Internet World Wide Web Site and Services Provision

Top Connect Ltd, its subsidiaries and affiliates requires that all visitors to our site(s) on the World Wide Web (the “Site”) adhere to the following rules and regulations. By accessing the Site you indicate your acknowledgment and acceptance of these terms and conditions.

1. Laws and Regulations

User access to and use of the Site is subject to all applicable International, European Union and Estonian laws and regulations.

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2. Copyright/Trademarks

The trademarks, logos and service marks (“Marks”) displayed on the Site are the property of Top Connect Ltd and other parties. Users are prohibited from using any Marks for any purpose including, but not limited to use as meta-tags on other pages or sites on the World Wide Web without the written permission of Top Connect Ltd or such third party which may own the Marks. All information and content including any software programs available on or through the Site (“Content”) is protected by copyright. Users are prohibited from modifying, copying, distributing, transmitting, displaying, publishing, selling, licensing, creating derivative works or using any Content available on or through the Site for commercial or public purposes.

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3. No Warranties

All content, products, and services on the site, or obtained from a web site to which the site is linked (a “linked site”) are provided to you “as is” without warranty of any kind either express or implied including, but not limited to, the implied warranties of merchantability and fitness for a particular purpose, title, non-infringement, security or accuracy. Top Connect Ltd does not endorse and is not responsible for (a) the accuracy or reliability of any opinion, advice or statement made through the site or a linked site by any party other than Top Connect Ltd, or (b) the capabilities or reliability of any product or service obtained from a linked site. Other than as required under applicable consumer protection law, under no circumstance will Top Connect Ltd be liable for any loss or damage caused by a user’s reliance on information obtained through the site or a linked site, or user’s reliance on any product or service obtained from a linked site. It is the responsibility of the user to evaluate the accuracy, completeness or usefulness of any opinion, advice or other content available through the site, or obtained from a linked site. Please seek the advice of professionals, as appropriate, regarding the evaluation of any specific opinion, advice, product, service, or other content.

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4. Limitation of Liability For Use of the Site and Linked Sites

The information, software, products and descriptions of services published on the site or a linked site may include inaccuracies or typographical errors, and Top Connect Ltd specifically disclaims any liability for such inaccuracies or errors. Changes are periodically made to the information on the site and linked sites. Top Connect Ltd may make improvements or changes to the site at any time. You agree that Top Connect Ltd, its affiliates and any of their respective officers, directors, employees, or agents will not be liable, whether in contract, tort, strict liability or otherwise, for any direct, indirect, punitive, consequential, incidental or special damages (including without limitation lost profits, cost of procuring substitute service or lost opportunity) arising out of or in connection with the use of the site or a linked site, or with the delay or inability to use the site or a linked site, even if Top Connect Ltd is made aware of the possibility of such damages. This limitation on liability includes, but is not limited to, the transmission of any viruses which may infect a user’s equipment, failure of mechanical or electronic equipment or communication lines, telephone or other interconnect problems (e.g., you cannot access your internet service provider), unauthorized access, theft, operator errors, strikes or other labour problems or any force majeure. Top Connect Ltd cannot and does not guarantee continuous, uninterrupted or secure access to the web site.

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5. Limitation of Liability for Services Arranged Through the Site

You agree that Top Connect Ltd is a mere agent for the providers of services available through the site, including but not limited to travel services. Any and all claims regarding any failure or breach with respect to the services offered through the site are limited to claims against any and all service providers. Top Connect Ltd hereby disclaims any liability, whether based on contract, tort, strict liability or otherwise, including without limitation liability for any direct, indirect, punitive, consequential, incidental or special damages, in connection with the goods or services provided by any carrier or other supplier through the site, including without limitation liability for any act, error, omission, injury, loss, accident, delay or irregularity which may be incurred through the fault, negligent or otherwise, of such carrier or supplier and you hereby exonerate Top Connect Ltd from any liability with respect to the same.

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6. Confidentiality of User Communications

Except as required by law and in accordance with the Top Connect Ltd Internet Privacy Statement, Top Connect Ltd will maintain the confidentiality of all user communications which contain personal user information and which are transmitted directly to Top Connect Ltd. Postings by a user on any message board or in any chat room will not be protected as confidential and Top Connect Ltd may use and provide information contained in any such postings (including any ideas, concepts, know-how or other intellectual property) to any of its parent Inc., subsidiaries and affiliates for any purpose whatsoever and as deemed appropriate by Top Connect Ltd. User should be aware that Linked Sites may contain confidentiality provisions that differ from the provisions provided herein. Top Connect Ltd is not responsible for such provisions, and expressly disclaims any and all liability related to such provisions.

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7. Linked Internet Sites

Top Connect Ltd prohibits caching, unauthorized hypertext links to the Site and the framing of any Content available through the Site. Top Connect Ltd reserves the right to disable any unauthorized links or frames and specifically disclaims any responsibility for the Content available on any other Internet sites linked to the Site. Access to any other Internet sites linked to the Site is at the user’s own risk. User should be aware that Linked Sites may contain rules and regulations, privacy provisions, confidentiality provisions, transmission of personal data provisions, and other provisions that differ from the provisions provided on the Site. Top Connect Ltd is not responsible for such provisions, and expressly disclaims any and all liability related to such provisions.

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8. Postings

Top Connect Ltd is under no obligation to review any messages, information or content (“Postings”) posted on the Site by users and assumes no responsibility or liability relating to any such Postings. Notwithstanding the above, Top Connect Ltd may from time to time monitor the Postings on the Site and may decline to accept and/or remove any Postings that contain:

Any unlawful, harmful, threatening, abusive, harassing, defamatory, vulgar, obscene, profane, hateful, racially, ethnically or otherwise objectionable material of any kind, including, but not limited to, any material which encourages conduct that would constitute a criminal offence, give rise to civil liability or otherwise violate any applicable local, state, national or international law.

Advertisements or solicitations of any kind.

Messages posted by users impersonating others.

Personal information such as messages which state phone numbers, social security numbers, account numbers, addresses, or employer references.

Messages by non-spokesperson employees of Top Connect Ltd purporting to speak on behalf of Top Connect Ltd or containing confidential information or expressing opinions concerning Top Connect Ltd.

Messages that offer unauthorized downloads of any copyrighted or private information.

Multiple messages placed within individual folders by the same user restating the same point.

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9. Privacy Policy

9. Privacy Policy

This revised Privacy policy is available here and will take effect on May 25, 2018 since a new data protection regulations (GDPR) come into effect in the European Union, and we’re taking the opportunity to make improvements for our users.

  1. 1.           Data controller

OÜ Top Connect (referred to as “Top Connect”, “we”, “us” or “our” in this policy) is the data controller of all personal data that is collected and processed for providing telecommunication services. Top Connect is operating with such telecommunication products as TravelSim ( , TravelChat ( and this list may be updated with new products. This Privacy policy is applicable for all telecommunication products of Top Connect.

Top Connect is registered in Estonia with registration number 10668897 and registered offices at Väike-Paala St. 1, 11415 Tallinn. Top Connect as a provider of the Telecommunication services, is committed to providing you with privacy safeguards that are consistent with your right to choose whether to provide information about yourself, and if you do provide it, the nature and quality of that information.

Top Connect will always be open and honest about the way in which we manage personal identifiable information.

You have the right to make a complaint at any time to a supervisory authority. The Estonian Data Protection Inspectorate (registered offices at 19 Väike-Ameerika St., 10129 Tallinn, tel. + 372 627 4135, e-mail ) is the lead data protection supervisory authority for Top Connect as an Estonian data controller.

By using the website and services, you agree to the collection and use of your personal data in accordance with this Privacy Policy. It’s important you understand that by using our services, you give us consent to collect, use, disclose, and retain your personal data. We will never read or listen to the content you are sharing privately. You can be sure that we will only use your information as described in this Policy. If you do not agree with this Privacy Policy, please do not use the website or our services.

  1. 2.           Personal data we collect and purpose for processing of personal data

Personal data means any information relating to an identified or identifiable natural person.

Top Connect will collect personal data from you that is necessary for the purposes of supplying to you the service you subscribe to, such as name, postal address, email address, and telephone number. Top Connect may also collect information about your location. This information is based on the cell tower locations used to transmit your mobile phone call, or the local country access numbers dialed to use your phone card.

In certain jurisdictions, we may ask for a government issued personal identification number (ID) in limited circumstances including when setting up a wireless account and activating your device as required by law.

Except as provided herein, Top Connect will not provide your personal data to any other person unless we ask you and you agree, or unless we are forced to do so by law.

  1. 3.           Children’s personal data

We understand the importance of taking extra precautions to protect the privacy and safety of children using Travel Sim products and services. Children under the age of 16 in Estonia, or equivalent minimum age in the relevant jurisdiction, are not permitted to use Telecommunication services, unless their parent provided verifiable consent. If we learn that we have collected the personal information of a child under 16, or equivalent minimum age depending on jurisdiction, outside the above circumstances we will take steps to delete the information as soon as possible. If at any time a parent needs to access, correct, or delete data associated with child, they may contact us through our Contact page.

  1. 4.           Processing of special categories of personal data

Top Connect will not collect or use information revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation, or any other information considered sensitive.

  1. 5.           Non-personal Information

Top Connect may automatically collect non-personal information about you. This includes but not limited to technical information about your mobile device, system and application software, and peripherals, the type of internet browser and IP address you use and the site, which linked you to the Top Connect telecommunication product’s website. This information is used to assist Top Connect in providing you with an effective website.

Top Connect uses non-personally identifiable information for internal purposes and to help us interact with visitors to the website. Top Connect may also share non-personally identifiable information in the aggregate form with third parties to illustrate trends and patterns. You cannot be personally identified from this information.

  1. 6.           What do we use for and disclose your personal date

Top Connect will use your personal data for customer service, to provide you with information that you may request, and to customize your experience on the website or with the service. Your personal data is used by Top Connect to respond to your requests, process your transactions, tailor offerings to you, and for general internal business purposes.

Top Connect will use your financial information (bank’s account number, payment card number and other electronic payment measure’s data) to bill you for products or otherwise process your transactions. By making a purchase on the website or using the services, you consent to Top Connect providing your financial information to Top Connect’s billing service providers (credit card processor, Adyen, PayPal etc. electronic payment measures) and to such third parties as Top Connect determines for processing your transactions. These third parties may include the credit card companies and banking institutions used to process the transaction. We require all third parties to have appropriate technical and operational security measures in place to protect your personal data, in line with Estonian and EU law on data protection rules.

Top Connect operates businesses in multiple jurisdictions, some of which are not located in the European Union, such as Ukraine and USA and Russia, (for which EU Commission has not adopted adequacy decision). While countries outside the EU do not always have strong data protection laws, we require all services providers to process your information in a secure manner and in accordance with Estonian and EU law on data protection. We utilize standard means under EU law to legitimize data transfers outside the EU.

If you have given additionally your consent, Top Connect may use your personally identifiable information to contact you with information it thinks you would be interested in. If you do not want to receive this information, indicate that Top Connect may not do so at the point on the website, where you give Top Connect your personally identifiable information. If you change your mind later, you may contact us through our Contact page. Email messages will also provide you with an opportunity to opt-out of receiving this information. Please note that changes to your preferences may not be effective immediately. Please note that your removal from these communications will only apply to the processing of your data in the future and not to data that have already been processed as provided in this Privacy Policy.

If Top Connect or part of this company as a TravelSim department is sold to or merges with, another company, or declares bankruptcy, some or all of the data collected from you may be transferred to a third party as a result of the transfer of assets. Top Connect may also disclose your data when Top Connect determines it necessary to comply with applicable laws or protect the interests or safety of Top Connect or other website or service users.

  1. 7.           Legal ground for processing personal data

Legal grounds for processing your personal data are:

-               processing is necessary for the performance of a contract to which the you are a party or in order to take steps at your request prior to entering into a contract;

-               processing is necessary for compliance with a legal obligation to which Top Connect is subject;

-               by accepting this privacy policy, you give consent for the processing of your personal data for sending you our information and offers.

If you do not provide personal data referred in clause 2, Top Connect will not be able to provide its services to you.

  1. 8.           Community Functions

The website and services may make available to its users chat rooms, forums, message boards, and/or other community functions. Remember that any information you disclose in these areas becomes public information and you should exercise caution when deciding to disclose your personal, financial or other information.

  1. 9.           Personal data security

Top Connect will take reasonable steps to ensure that the data we collect from you, use or disclose is accurate, complete and up-to-date.

Top Connect will take all reasonable steps to ensure that the personal identifiable information we hold about you is protected from misuse and loss or from unauthorized access, modification or disclosure.

The data you provide to us is protected using SSL (Secure Socket Layer) technology. SSL is the industry standard method of encrypting personal information and credit card details so that they can be securely transferred over the Internet.

Top Connect will also take reasonable steps to destroy or de-identify your personal data when we no longer need it and it is not necessary retain data to comply with applicable laws.

Please note that we retain personal data till it is necessary to provide Telecommunication services or till we have a legal obligation to process it.

To determine the appropriate retention period, we consider the amount, nature and sensitivity of the personal data and the purposes for which we process it. We must also consider periods for which we might need to retain personal data in order to meet our legal obligations or to deal with complaints, queries and to protect our legal rights in the event of claims being made.

  1. 10.      Your Data Protection Rights

Under certain circumstances, by law you have the right to:

-               Request information about whether we hold personal information about you, and, if so, what that information is and why we are holding or using it.

-               Request access to your personal data (data subject access request). This enables you to receive a copy of the personal data we hold about you.

-               Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected.

-               Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing.

-               Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation, which makes you want to object to processing on this ground. You also have the right to object when we are processing your personal information for direct marketing purposes.

-               Object to automated decision-making including profiling, that is not to be subject of any automated decision-making by us using your personal data or profiling of you.

-               Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.

-               Request transfer of your personal data in an electronic and structured form to you or to another party (commonly known as a right to “data portability”). This enables you to take your data from us in an electronically useable format and to be able to transfer your data to another party in an electronically useable format.

-               Withdraw consent. Then you have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your data for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so.

If you want to exercise any of these rights, then you may contact us through our Contact page, or contact our Data Protection Officer by post at: Data Protection Officer, Top Connect OÜ, Väike-Paala St. 1, Tallinn 11415 Estonia.

You can check and correct some of your personal data details after logging onto the website with your account as well.

  1. 11.      Anonymity

Top Connect is committed to allowing our customers to conduct their activities through any of the services we provide without being required to identify themselves. In some circumstances, such as providing us with credit card details, we obviously cannot deal with you anonymously. However, unless there are good practical or legal reasons that require you to be identified, we will give you the option of operating anonymously or pseudo-anonymously.

  1. 12.      Cookies, site tracking and links

A cookie is a piece of data temporarily stored on the user’s hard drive containing information about the user. A cookie contains your contact information and information to allow us to identify your computer using Telecommunication services. The cookie helps the user to save time. For instance, by setting a cookie on our site, you do not have to log in using your account more than once during each visit, thereby saving time while on our site. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

We use tracking software to monitor client traffic patterns and site usage to help us develop the design and layout of the websites. This software does not enable us to capture any personal data.

This website may contain links to other sites. Please be aware that Top Connect is not responsible for the privacy practices of such other sites. This privacy statement applies solely to information collected by this website.

  1. 13.      Changes to the Privacy Policy

Top Connect reserves the right to change the terms of this Privacy Policy. Any changes will be posted on this page. Notification will be sent also by email.

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