Personal Data Policy
This is a translation of the Russian original. In case of any discrepancy, the Russian version prevails.
1. General
1.1. This Policy sets out how personal data of users of the BeTop service is processed and protected: the websites https://betop.me and https://lk.betop.me, the BeTop Helper browser extension and the @betopme_bot Telegram bot (the "Service"). The Policy is adopted under Federal Law No. 152-FZ of 27.07.2006 "On Personal Data".
1.2. The Operator is individual entrepreneur Daniil Vitalievich Dzhumaylo, INN 234808164682, OGRNIP 319237500139632, Krasnodar, Russia, email [email protected].
1.3. The Policy is published at https://lk.betop.me/legal/privacy and is available without registration. Consent to personal data processing is a separate document: https://lk.betop.me/legal/consent.
2. Data we process
2.1. Account data: email address, password (stored only as a hash), interface language, country (derived from the IP address), registration date, traffic source (UTM tags, referring page, referral link).
2.2. Third-party platform profiles you link: Behance, Dribbble, ArtStation profile ID and name, whether there is an avatar, number of works, used to verify tasks and profile requirements.
2.3. Service usage data: orders and links to promoted pages, completed tasks (work, action, time, verification result, text of the comment left), coin transactions, payments (amount, method, status; the Operator does not receive card details), support requests.
2.4. Telegram: Telegram user ID and username if you link your account to the @betopme_bot bot, and support conversations in the bot.
2.5. Technical data: IP address, browser and device information, BeTop Helper version, cookies and analytics identifiers, date and time of actions.
2.6. The Operator does not process special categories of personal data (health, beliefs, etc.) or biometric data.
3. Purposes and legal grounds
| Purpose | Data | Ground |
|---|---|---|
| Registration, sign-in, Account operation | 2.1, 2.5 | performance of a contract (Art. 6(1)(5) of 152-FZ), consent |
| Fulfilling orders, verifying tasks, coin accounting, payments and refunds | 2.1–2.3 | performance of a contract, consent |
| Abuse prevention (multiple accounts, bots, repeated rewards) | 2.1–2.3, 2.5 | performance of a contract, consent |
| Service notifications and support | 2.1, 2.3, 2.4 | performance of a contract, consent |
| Newsletters and marketing emails | email, Service usage data | separate marketing consent (Art. 18 of Federal Law 38-FZ "On Advertising") |
| Visit statistics, advertising performance | 2.5, traffic source | consent |
| Accounting, tax and online cash register obligations | email, payments | legal obligation (Art. 6(1)(2) of 152-FZ) |
4. Processing operations and retention
4.1. The Operator collects, records, organises, accumulates, stores, updates, retrieves, uses, transfers (provides, grants access to), anonymises, blocks, deletes and destroys personal data using automated means.
4.2. Retention: account data for as long as the account exists and 3 years after deletion (limitation period); payment records for 5 years (tax and accounting requirements); technical logs for up to 12 months; marketing data until marketing consent is withdrawn.
4.3. When the retention period expires or the purpose is achieved, data is deleted or anonymised. To delete your account, write to [email protected] from the email address the account is registered with. Data is deleted or anonymised within 30 days, except data the Operator must keep by law.
5. Recipients
5.1. The Operator shares data only to the extent necessary for the purposes above:
- payment agents UnitPay, FreeKassa, Interkassa: amount, email, payment ID (payment, receipt, refunds);
- Beget LLC: sending email;
- DigitalOcean, LLC (USA): hosting the Service servers;
- Cloudflare, Inc. (USA): website delivery and protection;
- Yandex LLC: Yandex Metrica (visit statistics);
- Google LLC (USA): Google Analytics, Google Tag Manager, reCAPTCHA (statistics, protecting the sign-up form from bots);
- Functional Software, Inc. (Sentry, USA): error diagnostics;
- Telegram: conversations through the @betopme_bot bot;
- third-party promotion services: only the link to the promoted page or work given in the order;
- other Service users: the link to the promoted work in the task text;
- public authorities: upon a lawful request.
5.2. Recipients marked as located in the USA process data outside the Russian Federation (cross-border transfer). The USA is not on the list of countries ensuring adequate protection of data subjects' rights. The transfer is based on your consent and is necessary to perform the contract with you (Art. 12 of 152-FZ).
5.3. The Operator does not sell personal data.
6. Cookies
6.1. Necessary cookies are required for the Service to work: sign-in, form protection, language, interface and currency selection, referral link, your choice in the cookie banner. They are always set.
6.2. Analytics and advertising cookies: Yandex Metrica, Google Analytics (via Google Tag Manager). If you choose "Necessary only" in the cookie banner, these counters are not loaded on lk.betop.me.
6.3. You can delete or block cookies in your browser settings. Without necessary cookies you cannot sign in to the Account.
7. BeTop Helper extension
7.1. The extension works only on lk.betop.me, behance.net and dribbble.com. It receives the ID of the profile you are signed in to on the platform and task completion data (like, follow, save, comment on a specific work) and sends them to the Operator to verify the task.
7.2. The extension does not read passwords, messages, browsing history or data from other websites. See the extension privacy policy for details.
8. Security
8.1. The Operator applies legal, organisational and technical safeguards: encrypted connections (HTTPS), passwords stored only as hashes, restricted access to data, logging of administrator actions, backups.
8.2. In the event of a personal data breach, the Operator notifies Roskomnadzor within the time limits set by Art. 21(3.1) of 152-FZ.
9. Your rights
9.1. You have the right to: obtain information about the processing of your data; require that data be corrected, blocked or destroyed if it is incomplete, outdated, inaccurate, unlawfully obtained or not necessary for the stated purpose; withdraw your consent to data processing and your marketing consent; appeal against the Operator's actions to Roskomnadzor or a court.
9.2. Send your request to [email protected] from the email address the account is registered with. The Operator responds within 10 working days; this may be extended by up to 5 working days with a notice of the reason.
9.3. After consent is withdrawn, the Operator stops processing unless there are other legal grounds (for example, performance of the contract or retaining payment records as required by law). The Service cannot be used without processing account data.
10. Users in the European Union and the United Kingdom
10.1. Where the EU General Data Protection Regulation (GDPR) applies, the legal bases are: performance of a contract (Art. 6(1)(b)), consent (Art. 6(1)(a)) for marketing and analytics, legitimate interest in preventing abuse (Art. 6(1)(f)), and compliance with legal obligations (Art. 6(1)(c)).
10.2. In addition to the rights in Section 9, you may obtain a copy of your data in a machine-readable format, restrict processing, object to processing based on legitimate interest, and lodge a complaint with the data protection authority of your country. The Service does not make automated decisions producing legal effects for you.
10.3. Data is transferred outside the EEA based on your explicit consent (Art. 49(1)(a) GDPR) and to perform the contract (Art. 49(1)(b)). Data protection contact: [email protected].
11. Changes to this Policy
11.1. The Operator may amend this Policy. A new version is published at https://lk.betop.me/legal/privacy with its date and takes effect upon publication. Previous versions are available in the archive on the same page.