1.1. INTERTOP UKRAINE LLC respects the right of intertop.com website visitors and INTERTOP mobile application users to privacy and confidentiality and recognises the importance of protection of user information we collected.
1.2. This Privacy Policy (hereinafter referred to as the “Privacy Policy” or “Policy”) is a public document covering all personal data (PD) processed by INTERTOP UKRAINE LLC who is the Controller (Owner) of personal data.
1.3. This policy regulates the use of resources, services, capabilities of the intertop.com website, INTERTOP mobile application, as well as the use of information provided by you to INTERTOP UKRAINE LLC.
1.4. INTERTOP UKRAINE LLC will not collect, use, disclose or otherwise process your personal data other than as provided for in this Privacy Policy and applicable law.
1.5. By using the intertop.com website and the INTERTOP mobile application you agree to the terms and conditions of the Privacy Policy of INTERTOP UKRAINE LLC. This privacy policy is an integral part of the Public Offer located at https://intertop.ua/offerta/ (if you are in Ukraine) and https://intertop.kz/customers/offer/ (if you are in the Republic of Kazakhstan).
1.6. If any amendments to the terms hereof are made, this shall be announced in a clear, easy-to-understand form on the intertop.com website and in the INTERTOP mobile application, and such amendments shall take effect immediately upon publication on the website.
1.7. In this document, the following terms shall have the meaning as described below;
Personal data – information or a set of information about an individual who is identified or can be specifically identified.
Controller (Owner) of personal data – an individual or legal entity that determines the purpose of processing personal data, establishes the scope of such data and sets the procedures for personal data processing, unless otherwise provided by law;
Consent of a personal data subject – a voluntary expression of will by an individual (subject to his/her awareness) to grant his/her permission to process his/her personal data in accordance with the stated purpose of data processing, expressed in writing or in a different form that allows to conclude that consent has been granted;
Personal data Processing – any action or a cumulative action, such as collection, recording, accumulation, storage, adaptation, modification, updating, use and dissemination (distribution, sale, transfer), depersonalisation, destruction of personal data, including by use of information (automated) systems.
Personal data depersonalisation – removal of information that allows for the direct or indirect identification of a person;
Cookies – small pieces of information sent by a web server to a web browser and stored on the user’s device (computer, mobile phone etc) for user identification on the website in the future.
The intertop.com website and the INTERTOP mobile application may contain links to the websites of other retailers, brands and advertisers. Please note that this Privacy Policy does not apply to such websites. INTERTOP UKRAINE LLC is not responsible for their activities, so we recommend that you familiarise yourself with their privacy policies before submitting any personal data to those websites.
3.1. INTERTOP UKRAINE LLC receives your PD when:
3.2. We may receive your personal data from various third parties and public sources, including Apple, Google or Facebook. By logging in to our website or INTERTOP mobile application using Apple, Google or Facebook or by linking your INTERTOP account to your Apple, Google or Facebook account, you consent to the processing of your personal data specified in these accounts. The type of information provided will depend on the settings of your account or website and is governed by the privacy policy of these sites.
4.1. The following data is required:
4.2. Additional data:
4.3. We also collect and process information from the technical means through which you contact us: cookie file data, information received in requests, questions, comments and feedback, geographical location, information about the technical means themselves (device type, operating system, browser name).
4.4. Entering additional data in the questionnaire will allow us to inform loyalty program participants about unique offers based on specified preferences, create personalised promotion campaigns that provide for crediting extra bonuses to participant’s bonus card account.
5.1. We will collect and process your personal data only to the extent necessary to provide the services we offer and/or for the purposes specified in this Privacy Policy. We may also process your personal data based on any legitimate interests and in order to comply with legal obligations. These interests and obligations may include bringing or defending legal claims, complying with the orders of any court or body of power, and disclosing information to a governmental or regulatory body.
We may rely on the following legal bases in processing your personal data:
6.1. INTERTOP UKRAINE LLC does not transfer data provided by you to third parties except as described in this Policy.
INTERTOP UKRAINE LLC has the right to provide access to and transfer your personal data to third parties without any additional notifications to achieve the data processing purpose specified in this Policy.
In order to achieve the purpose of data collection provided for in this Policy, INTERTOP UKRAINE LLC transfers your personal data to companies that are subject to the requirements of this Policy or follow no less strict rules for the personal data protection than the rules described in this Policy.
6.1.1. Transactions involving third parties.
If we provide you with products and services provided by third parties, in particular, if you purchase
products from third-party sellers through our website intertop.com or the INTERTOP mobile application,
such third parties will receive information about your personal data to the extent necessary for your
identification, processing and fulfilment of your order.
6.1.2. Third parties providing services to us.
We enter into agreements with third parties to fulfil our obligations to you and to exercise our
legitimate rights and interests. In particular, in the case of fulfilment of orders for services,
courier delivery services for the delivery of goods, correspondence, sending e-mail, processing
payments, data analysis, providing marketing support, transferring content, etc. Third parties providing
services to us are entitled to use personal data they receive only to perform their functions and may
not use it for other purposes.
6.1.3. In case of fulfilment of legal requirements.
In case of need to cooperate with regulatory authorities and/or law enforcement agencies or conduct
legal proceedings.
Sometimes, we may be required to provide access to your personal data to regulatory authorities and/or
law enforcement agencies. If we consider such actions to be reasonable, we reserve the right to provide
information about personal data in a manner consistent with applicable law.
6.2. INTERTOP UKRAINE LLC may transfer personal data across borders to recipients in other countries where personal data protection laws may establish a different level of protection than the laws of your country. Transfer of information about personal data is carried out in accordance with the requirements of this Policy and in accordance with the applicable personal data protection laws.
7.1. Data provided by you is stored in accordance with the applicable law only as long as storage is reasonable or required to achieve the purpose stated in this Privacy Policy and in accordance with statutory requirements (e.g., to provide you with our services or to meet any legal, accounting or reporting requirements). In any event, data shall not be stored for more than 10 years from the date of termination or completion of services, unless a longer period is required by applicable law.
8.1. You have the right to:
8.2. In some cases, we may not be able to remove some of your personal data when we are obliged to store information in accordance with the law or to continue fulfilling your order or for other purposes in accordance with the terms of this Policy. You can change or update your personal data online by changing the data you previously entered in forms or data fields on our website or in our mobile application. Where required by law or our Privacy Policy, in cross-border data transfers the possibility to access and correct your personal data may be limited, if access and correction:
8.3. If you gave your consent to the use of your personal data for newsletters*, you can withdraw your consent at any time by calling the hotline or by clicking “unsubscribe” in the email newsletter or by unsubscribing from text messages**.
* newsletters include electronic and postal mailings with advertising information about products, special offers, promotion campaigns, events organised by INTERTOP UKRAINE LLC.
** You may receive a small number of additional messages immediately after unsubscribing, but we will fulfil your request as soon as possible.
8.4. In order to use any of the abovementioned rights, you may:
a) if you are in Ukraine:
b) if you are in the Republic of Kazakhstan
8.5. To avoid violations and illegal use of your personal data by third parties, we may ask you to confirm your identity before fulfilling your request.
9.1. To ensure the protection of personal data, we follow international standards and employ best practices in the information security industry, including physical, administrative, technical and organisational measures.
9.2. Our task is to ensure confidentiality, integrity, availability and controllability of personal data processing. At the stage of introducing new (and operating the existing) services, we use modern security methods and technologies to prevent unauthorised access to personal data (software and hardware to detect and prevent data breach, intelligent systems for detecting unauthorised access, reliable encryption for data storage and transmission, control of physical and technical access to data).
9.3. At the interval set by the company’s internal rules, we check the level of security of our services and infrastructure and ensure constant protection against malware and modern cyber threats.
9.4. We also have measures in place to prevent any sudden loss of stored data and to timely recover data in the event of a physical or technical failure. We constantly monitor security and periodically evaluate the effectiveness of security measures and implement necessary improvements. We also require data processors to implement appropriate measures to protect against unauthorised access and maintain data confidentiality.
9.5. In addition, we enter into contractual confidentiality obligations with our employees and contractors who will be fined for breach of such obligations.
10.1. Like many other websites, the intertop.com resource uses cookie technology which helps customise its work with you. In particular, without this technology it is impossible to work with the shopping cart. These cookies are necessary for the technically correct operation of the website and the mobile application.
10.2. Сookies are very small files that are sent by us to your computer or other device which we can access when you visit our website. This technology allows the website to access stored information if necessary and improve the convenience of working with our information resources. You can always change your browser settings yourself and thus refuse from storing cookies.
10.3. Our website may use plug-ins for social networks such as Apple, Google or Facebook. The content of such social media plug-ins is regulated by the policies published directly on the social media pages. When you visit our website with open access to your social network page, your browser establishes a direct connection with the social network servers. If you are not logged in to a social network, your browser will send limited information to the social network. Social media plug-ins on our website are regulated by the Privacy Policy and other policies and regulations of the respective websites.
11.1. Persons under 16 have the right to enter into transactions (including the purchase of products by providing their personal data) only with the permission of their parents/guardians in accordance with the established procedure, unless otherwise provided by applicable law. The transfer of personal data by such person will be considered by us as the consent of the parents/guardians and person’s eligibility to enter into transactions.
12.1. INTERTOP UKRAINE LLC does its best to promptly process any questions or requests related to the methods of processing your personal data. You can contact our personal data protection officer at [email protected] or use the contact details specified in the “Contact us” section, and we will make every effort to resolve any issue or concern you may have. You also have the right to file a formal complaint with your local supervisory authority responsible for personal data protection.
13.1. To contact us for issues related to this Privacy Policy, please use the following means of
communication:
a) if you are in Ukraine:
b) if you are in the Republic of Kazakhstan: