Privacy Policy

iTop Inc. (hereinafter, “the Company”, “We”, “Us” and the like) is firmly committed to regulatory compliance and the privacy and protection of personal data. Accordingly, in the present Privacy Policy (hereinafter, “this Policy”), the User (hereinafter “the User”, “you”, “your”) of iTop AI Cleaner for iPhone (hereinafter, “the/our app”) will find all the relevant information to better understand what we do with their personal data. If you do not agree with this Policy, please do not access and use our app.

We may update this Policy according to new legislative or jurisprudential requirements and/or business needs, among other reasons. Any updates or modifications of this Privacy Policy will be considered applicable from the moment of their publication on the app. Therefore, the User is recommended to review this Policy regularly. This Policy will always be available on the app so that the data subjects can consult it at all times.

What does this Policy apply to?

This Policy applies to the personal data that we collect and process from you as a User of our app, as well as the services offered within it.
Please bear in mind that in order to access and use our app, the User must be an adult according to the laws and regulations of their birth or residence country and/or state.

What does personal data mean, and which data do we collect and process?

For the purposes of this Policy, "personal data" refers to all data that identifies you or that could be used to identify you, such as:

Some of your device details, as when you access our app or log in, is received but note that such data is received as disaggregated data (strictly device identifier information), that means that is not associated with a particular User or their personal information, but it only has to do with information concerning the general use that all Users make of our app.
Information about the use that the User makes of our app (the sections you consult on our app), as accessing your device to match repeated information by exploring, among others, the contact list, events located in the device calendar, videos, and photographs in your camera roll. In this regard, note that we do not store or use the data placed in your device, but we only require you to access it to provide you with the entrusted services, and, therefore, all information is exclusively located in your device and/or iCloud account.
Information about the location of your device (that is, your IP address);
When accessing the app, you will be required to give your consent, by means of a pop-up, to enable us to get to know your geolocation data according to Apple/Google policies. In this sense, you are solely responsible for allowing us to get access, temporarily access while using the app, or to refuse access on our part to such data. If you accept, note that you can go to “Settings” on your device and withdraw such consent at any time.
Information about your Apple/Google account is shared when you have provided your consent to these platforms to communicate this data to third-party partners who develop apps offered through the platforms.
Advertisements while using the app, when applicable, by means of AdMob from Firebase (Google Inc), AppLovin MAX, or any other platform we may use. For further information, please consult Apple/Google’s partner privacy policy.
Information about the email address is required in order to send you confirmation of the payment you have made, and in this way, the User can access the App with Premium access applied.

In all cases, we only process personal data that is strictly necessary for the fulfillment of the purposes described above. That is, if you provide Us with more information than the one expressly required, you consent to its processing for the informed purpose(s) for which it was granted.

In order to properly provide the services offered within the app, the User must provide Us with accurate, truthful, updated, and complete information, which is a reflection of the User’s real circumstances. In this sense, please note that if you provide us via email with information and/or personal data of third parties, you guarantee us that you have obtained their consent and that you have informed them about the purpose of the processing, which is to optimize your device storage memory by deleting duplicate information.

In light of the above, the Company will not be held responsible if:

The User is under fourteen (14) years of age. In this sense, it is the sole responsibility of the parents and/or legal guardians to exercise adequate control over their minor children’s/wards’ online activity and to prevent their access to apps whose content is not suitable or recommended for minors. Therefore, the communication of a minor's personal data without the prior authorization of their parents/legal guardians is under the exclusive responsibility of the latter. If we become aware that we have collected personal data about a User under the aforementioned age, we will delete that data as soon as it is possible from a technical standpoint.
The Company has received an adult’s personal data and/or private information to provide the services offered in the app by a third party who has not requested the adult’s consent to communicate their personal data to us. In such case, the Company reserves the right to inform the interested person of how their personal data and/or private information has been collected and, where appropriate, We will ask the individual who provided the personal data to the Company to confirm that they requested the consent of the data subject and/or to amend this circumstance, as well as, if appropriate, to suspend the services and/or the User account. For circumstances that are beyond our reasonable control, such as being provided with erroneous, incomplete, and/or fraudulent information from you as a User, you will be solely responsible for the inaccuracy or lack of veracity of the information provided. In this regard, the Company will not be held responsible for the impossibility of providing the Services or for the Services not being correct or complete because the User has not complied with this requirement.

Who is the personal data controller?

iTop Inc. is the controller of the User’s personal data mentioned above.

What do we use your personal data for?

Please be informed that you are only required to provide personal data and information that is strictly necessary to fulfill the purposes explained below. In this regard, if you provide us with more information than is expressly required, you consent to its processing for the purpose(s) for which it was granted.

Having said that, we use your personal data for the following purposes:

To make available and render the service offered through our app;
To collect the fees for the subscription plans to the services offered through the app;
To manage your information queries regarding our app and/or services offered through it;
To comply with our legal obligations, legal requirements, laws, and regulations, and/or to respond to judicial, police, or the corresponding authorities’ requirements;
To protect, investigate, and deter fraudulent, unauthorized, or illegal activity on/through our app;
To improve our app’s functionalities and services offered by analyzing disaggregated data not associated with a particular user’s personal information.
To improve the User's experience, based on their preferences, and to show you advertisements related to our app while you are browsing your social media or third-party websites.

What is the legal basis for processing your personal data?

We only process your personal data when there is a legal basis for doing so. The legal basis will depend on the reason(s) why we collect and process your personal data. In almost all cases, the legal basis will be:

The consent that you provided us for the processing of your personal data in order to be able to provide you with the services offered through the app and for other purposes was informed at the time of collection of your data. As well as for the purpose of tracking your activity or advertising purposes, for geolocalization purposes, when the User enables such option voluntarily.
The consent you have provided Apple/Google to install similar technologies on your device(s) for the purpose of tracking your activity in these platforms, for example, what applications you have installed or which information you share with third-party partners about your browser or device for advertising purposes.
To comply with our legal obligations and/or to attend to administrative, judicial, police, or the corresponding authorities’ official requirements.
Our legitimate interests in (i) offering an enhanced user experience when you access and use the app and operating it efficiently, (ii) providing advertisements to users according to their interests, (iii) monitoring fraudulent activity to preserve the security and integrity of our app, and (iv) defending and addressing our rights if a claim regarding our app and/or Services may arise.

How long do we keep your personal data for?

We will keep your personal data only for as long as it is necessary to fulfill the purposes for which they are being processed and, beyond that, your personal data will be retained, and securely blocked, for the necessary retention period to meet our legal obligations and/or for our legitimate reasons (i.e to address claims in connection with the services offered through the app; to finish the investigation of detected fraudulent or illicit activity).

Regarding similar technologies used by Apple/Google to collect and store the information on your device that is later shared with the partners of the services offered by these platforms, we recommend that you consult the Privacy and Cookie Policies of these platforms for information on how to revoke the consent that you have given to them for the installation of similar technologies.

Once the necessary retention period has elapsed, your personal data will be securely deleted from our information systems.

Who do we share the User’s personal data with?

We may communicate your personal data to the following third parties, including but not limited to:

(i) our main service provider, Apple/Google;
(ii) other providers such as Google Inc., AppsFlyer, among others;
(iii) administrative, police, or judicial authorities as long as the data is required in accordance with the applicable law and regulations;
(iv) law firms to respond to claims regarding our app or services offered through it;
The third parties mentioned above may have their headquarters outside the European Economic Area (EEA); therefore, your personal data will be subject to international transfers. In any event, if a personal data international transfer is deemed appropriate, We inform you that We will only transfer personal data to recipients located in countries that ensure an adequate level of data protection or, failing that, offer the appropriate safeguards required by the current applicable law and regulations on the protection of personal data, to ensure that your personal data is properly protected and that your individual rights and freedoms are guaranteed. In this regard, please be informed that the third parties mentioned above are committed to standard contractual clauses approved by the EU Commission certification in case of transfers to the USA.

How do we protect your personal data?

Your trust is very important to us. For this reason, your personal data is stored confidentially and securely in our information systems. We have established the appropriate technical and organizational measures to safeguard and protect your personal data against illegal or unauthorized access, loss, accidental destruction, damage, use, and illegal or unauthorized disclosure.

Google API Services Usage Disclosure. How do we handle your data with this API?

Regardless of any other provisions in this Privacy Policy, if you grant us access to your Google data, our use of that information will be subject to the following additional restrictions:

We will only use access to read or manage Gmail smart message, headers, and email content to provide a web extension that enables users to process (delete, move, archive, or unsubscribe from) emails. We will not share this Gmail data with third parties unless required to comply with applicable law.
e only use this access to let the User select among their e-mails to delete, identify frequent senders, delete the sender’s e-mails, and create a filter to automatically remove future emails from the sender.
We will not use this Gmail data for advertising purposes.
We will not allow human access to this data unless we have your explicit consent for specific messages, it is necessary for security reasons, such as investigating abuse, or to comply with applicable law.
The use of raw or derived user data received from Workspace APIs will adhere to the Google User Data Policy, including the Limited Use requirements.

What rights do you have, and how can you exercise them?

You may exercise your data protection rights (i.e, access, rectification, erasure, object, portability, and restriction of the processing of your data) by written request addressed to our Company to the following email: tickets@itopvpn.com

As a general rule, we will respond to data protection rights requests within one (1) month from the communication of the exercise of the right by the User. Occasionally, this period may be extended by two (2) further months where necessary, taking into account whether your request is particularly complex or you have made several requests. In this case, we will notify you of this event and explain the reasons for the delay to you.

Finally, we inform you that you should consider it appropriately; you have the right to lodge a complaint before the corresponding Supervisory Authority, especially if you consider that your data protection rights have not been adequately addressed.

We remain at your disposal for any doubts or questions you may have about this Policy. Please contact us by email at tickets@itopvpn.com

If the User is using our App from the United States, please bear in mind that you can exercise the following rights according to the California Consumer Privacy Act (“CCPA”):

Opt-out of marketing tracking: Our company does not show, nor do our partners, personalized ads within our App. Even though the above-mentioned, please bear in mind that if that happened, and in the event you do not want third parties to use personalized ads based on your interests, please activate the "Limit Ad Tracking" function of your device, which you can access through the "Settings" icon, then “Privacy” and “Advertising” section. Also, please note that even if you have chosen this option, you may still receive interest-based information from third parties.
Opt-out of location Data processing: Our company does not process location data, nor do our third parties. Even though the above stated, please note that in case a third party process such data, and in the event you do not want third parties to use it, please turn the Location Services off function of your device, which you can access through the “Settings” icon, then Privacy and “Location Services” section, and then setting “Share my Location” status to “Never”.