Privacy Policy

About Us:

TOPWORK MEDIA Sp. z o.o. (“we”or “us”) is a company incorporated in the Poland, having its registered office at Str. Hoża 86 office 410, 00-682 Warsaw, Poland. TOPWORK MEDIA Sp. z o.o. owns and operates the domain name

Purpose of this privacy policy:

This Privacy Policy (“Privacy Policy”) describes the privacy practices of TOPWORK MEDIA Sp. z o.o. with regard to your personal data and personal information in connection with your access and use of ‘' (the “Website” which term shall, unless repugnant to the context thereof, include any related applications, including mobile phone applications) and the Website related services (“Heycom Service”).


By using the Services and/or by providing any information to TOPWORK MEDIA Sp. z o.o., the User agrees and consents to the collection & use of information as per the terms of this Privacy Policy, including but not limited to sharing and/or transfer of the Information so collected. The Consent of the User is given as soon as the User starts using the Services. We reserve the right to make any changes to this Privacy Policy. On doing so, We will update this Privacy Policy on its website and the user shall be deemed to have consented to the Policy on such publication.

The Privacy Policy sets out how:
  • The Website collects, stores, shares and uses your Personal Data collected from you when you use our Website and/or the Heycom Service, and
  • Details the types of Personal Data collected, stored, shared and used and your right to control your Personal Data.

TOPWORK MEDIA Sp. z o.o. is committed to ensuring that your privacy is protected and to processing your Personal Data in accordance with the relevant and applicable laws. We will only collect and use your personal data in accordance with this Privacy Policy.

You should read this Privacy Policy carefully and we recommend that you print and keep a copy of it for your future reference. We reserve the right to change and update this Privacy Policy from time to time. We recommend that you revisit this page regularly to stay informed on the current Privacy Policy and ensure that you are in agreement with any such changes.

By continuing to use this Website and/or the Heycom Services, you confirm that you have read, understood and agree with the entire Privacy Policy in effect at the time of your use. If you do not agree to the entire Privacy Policy in effect at the time of your use, then you must not use this Website.

Third Party Websites

This Privacy Policy does not apply to information that may be collected by third parties who own or operate websites and/or third party mobile applications which link to our Website or are accessible by links from our Website, if any. While accessing third party websites and/or mobile applications, you will be subject to the terms and conditions of use and privacy policy of those other websites and/or mobile applications.


If you are under the age of 18, you must not use this Website or the Heycom Service or submit Personal Data to it unless you have the consent of and are supervised by a parent or guardian.

The Personal Data that we collect from you:

When you access and use this Website (including by accessing or browsing it or by communicating with us via email or by signing up for newsletters or other communications through it), we may collect all or some of the following Personal Data from or about you:

  • Your name and contact information such as e-mail address, phone number, billing address, etc. and other information as may be required to access and use this Website;
  • Where you have registered with us, your user name and password;
  • Data pertaining to the usage of the Heycom Service, including the number of page views on the Website, the nature of your internet connection, internet protocol (IP) address, access times, domain name, web browser and operating systems;
  • Certain statistical information such as the number of registered devices, the number of notifications sent by you, when you register your website with us;
  • Financial information for payment of fees, such as your credit card information in connection with our services, as applicable.

In relation to above clause, your express consent shall be obtained prior to us obtaining and processing any financial information from you.

We may also collect some or all of the above types of information from our business partners or third parties who have your consent to pass that information to us or who may be authorised by you to authenticate or identify you to us or to sign in to our Website using credentials from that business partner or third party. We may also collect information through the use of log files, web beacons, or other electronic tools.

You understand and acknowledge that if you post personal information online that is accessible to the public, you may receive unsolicited messages from other parties in return and TOPWORK MEDIA Sp. z o.o. will not be responsible for the use or misuse of such information by third parties.

You understand that through your use of the Website you consent to the collection and use (as set forth in this Privacy Policy) of the Personal Data, processing and use by TOPWORK MEDIA Sp. z o.o. We expressly disclaim any legal liability, whether civil or criminal, pertaining to the content of, security of, or rights in, any part of such information.

We do not knowingly collect information from children under the age of 18 unless we have the consent to do so of the parent or guardian.

What we do with your Personal Data:

We (and third party data processors, vendors and hosting partners who may be acting on our behalf) may collect, store and process your Personal Data for the following reasons:

  • For sending registration information and activation of your account on the Website ("Account") and to keep the Account active and maintain it and to provide you with updates or notifications of changes to your Account
  • For use of your IP addresses to analyse trends, to administer the Website and to track your movement on the Website, etc.
  • For our internal record keeping requirements including collection of anonymised details about visitors to our Website to compile aggregate statistics or produce internal reports;
  • Certain statistical information such as the number of registered devices, the number of notifications sent by you, when you register your website with us;
  • To contact you about our or our business partners’ promotions, products and services or other information which we think you may find interesting, offers, or for customer satisfaction purposes (including contact by email);
  • For market research, analysis, testing, monitoring, risk management and administrative purposes (including diagnosing technology problems which may be reported to us);
  • For sending more relevant advertisements referred to as "Retargeting"
  • For any purposes related to the above or where we have a legal right or duty to use or disclose your Personal Data (including for abuse, crime and fraud prevention and related purposes); and
  • As otherwise required or permitted by law.
Disclosure to Third Parties:

In terms of sharing, disclosing or transferring your Personal Data to third parties (together, “Disclose” or “Disclosing”), except as set out in this Privacy Policy, we will not Disclose your Personal Data unless we have your permission or unless we are required to do so to

  • In connection with dispute resolution, comply with applicable law or an order of a competent court, any governmental or law enforcement body, but we shall not be responsible to seek any protective orders, confidential treatment or any other remedy regarding the disclosure; or
  • Investigate, prevent or take action against suspected illegal activities (including fraud or where the personal safety of another person may be threatened) or any breach of our Website Terms of Use and this Privacy Policy; or
  • Establish or exercise our legal rights or defend against legal claims;
  • We may disclose any information if in Our discretion, such disclosure is necessary for any investigation or complaint of the User’s breach of the Terms and Conditions, Privacy Policy or any law in force;
  • We may disclose any information if in Our discretion, such disclosure is necessary to prevent any harm being committed to Our Rights or of rights of any of the other Users or
  • As may be otherwise required or permitted by law.

If we become aware that we have collected or been sent Personal Data from a person under the age of 18 without the consent of the parent or guardian, we will deactivate the relevant Account as soon as is reasonably practicable.

In the event that a third party proposes to acquire all or some of our business and/or assets, we may disclose your Personal Data to that third party in connection with their proposed or actual acquisition. In the event that we become insolvent or we are in any similar situation, we may also disclose your Personal Data to third parties as part of a business or asset sale carried out where such disclosure is lawful and compliant with the relevant laws in force at the time.

We reserve the right to retain your Personal Data, any other information which we have collected and any other information, data, text or content that you have submitted to the extent required by applicable laws and as we may require for operational and legal purposes. Your privacy is important to us and we do not sell or rent the information to third parties for marketing purposes unless you have granted us permission to do so.

You shall not disclose any information that you may receive from us, directly or indirectly, without our prior written consent.

Transfer of Information:

Information collected by US may be stored in house servers or may be stored on the servers of third party service providers whether in Your Home Country or located in any other country. The User agrees and acknowledges that to the storage of information with such third party service providers at locations other than the User’s home country.

We use Model Contractual Clauses adopted by the EU Commission as a legal mechanism for the international transfer of data to a third party located in a country outside Europe. We take all reasonable precautions to protect personal information from misuse, loss and unauthorized access. We have implemented physical, electronic, and procedural safeguards in order to protect the information, including that the information will be stored on secured servers and protected by secured networks to which access is limited to a few authorized employees and personnel. However, no method of transmission over the Internet or method of electronic storage is 100% secure.

Access and Control of Your Personal Data

We provide various mean and mechanism for You to control and manage Your personal information. Subject to applicable law, you may also have the following rights in relation to Your personal information:

  • Right of access: You may request a confirmation as to whether or not personal information is being processed by Datability and to obtain a copy of that information. We may decline to process requests that are vexatious or frivolous or extremely impractical, jeopardize the privacy of others, or for which access is not otherwise required by applicable law.
  • Right to rectification: In case any of Your Data with us is inaccurate, You may request rectification for the same.
  • Right to erasure: You may request that your personal information is erased in certain situations, However, in such a case, Datability will not be liable to provide any Services to You.
  • Right to object: You may object to the processing of Your personal information in certain situations e.g. for use of your data for ad targeting.
  • Right to restriction: You may request restrictions of the processing of Your personal information in certain situations e.g. if Your personal information is inaccurate or unlawfully processed.
  • Right to data portability: You may request to receive personal information provided by You in machine readable format.

You can exercise Your rights above via the Settings of the Website, where You can access, edit, delete and download Your personal information and limit or opt-out of the collection and use of Your information for ad targeting and the provision of special offers or promotions by third parties. You may also contact Us for assistance using the contact information below, and we will consider your request in accordance with applicable law.

How We Use Cookies:
  • A cookie is a small data file which asks permission to be placed on your computer’s hard drive or other mobile or handheld device as you browse this Website or advertisements, videos or other types of content and which “remembers” that your computer or device accesses this Website or the HeyCom Service.
  • If you accept the cookie, the file is added to your computer’s hard drive or other mobile or handheld device. Most web browsers automatically accept cookies but you may modify your browser settings to decline cookies or to be notified of cookies being placed. Cookies may be used by us to do any of the following :
  • Enable us to respond to you as an individual and to tailor our operations to your needs by gathering and remembering Personal Data about your preferences; Assist the effective operation of this Website;
  • Enable traffic to the Website and pages to be logged to identify pages used and browsing and purchasing behaviour of users of our Website for statistical purposes and to monitor which pages users find useful or not; or
  • Identify you as an account holder or user and assist with account or user security (such as by obliging you to re-set passwords if the password has lapsed).
  • The cookies do not give us access to any other Personal Data on your computer or device other than the Personal Data you choose to share with us.
  • Rejecting cookies used by this Website may prevent you from taking full advantage of the Website and may stop this Website from operating properly when you use it. You may be unable to complete a transaction with us on this Website.
  • If you do not consent to use of the cookies, you must disable the cookies by deleting them or amending your cookie settings on your computer or you must stop using this Website.
Protection of your Personal Data:

We are committed to ensuring that your Personal Data is secure. However, we cannot guarantee the security of the information in any form or at any location.In order to minimise the risk of unauthorised access to or disclosure of your Personal Data, we put in place where practicable appropriate physical, electronic and managerial procedures that are in compliance with reasonable security practises to safeguard and secure the Personal Data.

Although we take appropriate measures to safeguard the Personal Data that you provide to us, no transmission over the internet is guaranteed to be secure. For your security, you should:

  • If using a computer in a public location, always log out and close the website browser when you complete your online session;
  • Keep your account details and passwords private;
  • Frequently change your password;
  • Avoid using the same password for multiple online accounts.

You shall conduct periodic risk assessments to ensure that any security risks are properly managed, and shall ensure that personal data is kept accurate, up-to-date, secure and for no longer than is necessary.

You shall ensure that devices that you use to access the services are equipped with the appropriate levels of security requirements.

Links to other websites and their privacy policies:

Your use of other websites which are owned and operated by third parties, and if accessed by you through links from this Website, is not governed by this Privacy Policy and we do not control any of those other websites. Once you use the links from this Website to access those other websites, we are not responsible for the privacy of any data that you provide while using them.

You should review the privacy policies applicable to those other websites and ask any questions or raise any concerns about their collection or use of your Personal Data with that website operator.


Should youhave any queries regarding this Privacy Policy or TOPWORK MEDIA Sp. z o.o. policy on data collection, use and disclosure policies, you may do so by writing to us Str. Hoża 86 office 410, 00-682 Warsaw, Poland., or e-mail us at

You understand and acknowledge that you are responsible for maintaining the confidentiality of the password and Account, and are fully responsible for all activities that occur under your password or Account. You agree to immediately notify TOPWORK MEDIA Sp. z o.o. of any unauthorized use of your password or Account or any other breach of security. TOPWORK MEDIA Sp. z o.o. cannot and will not be liable for any loss or damage arising from your failure to comply with the provisions set out herein.

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