Privacy Policy
By ticking the “I agree” box, accompanied by a link to this Policy, you (hereinafter referred to as the “User”) freely, by your own will and in your own interest, give your consent to the processing of Personal Information in the manner and on the terms established by this Policy.
1. General Provisions
This Policy is an integral part of the User Agreement (hereinafter referred to as the “Agreement”), posted and/or available on the Internet at: https://toptalent.md/privacy-policy, as well as other contracts concluded with the User, when this is expressly provided by their terms. Thus, by concluding the Agreement and the specified contracts in the manner established by them, you fully accept the terms of this Policy.
The methods of processing Personal Information include any actions (operations) or a combination of actions (operations), including collection, recording, systematization, storage, clarification (updating, changing), extraction, use, transfer (provision, access), anonymization, blocking, deletion, destruction for the purposes established by this Policy using automation tools or without using such tools at the discretion of “TopTalent.md”.
Hereinafter in the Policy, the terms and definitions provided by the Agreement, as well as other contracts concluded with the User, are used, unless otherwise provided by this Policy or does not follow from its essence. In other cases, the interpretation of the term used in the Policy is carried out in accordance with applicable law or business customs.
2. Personal Information
Personal Information in this Policy means:
Information that the User provides about themselves independently during registration or authorization, as well as in the process of further use of the Site.
Data that is transmitted automatically depending on the settings of the User’s software in an anonymized form.
“TopTalent.md” has the right to establish requirements for the composition of the User’s Personal Information, which must be necessarily provided for the use of the Site. If certain information is not marked by “TopTalent.md” as mandatory, its provision or disclosure is carried out by the User at their discretion.
When registering, the User specifies the account name (login), phone, email address, and password.
Upon registration, “TopTalent.md” creates a unique identifier for each User (user_id). The User’s identifier is linked to the User’s profile information. If an individual acts on behalf of an organization, the name, registration address, and mailing address of such an organization, corporate phone number, etc., may additionally be provided. The specified information about the organization does not relate to personal data. If an individual acts as a sole proprietor or on their behalf, at the request or with the direct written consent of such a sole proprietor, respectively, the following may additionally be provided: the surname and initials of the sole proprietor, and correspondence address, phone number, etc.
The User may independently, by their actions, at their discretion, disclose to an indefinite circle of people (publish on the Site) information about their profile, which may include personal data, including: surname, first name, patronymic, gender, date of birth, city of residence, place of work, position, information about themselves in free form. The information added by the User to the profile becomes available to an unlimited number of people, taking into account the profile information display settings on the Site.
“TopTalent.md” does not verify the authenticity of the provided Personal Information and the presence of the User’s necessary consent for its processing in accordance with this Policy, assuming that the User acts in good faith, prudently, and makes all necessary efforts to keep such information up to date and obtain all necessary consents from personal data subjects.
“TopTalent.md” collects and stores data about the User’s actions on the Site, using cookies in the process. If actions are performed by an authorized User, such information is associated with the User’s identifier.
The User acknowledges and accepts the possibility of using third-party software on the Site, as a result of which such persons may receive and transmit the data specified in clause 2.1.2 in an anonymized form. Such third-party software includes:
systems for collecting analytical data: Google Analytics, HubSpot, etc.;
advertising placement systems: Google DoubleClick for Publishers (DFP), Google Adsense, Criteo, etc..
The composition and terms of the collection of anonymized data using third-party software are determined directly by their rights holders and may include: browser data (type, version, cookies); operating system data (type, version, screen resolution); request data (time, referral source, IP address); other anonymized data about the User’s actions on the Site.
As part of providing certain types of services, “TopTalent.md” may offer Users the opportunity to independently place on
individual pages of the Site software for collecting and processing anonymized data, similar to that specified in this clause of the Policy, as a result of which such Users may receive the specified data in an anonymized form. The composition and terms of the collection of anonymized data in this case are determined by the User who placed the software for collecting and processing anonymized data but cannot contradict this Policy.
“TopTalent.md” is not responsible for the order of use of the User’s Personal Information by third parties with whom the User interacts within the use of the Site.
3. Legal Basis for Processing Personal Information
The legal bases for processing Personal Information include:
Processing of Personal Information when the User has given consent to the processing for one or more specific purposes;
Processing of Personal Information when it is necessary for the performance of a contract to which the User is a party;
Processing of Personal Information that is necessary for “TopTalent.md” to fulfill its obligations under applicable law.
4. Policy Regarding Children
“TopTalent.md” does not intentionally collect personal data from children under the age of 18, does not request it, and does not allow them to use the Application. Individuals under the age of 18 are not allowed to provide personal information, including name, address, phone number, and email address. If “TopTalent.md” becomes aware that information has been received from a child under the age of 18, “TopTalent.md” will immediately delete such information. If you believe that we may have received any information from or about a child under the age of 18, please contact us by email: [email protected]
5. Purposes of Processing Personal Information
“TopTalent.md” processes, including collects and stores, the Personal Information necessary for concluding and executing contracts with the User, as well as made publicly available by the User by filling out the profile and setting preferences in the Personal Account.
“TopTalent.md” is entitled to use Personal Information for the following purposes:
Concluding contracts for the use of the Site; The conclusion of the Contract is carried out remotely through the exchange of electronic documents, which are signed with a simple electronic signature. In this case, the role of the key to the simple electronic signature of the User can be performed by the login-password pair or the User’s email address. Therefore, they are requested at registration.
Fulfillment of obligations under concluded contracts, including providing the User with access to the Site;
Requests for granting access to the Site are accepted using software tools and email. Within the framework of implementing the functional capabilities of the Site, the Right Holder stores, systematizes, and displays on the Site the profiles of Users containing Personal Information.
Identification of the User within the framework of fulfilling obligations under contracts concluded with them; The User’s Personal Account is associated with the login-password and the User’s email address.
Providing technical support in connection with the use of the Site; Inquiries to the support service are accepted using software tools and email.
Ensuring communication with the User for informational service purposes and improving the quality of the Site under the concluded Agreements, including in the form of notifications involving third parties; Communication with the User is carried out via email or the subscriber phone number specified by the User at registration or in the process of using the Site.
Using anonymized data for targeting advertising and/or informational materials by age, gender, and other characteristics.
Conducting marketing, statistical, and other research based on anonymized data. Data from the systems mentioned in clause 2 in anonymized form is collected and analyzed to find out how much time Users spend in different sections of the Application, their interests, and preferences.
Fulfillment of legislative requirements. Being an organizer of information distribution on the Internet, “TopTalent.md” stores information about the facts of reception, transmission, delivery, and (or) processing of written text, images, sounds, video, or other electronic messages of Internet users and information about these users for one year from the end of such actions.
6. User Rights Regarding Personal Information
If provided by applicable law, the User has the right to:
Receive information about the collection and use of their personal data.
Access their personal data and correct them if they are inaccurate or incomplete.
Prohibit the processing of their personal data in cases where their accuracy is disputed, processing is carried out unlawfully, as well as in cases where “TopTalent.md” no longer requires personal data for the purposes in which they were processed by “TopTalent.md”.
Object to the processing of their personal data, as well as prohibit their processing in cases where “TopTalent.md” processed them in the performance of tasks in the public interest or in its own legitimate interests, and at the same time there is no compelling necessity for continuing such processing.
Withdraw consent at any time, which the User has given for the processing of their personal data. In the event of the User’s withdrawal of consent to the processing of personal data, such withdrawal will not affect the
legality of the processing carried out by “TopTalent.md” on the basis of such consent before its withdrawal.
Demand the deletion of their personal data, in cases where: they are no longer related to the purposes for which they were collected or processed; when consent has been withdrawn and “TopTalent.md” has no grounds for continuing processing; when there are objections against further processing in the public interest or in the legitimate interests of “TopTalent.md” and there is no compelling necessity for continuing such processing; when personal data were processed unlawfully.
Not be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning the User or similarly significantly affects them, except in cases where there is a legal basis for continuing processing.
The aforementioned rights can be exercised by using the tools that “TopTalent.md” offers on the Site or by sending a special request to “TopTalent.md” by the methods described below. “TopTalent.md” will promptly respond to any such requests in accordance with applicable law. In some cases, “TopTalent.md” may ask the User to undergo an identification procedure before processing the request.
7. Storage of Personal Information
All collected Personal Information is stored only for the period necessary to achieve the purposes for which such information was collected, or for the period permitted or required in accordance with the provisions of applicable law. Periodically, “TopTalent.md” conducts an audit of data processing systems to determine whether the purposes of collecting and processing users’ personal data remain valid. This determination is based on several factors, which include, but are not limited to the following: whether the User maintains relations with “TopTalent.md”, whether “TopTalent.md” has fulfilled the User’s requests (including any additional tasks), whether there are contractual relations between the User and “TopTalent.md”, as well as whether there are contractual or legal grounds for continuing the storage of the User’s personal data. Based on the results of such an audit and notifications received from personal data subjects, “TopTalent.md” updates its systems.
For the purpose of improving the quality of the Site and ensuring the possibility of legal protection, “TopTalent.md” is entitled to store log files about actions performed by the User within the framework of using the Site, as well as in connection with the conclusion and execution by the User of the Agreement and other contracts on their part, for 1 (One) year from the moment of their execution.
8. Requirements for the Protection of Personal Information
“TopTalent.md” carries out the storage of Personal Information and ensures its protection from unauthorized access and distribution in accordance with internal rules and regulations.
Regarding the User’s Personal Information, its confidentiality is maintained, except for information disclosed by the User to an unlimited number of people (clause 2 of this Policy), and other cases where the technology of the Site or the settings of the software used by the User provide for open exchange of information with other Users of the Site or with any users of the Internet network.
9. Transfer of Personal Information
“TopTalent.md” is entitled to transfer Personal Information to third parties in the following cases:
– The User has expressed their consent to such actions, including in cases where the User has applied the settings of the software used, not limiting the provision of certain information;
– The transfer is necessary within the framework of the User’s use of the Site’s functionalities;
– At the request of the court or other authorized state body within the procedure established by law;
– To protect the rights and legitimate interests of “TopTalent.md” in connection with violations of contracts concluded with the User.
10. Modification and Deletion of Personal Information
The User has the right at any time to independently edit the Personal Information provided at registration or authorization in their Personal Account. The User has the right to delete their own account or exercise the right to withdraw consent for the processing of their personal data by sending a request to “TopTalent.md” to delete their account at [email protected].
11. Changes to the Privacy Policy
This Policy may be changed or terminated by “TopTalent.md” unilaterally without prior notice to the User. The new version of the Policy comes into effect from the moment it is posted on the “TopTalent.md” Site unless otherwise provided by the new edition of the Policy.
The current edition of the Policy is located on the “TopTalent.md” Site on the Internet at https://toptalent.md/privacy-policy