Privacy Notice

Last updated: January 22, 2021

This Privacy Notice explains how we use the personal information that collects or generates in relation to the Service whether it is accessed via our Website ( or the App.

The list below sets out what is covered in this Privacy Notice and you can click on the headings below to go to a specific section.



1.1 Tortu LLC (a company registered in Russian Federation with registered number 1183926020585 and its registered address at 9 Polkovnika Efremova street, flat 32, 33, Kaliningrad, Russian Federation (“”, “we” “us” and “our”) collect and use certain Personal Data in relation to you.

1.2 is responsible for ensuring that it uses that Personal Data in compliance with data protection laws, including (but not limited to) the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and any other national, implementing or supplementing Data Protection Legislation.

1.3 At we respect the privacy of our Users and we are committed to keeping all your Personal Data secure. This Privacy Notice governs the handling of Personal Data by in the course of carrying on commercial activities.

1.4 We use the following definitions in this Privacy Notice:

“Cookie”means a small text file that includes a small quantity of information sent to the browser of website Users, by a web server, and stored on the hard disk drive of a computer for purposes of archiving, collecting navigation data for statistical analysis purposes, and offering Users services related to their interests or location.
“User(s)” or “you”means the users of the Website and App.
“ App”means the mobile application used to access the Service.
“ Service” or the “Service”means the maps service and related offerings including the App or Website.
“ Website”means the
“Personal Data”means any data which relates to a living individual who can be identified from that data or from that data and other information, which is in the possession of, or is likely to come into the possession of, (or its representatives or service providers). In addition to factual information, it includes any expression of opinion about an individual and any indication of the intentions of or any other person in respect of an individual.
“Privacy Notice”means this Privacy Notice.


2.1 This Privacy Notice concerns the following information that we collect about you when providing the Service:

  1. information we receive through the Website and the App; and
  2. information we receive from third parties or our affiliates in providing you the Service.


3.1 The Service offered by requires us to obtain Personal Data about you in order to provide the Service. Users may be unable to access and use the Service, the Website and the App if such Personal Data are not provided. In relation to each of the services described at Section 2.1 above, we will collect and process the following Personal Data about you:

  • Information that you provide to This includes information about you that you provide to us. The nature of the services you are requesting will determine the kind of Personal Data we might ask for, though such information may include (by way of a non-exhaustive list):
    • basic Personal Data (such as first name, last name, title, username or similar identifier, password, date of birth);
    • contact details (such as billing address, residential address, email address and telephone numbers);
    • payment information such as credit / debit card details;
    • where necessary, information required for us to complete ‘know your customer’ checks or to confirm your identity; and
    • any information that you choose to share with using the Service which may be considered Personal Data. This might include your preferences, feedback and any survey responses.
  • Information that we collect or generate about you. This includes (by way of non-exhaustive list):
    • information related to your device, such as your device’s IP address, referring website, what pages your device visited, and the time that your device visited our Website;
    • location data;
    • information collected by cookies and other similar technologies;
    • any information regarding the any additional services you may purchase and our interactions with you;
    • a file with your contact history to be used for enquiry purposes so that we may ensure that you are satisfied with the services which we have provided to you;
    • technical data including your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the services; and
    • through our cloud security services, traffic and security reports that include information on the internet usage of the organisation’s computer users (e.g. what websites were visited by each User, any documents downloaded, security incidents, prevention measures taken by the gateway, etc.).
  • Information we obtain from other sources. This includes the Personal Data provided to us by third-party service providers, agencies or other publicly available sources where applicable.
    • Information collected from third party providers such as your social media interactions or information we collect from companies we use to provide our Service;
  • Cookies.
    • When you visit the Website, cookies are used to collect technical information about the services that you use, and how you use them.
    • For more information on the cookies used by please see Section 10 of this Privacy Notice.
  • Anonymised data
    • In addition to the categories of Personal Data described above, may also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your Personal Data but is not considered Personal Data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this privacy policy.
  • Special category Personal Data
    • We do not collect any special categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, genetic and biometric data).


4.1 Your Personal Data may be stored and processed by us in the following ways and for the following purposes:

  • for ongoing review and improvement of the information provided on the Service to ensure they are user friendly and to prevent any potential disruptions or cyber attacks;
  • to allow you to use and access the functionality provided by the Service;
  • to set up Users to use the Service;
  • to understand feedback on the Service and to help provide more information on the use of those products and services quickly and easily;
  • in relation to the award and redemption of rewards that may offer from time to time;
  • to communicate with you in order to provide you information, updates or announcements about and the Service and to provide personalised content including adverts, marketing and content;
  • for in-depth threat analysis;
  • to understand your needs and interests;
  • for the management and administration of our business;
  • in order to comply with and in order to assess compliance with applicable laws, rules and regulations, and internal policies and procedures;
  • to detect and prevent fraud and other illegal activities; or
  • for the administration and maintenance of databases storing Personal Data.

4.2 However, where we use Personal Data, we make sure that the usage complies with law and the law allows us and requires us to use Personal Data for a variety of reasons. These include:

  • we need to do so in order to perform its contractual obligations with our customers and third-party providers;
  • we have obtained your express consent (for example, through a checkbox, signature or in writing);
  • we have legal and regulatory obligations that we must discharge;
  • we may need to do so in order to establish, exercise or defend our legal rights or for the purpose of legal proceedings;
  • the use of your Personal Data as described is necessary for our legitimate business interests, such as:
    • allowing us to effectively and efficiently manage and administer the operation of our business;
    • maintaining compliance with internal policies and procedures; and
    • monitoring the use of our copyrighted materials.

4.3 We will take steps to ensure that the Personal Data is accessed only by employees of that have a need to do so for the purposes described in this Privacy Notice.


5.1 We may share your Personal Data within the group of companies for the purposes described above. We will take steps to ensure that access to Personal Data is restricted to employees who have a legitimate interest in the purposes described in this Privacy Notice.

5.2 We may also share your Personal Data outside of the group for the following purposes: purposes:

  • with our business partners. For example, this could include third party providers who provide elements that make up our Service offering for you to use (such as Foursquare). Personal Data will only be transferred to a business partner who is contractually obliged to comply with appropriate data protection obligations and the relevant privacy and confidentiality legislation;
  • with third party agents and contractors for the purposes of providing services to us (for example,’s accountants, professional advisors, IT and communications providers and debt collectors). These third parties will be subject to appropriate data protection obligations and they will only use your Personal Data as described in this Privacy Notice;
  • to the extent required by law, for example if we are under a duty to disclose your Personal Data in order to comply with any legal obligation (including, without limitation, in order to comply with tax reporting requirements and disclosures to regulators), or to establish, exercise or defend its legal rights;
  • if we sell our business or assets, in which case we may need to disclose your Personal Data to the prospective buyer for due diligence purposes; and
  • if we are acquired by a third party, in which case the Personal Data held by us about you will be disclosed to the third-party buyer.


6.1 The Service is offered to a global audience - our Users and our operations are spread around the world. As a result, we collect and transfer Personal Data on a global basis. That means that we may transfer your Personal Data to locations outside of your country.

6.2 Where we transfer your Personal Data from within the EEA or the United Kingdom to outside the EEA or the United Kingdom we will ensure that it is protected and transferred in a manner consistent with legal requirements. This may be done in one of the following ways:

  • the country that we send the data to might be approved by the European Commission or the UK Government (as applicable) as offering an adequate level of protection for Personal Data;
  • the recipient might have signed up to a contract based on “model contractual clauses” approved by the European Commission or by the UK Government (as applicable), obliging them to protect your Personal Data;
  • the recipient may have adhered to binding corporate rules (only for intragroup transfers); or
  • in other circumstances the law may permit us to otherwise transfer your Personal Data outside the EEA or the United Kingdom.

6.3 You can obtain more details of the protection given to your Personal Data when it is transferred outside the EEA or the United Kingdom (including a copy of the standard data protection clauses which we have entered into with recipients of your Personal Data) by contacting us as described in Section 14 below.


7.1 We have extensive controls in place to maintain the security of our information and information systems. Client files are protected with safeguards according to the sensitivity of the relevant information. Appropriate controls (such as restricted access) are placed on our computer systems. Physical access to areas where Personal Data is gathered, processed or stored is limited to authorised employees.

7.2 As a condition of employment, employees are required to follow all applicable laws and regulations, including in relation to data protection law. Access to sensitive Personal Data is limited to those employees who need to it to perform their roles. Unauthorised use or disclosure of confidential client information by an employee is prohibited and may result in disciplinary measures.

7.3 When you contact an employee about your file, you may be asked for some Personal Data. This type of safeguard is designed to ensure that only you, or someone authorised by you, has access to your file.


8.1 How long we will hold your Personal Data for will vary and will be determined by the following cumulative criteria:

  • the purpose for which we are using it – will need to keep your Personal Data for as long as is necessary for that purpose; and
  • legal obligations – laws or regulation may set a minimum period for which has to keep your Personal Data.


9.1 In all the above cases in which we collect, use or store your Personal Data, you may have the following rights which you can exercise free of charge. These rights include:

  • the right to obtain information regarding the processing of your Personal Data and access to the Personal Data which we hold about you;
  • the right to withdraw your consent to the processing of your Personal Data at any time. Please note, however, that we may still be entitled to process your Personal Data if we have another legitimate reason for doing so. For example, we may need to retain Personal Data to comply with a legal obligation;
  • in some circumstances, the right to receive some Personal Data in a structured, commonly used and machine-readable format and/or request that we transmit those data to a third party where this is technically feasible. Please note that this right only applies to Personal Data which you have provided directly to;
  • the right to request that we rectify your Personal Data if it is inaccurate or incomplete;
  • the right to request that we erase your Personal Data in certain circumstances. Please note that there may be circumstances where you ask us to erase your Personal Data, but we are legally entitled to retain it;
  • the right to object to, or request that we restrict, our processing of your Personal Data in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your Personal Data but we are legally entitled to refuse that request; and
  • the right to lodge a complaint with the relevant data protection regulator if you think that any of your rights have been infringed by us.

9.2 You can exercise your rights by contacting us using the details listed in Section 14 below.

9.3 You can opt-out of receiving certain promotional or marketing communications from us at any time (or by using the unsubscribe link in the emails communications we send) (please note that if you have any account for our Services, we will still send you non-promotional communications, like service related emails).

9.4 You can always opt not to disclose information to us, but keep in mind some information may be needed to register with us or to take advantage of some of our features.

9.5 Further information about your rights may be obtained by contacting the supervisory data protection authority located in your jurisdiction.


10.1 To the extent that we collect Personal Data with the help of Cookies we will process them in accordance with this section 10 of the Privacy Notice.

10.2 Our website uses cookies to distinguish you from other users of our website. A cookie is a small piece of text sent to your browser by a website you visit. It helps the Website to remember information about your visit, like your preferred language and other settings. That can make your next visit easier and the site more useful to you. Cookies play an important role. Without them, using the web would be a much more frustrating experience. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

10.3 A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

10.4 We use the following cookies:

  • Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
  • Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
  • Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
  • Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. [We may also share this information with third parties for this purpose].

10.5 Please note that the following third parties may also use cookies, over which we have no control. These named third parties may include, for example, advertising networks and providers of external services like web traffic analysis services. These third party cookies are likely to be analytical cookies or performance cookies or targeting cookies:

  • Google Analytics
  • Yandex.Metrika
  • CloudFlare
  • AddThis
  • Zopim
  • Optimizely

There are ways you can control and manage cookies on your device. Please remember that any settings you change will not just affect the cookies we use. These changes will apply to all websites you visit (unless you choose to block cookies from particular sites).

10.6 Managing cookies in your browser
Most browsers will allow you to choose the level of privacy settings you want. You can block all cookies, or accept all cookies or pick a setting somewhere in between. This range lets you control your cookie settings, so you can:

  • Block third party cookies;
  • See what cookies you've got and delete them on an individual basis;
  • Block all cookies from being set;
  • Block cookies from particular sites;
  • Delete all cookies when you close your browser;

Deleting cookies means that any preference settings you have made on a website will be lost. If you’ve set your preferences to opt out of cookies, this setting will be lost too, as that information is stored in a cookie. Blocking all cookies means functionality on our websites will be lost, as described above. We don’t recommend turning all cookies off when using our websites.

If you want to reduce your cookie settings at any time – for example, if you accept all cookies, but later decide you don’t want a certain type of cookie – you’ll need to use your browser settings to remove any third party cookies dropped on your previous visit.

Find out how to manage your cookies using the most popular browsers below.

You can also find general information and opt-out resources at


11.1 We may use your contact details to inform you of products, services and offers may be relevant for you – we call this “marketing”.

11.2 We will only market to you with your consent (where required by law) and you will be able to withdraw that consent.


12.1 Unfortunately, if you’re under 18, you can’t use the services. We do not knowingly solicit or collect information from anyone under 18. If we become aware that a person under the age of 18 has provided us with personal information, we’ll delete it immediately.


13.1’s may be contacted using the following contact information:

Address:9 Polkovnika Efremova street, flat 32, 33, Kaliningrad, Russian Federation


14.1 For further information regarding the processing of your Personal Data by, this Privacy Notice, questions relating to consent, or in order to exercise the rights mentioned above, please contact our data protection officer using the following contact details:

Address:9 Polkovnika Efremova street, flat 32, 33, Kaliningrad, Russian Federation

14.2 We are usually able to resolve privacy questions or concerns promptly and effectively. If you are not satisfied with the response you receive from our data protection officer, you may escalate concerns to the applicable privacy regulator in your jurisdiction. Upon request,’s data protection officer will provide you with the contact information for that regulator.