Privacy Policy
Updated and effective as of February 26, 2025
Important notice
To use some of our Services (apps, websites, and others), we may ask you to provide specific information such as your name (or nickname), email address, date of birth, information about your feelings and mental well-being, and other onboarding details. Depending on the app or web product you choose within our ecosystem, additional data — such as your pulse, heart rate, a photo of your hand, or other information — may be required (see Section 2). In some cases, you can skip certain onboarding questions by selecting "Skip" or a similar feature.
Additionally, we may automatically collect information from your device, including language settings, IP address, time zone, device type and model, and other data points. This data enables us to provide Services, analyze app usage, and enhance specific experiences like refund processing.
To improve subscription management and engagement tracking, we integrate with Apple's App Store Server API, including the consumptionRequestReason feature. Certain event data (Customer Account Age, User Account Details, Content Consumption Level, Platform Information, Total In-App Purchase Amount, App Usage Time, and Account Status) may be shared with Apple to enhance subscription management in line with Apple's guidelines. Apple uses and protects this data per its Privacy Policy. You may opt out of transferring this event data to Apple by contacting us.
If you have any unanswered questions or wish to exercise your privacy rights, please contact us at gototop@support-team.app.
Definitions: «Services» — our Apps, Websites, and any related services or properties we control; «Apps» — games, applications, and other products produced by us on any and all platforms; «Websites» — websites and other online properties we control; «Personal Data» — data that relates to you as an identified or identifiable individual; «Anonymous data» — data where the identity has been removed; «User, consumer, you» — any third party that uses our Services.
PLEASE DO NOT PROVIDE ANY SENSITIVE INFORMATION UNLESS YOU ARE CERTAIN ABOUT ITS NECESSITY AND HAVE GIVEN YOUR EXPLICIT CONSENT.
1. General
This privacy policy describes how we at GOTOTOP LTD, the legal entity incorporated in accordance with the laws of the Republic of Cyprus ("we," "us," or "our"), collect, use, store, transfer, and disclose personal information from our Users in connection with our Services. For the purpose of the General Data Protection Regulation 2016/679 ("GDPR"), GOTOTOP LTD will be the data controller responsible for any personal data we process.
We reserve the right to update this Privacy Policy from time to time. If the changes are material, we will notify you. If permitted by law, your continued use of the Services after this policy has been updated indicates your acceptance of changes made. You should not use the Services if you do not agree with this Policy and our Terms of Use.
How to contact us — Name: GOTOTOP LTD · Address: 14 Panagioti Tsangari, 1st Floor, Office 1E, 4047, Limassol, Cyprus · E-mail: gototop@support-team.app
2. Personal Data
When you use our Services, we can collect, use, receive, process, transfer, and share some of your Personal Data for different legitimate purposes. The types of information we may collect depend on how you use the Services and interact with us. We may anonymize your Personal Data for research or statistical purposes; anonymous information is not considered Personal Data.
2.1. User-provided information
- Registration Information: your name (or nickname); login/e-mail address; password or passcode; age (year of birth); gender; content of your question or request; telephone number.
- Quiz Data (onboarding): pulse and heart rate; photo of your hand; information about your feelings and emotional situation; mental well-being; general information about your health condition; relationship status; the area of life you want to develop; place of birth; time of birth.
- In-app purchases: payments are processed via the Apple App Store, the Google Play Store, or other payment processors. We don't collect or store payment data, details, or payments-related personal data, though our payment processors may share information with us related to your purchases.
- Location Data: we do not collect precise location — only country, state, or coarse (non-precise) location.
2.2. Automatically collected information
- Device Info: type and model; operating system and version; hardware type; connection type; network service provider; device motion parameters and carrier; platform; device locale; app version.
- Identity Data: IP address; IDFA (iOS only); Google Advertising ID or GPS ADID; API level (Android only); Firebase ID.
- Usage Data (Events): mobile or web activity; session lengths and counts; push notification token; clicks on ads; downloads and installations of applications.
- Diagnostic information: logs, error reports, and related events.
- Location information: IP address; time zone; information about your mobile service provider.
- Apple App Store Server API: customer account age, user account details, content consumption level, platform information, total in-app purchase amount, app usage time, and account status may be shared with Apple to enhance subscription management, per Apple's Privacy Policy.
2.3. Information received from third parties
- Third-party log-in data: if you sign in with Facebook Connect (Instagram), Google Connect, or Apple, we collect information visible via that account: first and last name, Facebook/Google/Apple ID, profile picture/URL, city-level location.
- Analytics information: user ID, in-app activity data, advertising ID, IP address, location.
- Apple HealthKit or Google Fit: with your permission, we may import data about your health and activities (calories burned, heart rate, etc.), subject to Google Fit and Apple HealthKit privacy policies.
2.4. Cookies and other tracking technologies
Cookies, web beacons, embedded scripts, location-identifying technologies, fingerprinting, device recognition technologies, in-app tracking methods, and other tracking technologies may be used to collect information about interactions with the Service or e-mails. We may use this information to maintain and improve our Services: automatically update applications; remember your information; provide customized third-party advertisements and content; monitor the effectiveness of marketing campaigns; and monitor aggregate site usage metrics.
2.5. Access to your library or microphone
The app requires your permission to access your microphone and your photo and video library to activate voice commands and enable sharing your achievements on social media. We do not collect or have access to such data. We may send push notifications with app updates, high scores, and other service-related notifications (you can disable this anytime in your phone settings).
3. Purposes and Legal Bases for Processing
We collect personal data to perform our contractual obligation towards the User and make our Service available. We generally process your personal data on the following legal bases: Contract (to provide services you have requested); Legal obligations (to comply with a subpoena or legal process); Legitimate interests (fraud prevention and safety, protecting property rights, defending legal claims, enforcing our Terms, analyzing and improving our services); and Consent (which you may withdraw at any time without affecting prior processing).
| Purpose of processing | Lawful basis |
|---|---|
| Registration Data — to set up and administer your account, provide support, verify identity, send important account and Service information | Contract (art. 6(1)(b) GDPR) |
| To provide and deliver the Services and all features, customize your experience, enable access, address technical issues | Contract (art. 6(1)(b) GDPR) |
| To communicate with us; to provide feedback and progress information | Legitimate interest (art. 6(1)(f) GDPR) |
| Billing, account management, and administrative purposes | Contract (art. 6(1)(b) GDPR) |
| To provide features of the Services and make recommendations; camera, health data, and motion sensor permissions | Consent (art. 6(1)(a) GDPR) |
| To determine zodiac sign, horoscope, natal map (voluntarily provided) | Contract (art. 6(1)(b) GDPR) |
| To analyze, operate, and improve our Services; conduct research; store App Data and progress; comply with legal obligations; monitor trends and usage | Legitimate interest (art. 6(1)(f) GDPR) |
| Automatically collected data — content accessibility, subscription management, App Store policy compliance | Legitimate interest (art. 6(1)(f) GDPR) |
| Emails and push notifications with marketing communications (tips, offers, newsletters) | Consent (art. 6(1)(a) GDPR) |
| Marketing campaign performance; recognizing you as an existing user; optimizing app features | Legitimate interest (art. 6(1)(f) GDPR) |
| Information required by law (e.g., age verification) | Legal obligation (art. 6(1)(c) GDPR) |
| Interest-based (behavioral) advertising and targeted content | Consent or Legitimate interest |
| Customization of product and service offerings and recommendations | Consent (art. 6(1)(a) GDPR) |
| Personalization using geolocation (if shared; can be turned off anytime) | Contract or Consent |
| Fulfilling contractual obligations with third parties (pseudonymized analytics, payment processing) | Legitimate interest (art. 6(1)(f) GDPR) |
AI Feature
In our apps, we may use AI technologies. If you choose to engage in a conversation with the Advisor, your conversations will be transmitted to OpenAI's servers via an API connection. We will not transfer any data that would enable OpenAI to identify you unless you explicitly provide such information within your conversations. We share your nickname with OpenAI to ensure proper addressing by the Advisor. We do not permit OpenAI to use your information for training or enhancing its models. Please refrain from providing sensitive information in conversations. The data transfer occurs through a SOC 2 Type 2 compliant API connection. OpenAI retains information sent via the API for a maximum of 30 days, after which it is deleted, except where retention is required by law. See OpenAI's API data usage policies for details.
4. Third-Party Processing of Your Personal Data
We may share your information with third-party companies to perform certain services, including hosting, payment processing, analytics, customer service, and marketing assistance — whether shared by us or gathered directly by third parties through SDKs integrated into the Service. The following companies are Processors of Personal Data of the Services (consult their websites and privacy policies for details and opt-out options):
- Customer support: HelpDesk (Text, Inc.) — email address, content of emails.
- Ad partners (collect data via their own SDKs): AppLovin Corp; AdColony, Inc; TikTok (Bytedance, Ltd); Chartboost; IronSource Mobile Ltd.; Unity Technologies; Pinterest; Snap Inc. You may opt out of interest-based advertising via your device advertising settings, www.aboutads.info/choices, or www.youronlinechoices.eu (EU).
- Analytics: Adjust, Ltd. — mobile attribution and analytics (cookies, usage data, device info, identity data).
- Other partners: Apple, Inc. (payments, subscription management); Amazon Web Services, Inc. (hosting and backend); BunnyWay d.o.o. (CDN); Hetzner Online GmbH (hosting); Facebook Ireland Ltd. (conversion measurement, analytics); Google Inc. (payments, AdMob advertising); Solid (payments); OpenAI, L.L.C. (AI-generated content).
- Competent authorities: where we are bound to disclose your personal data by judicial order or by a governmental or regulatory authority.
5. Storing Personal Information
We will keep your Personal Information for the length of time required to provide you with the Service and for the reasons described in this policy, unless a longer retention period is required or permitted by law. In all cases, we do not retain such data for more than 5 years. If you no longer want us to use your information, you can request that we erase your personal information and close your account. At the end of these periods, processed personal data will be deleted or anonymized.
6. Personal Data Protection
Personal data may be processed by both automated and non-automated means and may be stored at our premises and on our service providers' servers. We have implemented industry-standard security measures, including encryption, pseudonymization, tokenization, and protection of data integrity. However, transmissions over the Internet are never 100% secure. We will not use information received through HealthKit or Google Fit for advertising or similar services, nor will we sell it.
We operate internationally. Server locations include: (1) Cyprus and (2) Germany (the European Union). Your data may be processed on servers not located in your country of residence; we take appropriate safeguards to guarantee your rights in conformity with this Privacy Policy and applicable laws. Your consent to this Privacy Policy, followed by your submission of information, represents your agreement to such transfer.
7. Users' Rights
- Withdrawal: withdraw consent at any time by emailing gototop@support-team.app with the topic «Consent withdrawal» or via the app's Settings menu.
- Access: know what Personal Data we hold and ask for a copy.
- Opt-out of targeted advertising: on Apple — Settings > Privacy > Advertising > "Limit Ad Tracking"; on Android — Settings > Google Services > Ads > "Opt out of Ads Personalization."
- Rectification: request an update or correction of out-of-date, incomplete, or incorrect data (art. 16 GDPR).
- Deletion (right to be forgotten): request that we delete certain of your personal data.
- Objection: object to processing on grounds relating to your situation, or for direct marketing purposes.
- Restriction: restrict processing under the conditions of art. 18 GDPR.
- Portability: receive your data in electronic format and transmit it to another controller.
- Complaint: complain to a data protection authority (see https://edpb.europa.eu/about-edpb/board/members_en; for Switzerland, the FDPIC).
We will respond to requests within 30 business days. One copy of the personal data undergoing processing is provided free of charge; additional copies on a reimbursement basis. Requests may be sent to our email or business address.
8. Age Requirement
Our services usually have a minimum age requirement and are not directed to children. We do not knowingly collect personal data relating to children. We consider a user to be a child if they are under the age of 13, unless more stringent regulation applies in their country of residence. In EU countries, users under 16 are considered children unless local data protection regulation specifies another age. If you become aware that your child has provided us with personal information without your consent, please contact us and we will take the required steps to delete such information. Some of the apps are limited to users younger than 18.
9. California Privacy Rights (CCPA)
This section applies to individual residents of the State of California within the scope of the California Consumer Privacy Act of 2018 ("CCPA"). Within the last twelve months, our Services have collected the following categories of personal information:
| Category | Collected | Sold | Sources | Shared with |
|---|---|---|---|---|
| A. Identifiers (name, alias, IP address, email, account name) | YES | NO | User, their devices | Advertisers, analytics providers, third parties as legally required |
| B. Cal. Civ. Code § 1798.80(e) categories (financial, medical info) | NO | NO | N/A | N/A |
| C. Protected classification characteristics | NO | NO | N/A | N/A |
| D. Commercial information (purchase records and tendencies) | YES | NO | User | Payment service providers |
| E. Biometric information | NO | NO | N/A | N/A |
| F. Internet or network activity (browsing, search, interaction data) | YES | NO | User, their devices | Advertisers, analytics providers, third parties as legally required |
| G. Geolocation data | NO | NO | N/A | N/A |
| H. Sensory data | NO | NO | N/A | N/A |
| I. Professional or employment-related information | NO | NO | N/A | N/A |
| J. Non-public education information | NO | NO | N/A | N/A |
| K. Inferences drawn from other personal information | YES | NO | Users, their devices, partners | Advertisers, analytics providers, third parties as legally required |
As a California resident, you have the right to: request information about how we have collected and used your personal information during the past 12 months (categories, sources, purposes, third parties, and specific pieces of data); request a copy of your personal information; request deletion of the personal data we have collected from you (subject to exceptions, e.g., completing your transaction, providing a good or service, security, legal compliance, bug fixing, free speech, research, or internal lawful uses); be free from discrimination for exercising your rights; and opt out of the "sale" of personal information. We do not sell your information to third parties and have not within the last 12 months.
Under California's "Shine the Light" law, you may request, once a year and free of charge, a list of third parties to whom we have disclosed personal information for their direct marketing purposes during the previous calendar year. You may exercise your California privacy rights by emailing us at gototop@support-team.app. We must confirm your identity and California residency to process requests. We aim to respond within 45 days of receiving a request; if we require more time, we will inform you of the reason and extension period in writing.
10. Contact Details of GOTOTOP LTD
If you have any questions or comments about this policy, you may contact us via email at gototop@support-team.app, or via post to: GOTOTOP LTD, 14 Panagioti Tsangari, 1st Floor, Office 1E, 4047, Limassol, Cyprus.