as long as is necessary to provide our services and to comply with our legal obligations. Where your personal information is no longer required we will ensure it is securely deleted.

If you would like to stop us using your personal information, you shall request that we erase your personal information and close your TopHostingTech Account.

After de-activation of Account, we will still retain the following data for the purposes of compliance with applicable legal requirements (such as tax, accounting, legal reporting, AML, other), for as long as we are legally required by virtue of such legal requirements:

• profile with de-personalised information like purchased services, login information, payment information, etc.

Please also note that we may further retain some of your personal information in such cases (i.e., after closure of your TopHostingTech Account):

• as long as it is necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety. If TopHostingTech suspends your TopHostingTech Account for safety reasons, we may retain certain information from that TopHostingTech Account to prevent that User from opening a new TopHostingTech Account in the future;
• the extent necessary to comply with our legal obligations. TopHostingTech may keep some of your information for tax, legal reporting and auditing obligations;
• forum posts or other publicly visible information may continue to be publicly available on the TopHostingTech Platform, even after your TopHostingTech Account is deactivated. However, attribution of such information to you will be removed. Additionally, some copies of your information (e.g., log records) may remain in our database, but are disassociated from personal identifiers;
• to resolve disputes;
• to enforce our agreements and/or pursue or protect our legitimate interests;
• as we protect TopHostingTech Platform from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time;
• domain name registration data - at the moment of writing this Policy, in order to register domain, we are requested to provide personal information about the owner of domain; this information is shown in WHOIS directory and is public.

11. DATA TRANSFERS AND USE OF THIRD-PARTY SERVICES

While collecting and processing your Personal Data, we may perform data transfers to various third parties.

11.1. With your consent or under other legitimate basis

We will share your Personal Data with companies, organizations, or individuals outside our group of companies when we have your consent to do so or under another legitimate basis.

11.2. Where do we process your personal data?

• Users' Personal Information may be maintained, processed, and stored by TopHostingTech and our authorized affiliates and service providers in the United Kingdom, Netherlands, Lithuania, Cyprus, and other jurisdictions as necessary for the proper delivery of our Services and/or as may be required by law (as further explained below).
• Job Applicants' Information will be maintained, processed, and stored in Lithuania, in the applied position's location(s), and as necessary, in secured cloud storage provided by our Third-Party Services.
• TopHostingTech affiliates and service providers (such as third-party data centers, servers, website design, administration services, online traffic and website analysis, statistics, direct marketing services, mailers, messengers, email service providers when you choose to purchase or use such services, and machine learning or AI-powered service providers, etc.), that store or process your personal data as well as personal data of your users on TopHostingTech's behalf, are contractually committed to keep it protected and secured, in accordance with industry standards and regardless of any lesser legal requirements which may apply in their jurisdiction (see below).
• While implementing various fraud detection processes as part of our ordering system, we share data with Ravelin, a fraud prevention service provider.
• Domain name registration data and identification data is shared with third parties in accordance with ICANN rules. For more information see:

We may share non-personally identifiable information publicly as well as with our partners - publishers, and advertisers. For example, we may share information publicly to show trends about the general use of our platform.

If we are involved in a merger, reorganization, acquisition, or sale, we will continue to ensure the confidentiality of any Personal Data and give all affected Users appropriate notices.

Some of our servers are located outside the EU or European Economic Area (EEA), such as the US, Brazil, Singapore, and Indonesia. Therefore, depending on your choice or the Services, your personal data, as well as personal data of your users, might be transferred to processors, sub-processors, or other data recipients established in such third countries (i.e., data centers and servers located outside the EU or EEA). Please see more here.

We will ensure that the said personal data will be transferred only if there is a sufficient basis for this under the GDPR and other applicable legal acts.

Standard contractual clauses for data transfers outside the EU or EEA:

Your personal data, as well as personal data of your users, might be transferred to processors, sub-processors, or other data recipients established in third countries (i.e., data centers and servers located outside the EU or EEA). For such transfers to be compatible with the requirements of GDPR, we have concluded with the data processors and/or sub-processors relevant agreements on such data transfers outside the EU or EEA, which comply with the European Commission-approved standard contractual clauses for data transfers from data controllers in the EU to data processors and/or controllers established outside the EU or European Economic Area (EEA). For more, see:

For the said purposes and to the extent relevant, we have deemed that the said agreements were concluded on your behalf and under your instructions, as the case may be, all in line with Art. 46 of GDPR.

Your personal data, as well as personal data of your users, might be transferred to data recipients established in third countries on other legal grounds compatible with the requirements of GDPR (Art. 45-49).

In certain situations, TopHostingTech may be asked to disclose personal data in response to lawful requests by public authorities or other competent authorities, including when it is required to meet national security or law enforcement requirements. TopHostingTech will do so where permitted by local data protection laws.

11.3. Data Localisation Obligations

If you reside in a jurisdiction that imposes "data localisation" or "data residency" obligations (i.e., requiring that personal information of its residents be kept within the territorial boundaries of such jurisdiction), and this fact comes to our attention, we may maintain your personal information within such territorial boundaries, if we are legally obligated to do so.

You acknowledge that while doing so, we may continue to collect, store, and use your personal information elsewhere.

11.4. Social Media Features

Our services include certain social media features and widgets, single sign-on features, such as the "Facebook Connect" or "Google Sign-in", the "Facebook Like" button, the "Share this" button, or other interactive mini-programs ("Social Media Features"). These Social Media Features may collect information such as your IP address or which page you are visiting on our website and may set a cookie to enable them to function properly. Social Media Features are either hosted by a third party or hosted directly on our services. Your interactions with these third parties' Social Media Features are governed by their respective policies.

11.5. Our Legal Obligation to Use or Disclose Personal Data

We will reveal your personal data to state and public authorities without your prior permission only when we are legally required to provide information. This includes taking legal action to defend our rights, as well as in cases where we have a belief in good faith that access, use, preservation, or disclosure of the information is reasonably necessary to meet any applicable law, regulation, legal process, or enforceable governmental request, enforce applicable terms of services, including investigation of potential violations, and detect, prevent, or otherwise address fraud, security, or technical issues.

11.6. Other

We may share your personal data in manners other than as described above, pursuant to your explicit consent, or if we are legally obligated to do so.

12. SECURITY

TopHostingTech has implemented security measures designed to protect the Personal Information you share with us, including physical, electronic, and procedural measures. Among other things, we offer HTTPS secure access to most areas on our Services. We also regularly monitor our systems for possible vulnerabilities and attacks, and regularly seek new ways and third-party services for further enhancing the security of our Services and protection of our Visitors' and Users' privacy.

Regardless of the measures and efforts taken by TopHostingTech, we cannot and do not guarantee the absolute protection and security of your Personal Information, or any other User Content you upload, publish, or otherwise share with TopHostingTech or anyone else.

We therefore encourage you to set strong passwords for your User Account and avoid providing us or anyone with any sensitive information of which you believe its disclosure could cause you substantial or irreparable harm.

If you have any questions regarding the security of our Services, you are welcome to contact us at tophostingtech@gmail.com.

13. YOUR RIGHTS

You are entitled to a range of rights regarding the protection of your Personal Data, which are subject to limitations, restrictions, and conditions as laid down in GDPR and applicable law. Those rights are:

• The right to access the information we process about you;
• The right to rectify incorrect/inaccurate information about you;
• The right to transfer all or part of the information collected about you to you or another data controller, where technically feasible (the right to data portability; with limitations and restrictions as specified in the EU General Data Protection Regulation);
• The right to erase any data concerning you. Users may demand erasure of data without undue delay for legitimate reasons, e.g., where data is no longer necessary for the purposes it was collected, or where the data has been unlawfully processed;
• The right to the restriction of data processing. Users, for legitimate purposes, may obtain restriction of data processing from the controller;
• The right to object to the processing of Personal Data when processing is carried out on the basis of legitimate interest, as well as in cases of use of your personal data for direct marketing purposes, as specified above in this Policy.

Some of the rights as above are easy to exercise: i.e., you may at any time access and edit, update or amend your details, opt out of receiving communications from us and our partners by visiting and adjusting your personal account settings, or by e-mail: tophostingtech@gmail.com.

When you object to processing of Personal Data when processing is carried out on the basis of legitimate interest, we will carefully consider such a request, which may result in your Account closure or de-activation.

Users have the right to lodge a complaint with the national Data Protection Agency in their country of residence in the event where their rights may have been infringed. However, we recommend attempting to reach a peaceful resolution of the possible dispute by contacting us first.

Automated Individual Decision Making, Including Profiling

In certain cases, we make automated decisions related to you. We may use technology to assess your personal situation and other factors to predict potential risks or outcomes (this practice is known as profiling). We implement this to make decisions that are fair, consistent, and informed by accurate data.

In cases where a decision based solely on automated processing produces legal effects concerning you or similarly significantly affects you, you have the right to contest the decision, express your point of view and request human intervention. You can do this by contacting our Customer Success team or by using email indicated in this section. We will review your request and provide a human review of the decision, ensuring that your rights are fully respected.

For example, we make automated decisions and profiling in the following cases:

• Perform a fraud prevention check before a purchase is accepted. This helps to protect our customers and our website from any potential risk of fraud, consumer scam, or abuse. The processing is necessary so that we could fulfill a contract with you (Art. 6 para. 1 b) GDPR). If based on data and behavior patterns (e.g., your behavior consistency with previous use of our services) it is determined that a purchase poses a risk, we will not be able to complete the purchase;
• To evaluate whether to apply a discount to the price of the product or service you purchase. This will not be used to increase the price of the product or service you want to purchase. The processing is based on our legitimate interest to enhance customer experience and encourage long-term commitment (Art. 6 para. 1 f) GDPR).

14. ACCEPTANCE OF THIS POLICY

We assume that all Users of TopHostingTech Platform have carefully read this document and agree to its contents. If someone does not agree with this Policy, they should refrain from using our website and mobile applications. We reserve the right to change our Policy at any time and inform by using the way as indicated in Section 17. Continued use of TopHostingTech's website and mobile applications implies acceptance of the revised Policy.

This Policy is an integral part of TopHostingTech's Terms and Conditions.

We will ask for your consent before using information for a purpose other than those set out in this Policy.

15. CONTACTS

For all your requests or comments concerned with this Privacy Policy, please contact: tophostingtech@gmail.com.

16. APPLICATION OF POLICY

Our Policy applies to all of the services offered by us and our affiliates, including TopHostingTech, UAB, private limited liability company, organized under the laws of the Republic of Lithuania, code 302710386, legal address at Švitrigailos str. 34, LT-03230 Vilnius, the Republic of Lithuania, TopHostingTech operations, UAB, private limited liability company, organized under the laws of the Republic of Lithuania, code 306308157, legal address at Švitrigailos str. 34, LT-03230 Vilnius, the Republic of Lithuania, but excludes services that have separate privacy policies that do not incorporate this Policy.

17. AMENDMENTS

Our Policy may change from time to time. We will post any Policy changes on our website and, if the changes are significant, we may consider providing a more explicit notice (including, for certain services, email notification of Policy changes).

18. FURTHER INFORMATION

If you have any further questions regarding the data TopHostingTech collects, or how we use it, then please feel free to contact the Data Protection Officer at the details as indicated above hereof.