Privacy Policy

1. General provisions

This policy describes personal data processing by the TopMacro operator, an individual in Ukraine. Ukrainian personal data protection law applies, together with the GDPR to the extent it applies to the processing concerned.

The Controller treats respect for human rights and freedoms, including privacy and personal-data protection, as a fundamental priority when processing personal data.

This Policy applies to information the Controller may obtain about visitors to TopMacro.net.

2. Terms used in this Policy

• Automated processing — processing performed with computer technology;
• Blocking — temporarily suspending processing, except when processing is required to clarify data;
• Website — the information, software and databases available at TopMacro.net;
• Personal-data information system — personal data contained in databases and the technologies used to process it;
• Depersonalisation — actions that prevent data from being linked to a particular user without additional information;
• Processing — any operation or set of operations performed on personal data, by automated or other means;
• Controller — the legal or natural person that determines the purposes and means of processing;
• Personal data — information relating directly or indirectly to an identified or identifiable user;
• User — any visitor to the website;
• Provision — disclosure of personal data to a specified person or group;
• Dissemination — disclosure of personal data to an indefinite group, including publication online or in media;
• Cross-border transfer — transfer of personal data to a third country or international organisation;
• Destruction — actions that irreversibly destroy personal data or its storage media.

3. Personal data we may process

• Email address;
• Account and purchase data, including email verification, preferred language, subscription status, activation or order identifiers and marketing preferences;
• Technical and security data, including IP address, browser and user-agent, device type, hardware identifier or its hash, application and operating-system versions, authentication events and diagnostic records;
• Content submitted through contact forms, the support bot or the account community chat.
• Usage and analytics data, including cookies and online identifiers, pages viewed, site interactions, approximate location, and device and browser information collected through Google Analytics 4 or Yandex Metrica, including Webvisor where enabled.

These categories are collectively referred to as Personal Data in this Policy.

Full payment-card details are processed by Digiseller, Oplata.info or their payment partners. TopMacro does not receive or store full card numbers.

4. Purposes of processing

• To enter into and perform a contract with the user and provide access to website services, information and materials.
• With the user’s consent, to send email about products, services, special offers and events. A user may unsubscribe at any time or email topmacros@gmail.com.
• To analyse use of the website, measure its performance, identify technical problems and improve its content and usability.
• To authenticate users, activate subscriptions, bind authorised devices, provide support, diagnose errors, prevent abuse and protect accounts and services.

5. Legal grounds for processing

Personal data submitted through website forms may be processed to perform a contract under Article 6(1)(b) GDPR.

Usage and analytics data may be processed on the basis of the Controller’s legitimate interest in operating and improving the website under Article 6(1)(f) GDPR and, where applicable law requires consent, under Article 6(1)(a) GDPR. Users can manage cookies in their browser settings.

Data required for account security, abuse prevention, diagnostics and service improvement may be processed on the basis of the Controller’s legitimate interests under Article 6(1)(f) GDPR; records required by law are processed under Article 6(1)(c) GDPR.

6. Collection, storage, transfer and security

The Controller uses legal, organisational and technical measures required to comply with GDPR and protect personal data.

The Controller maintains confidentiality and takes reasonable measures to prevent unauthorised access.

To operate the service, the Controller may share the minimum necessary data with the Digiseller and Oplata.info payment platforms, hosting and email-delivery providers, Google Analytics 4 and Yandex Metrica, and OpenAI. The support bot sends the user’s message and limited recent chat context to OpenAI to generate a reply.

Users may correct inaccurate data by emailing topmacros@gmail.com with the subject “Data update”.

Data is processed no longer than necessary for the stated purposes. Consent may be withdrawn by emailing the Controller with the subject “Withdrawal of consent”.

Account and subscription data is retained while the account is in use and afterwards only as long as required by law, dispute resolution or the protection of legal rights. Short-lived authentication and rate-limit records, support requests, chat messages and diagnostics are retained only for as long as reasonably necessary for their purpose, then deleted or anonymised.

7. Cross-border transfers

Before transferring personal data to a third country, the Controller verifies that the destination has an adequate level of protection recognised by the European Commission or that safeguards such as Standard Contractual Clauses are in place.

Transfers to countries without an adequacy decision take place only under appropriate safeguards or with the explicit consent of the data subject.

8. Your data-protection rights

Subject to applicable law, you may request access, correction, erasure, restriction or portability of your data, object to processing based on legitimate interests and withdraw consent at any time. Withdrawal does not affect processing already carried out lawfully.

For personal data enquiries and rights requests, contact us via https://t.me/topmacro. You may complain to the competent supervisory authority under applicable law, including the authority where you habitually reside when provided for by the GDPR.

9. Final provisions

Users may request information about their personal data by emailing topmacros@gmail.com.

Changes to this Policy will be published on this page. The Policy remains valid until replaced by a newer version.

The current English version is available at English version.