Privacy Policy
1Terms and definitions
1.1The Policy means this Personal Data Processing Policy.
1.2You, Your, Yours, etc., and Data Subject mean our counterparty under the Public Offer, who may be an individual using the Website to receive Services top-up services.
1.3GDPR or Regulation means Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, repealing Directive 95/46/EC, as amended from time to time and incorporated into the national laws of participating countries.
1.4Personal Data means any information relating to an identified or identifiable natural person. An identifiable person is someone who can be identified directly or indirectly, in particular by reference to an identifier such as a name, identification number, location data or online identifier, or to one or more factors specific to that person’s physical, physiological, genetic, mental, economic, cultural or social identity.
1.5Personal Data Processing means any action (operation) or set of actions (operations) performed on Personal Data, with or without automated means, including collection, recording, organization, accumulation, storage, updating, modification, retrieval, use, transfer (disclosure, provision or access), depersonalization, blocking, erasure and destruction. Personal Data is processed using mixed methods, including automated processing.
1.6Automated processing of Personal Data means processing Personal Data using computer technology.
1.7Confidentiality of Personal Data means the obligation of Us or any other person who has gained access to Personal Data not to disclose it without the Data Subject’s consent or another lawful basis.
1.8Depersonalization of Personal Data means actions that make it impossible to determine, without additional information, which specific Data Subject the Personal Data belongs to.
1.9A Transfer means a payment transaction made by the User on the Website.
1.10The Website means our website https://sth.team.
1.11Cookies are small text files placed by the Website on Your computer or device, for example when You visit certain sections of the Website and/or use certain Website features.
2Subject and legal basis for processing personal data
2.1Scope of the Policy. This Policy applies to the relationship between Us and You in connection with Personal Data Processing as part of our relationship arising from Your use of the Website and the Company’s provision of services under the terms of the Public Offer accepted by You.
2.2Legal basis for processing. Your consent is always the basis for processing Your Personal Data. Without Your agreement to this Policy, we cannot fully perform our obligations under the agreements concluded with You; therefore, acceptance of this Policy is a mandatory condition for concluding them.
3Policy term and personal data processing period
3.1Policy term. Once accepted, this Policy remains in force indefinitely. This does not affect the period for which Your Personal Data is processed, which is set out in this Policy.
3.2Personal Data processing period. As a general rule, We process Your Personal Data for as long as Your Personal Account exists and for five (5) years after it is deleted (or from the date We receive a properly completed written withdrawal of Your consent to Personal Data processing), unless a retention period is set by applicable law, the Public Offer or another agreement related in any way to Your use of the Website to which You are a party. In other cases, We will stop processing Your Personal Data if You object to the processing or withdraw Your previously given consent in accordance with this Policy. However, this may prevent Us from fulfilling our obligations under our agreements with You.
3.3Changes. We may change this Policy at any time, including due to changes in our business processes, external factors or other reasons. We will promptly publish the revised Policy on the Website so You can review it. We will notify You of changes by sending a notice to Your Personal Account and/or publishing the revised Policy on the Website. If You continue to use the Website after the changes are made, We will consider that You agree to the revised Policy.
4Policy basis, purposes and principles
4.1Basis for the Policy. This Policy was developed to meet the requirements of: (a) the GDPR; (b) CalOPPA; (c) CCPA; (d) PECR; (e) Federal Law No. 152-FZ; (f) GDPR; and (g) other laws and regulations governing when and how a Data Subject’s Personal Data may be processed.
4.2Purposes. This Policy aims to: (1) protect human and civil rights and freedoms when Personal Data is processed, including the rights to privacy and personal and family confidentiality; (2) prevent unauthorized actions by third parties, including unlawful or accidental access to Your Personal Data, as well as its destruction, alteration, blocking, copying or disclosure; (3) ensure legal and regulatory confidentiality safeguards and control over Your Personal Data; and (4) protect citizens’ constitutional right to privacy and the confidentiality of information constituting Personal Data, and prevent potential threats to Your security.
4.3The main purpose of this Policy is to give You a full and transparent understanding of the legal basis for collecting and processing Your Personal Data; the categories of Personal Data We may collect about You; what happens to the Personal Data We collect; where We process Your Personal Data; how long We retain it; who We may disclose it to; and Your rights as a Data Subject.
4.4Principles. We follow these Personal Data Processing principles: (1) Personal Data must be processed lawfully and fairly; (2) processing must be limited to specific, predetermined and lawful purposes, and must not be incompatible with the purposes for which the Personal Data was collected; (3) the content and scope of the processed Personal Data must match the stated processing purposes and must not be excessive; (4) Personal Data must be accurate, sufficient and up to date in relation to the processing purposes; and (5) Personal Data must not be retained longer than necessary for those purposes, unless this Policy provides for another retention period or method of determining it.
5Personal data collected
5.1Website registration. Under the Public Offer, when You register on the Website We collect the following Personal Data: (1) name (if You provide Your personal name); and (2) email address.
5.2Service data. After registering, You can receive Services top-up services. You will need to enter the identifier for Your user account with that Service, which may contain Personal Data. By doing so, You are considered to have consented to our processing of that data.
5.3Payment data. To make a payment, the following information may be required: (1) bank card number; (2) card expiry date (month/year); and (3) card security code (PPC2/CVC2/CVV2). Please note that this information is stored by our payment partners. We do NOT collect or store payment data as part of the relationship between Us under the Public Offer.
5.4Technical data. While You use the Website, We automatically collect some of Your Personal Data. This may include technical information such as the Internet Protocol (IP) address used to connect Your computer to the Internet, login data, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, information about Your visits to websites, and other similar data.
5.5Other data. In exceptional cases, We may ask You to provide additional Personal Data. We will notify You in advance and ask for Your additional consent to process it.
5.6Third-party Personal Data. If You provide us with Personal Data relating to third parties, You warrant that You have obtained all necessary consents from them (including consent to transfer their Personal Data) and any other documents needed to comply fully with this Policy, executed in the form required by their applicable law (Third-Party Consent). If You act as the operator of those individuals’ Personal Data, You also warrant that You ensure its transfer and protection to a standard no lower than that required by this Policy. Third-Party Consent must be in writing, and You must provide the original no later than seven (7) calendar days after the Operator sends the relevant request. Providing third-party Personal Data without meeting this warranty is prohibited, and You accept full responsibility for any breach of it.
6Rights of the data subject
6.1Right to information. You may request information about Us and our location, whether We hold Your Personal Data, and access to that Personal Data.
6.2Correction. You may ask Us to correct, block or delete Your Personal Data if it is incomplete, outdated, inaccurate, unlawfully obtained or unnecessary for the stated processing purpose. You may also take other measures provided by law to protect Your rights.
6.3Form of disclosure. We will provide information about whether We hold Your Personal Data in an accessible form. It will not contain Personal Data relating to other Data Subjects.
6.4Access procedure. You or Your legal representative may access Your Personal Data by applying in person or sending a written request. The request must include the number of the primary identity document belonging to You or Your legal representative, the document’s issue date and issuing authority, and a handwritten signature. The request may be sent electronically. We must respond within thirty (30) days of receiving it; depending on the complexity and number of requests, this period may be extended to sixty (60) days.
6.5Contents of the response. In a request for access to Personal Data, You may ask Us for information about its Processing, including: (1) confirmation that Personal Data is being processed and the purpose of that processing; (2) the processing methods; (3) the Operator’s name and location, and information about people who have or may be given access to the Personal Data; (4) the categories of Personal Data processed and their source; (5) processing periods, including retention periods; and (6) information about the legal consequences that processing may have for the Data Subject.
6.6Withdrawal of consent. You may withdraw Your consent to Personal Data processing, restrict the methods and forms of processing, and prohibit disclosure of Your Personal Data without Your consent.
6.7Right to complain. You may appeal Our actions or omissions to the authorized body responsible for protecting Data Subjects’ rights or through the courts.
6.8Right to protection. You have the right to protect Your rights and legitimate interests, including seeking compensation for losses and moral harm through the courts.
7Disclosure of personal data
7.1Disclosure of Personal Data. To achieve the purposes of Personal Data Processing, We may need to provide Your Personal Data to: (1) our payment partner and credit institutions involved in Transfers, to maintain an appropriate level of security for online payments made using electronic payment methods through an authorization page, as determined by payment-system security protocols, acquiring banks and issuers of electronic payment methods, in accordance with the Public Offer; (3) fraud-prevention organizations, including those addressing conduct-related and financial fraud and financial-fraud bureaus; and (4) government authorities, including executive authorities.
7.2Mandatory and optional disclosure. Disclosure may be mandatory, for example, for information about the User’s device: IP address, operating system, location data, device ID/type, channel used (browser/application), payment authorization, identification/verification; or optional, for example, address-matching indicators, account information and similar data.
8Storage of personal data
8.1Personal Data localization. If You are a citizen of a member state of the European Economic Area or the United Kingdom, Your Personal Data is collected and processed in the European Economic Area. If You are a citizen of the Russian Federation, We store Your data on servers located in the Russian Federation.
9Cookies
9.1Use of Cookies. The Website uses Cookies. When You visit the Website, Your browser sends certain information to our server: (1) date and time of the visit; (2) browser type; (3) language settings; and (4) operating system. This information is stored in connection logs for a limited period (from a session to one year) to ensure the Website’s security and proper operation and to collect statistical information.
9.2Cookie functions. The Website uses different groups of Cookies. The first group consists of functional and technical Cookies. Their main function is to let the Website server receive information about Your session, language, browser and similar details, and to ensure that the Website works properly. These files allow us to recognize You when You return to the Website, personalize its content to Your needs and remember Your preferences. The second group consists of analytical Cookies, which help us estimate and count visitors and understand how they navigate the Website. This helps us improve the Website, for example by making it easier and more efficient to find the sections You need. You may opt out of analytical Cookies by changing the relevant settings in Your web browser.
9.3Cookie retention period. Based on how long they remain on users’ devices, Cookies are divided into Persistent and Session Cookies. “Session Cookies” remain on Your device until You close Your browser. “Persistent Cookies” remain on Your device until they expire or You delete them.
9.4Disabling Cookies. You can accept or reject all Cookies on all websites You visit by changing the settings in Your web browser.
10Final provisions
10.1Severability. If one or more provisions of this Policy are held to be invalid, unenforceable or similar, those provisions will be deemed replaced with valid provisions that come as close as possible to their meaning. Under no circumstances will the entire Policy be deemed invalid.