PRIVACY AND DATA PROTECTION POLICY

Last updated on February 24, 2022

Effective date: February 24, 2022

This Privacy and Data Protection Policy (“Policy”) is effective as of the date set forth above. Rocket Cleaner ("Company") is committed to honoring and encouraging the protection of your privacy whether you just visit our application or create an account.

We drafted this Policy to explain how we collect and process personal data you provide us with while you use SlipClip Application (“App”), as well as your rights concerning your personal data and choices you have as to data processing we carry out.

We cannot control privacy practices of third parties. There are links to other websites and applications placed within the App. Therefore, if you visit another website or application, another person or entity may collect and use your personal data. Be sure to check their privacy policies before accepting their terms or services.

Please, take the time to read these details to fully understand how we handle your data and keep it safe. All the terms that are not defined herein are used in the meaning given to them in accordance with the Terms of Service.

We act as a data controller as to processing of personal data.

We act as a data controller, namely a legal person that determines the purposes and means of the processing of personal data, with regard to your personal data. Questions, comments and complaints about our data practices can be submitted to the following address:

Rocket Cleaner

Address: Russia, Samara, Leninskay 282, 2;

Email address: support@tiptopvid.com

We do not intend to collect your sensitive data through this App or otherwise. Be attentive while disclosing your sensitive personal information (for example, data about your race or ethnicity, political opinions, religious or philosophical beliefs, trade-union membership, genetic data, health, your sex life or sexual orientation) (“Sensitive information”) to other Users and/or Visitors when using this App (e.g. while downloading videos to your account, writing comment etc.).

Your age and eligibility

By using or accessing the App, you acknowledge that you are at least sixteen (16) years old and have all rights and legal capacity to enter into an agreement with us as to the receipt SlipClip Services and use the App, as well as collect and process personal data of SlipClip Users and/or Visitors under their consent for the purposes we mention in this Policy.

We reserve the right to implement any tools and techniques to reveal the human trafficking and exploitation of children, and report them immediately to the appropriate state authorities and enforcement agencies, including the personal data associated with the activities that, at our own discretion, are suspicious and may raise concerns about their association with the violation of applicable laws.

We do not intend nor knowingly collect and process personal data of minors. If you know that we process personal data of individuals under sixteen (16), please inform us by sending email at support@tiptopvid.com.

DATA WE COLLECT

We collect different categories of personal data of visitors and users of our App. If you visited the App with or without any purpose and did not fill in the registration form, you instantly become a visitor ("Visitor").

Should you want to continue to use the App by registering your account you need to fill in the registration form and acquire a user status ("User").

Information of Visitors we collect:

• IP address;
• browser information;
• network connection;
• device identifiers;
• date and time of access, and other data of the kind relating purely to the communications architecture.

We use this information to make the functionality of our App available to you, enable you to use the third-party services, to enhance our App, and answer any question or query you may have. Information of Users we collect:

• Name;
• Email address;
• Telephone number;
• Date of birth.

We treat the information as true data about you. We use these data in order to identify you and confirm your persona, facilitate the communication on the matter of SlipClip Services and to make it possible to communicate and offer goods and services to Users.

Likewise, under щur direction, some of our contractors collect the following information of both Visitors and Users:

• AdMob: data concerning the use of and activities within the device, including data regarding devices, apps and browsers you use, your actions in Google browser, your search queries in Google browser, ads you interact with, your visits to websites that use Google services, location;
• App Metrica: data concerning technical properties and the activities, including information on the time spent in App, the interaction with App, the IP address and cookies information.

We use this information to improve the functionality of our App available to you, improve the ads displayed to you to make every ad impression as valuable as possible and to monetize the App.

HOW WE USE PERSONAL DATA

Our App is aimed at providing you with the services described in the Terms of Service. Thus, we need your data to provide you with the respective services.

Your decision to provide personal data to us is voluntary, however, if you do not provide such personal data you may no longer be able to benefit from our services.

We will use your personal data for the following purposes:

• Identification and verification of your persona and your verifiable device;
• Account signup registration and administration;
• Saving the preferred settings and ensuring the smooth and enhanced experience with our App;
• Enabling you to receive notifications and marketing information related to SlipClip Services;
• Providing you with technical and related support as to use of the App;
• Replying to your requests submitted via communication tools available on the App;
• Screening the account in the case of a suspected fraud or breach of this Policy and Terms of Service;
• Invoicing you for our services;
• Providing you with access to data of Users;
• Complying with applicable law;
• Obeying the requests and court or other authority decisions;
• Statistics and analytics, app optimization.

The legal basis on which we process your personal data for the aforementioned purposes is your consent. You are not under any obligation to provide us with your personal data and you can withdraw your consent to your personal data being processed in this way at any time by contacting us at support@tiptopvid.com. If you do choose to withdraw your consent, this will not mean that our processing of your personal data before you withdraw your consent was unlawful.

We do not represent or warrant and do not responsible for the lawfulness of collecting, processing, using, storing and other activities related to the personal data of persons whose personal data was transfer to us by our contractors or who accessed/were redirected to the App via the link placed not on the website/any other resource of our contractors or were placed not by our contractors.

Processing personal data for marketing purposes

Where you have opted in to receive marketing communications from us, we will process your personal data to provide you with marketing communications in line with the preferences you have provided.

The legal basis on which we process your personal data for marketing purposes is your consent. You are not under any obligation to provide us with your personal data for marketing purposes, and you can withdraw your consent to your personal data being processed in this way at any time by contacting us at support@tiptopvid.com or via online form in any marketing communication you receive from us. If you do choose to withdraw your consent, this will not mean that our processing of your personal data before you withdraw your consent was unlawful.

COOKIES AND THIRD PARTIES TECHNOLOGIES

We use cookies and other similar technologies to distinguish you from other Users and Visitors of our App. This helps us to provide you with a better experience when you use the App and allow us to improve it.

A cookie is a small file of letters and numbers that we store on your browser of your mobile device (“Cookie”). For example, cookies can be used to collect information about your use of the App during your current session and over time (including webpages you view and the files you download), your operating system, IP address etc. If you are concerned about having cookies on your mobile device, you can set your browser to refuse all cookies or to indicate when a cookie is being set, allowing you to decide whether to accept it. You can also delete cookies from your computer. However, if you choose to block or delete cookies, certain features of the App may not operate correctly.

There are several types of cookies we use:

• 1. Strictly necessary cookies: are used to help make an app usable by enabling basic functions like page navigation and access to secure areas of the app. The app cannot function properly without these cookies.
• 2. Preference cookies: are used to remember information that changes the way the app behaves or looks, like your preferred language or the region that you are in.
• 3. Statistic cookies: are used to help app owners to understand how visitors interact with an application by collecting and reporting information anonymously.
• 4. Marketing cookies: are used to track visitors across websites. The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third party advertisers.
• 5. Unclassified cookies: are cookies that we are in the process of classifying, together with the providers of individual cookies.

Why we use cookies

We implemented cookies in the App for a few reasons:

• To verify your persona (your account on the App) and help prevent identity theft or other fraudulent use of credentials;
• To ensure your good experience while using the App, for instance:
• To keep you logged in;
• To recognize your device and remember the options as to the settings you have made earlier;
• To analyze the way the App is used and accessed (click path, time you spend reading a page or an ad, etc.) etc.
• To maintain analytics and statistics.

For these purposes, we use Yandex App Metrica and Google AdMob. Please, pay attention that these services might collect personal data. For more information, please checkApp Metrica Privacy Policy andAdMob Privacy Policy.

PUSH NOTIFICATIONS

We use the push notifications in the App to provide you with technical support and send marketing notifications.

OUR PARTNERS

Some features are not developed by us but embedded into our App by our partners and are not used by us to collect your data or provide services to you on our own behalf. Strictly speaking, some services you can obtain access to via our App are a part of our partner’s sites or apps and these services place the cookies (and collecting your personal data through them, if you provide them with such personal data) themselves. Cookies of our partners are subject to such partners’ privacy policies.

List of Our partners is as follows:
• Google LLC (AdMob);
• Yandex LLC (App Metrica).

YOUR RIGHTS

Rights you are granted with You may enjoy the rights granted to each data subject whose personal data we process as a data controller:

• right of access (i.e. you may ask us to send you a copy of the data about you that we collected);
• right to rectification (i.e. you may ask us to correct the outdated or false data, or complete the data which is missing or incomplete)
• right to erasure (i.e. you may ask us to delete the personal data we retain);
• right to restriction of processing (i.e. you may ask us to restrict the processing of the personal data)
• right to object to processing (you have the right to object to the processing of the personal data)
• right to data portability (i.e. you may ask us to transfer a copy of your data to another organization or to you).

We generally do not charge any fees in relation to exercising your rights. Nonetheless, we retain the right to do so in case we receive an excessive amount of repeated requests. We do our best to answer you as soon as possible or within the reasonable period taking into account the complexity of the request, but in case we are processing a large amount of requests the answer may take us longer than you might expect.

You can send us the request via email support@tiptopvid.com. Please verify that your request comprises the details:
• your name;
• contact information;
• right you want to exercise, and, where applicable;
• your personal data in our processing;
• reason/justification behind such request.

We may ask you to provide us with some information we already have to verify that it is you or the holder of parental responsibility on your behalf.

Right to Withdraw a Consent

You have a right to withdraw your consent to processing of your personal data. You may enjoy this right at any time you wish. Please remember, that the withdrawal of consent does not mean that the processing before the withdrawal is considered thus illegal.

You may withdraw your consent by deleting your account, sending us an email to support@tiptopvid.com as well as through online form of withdrawal. Before withdrawing your consent, take into attention the outcome such withdrawal may entail (e.g. termination of your Account etc.) We will verify your withdrawal of consent within 72 hours since the receipt of your request. If you are a User whose data we process as a data processor, you may exercise the right to withdraw a consent either by contacting the data controller directly as explained by its privacy policy or sending us an email to support@tiptopvid.com as well as through online form of withdrawal. In the case of the latter, we will immediately inform the data controller of receiving such a request and will act due to its instructions.

RETENTION OF PERSONAL DATA

We will store and process your personal data for as long as your Account is active or for as long as needed to provide you with SlipClip Services. In case your Account is not active anymore, the personal data will not be stored longer than 12 months from the moment of its last activation. We store your personal data at our own physical server or at cloud servers provided by our partners in Netherlands. After expiry of a retention period we are to delete your personal data, unless its storage is justified by legal obligation or our legitimate interest to do so (i.e., your account has been previously noticed or suspected in participation in the fraudulent schemes, botnet, etc.).

If you tell us that you no longer wish to receive marketing communications, your personal data used exclusively for that purpose will be removed from our database. However, if we use those data for other legitimate purposes, we may retain it unless we cannot demonstrate the compelling legitimate interests to do so.

Deleting your Account will automatically entail deletion of your data, unless its storage is justified by legal obligation or our legitimate interest to do so (i.e., your Account has been previously noticed or suspected in participation in the fraudulent schemes, botnet, etc.).

You may also solely delete your Account under its settings, or request deletion of your Account at any time by sending us an email at contact support@tiptopvid.com or via special online form of withdrawal. Executing your request, we will delete your Account within thirty (30) days. Sometimes we may be unable to delete your Account or personal data (for instance, in case of unsettled or unresolved dispute or claim, or in case we suspect you in being associated with a crime or other violation of applicable law, e.g. fraud, unsafe behavior, security incident). Upon the resolution or settlement of claim, conclusion of a criminal or administrative proceeding, or learning that our suspicion is unjustified, we will delete your account or personal information.

INFORMATION COLLECTED FROM THIRD PARTIES

We may obtain the data from third parties not mentioned in this Policy. If this is the case, we will notify you of such collection if it is commercially reasonable.

You could be a subject to an automated decision-making, including profiling. We may involve an automated decision-making, including profiling, to analyse or predict aspects concerning your personal preferences, interests and choices, ways of use of and behavior within the App etc. We may use the results of the automated decision-making, including profiling, for targeting of SlipClip Services and other marketing purposes. The automated decision-making, including profiling, is limited by the purposes of receipt of personal data specified hereinabove. The automated decision-making, including profiling, does not significantly affect you and does not produce legal effects and cannot deprive you of your rights. We use cookies as provided under Cookies and Third-Party Technologies as specified hereinabove.

DATA TRANSFER

We do not sell or trade personal data to any legal persons or individuals.

We may transfer the personal data to our contractors specified in this Policy. We transfer personal data based on adequacy decision/appropriate safeguards if needed.

We may transfer the personal data to third countries, including the onward transfers of the personal data from the third countries to other third countries. If the adequacy decision and/or appropriate safeguards regarding the transfer the personal data to a third countries are absent, we transfer the personal data to third countries based on the consent provided by you.

Personal data are being transferred for the purposes and by using the methods defined under this Policy.

PERSONALIZED ADVERTISEMENT

We rely on advertising to make many of the SlipClip Services available to you. By using some of the information we collect and receive related to you as it is described in this Privacy, as well as the information collected automatically through cookies and third parties technologies, we try to deliver advertising that is personalized for your interests in the hope that it will be more relevant and useful to you.

We may also work with third parties such as ad networks, which are third parties that display advertisements based on your visits to websites that you have visited in the past. These advertisers will deliver you targeted advertisements for products and services that may interest you. Third-party ad networks, our advertisers (and their content providers and agents), and/or traffic measurement services may also use cookies, JavaScript, web beacons (including clear GIFs), Flash LSOs, and other technologies to measure the effectiveness of their ads and to personalize advertising content to you.

COMPLAINT LODGMENT

You have the right to lodge a complaint with a respective supervisory authority if it consider that the processing of personal data related to you infringes this Policy of applicable laws.

UPDATES TO THE PRIVACY POLICY

We may occasionally update this Policy at our own discretion. If we make significant changes, we will notify you of the changes on our App or through other means, such as email, before they enter into force. To the extent permitted under applicable law, by using our App after such notice, you consent to our updates to this Policy. We encourage you to review this Policy periodically for the latest information on our privacy practices.

CONTACT US

Should you have any questions or complaints concerning this Policy, please mail us on support@tiptopvid.com.