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Please note that the above text is a translation from Romanian into English. In case of discrepancies between the English version of the text and the Romanian version, the Romanian version shall prevail.



"Personal data" - any information related to an identified or identifiable natural person (subject of personal data) and means a set of personal data and / or non-personalized information about the User provided by him to the Company and / or automatically collected by the Company and / or third parties.


"Company" - the company SRL "TOP 100 INT", (Tax ID: J22/1525/2023, address: Str. Fîntînilor 43, bl. B14, ap. B39, Iași), that is the developer and owner of the site “”, on which processes and collecting personal data of Users. Contact information for the Data Protection Officer (DPO) You can contact the company's DPO at the email address: [email protected].


"Processing of personal data" - any action (operation) or a set of actions (operations) performed by using automation tools or without using such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, using, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.


“Cross - border transfer of personal data” - means the transfer of personal data to the territory of a foreign state, to an authority of a foreign state, to a foreign individual or foreign legal entity. 


"Destruction of personal data" - any actions as a result of which personal data is destroyed irretrievably, with the impossibility of further restoration of the content of personal data in the information system of personal data and / or material carriers of personal data are destroyed.


"Policy" - means the present Privacy Policy (with all existing additions and changes).


"User" - means an individual and legal entity authorized / registered on the website.


"Cookies" - means a small, unique text file that a website sends to a User's computer/device by visiting a website.


"Site" -, as well as sites in the domain.




The present Privacy Policy of Users' personal data is accepted by the Company and is effective in relation of  all information that the Company may receive about the Site Visitor from any device and by communicating with the Company in any form.


By using the Site (viewing, reading text, sending or downloading information) and providing their personal data, the Visitor consents to the processing of personal data in accordance with this Policy.


The Company sets as its most important goal and condition for the implementation of its activities the observance of the rights and freedoms of a person and a citizen by the processing of his personal data, including the protection of the rights to privacy, personal and family confidentiality.


The present privacy policy of the Company regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Company may receive about the Site Users.


The Company will only use the personal data for the purposes described in the present Privacy Policy and will not use them for purposes materially different from those set out herein without obtaining the positively explicit unequivocal consent.


The Company is responsible for processing of the received Personal Data in accordance with the Security Policy adopted by the Company and transfers the corresponding obligations to any third parties acting on its behalf (processors, third parties).


The Company's website is maintained by qualified specialists who ensure the reliability and uninterrupted operation of the site. Technical support is available to users during business hours of the Company, according to the established work schedule, from 08:00 to 17:00.

2.1. Legal bases for the processing of personal data

As a data controller authorized person, we process personal data in the following ways: 

  • based on the consent of the data subject for the processing of their personal data, which are processed in accordance with point (a) of Article 6.1 GDPR;
  • if processing is necessary for the performance of a contract (including these Rules), processing is carried out in accordance with point (b) of Article 6.1 GDPR; 
  • if processing is necessary for compliance with a legal obligation, it is carried out in accordance with Article 6.1, letter (c) GDPR; 
  • if processing is necessary for the legitimate interests of the Site, it is carried out in accordance with Article 6.1, letter (f) GDPR.


By registering a user account on the Site, you agree to the terms and conditions of use of the Site, which can be found here, and these constitute an agreement between you and our company. Therefore, the data provided by you through the Site's user account will be processed in accordance with point (b) of Article 6.1 GDPR.


2.2. User’s rights regarding the protection of personal data.

In connection with the provision of Personal Data, in accordance with the provisions of the GDPR, you have the following rights:


  • to withdraw the consent for the processing of personal data;
  • to receive data relating to their processing (grounds and purposes of such processing, methods of processing used, information about persons who have access to them or to whom they can be disclosed on the basis of an agreement or the Law).
  • to receive data about the location and identification data of persons performing the processing of Personal Data.
  • to receive data about the periods of storage of Personal Data.
  • to receive information about the completed or proposed cross-border transfer of Personal Data.
  • to clarify, update his personal data, to demand their blocking or destruction;
  • to request from the Company: a list of processed personal data, legal grounds for processing, sources of their receipt, information on the terms of processing and storage, as well as other information related to the processing of his personal data.
  • to exercise other rights in the field of personal data protection provided for by the Law or the provisions of this Policy.


The user may at any time withdraw his consent to the processing of personal data by sending a notification to the Company by e-mail to the email address: [email protected], marked "Withdrawal of consent for the processing of personal data".


Upon the request, the Company will provide information about the Personal Data that it processes. To request this information, please, contact email: [email protected].


You have the right to access your Personal Data and privacy settings at any time in order to change or delete them. This can be done in the "Profile Settings" section, where You can immediately view and change most of Your personal data. For security reasons, some elements of personal data can only be changed by contacting customer service. We will promptly respond to Your request within a reasonable time frame.


2.3. Personal data about users.


The User provides the Company with the following his personal details:

  • last name, first name and patronymic;
  • E-mail address;
  • Mobile phone number;
  • User's gender.


The user is the only person responsible for the completeness of the personal (private) data provided and is obliged to change them in a timely manner (update, check, correct) on a regular basis.

The Company proceeds from the fact that all personal (personal) data provided by the User are reliable, and that the User keeps such information up to date.




We may use session cookies files, which are automatically deleted when the user closes their browser, and/or persistent cookies files, which remain on the user's computer until manually deleted. Most browsers can either warn You about the use of cookies files or refuse to accept cookies entirely. If You do not want that we use cookies in Your browser, You can set Your browser so that it refuses cookies or notifies You when any site attempts to install cookies on Your computer.


The user has the right to disable cookies at any time by changing certain settings on his smartphone, tablet, watch or other mobile device. Such disconnection may result in the limiting or change of the User's access to the functional possibilities of the site and / or content.


By viewing the websites, data about the Site Visitor is automatically collected (from Cookies), in accordance with clause 2.2. Policy.


If You interact by any way with third-party programs while using the service, for example, provide the service with Your personal data by logging in / registering of an account through social networks, we may delete this data from our service, but they will still be available in the program of the third party-developer. In this case, we cannot delete Your personal data. In this and other situations, we will notify You at the email address you provided on the Company's website that we cannot do this and explain the reasons. If you use a third-party application to post such information, You can delete it yourself. For this purpose, you must either log in to the relevant application and delete the information, or contact the support team of the relevant application.




4.1. Determination of the purposes of processing.


The collection and processing of Personal Data is carried out for the following purposes:

a. for analysis of the User's behavior, as well as identification of the User's preferences for a particular type of content;

b. for operational and correct operation of the site, improving the content of the site, improving the internal architecture and functionality of the site;

c. for identification of the User;

d. for registration in the self-service system (personal account);

e. for providing personalized advertising and marketing materials;

f. for providing the Site Visitor with information about the Company and the services provided;

g. to comply with the requirements of the Law;

h. for establishing of the feedback, including sending notifications, requests regarding the provision of services, processing of requests and applications from the User’s site;

i. for determining the location of the Site User to ensure security, prevent fraud;

j. for confirmation of the accuracy and completeness of personal data provided by the user’s Site; 

k. providing the User with access to the websites or services of the Company's partners in order to obtain products, updates and services;

l. for any other purposes, subject to obtaining of the separate consent from the User.


The processing of Personal Data is carried out on the basis of the following principles:

1.1. Lawfulness of the purposes and methods of processing;

1.2. good faith;

1.3. Compliance of the purposes of processing of Personal Data with the purposes predetermined and declared by collecting of such Personal Data;

1.4. Compliance of the volume and nature of the processed Personal data with the stated purposes of their processing.


4.2. Conditions of the processing of personal data.


The processing of Personal Data is carried out in the following cases:

a. by obtaining consent from the User;

b. by achievement by the Copyright Holder of the goals stipulated by an international treaty or the Law;

c. by provision by the User of his Personal data to an unlimited number of persons;

d. by fulfillment of other obligations of the Company towards the User, including, but not limited to, the provision of certain content to the User;

e. by saving of the life or health of the User, when consent to the processing of his Personal Data cannot be obtained in advance.


In case of depersonalization of Personal Data, that does not allow to directly or indirectly identify the User, the subsequent use and disclosure of such data to third parties is allowed and the rules of this Policy are no longer applied to them.


The Rightsholder takes all possible measures to protect the confidentiality of the received Personal Data, except the cases when the User has made such data publicly available.

The processing of Personal Data is carried out by using automation tools and without the use of such automation tools.




Data is stored for the entire duration of the provision of Services, except for obligations provided by current legislation (in the field of tax and accounting, as well as for investigating complaints related to the use of our Services).




We apply daily all necessary technical and organizational measures to ensure the security of your data, especially to combat any risk of destruction, loss, alteration, or unauthorized disclosure of your data (e.g., training, access control, passwords, antivirus programs, "https," etc.).




If it is necessary to make changes to the privacy rules, we will publish these changes on this page and inform you by email.


If you have any questions about our Privacy Policy, please write to us at [email protected].


Thank you for using our services.