privacy
Owner and Data Controller
Owner contact email: [email protected]
Types of Data collected
Among the types of Personal Data that top7choice.com collects, by itself or through third parties, there are: Cookies; Usage Data; geographic position.
Complete details on each type of Personal Data collected are provided in the dedicated
sections of this privacy policy or by specific explanation texts displayed prior to the Data
collection.
Personal Data may be freely provided by the User, or, in case of Usage Data,
collected automatically when using top7choice.com.
Unless specified otherwise,
all Data requested by top7choice.com is mandatory and failure to provide this
Data may make it impossible for top7choice.com to provide its services. In cases
where top7choice.com specifically states that some Data is not mandatory, Users
are free not to communicate this Data without consequences to the availability or the
functioning of the Service.
Users who are uncertain about which Personal Data is
mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking
tools – by top7choice.com or by the owners of third-party services used by
top7choice.com serves the purpose of providing the Service required by the User,
in addition to any other purposes described in the present document and in the Cookie
Policy, if available.
Users are responsible for any third-party Personal Data obtained, published or shared through top7choice.com and confirm that they have the third party's consent to provide the Data to the Owner.
Mode and place of processing the Data
Methods of processing
The Owner takes appropriate security measures to prevent unauthorized access, disclosure,
modification, or unauthorized destruction of the Data.
The Data processing is carried out
using computers and/or IT enabled tools, following organizational procedures and modes
strictly related to the purposes indicated. In addition to the Owner, in some cases, the
Data may be accessible to certain types of persons in charge, involved with the operation of
top7choice.com (administration, sales, marketing, legal, system administration)
or external parties (such as third-party technical service providers, mail carriers, hosting
providers, IT companies, communications agencies) appointed, if necessary, as Data
Processors by the Owner. The updated list of these parties may be requested from the Owner
at any time.
Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:
- Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
- provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
- processing is necessary for compliance with a legal obligation to which the Owner is subject;
- processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
- processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Place
The Data is processed at the Owner's operating offices and in any other places where the
parties involved in the processing are located.
Depending on the User's location,
data transfers may involve transferring the User's Data to a country other than their own.
To find out more about the place of processing of such transferred Data, Users can check the
section containing details about the processing of Personal Data.
Users are also entitled to learn about the legal basis of Data transfers to a country outside
the European Union or to any international organization governed by public international law
or set up by two or more countries, such as the UN, and about the security measures taken by
the Owner to safeguard their Data.
If any such transfer takes place, Users can find
out more by checking the relevant sections of this document or inquire with the Owner using
the information provided in the contact section.
Retention time
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
Therefore:
- Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
- Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has
given consent to such processing, as long as such consent is not withdrawn. Furthermore, the
Owner may be obliged to retain Personal Data for a longer period whenever required to do so
for the performance of a legal obligation or upon order of an authority.
Once the
retention period expires, Personal Data shall be deleted. Therefore, the right to access,
the right to erasure, the right to rectification and the right to data portability cannot be
enforced after expiration of the retention period.
The purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Traffic optimization and distribution, Analytics, Hosting and backend infrastructure, Access to third-party accounts, Registration and authentication, Advertising and Location-based interactions.
For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.
Facebook permissions asked by top7choice.com
top7choice.com may ask for some Facebook permissions allowing it to perform actions with the User's Facebook account and to retrieve information, including Personal Data, from it. This service allows top7choice.com to connect with the User's account on the Facebook social network, provided by Facebook Inc.
For more information about the following permissions, refer to the Facebook permissions documentation and to the Facebook privacy policy.
The permissions asked are the following:
Basic information
By default, this includes certain User’s Data such as id, name, picture, gender, and their locale. Certain connections of the User, such as the Friends, are also available. If the User has made more of their Data public, more information will be available.
Provides access to the User's primary email address.
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
The rights of Users
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following:
- Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
- Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
- Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
- Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
- Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
- Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
- Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.
- Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.
Additional information about Data collection and processing
Legal action
The User's Personal Data may be used for legal purposes by the Owner in Court or in the
stages leading to possible legal action arising from improper use of
top7choice.com or the related Services.
The User declares to be aware that the
Owner may be required to reveal personal data upon request of public authorities.
Additional information about User's Personal Data
In addition to the information contained in this privacy policy, top7choice.com may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.
System logs and maintenance
For operation and maintenance purposes, top7choice.com and any third-party services may collect files that record interaction with top7choice.com (System logs) use other Personal Data (such as the IP Address) for this purpose.
Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.
How “Do Not Track” requests are handled
top7choice.com does not support “Do Not Track” requests.
To determine whether
any of the third-party services it uses honor the “Do Not Track” requests, please read their
privacy policies.
Changes to this privacy policy
The Owner reserves the right to make changes to this privacy policy at any time by notifying
its Users on this page and possibly within top7choice.com and/or - as far as
technically and legally feasible - sending a notice to Users via any contact information
available to the Owner. It is strongly recommended to check this page often, referring to
the date of the last modification listed at the bottom.
Should the changes affect
processing activities performed on the basis of the User’s consent, the Owner shall collect
new consent from the User, where required.
Latest update: December 16, 2019