Revised: October 14th, 2020

We have prepared this Privacy Policy to explain how we collect, use, protect, and disclose information and data when you use Top mobile applications or websites (“App”), and other services offered under the Top name (“Services”). This Privacy Policy also explains your choices for managing your information preferences, including opting out of certain uses of your Personal Information (defined below). This Privacy Policy applies to all users of the App and Services. The App and Services are provided by Velvetas LT, MB (“Top” “we” “our” “us”). By using the App or Services, you agree to this Privacy Policy. If you do not accept and agree with our Policy Policy, then you must stop using the App and Services immediately.


By including any of your Personal Information or other information in your Top profile, you will make it available to other users. For example, the Services will suggest possible matches to users based on certain criteria such as gender, age, and your approximate location (such as your current city, state, country or how far away you are). Your public profile is shown to other users before they list it to the top, including your first name, pictures, your age, About me description, your distance away, number of common Facebook friends, number of common interests. After you are matched with another user, they can view where you listed their profile in your top list. At any time, you can unmatch the people you have matched with from their profile screen. You can also delete certain of your Personal Information from your Edit screen. You can always delete your Top profile using settings in the app. If you don’t use Top for 5 years we will delete your account.


Personal Information

We collect information that personally identifies you, such as your name, physical location, e-mail, and other personally identifiable information that you choose to provide us with or that you choose to include in your account (“Personal Information”). You may be asked to provide us with Personal Information when you register with the Services or use any of our Services, and at other times.

Information from Facebook

When you log into the Services using your Facebook login credentials, we will receive Personal Information and other information from Facebook, such as your name, birthday, e-mail, photos, gender, friends, likes, physical location, and information about your device.

Device Information

We collect information about your device, including the hardware model, operating system and version, unique device identifiers, browser type and language, and mobile network information (“Device Information”). We also collect certain Device Information that will help us diagnose problems if you ever experience any crash or other problem while using our Services.

User Data and App Activity

We also automatically collect information regarding the actions you take on the App and Services (collectively with Device Information, “Usage Data”). For example, each time you use the Services we automatically collect the type of operating system you use, the pages or screens you view, and the time and duration of your visits to the App and Services. We use this information to help us understand how people use the App and Services, and to enhance the services we offer.

Cookies and Anonymous Identifiers

We may use cookies (a small text file placed on your device to identify your computer and web browser) and may use anonymous identifiers (a random string of characters that is used for the same purposes as a cookie). We use cookies and other anonymous identifiers to analyze use of and improve the App and Services and as described in the Advertising and Tracking Section of this Privacy Policy. Most web browsers and devices are initially set up to accept cookies. You can reset your web browser or device to refuse all cookies or to indicate when a cookie is being sent, however, certain features of the App or Services may not work if you delete or disable cookies. Some of our Service Providers may use their own cookies, anonymous identifiers, or other tracking technology in connection with the services they perform on our behalf.


We use Personal Information to provide you best possible Service from us: to match with new users, see who and how much likes you, find the best matches, participate in games, and so on.

You also understand that your Top profile and other information you make available via the App, including information you provide directly or indirectly through Facebook, may be viewed and shared by Top with individuals who may or may not be users or via third party applications in such Tops’ discretion. For example, a user may recommend or share you as a match to his or her Facebook friends by sharing your picture, regardless of whether such friend(s) is also a user of the App. You might share information like the photos and messages you send or upload and any metadata provided with those messages, along with any comments or information you provide in connection with your photos.

When using Top, you should assume that anything you post or submit on the App may be publicly-viewable and accessible, both by users of the App and non-users of the App. Before you post this information, be aware that this content may be searchable by search engines.


From time to time, we may establish a business relationship with other businesses whom we believe trustworthy and who have confirmed that their privacy practices are consistent with ours (“Service Providers”). For example, we may contract with Service Providers to provide certain services, such as hosting and maintenance, data storage and management, and marketing and promotions. We only provide our Service Providers with the information necessary for them to perform these services on our behalf. Each Service Provider must agree to use reasonable security procedures and practices, appropriate to the nature of the information involved, in order to protect your Personal Information from unauthorized access, use, or disclosure. Service Providers are prohibited from using Personal Information other than as specified by us.


We may allow third-party companies to serve ads and collect certain anonymous information when you visit the App and Services. These companies may use non-personally identifiable information (e.g. click stream information, time you spend on app, subject of advertisements clicked or listed to your top) during your visits to the App and Services in order to provide advertisements about goods and services likely to be of interest to you. To learn more about these advertising practices or to opt out of this type of advertising, you can visit or


We may share Personal Information and Usage Data with businesses controlling, controlled by, or under common control with Top. If Top is merged, acquired, or sold, or in the event of a transfer of some or all of our assets, we may disclose or transfer Personal Information and Usage Data in connection with such transaction. You will have the opportunity to opt out of any such transfer if, in our discretion, it will result in the handling of your Personal Information in a way that differs materially from this Privacy Policy.


We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We may disclose Personal Information and any other information about you to government or law enforcement officials or private parties if, in our discretion, we believe it is necessary or appropriate in order to respond to legal requests (including court orders and subpoenas), to protect the safety, property, or rights of our company or of any third party, to prevent or stop any illegal, unethical, or legally actionable activity, or to comply with the law.


We maintain physical, electronic, and procedural safeguards to protect the confidentiality and security of information transmitted to us. However, no data transmission over the Internet or other network can be guaranteed to be 100% secure. As a result, while we strive to protect information transmitted on or through the App or Services, we cannot and do not guarantee the security of any information you transmit on or through the App or Services, and you do so at your own risk.


Our App and Services may contain links to other websites or allow others to send you such links. A link to a third party’s website or app does not mean that we endorse it or that we are affiliated with it. We do not exercise control over third-party websites or apps. You access such third-party websites, apps or content at your own risk. You should always read the privacy policy of a third-party website before providing any information to the website.


The App and Services are intended for users who are 18 years old or older. If we become aware that we have inadvertently received Personal Information from a child under the age of 13, we will delete such information from our records.


Please be aware that your Personal Information and communications may be transferred to and maintained on servers or databases located outside your state, province, or country. If you are located outside of the Europe Union, please be advised that we process and store all information in the Europe Union. The laws in the Europe Union may not be as protective of your privacy as those in your location. By using the App or Services, you are agreeing to the collection, use, transfer, and disclosure of your Personal Information and communications will be governed by the applicable laws in the Europe Union.


We reserve the right, at any time, to add to, change, update, or modify this Policy, simply by posting such change, update, or modification on the App or Services and without any other notice to you. Any such change, update, or modification will be effective immediately upon posting it on page. If any changes are made to this Privacy Policy we will reflect the "Revised" date above. It is your responsibility to review this Policy from time to time to ensure that you continue to agree with all of its terms. By continuing to use the App or Services, you are consenting to the revised Privacy Policy.

If you have any questions about this Privacy Policy, please contact us at with subject line "Privacy Policy".

Velvetas LT, MB is registered in Lithuania under company number 304299001.