Welcome to the privacy policy of toppy.it. This policy will help you understand what data we collect, why we collect it, and what your rights are in relation to it.
Among the types of Personal Data that toppy.it collects, by itself or through third parties, there are:
Cookies
Usage Data
Data communicated while using the service
phone number
email address
first name
last name
county
state
country
ZIP/Postal code
city
address
company name
website
movement activity
geographic position
unique device identifiers for advertising (Google Advertiser ID or IDFA, for example)
number of Users
session statistics
answers to questions
user content
contents of the email or message
profile picture
date of the message
time the message was sent
sender of the message
session duration
clicks
interaction events
date of birth
payment info
billing address
shipping address
name
order ID
data relating to the point of sale
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 toppy.it. Unless specified otherwise, all Data requested by toppy.it is mandatory and failure to provide this Data may make it impossible for toppy.it to provide its services. In cases where toppy.it 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 toppy.it or by the owners of third-party services used by toppy.it 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.
Users are responsible for any third-party Personal Data obtained, published or shared through toppy.it.
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 toppy.it (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.
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.
Retention time
Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.
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:
Interaction with live chat platforms
Contacting the User
Displaying content from external platforms
Handling activity data
Hosting and backend infrastructure
Interaction with data collection platforms and other third parties
Interaction with external social networks and platforms
Location-based interactions
Access to third-party accounts
Analytics
Platform services and hosting
Registration and authentication
Advertising
Content performance and features testing (A/B testing)
Remarketing and behavioral targeting
Backup saving and management
Tag Management
Managing contacts and sending messages
Heat mapping and session recording
SPAM protection
User database management
Infrastructure monitoring
Building and running toppy.it
Facebook permissions asked by toppy.it
Toppy.it 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 toppy.it 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.
Email
Provides access to the User's primary email address.
Detailed information on the processing of Personal Data
Access to third-party accounts
This type of service allows toppy.it to access Data from your account on a third-party service and perform actions with it.
These services are not activated automatically, but require explicit authorization by the User.
Facebook account access
Company: Facebook, Inc.
Permissions asked: Email
This service allows toppy.it to connect with the User's account on the Facebook social network, provided by Facebook, Inc.
Permissions asked:
Email
Service provided by:
Facebook, Inc.
Category of Personal Information collected according to the CCPA
identifiers
LinkedIn account access
Company: LinkedIn Corporation
Place of processing: United States
Personal Data processed: Trackers +1
This service allows toppy.it to connect with the User's account on LinkedIn, provided by LinkedIn Corporation.
Category of Personal Information collected according to the CCPA
internet or other electronic network activity information
Advertising
This type of service allows User Data to be utilized for advertising communication purposes. These communications are displayed in the form of banners and other advertisements on toppy.it, possibly based on User interests.
This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.
Some of the services listed below may use Trackers to identify Users or they may use the behavioral retargeting technique, i.e. displaying ads tailored to the User’s interests and behavior, including those detected outside toppy.it. For more information, please check the privacy policies of the relevant services.
Services of this kind usually offer the possibility to opt out of such tracking. In addition to any opt-out feature offered by any of the services below, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section "How to opt-out of interest-based advertising" in this document.
Google AdSense
Company: Google LLC +1
Place of processing: United States +1
Personal Data processed: Cookies +1
Google AdSense is an advertising service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing. This service uses the “DoubleClick” Cookie, which tracks use of toppy.it and User behavior concerning ads, products and services offered.
Users may decide to disable all the DoubleClick Cookies by going to: Google Ad Settings.
Category of Personal Information collected according to the CCPA
internet or other electronic network activity information
This processing constitutes:
a Sale in California
a Sharing in California
Google Ads conversion tracking
Company: Google LLC +1
Place of processing: United States +1
Personal Data processed: Trackers +1
Google Ads conversion tracking is an analytics service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that connects data from the Google Ads advertising network with actions performed on toppy.it.
Category of Personal Information collected according to the CCPA
internet or other electronic network activity information
This processing constitutes:
a Sale in California
Hotjar Form Analysis & Conversion Funnels
Company: Hotjar Ltd.
Place of processing: Malta
Personal Data processed: Trackers +1
Hotjar is an analytics service provided by Hotjar Ltd.
Hotjar honors generic Do Not Track headers. This means your browser can tell its script not to collect any of your data. This is a setting that is available in all major browsers. Find Hotjar’s opt-out information here.
Category of Personal Information collected according to the CCPA
internet or other electronic network activity information
This processing constitutes:
a Sale in California
Google Ads Similar audiences
Company: Google Ireland Limited
Place of processing: Ireland
Personal Data processed: Tracker +1
Similar audiences is an advertising and behavioral targeting service provided by Google Ireland Limited that uses Data from Google Ads Remarketing in order to display ads to Users with similar behavior to Users who are already on the remarketing list due to their past use of toppy.it.
On the basis of this Data, personalized ads will be shown to Users suggested by Google Ads Similar audiences.
Users who don't want to be included in Similar audiences can opt out and disable the use of advertising cookies by going to: Google Ad Settings.
Category of Personal Information collected according to the CCPA
internet or other electronic network activity information
This processing constitutes:
a Sale in California
a Sharing in California
Google Ad Manager
Company: Google Ireland Limited
Place of processing: Ireland
Personal Data processed: Tracker +1
Google Ad Manager is an advertising service provided by Google Ireland Limited that allows the Owner to run advertising campaigns in conjunction with external advertising networks that the Owner, unless otherwise specified in this document, has no direct relationship with.
In order to opt out from being tracked by various advertising networks, Users may make use of Youronlinechoices. In order to understand Google's use of data, consult Google's partner policy.
This service uses the “DoubleClick” Cookie, which tracks use of toppy.it and User behavior concerning ads, products and services offered.
Users may decide to disable all the DoubleClick Cookies by going to: Google Ad Settings.
Category of Personal Information collected according to the CCPA
internet or other electronic network activity information
This processing constitutes:
a Sale in California
a Sharing in California
Analytics
The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.
Google Analytics (Universal Analytics)
Company: Google Ireland Limited
Place of processing: Ireland
Personal Data processed: Cookies +1
Google Analytics (Universal Analytics) is a web analysis service provided by Google Ireland Limited (“Google”). Google utilizes the Data collected to track and examine the use of toppy.it, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
Category of Personal Information collected according to the CCPA
internet or other electronic network activity information
This processing constitutes:
a Sale in the United States
User ID extension for Google Analytics
Company: Google LLC +1
Place of processing: United States +1
Personal Data processed: Cookies
Google Analytics on toppy.it makes use of a feature called User ID. This setup allows for a more accurate tracking of Users by associating that User with the same ID over various sessions and devices. It is set up in a way that doesn’t allow Google to personally identify an individual or permanently identify a particular device.
The User ID extension might make it possible to connect Data from Google Analytics with other Data about the User collected by toppy.it.
The opt-out link below will only opt you out for the device you are on, but not from tracking performed independently by the Owner. Contact the Owner via the email address provided in this privacy policy to object to the aforementioned tracking as well.
Category of Personal Information collected according to the CCPA
internet or other electronic network activity information
This processing constitutes:
a Sale in California
Analytics collected directly
Company: toppy.it
Personal Data processed: Cookies +1
Toppy.it uses an internal analytics system that does not involve third parties.
Personal Data processed:
Cookies
Usage Data
Service provided by:
toppy.it
Category of Personal Information collected according to the CCPA
internet or other electronic network activity information
Google Analytics Demographics and Interests reports
Company: Google LLC +1
Place of processing: United States +1
Personal Data processed: Cookies +1
Google Analytics Demographics and Interests reports is a Google Advertising Reporting feature that makes available demographic and interests Data inside Google Analytics for toppy.it (demographics means age and gender Data).
Users can opt out of Google's use of cookies by visiting Google's Ads Settings.
Personal Data processed:
Cookies
unique device identifiers for advertising (Google Advertiser ID or IDFA, for example)
Category of Personal Information collected according to the CCPA
identifiers
internet or other electronic network activity information
This processing constitutes:
a Sale in California
Google Analytics Advertising Reporting Features
Company: Google LLC +1
Place of processing: United States +1
Personal Data processed: Cookies +2
Google Analytics on toppy.it has Advertising Reporting Features activated, which collects additional information from the DoubleClick cookie (web activity) and from device advertising IDs (app activity). It allows the Owner to analyze specific behavior and interests Data (traffic Data and Users' ads interaction Data) and, if enabled, demographic Data (information about the age and gender).
Users can opt out of Google's use of cookies by visiting Google's Ads Settings.
Personal Data processed:
Cookies
unique device identifiers for advertising (Google Advertiser ID or IDFA, for example)
various types of Data as specified in the privacy policy of the service
Category of Personal Information collected according to the CCPA
internet or other electronic network activity information
This processing constitutes:
a Sale in California
Yandex Metrica
Company: YANDEX, LLC
Place of processing: Russian Federation
Personal Data processed: Cookies +1
Yandex Metrica is an analytics and heat mapping service provided by YANDEX, LLC.
Yandex Metrica can be used to display the areas of a page where Users most frequently move the mouse or click. This shows where the points of interest are.
Category of Personal Information collected according to the CCPA
internet or other electronic network activity information
This processing constitutes:
a Sale in California
Google Analytics 4
Company: Google Ireland Limited
Place of processing: Ireland
Personal Data processed: number of Users +3
Google Analytics 4 is a web analysis service provided by Google Ireland Limited (“Google”). Google utilizes the Data collected to track and examine the use of toppy.it, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
In Google Analytics 4, IP addresses are used at collection time and then discarded before Data is logged in any data center or server. Users can learn more by consulting Google’s official documentation.
Category of Personal Information collected according to the CCPA
internet or other electronic network activity information
This processing constitutes:
a Sale in the United States
Backup saving and management
This type of service allows the Owner to save and manage backups of toppy.it on external servers managed by the service provider itself. The backups may include the source code and content as well as the data that the User provides to toppy.it.
Backup on Google Drive
Company: Google LLC +1
Place of processing: United States +1
Personal Data processed: various types of Data as specified in the privacy policy of the service
Google Drive is a service to save and manage backups provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.
Personal Data processed:
various types of Data as specified in the privacy policy of the service
Category of Personal Information collected according to the CCPA
internet or other electronic network activity information
Building and running toppy.it
Key components of toppy.it are built and run directly by the Owner by making use of the software listed below.
WordPress (self-hosted)
Company: toppy.it
Personal Data processed: date of birth +1
Toppy.it is built and run by the Owner via a CMS software (Content Management System) called WordPress.
Personal Data processed:
date of birth
Usage Data
Service provided by:
toppy.it
Category of Personal Information collected according to the CCPA
identifiers
internet or other electronic network activity information
Contacting the User
Phone contact
Company: toppy.it
Personal Data processed: phone number
Users that provided their phone number might be contacted for commercial or promotional purposes related to toppy.it, as well as for fulfilling support requests.
Personal Data processed:
phone number
Service provided by:
toppy.it
Category of Personal Information collected according to the CCPA
identifiers
Mailing list or newsletter
Company: toppy.it
Personal Data processed: address +12
By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning toppy.it. Your email address might also be added to this list as a result of signing up to toppy.it or after making a purchase.
Personal Data processed:
address
city
company name
Cookies
country
county
email address
first name
last name
state
Usage Data
website
ZIP/Postal code
Service provided by:
toppy.it
Category of Personal Information collected according to the CCPA
identifiers
commercial information
internet or other electronic network activity information
This processing constitutes:
a Sale in Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island and Montana
Contact form
Company: toppy.it
Personal Data processed: address +11
By filling in the contact form with their Data, the User authorizes toppy.it to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.
Personal Data processed:
address
city
company name
country
county
email address
first name
last name
phone number
state
website
ZIP/Postal code
Service provided by:
toppy.it
Category of Personal Information collected according to the CCPA
identifiers
commercial information
internet or other electronic network activity information
Content performance and features testing (A/B testing)
The services contained in this section allow the Owner to track and analyze the User response concerning web traffic or behavior regarding changes to the structure, text or any other component of toppy.it.
Google Optimize
Company: Google LLC +1
Place of processing: United States +1
Personal Data processed: Cookies +1
Google Optimize is an A/B testing service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, ("Google").
Google may use Personal Data to contextualize and personalize the ads of its own advertising network.
Category of Personal Information collected according to the CCPA
internet or other electronic network activity information
This processing constitutes:
a Sale in California
Displaying content from external platforms
This type of service allows you to view content hosted on external platforms directly from the pages of toppy.it and interact with them.
This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.
Gravatar
Company: Automattic Inc.
Place of processing: United States
Personal Data processed: email address +1
Gravatar is an image visualization service provided by Automattic Inc. that allows toppy.it to incorporate content of this kind on its pages.
Please note that if Gravatar images are used for comment forms, the commenter's email address or parts of it may be sent to Gravatar - even if the commenter has not signed up for that service.
Category of Personal Information collected according to the CCPA
identifiers
internet or other electronic network activity information
This processing constitutes:
a Sale in California
Google Maps widget
Company: Google LLC +1
Place of processing: United States +1
Personal Data processed: Cookies +1
Google Maps is a maps visualization service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that allows toppy.it to incorporate content of this kind on its pages.
Category of Personal Information collected according to the CCPA
internet or other electronic network activity information
This processing constitutes:
a Sale in California
YouTube video widget
Company: Google LLC +1
Place of processing: United States +1
Personal Data processed: Cookies +1
YouTube is a video content visualization service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that allows toppy.it to incorporate content of this kind on its pages.
Category of Personal Information collected according to the CCPA
internet or other electronic network activity information
This processing constitutes:
a Sale in California
Google Site Search with AdSense
Company: Google LLC +1
Place of processing: United States +1
Personal Data processed: Cookies +1
Google Site Search is a search engine embedding service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that allows toppy.it to incorporate content of this kind on its pages.
Google Site Search may display AdSense advertisements. For details of which data are collected, please refer to the privacy policy of this service.
Category of Personal Information collected according to the CCPA
internet or other electronic network activity information
This processing constitutes:
a Sale in California
Google Fonts
Company: Google LLC +1
Place of processing: United States +1
Personal Data processed: Usage Data +1
Google Fonts is a typeface visualization service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that allows toppy.it to incorporate content of this kind on its pages.
Personal Data processed:
Usage Data
various types of Data as specified in the privacy policy of the service
Category of Personal Information collected according to the CCPA
internet or other electronic network activity information
This processing constitutes:
a Sale in California
Google Programmable Search Engine
Company: Google LLC +1
Place of processing: United States +1
Personal Data processed: Cookies +1
Google Programmable Search Engine is a search engine embedding service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that allows toppy.it to incorporate content of this kind on its pages.
Category of Personal Information collected according to the CCPA
internet or other electronic network activity information
This processing constitutes:
a Sale in California
Handling activity data
This type of service allows the Owner to use the activity data collected by your device in order for toppy.it to operate or to provide specific features. This may include movements, heartbeat, change in altitude or data about the surroundings.
Depending on what is described below, third parties may be involved in the activity tracking.
Most devices allow for the User to control which Data is accessed or stored.
Activity data tracked by your device
Company: toppy.it
Personal Data processed: movement activity
Toppy.it uses some activity data tracked by your device to operate or to provide specific features.
Personal Data processed:
movement activity
Service provided by:
toppy.it
Category of Personal Information collected according to the CCPA
biometric information
Heat mapping and session recording
Heat mapping services are used to display the areas of toppy.it that Users interact with most frequently. This shows where the points of interest are. These services make it possible to monitor and analyze web traffic and keep track of User behavior.
Some of these services may record sessions and make them available for later visual playback.
Hotjar Heat Maps & Recordings
Company: Hotjar Ltd.
Place of processing: Malta
Personal Data processed: Tracker +2
Hotjar is a session recording and heat mapping service provided by Hotjar Ltd.
Hotjar honors generic „Do Not Track” headers. This means the browser can tell its script not to collect any of the User's data. This is a setting that is available in all major browsers. Find Hotjar’s opt-out information here.
Personal Data processed:
Tracker
Usage Data
various types of Data as specified in the privacy policy of the service
Category of Personal Information collected according to the CCPA
internet or other electronic network activity information
This processing constitutes:
a Sale in California
Microsoft Clarity
Company: Microsoft Corporation
Place of processing: United States
Personal Data processed: clicks +4
Microsoft Clarity is a session recording and heat mapping service provided by Microsoft Corporation.
Microsoft processes or receives Personal Data via Microsoft Clarity, which in turn may be used for any purpose in accordance with the Microsoft Privacy Statement, including improving and providing Microsoft Advertising.
Category of Personal Information collected according to the CCPA
internet or other electronic network activity information
Hosting and backend infrastructure
This type of service has the purpose of hosting Data and files that enable toppy.it to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of toppy.it.
Some services among those listed below, if any, may work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
ArubaCloud
Company: Aruba S.p.A.
Place of processing: Italy
Personal Data processed: various types of Data as specified in the privacy policy of the service
ArubaCloud is a hosting service provided by Aruba S.p.A.
Personal Data processed:
various types of Data as specified in the privacy policy of the service
Category of Personal Information collected according to the CCPA
internet or other electronic network activity information
Infrastructure monitoring
This type of service allows toppy.it to monitor the use and behavior of its components so its performance, operation, maintenance and troubleshooting can be improved.
Which Personal Data are processed depends on the characteristics and mode of implementation of these services, whose function is to filter the activities of toppy.it.
Sentry
Company: Functional Software, Inc.
Place of processing: United States
Personal Data processed: various types of Data as specified in the privacy policy of the service
Sentry is a monitoring service provided by Functional Software, Inc. .
Personal Data processed:
various types of Data as specified in the privacy policy of the service
Category of Personal Information collected according to the CCPA
identifiers
Interaction with data collection platforms and other third parties
This type of service allows Users to interact with data collection platforms or other services directly from the pages of toppy.it for the purpose of saving and reusing data.
If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service.
Mailchimp widget
Company: The Rocket Science Group LLC
Place of processing: United States
Personal Data processed: Cookies +5
The Mailchimp widget is a service for interacting with the Mailchimp email address management and message sending service provided by The Rocket Science Group LLC.
Category of Personal Information collected according to the CCPA
identifiers
internet or other electronic network activity information
This processing constitutes:
a Sale in California
a Sharing in California
Interaction with external social networks and platforms
This type of service allows interaction with social networks or other external platforms directly from the pages of toppy.it.
The interaction and information obtained through toppy.it are always subject to the User’s privacy settings for each social network.
This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it.
It is recommended to log out from the respective services in order to make sure that the processed data on toppy.it isn’t being connected back to the User’s profile.
Google+ +1 button and social widgets
Company: Google LLC
Place of processing: United States
Personal Data processed: Cookies +1
The Google+ +1 button and social widgets are services allowing interaction with the Google+ social network provided by Google LLC.
Category of Personal Information collected according to the CCPA
internet or other electronic network activity information
This processing constitutes:
a Sale in California
YouTube button and social widgets
Company: Google LLC +1
Place of processing: United States +1
Personal Data processed: Usage Data
The YouTube button and social widgets are services allowing interaction with the YouTube social network provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.
Category of Personal Information collected according to the CCPA
internet or other electronic network activity information
This processing constitutes:
a Sale in California
Interaction with live chat platforms
This type of service allows Users to interact with third-party live chat platforms directly from the pages of toppy.it, for contacting and being contacted by toppy.it support service.
If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service. Moreover, live chat conversations may be logged.
LiveChat Widget
Company: LiveChat, Inc.
Place of processing: United States
Personal Data processed: Cookies +2
The LiveChat Widget is a service for interacting with the LiveChat live chat platform provided by LiveChat, Inc.
Category of Personal Information collected according to the CCPA
identifiers
internet or other electronic network activity information
audio, electronic, visual, thermal, olfactory, or similar information
inferences drawn from other personal information
This processing constitutes:
a Sale in the United States
a Sharing in California
Location-based interactions
Non-continuous geolocation
Company: toppy.it
Personal Data processed: geographic position
Toppy.it may collect, use, and share User location Data in order to provide location-based services.
Most browsers and devices provide tools to opt out from this feature by default. If explicit authorization has been provided, the User’s location data may be tracked by toppy.it.
The geographic location of the User is determined in a manner that isn't continuous, either at the specific request of the User or when the User doesn't point out its current location in the appropriate field and allows the application to detect the position automatically.
Personal Data processed:
geographic position
Service provided by:
toppy.it
Category of Personal Information collected according to the CCPA
geolocation data
This processing constitutes:
a Sharing in California
Managing contacts and sending messages
This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.
Mailjet
Company: SAS Mailjet
Place of processing: France
Personal Data processed: address +5
Mailjet is an email address management and message sending service provided by SAS Mailjet.
Category of Personal Information collected according to the CCPA
identifiers
commercial information
This processing constitutes:
a Sale in California
a Sharing in California
Platform services and hosting
These services have the purpose of hosting and running key components of toppy.it, therefore allowing the provision of toppy.it from within a unified platform. Such platforms provide a wide range of tools to the Owner – e.g. analytics, user registration, commenting, database management, e-commerce, payment processing – that imply the collection and handling of Personal Data.
Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
Blogger
Company: Google LLC +1
Place of processing: United States +1
Personal Data processed: various types of Data as specified in the privacy policy of the service
Blogger is a platform provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that allows the Owner to build, run and host toppy.it.
Personal Data processed:
various types of Data as specified in the privacy policy of the service
Category of Personal Information collected according to the CCPA
internet or other electronic network activity information
This processing constitutes:
a Sale in California
WooCommerce
Company: toppy.it
Personal Data processed: billing address +9
WooCommerce is a WordPress plugin used by toppy.it that allows the Owner to build and run an e-commerce website.
Personal Data processed:
billing address
data relating to the point of sale
email address
name
order ID
payment info
phone number
shipping address
Trackers
Usage Data
Service provided by:
toppy.it
Category of Personal Information collected according to the CCPA
identifiers
commercial information
internet or other electronic network activity information
Registration and authentication
By registering or authenticating, Users allow toppy.it to identify them and give them access to dedicated services.
Depending on what is described below, third parties may provide registration and authentication services. In this case, toppy.it will be able to access some Data, stored by these third-party services, for registration or identification purposes.
Google OAuth
Company: Google LLC +1
Place of processing: United States +1
Personal Data processed: various types of Data as specified in the privacy policy of the service
Google OAuth is a registration and authentication service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, and is connected to the Google network.
Personal Data processed:
various types of Data as specified in the privacy policy of the service
Category of Personal Information collected according to the CCPA
internet or other electronic network activity information
This processing constitutes:
a Sale in the United States
YouTube OAuth
Company: Google LLC +1
Place of processing: United States +1
Personal Data processed: various types of Data as specified in the privacy policy of the service
YouTube OAuth is a registration and authentication service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, and is connected to the YouTube network.
Personal Data processed:
various types of Data as specified in the privacy policy of the service
Category of Personal Information collected according to the CCPA
internet or other electronic network activity information
This processing constitutes:
a Sale in California
Remarketing and behavioral targeting
This type of service allows toppy.it and its partners to inform, optimize and serve advertising based on past use of toppy.it by the User.
This activity is facilitated by tracking Usage Data and by using Trackers to collect information which is then transferred to the partners that manage the remarketing and behavioral targeting activity.
Some services offer a remarketing option based on email address lists.
In addition to any opt-out feature provided by any of the services below, Users may opt out by visiting the Network Advertising Initiative opt-out page.
Users may also opt-out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.
Remarketing with Google Analytics
Company: Google LLC +1
Place of processing: United States +1
Personal Data processed: Cookies +1
Remarketing with Google Analytics is a remarketing and behavioral targeting service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that connects the tracking activity performed by Google Analytics and its Cookies with the Google Ads advertising network and the Doubleclick Cookie.
Category of Personal Information collected according to the CCPA
internet or other electronic network activity information
This processing constitutes:
a Sale in California
a Sharing in California
Google Ads Remarketing
Company: Google LLC +1
Place of processing: United States +1
Personal Data processed: Cookies +1
Google Ads Remarketing is a remarketing and behavioral targeting service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that connects the activity of toppy.it with the Google Ads advertising network and the DoubleClick Cookie.
Users can opt out of Google's use of cookies for ads personalization by visiting Google's Ads Settings.
Category of Personal Information collected according to the CCPA
internet or other electronic network activity information
This processing constitutes:
a Sale in California
a Sharing in California
Google Ad Manager Audience Extension
Company: Google Ireland Limited
Place of processing: Ireland
Personal Data processed: Tracker +1
Google Ad Manager Audience Extension is a remarketing and behavioral targeting service provided by Google Ireland Limited that tracks the visitors of toppy.it and allows selected advertising partners to display targeted ads across the web to them.
Category of Personal Information collected according to the CCPA
internet or other electronic network activity information
This processing constitutes:
a Sale in California
a Sharing in California
LinkedIn Website Retargeting
Company: LinkedIn Corporation
Place of processing: United States
Personal Data processed: Trackers +1
LinkedIn Website Retargeting is a remarketing and behavioral targeting service provided by LinkedIn Corporation that connects the activity of toppy.it with the LinkedIn advertising network.
Category of Personal Information collected according to the CCPA
internet or other electronic network activity information
SPAM protection
This type of service analyzes the traffic of toppy.it, potentially containing Users' Personal Data, with the purpose of filtering it from parts of traffic, messages and content that are recognized as SPAM.
Google reCAPTCHA
Company: Google Ireland Limited
Place of processing: Ireland
Personal Data processed: Tracker +1
Google reCAPTCHA is a SPAM protection service provided by Google Ireland Limited.
The use of reCAPTCHA is subject to the Google privacy policy and terms of use.
Category of Personal Information collected according to the CCPA
internet or other electronic network activity information
Tag Management
This type of service helps the Owner to manage the tags or scripts needed on toppy.it in a centralized fashion.
This results in the Users' Data flowing through these services, potentially resulting in the retention of this Data.
Google Tag Manager
Company: Google LLC +1
Place of processing: United States +1
Personal Data processed: Usage Data
Google Tag Manager is a tag management service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.
Category of Personal Information collected according to the CCPA
internet or other electronic network activity information
This processing constitutes:
a Sale in California
User database management
This type of service allows the Owner to build user profiles by starting from an email address, a personal name, or other information that the User provides to toppy.it, as well as to track User activities through analytics features. This Personal Data may also be matched with publicly available information about the User (such as social networks' profiles) and used to build private profiles that the Owner can display and use for improving toppy.it.
Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions performed on toppy.it.
ActiveCampaign
Company: ActiveCampaign, Inc.
Place of processing: United States
Personal Data processed: email address +1
ActiveCampaign is a User database management service provided by ActiveCampaign, Inc.
Category of Personal Information collected according to the CCPA
identifiers
internet or other electronic network activity information
Information on opting out of interest-based advertising
In addition to any opt-out feature provided by
any of the services listed in this document, Users may learn more on
how to generally opt out of interest-based advertising within the
dedicated section of the Cookie Policy.
Further information about the processing of Personal Data
Push notifications
Toppy.it may send push notifications to the User to achieve the purposes outlined in this privacy policy.
Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then change those settings for toppy.it, some or all of the apps on the particular device.
Users must be aware that disabling push notifications may negatively affect the utility of toppy.it.
Push notifications based on the User's geographic location
Toppy.it may use the User's geographic location to send push notifications for the purposes outlined in this privacy policy.
Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then changing those settings for some or all of the apps on the particular device.
Users must be aware that disabling push notifications may negatively affect the utility of toppy.it.
Push notifications for direct marketing
Toppy.it may send push notifications to the User for the purpose of direct marketing (to propose services and products provided by third parties or unrelated to the product or service provided by toppy.it).
Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then changing those settings for toppy.it or all of the apps on the particular device.
Users must be aware that disabling push notifications may negatively affect the utility of toppy.it.
Besides applicable device settings, the User may also make use of the rights described under User rights in the relevant section of this privacy policy.
Cookie Policy
Toppy.it uses Trackers. To learn more, Users may consult the Cookie Policy.
Further Information for Users in the European Union
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.
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.
Further information about retention time
Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.
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 fulfil a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right of 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 rights of Users based on the General Data Protection Regulation (GDPR)
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following, to the extent permitted by law:
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.
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 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 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.
Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Users are also entitled to learn about the legal basis for Data transfers abroad including 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.
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, free of charge and without providing any justification. Where the User objects to processing for direct marketing purposes, the Personal Data will no longer be processed for such purposes. 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 dedicated online form or the contact details provided in this document. Such requests are free of charge and will be answered by the Owner as early as possible and always within one month, providing Users with the information required by law. Any rectification or erasure of Personal Data or restriction of processing will be communicated by the Owner to each recipient, if any, to whom the Personal Data has been disclosed unless this proves impossible or involves disproportionate effort. At the Users’ request, the Owner will inform them about those recipients.
Further information for Users
in Switzerland
This section applies to Users in Switzerland, and, for such Users, supersedes any other possibly divergent or conflicting information contained in the privacy policy.
Further details regarding the categories of Data processed, the purposes of processing, the categories of recipients of the personal data, if any, the retention period and further information about Personal Data can be found in the section titled “Detailed information on the processing of Personal Data” within this document.
The rights of Users according to the Swiss Federal Act on Data Protection
Users may exercise certain rights regarding their Data within the limits of law, including the following:
right of access to Personal Data;
right to object to the processing of their Personal Data (which also allows Users to demand that processing of Personal Data be restricted, Personal Data be deleted or destroyed, specific disclosures of Personal Data to third parties be prohibited);
right to receive their Personal Data and have it transferred to another controller (data portability);
right to ask for incorrect Personal Data to be corrected.
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the dedicated online form or the contact details provided in this document. Such requests are free of charge and will be answered by the Owner as early as possible, providing Users with the information required by law.
Further information for Users
in Brazil
This section of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the entity running toppy.it and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”). This section applies to all Users in Brazil (Users are referred to below, simply as “you”, “your”, “yours”), according to the "Lei Geral de Proteção de Dados" (the "LGPD"), and for such Users, it supersedes any other possibly divergent or conflicting information contained in the privacy policy. This part of the document uses the term “personal information“ as it is defined in the LGPD.
The grounds on which we process your personal information
We can process your personal information solely if we have a legal basis for such processing. Legal bases are as follows:
your consent to the relevant processing activities;
compliance with a legal or regulatory obligation that lies with us;
the carrying out of public policies provided in laws or regulations or based on contracts, agreements and similar legal instruments;
studies conducted by research entities, preferably carried out on anonymized personal information;
the carrying out of a contract and its preliminary procedures, in cases where you are a party to said contract;
the exercising of our rights in judicial, administrative or arbitration procedures;
protection or physical safety of yourself or a third party;
the protection of health – in procedures carried out by health entities or professionals;
our legitimate interests, provided that your fundamental rights and liberties do not prevail over such interests; and
credit protection.
To find out more about the legal bases, you can contact us at any time using the contact details provided in this document.
Categories of personal information processed
To find out what categories of your personal information are processed, you can read the section titled “Detailed information on the processing of Personal Data” within this document.
Why we process your personal information
To find out why we process your personal information, you can read the sections titled “Detailed information on the processing of Personal Data” and “The purposes of processing” within this document.
Your Brazilian privacy rights, how to file a request and our response to your requests
Your Brazilian privacy rights
You have the right to:
obtain confirmation of the existence of processing activities on your personal information;
access to your personal information;
have incomplete, inaccurate or outdated personal information rectified;
obtain the anonymization, blocking or elimination of your unnecessary or excessive personal information, or of information that is not being processed in compliance with the LGPD;
obtain information on the possibility to provide or deny your consent and the consequences thereof;
obtain information about the third parties with whom we share your personal information;
obtain, upon your express request, the portability of your personal information (except for anonymized information) to another service or product provider, provided that our commercial and industrial secrets are safeguarded;
obtain the deletion of your personal information being processed if the processing was based upon your consent, unless one or more exceptions provided for in art. 16 of the LGPD apply;
revoke your consent at any time;
lodge a complaint related to your personal information with the ANPD (the National Data Protection Authority) or with consumer protection bodies;
oppose a processing activity in cases where the processing is not carried out in compliance with the provisions of the law;
request clear and adequate information regarding the criteria and procedures used for an automated decision; and
request the review of decisions made solely on the basis of the automated processing of your personal information, which affect your interests. These include decisions to define your personal, professional, consumer and credit profile, or aspects of your personality.
You will never be discriminated against, or otherwise suffer any sort of detriment, if you exercise your rights.
How to file your request
You can file your express request to exercise your rights free from any charge, at any time, by using the contact details provided in this document, or via your legal representative.
How and when we will respond to your request
We will strive to promptly respond to your requests. In any case, should it be impossible for us to do so, we’ll make sure to communicate to you the factual or legal reasons that prevent us from immediately, or otherwise ever, complying with your requests. In cases where we are not processing your personal information, we will indicate to you the physical or legal person to whom you should address your requests, if we are in the position to do so.
In the event that you file an access or personal information processing confirmation request, please make sure that you specify whether you’d like your personal information to be delivered in electronic or printed form. You will also need to let us know whether you want us to answer your request immediately, in which case we will answer in a simplified fashion, or if you need a complete disclosure instead. In the latter case, we’ll respond within 15 days from the time of your request, providing you with all the information on the origin of your personal information, confirmation on whether or not records exist, any criteria used for the processing and the purposes of the processing, while safeguarding our commercial and industrial secrets.
In the event that you file a rectification, deletion, anonymization or personal information blocking request, we will make sure to immediately communicate your request to other parties with whom we have shared your personal information in order to enable such third parties to also comply with your request — except in cases where such communication is proven impossible or involves disproportionate effort on our side.
Transfer of personal information outside of Brazil permitted by the law
We are allowed to transfer your personal information outside of the Brazilian territory in the following cases:
when the transfer is necessary for international legal cooperation between public intelligence, investigation and prosecution bodies, according to the legal means provided by the international law;
when the transfer is necessary to protect your life or physical security or those of a third party;
when the transfer is authorized by the ANPD;
when the transfer results from a commitment undertaken in an international cooperation agreement;
when the transfer is necessary for the execution of a public policy or legal attribution of public service;
when the transfer is necessary for compliance with a legal or regulatory obligation, the carrying out of a contract or preliminary procedures related to a contract, or the regular exercise of rights in judicial, administrative or arbitration procedures.
Further information for Users
in the United States
This part of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the business running toppy.it and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).
The information contained in this section applies to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are residents in the following states: California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island and Montana.
For such Users, this information supersedes any other possibly divergent or conflicting provisions contained in the privacy policy.
This part of the document uses the term Personal Information
(and Sensitive Personal Information).
Notice at collection
The following Notice at collection provides you with timely notice about the categories of Personal Information collected or disclosed in the past 12 months so that you can exercise meaningful control over our use of that Information.
While such categorization of Personal Information is mainly based on California privacy laws, it can also be helpful for anyone who is not a California resident to get a general idea of what types of Personal Information are collected.
Internet or other electronic network activity information
Sold or Shared
Targeted Advertising
Personal Data processed: Cookies; Usage data; Data communicated while using the service; Email address + 32
Personal Information collected or disclosed:
Cookies
Usage Data
Data communicated while using the service
email address
first name
last name
county
state
country
ZIP/Postal code
city
address
company name
website
phone number
various types of Data as specified in the privacy policy of the service
Trackers
unique device identifiers for advertising (Google Advertiser ID or IDFA, for example)
Tracker
number of Users
session statistics
answers to questions
user content
profile picture
date of the message
time the message was sent
sender of the message
session duration
clicks
interaction events
date of birth
billing address
shipping address
name
order ID
data relating to the point of sale
Sensitive Personal Information collected or disclosed
contents of the email or message, payment info
Purposes:
Interaction with live chat platforms
Contacting the User
Displaying content from external platforms
Hosting and backend infrastructure
Interaction with data collection platforms and other third parties
Interaction with external social networks and platforms
Analytics
Platform services and hosting
Registration and authentication
Advertising
Content performance and features testing (A/B testing)
Remarketing and behavioral targeting
Backup saving and management
Further information about Personal Data
Tag Management
Heat mapping and session recording
SPAM protection
User database management
Access to third-party accounts
Building and running toppy.it
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared:
Yes
Targeted Advertising:
Yes
Third-parties:
LiveChat, Inc., Automattic Inc., Google LLC, Aruba S.p.A., The Rocket Science Group LLC, LinkedIn Corporation, Facebook, Inc., X Corp., Pinterest, Tumblr Inc., Google Ireland Limited, YANDEX, LLC, Monotype Imaging Inc., Fonticons, Inc. , Hotjar Ltd., Meta Platforms, Inc., ActiveCampaign, Inc., Microsoft Corporation, toppy.it, SiteGround Hosting Ltd.
Service providers or contractors:
toppy.it
Identifiers
Sold or Shared
Targeted Advertising
Personal Data processed: Phone number; Email address; First name; Last name + 27
Personal Information collected or disclosed:
phone number
email address
first name
last name
Cookies
Usage Data
county
state
country
ZIP/Postal code
city
address
company name
website
Email
unique device identifiers for advertising (Google Advertiser ID or IDFA, for example)
various types of Data as specified in the privacy policy of the service
Data communicated while using the service
answers to questions
user content
profile picture
date of the message
time the message was sent
sender of the message
Trackers
date of birth
billing address
shipping address
name
order ID
data relating to the point of sale
Sensitive Personal Information collected or disclosed
contents of the email or message, payment info
Purposes:
Contacting the User
Displaying content from external platforms
Interaction with data collection platforms and other third parties
Access to third-party accounts
Analytics
Managing contacts and sending messages
Interaction with live chat platforms
User database management
Infrastructure monitoring
Building and running toppy.it
Platform services and hosting
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared:
Yes
Targeted Advertising:
Yes
Third-parties:
Automattic Inc., The Rocket Science Group LLC, Facebook, Inc., Google LLC, SAS Mailjet, Meta Platforms, Inc., ActiveCampaign, Inc., Functional Software, Inc. , toppy.it
Service providers or contractors:
toppy.it
Commercial information
Sold or Shared
Targeted Advertising
Personal Data processed: Email address; First name; Last name; Cookies + 16
Personal Information collected or disclosed:
email address
first name
last name
Cookies
Usage Data
county
state
country
ZIP/Postal code
city
address
company name
website
phone number
Trackers
billing address
shipping address
name
order ID
data relating to the point of sale
Sensitive Personal Information collected or disclosed
payment info
Purposes:
Contacting the User
Managing contacts and sending messages
Platform services and hosting
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared:
Yes
Targeted Advertising:
Yes
Third-parties:
SAS Mailjet, toppy.it
Service providers or contractors:
toppy.it
Biometric information
Sold or Shared
Targeted Advertising
Personal Data processed:
Personal Information collected or disclosed:
Sensitive Personal Information collected or disclosed
movement activity
Purposes:
Handling activity data
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared:
Yes
Targeted Advertising:
Yes
Service providers or contractors:
toppy.it
Geolocation data
Sold or Shared
Targeted Advertising
Personal Data processed: Geographic position
Personal Information collected or disclosed:
geographic position
Purposes:
Location-based interactions
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared:
Yes
Targeted Advertising:
Yes
Service providers or contractors:
toppy.it
Audio, electronic, visual, thermal, olfactory, or similar information
Sold or Shared
Targeted Advertising
Personal Data processed: First name; Last name; Phone number; Data communicated while using the service + 6
Personal Information collected or disclosed:
first name
last name
phone number
Data communicated while using the service
answers to questions
user content
profile picture
date of the message
time the message was sent
sender of the message
Sensitive Personal Information collected or disclosed
contents of the email or message
Purposes:
Interaction with live chat platforms
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared:
Yes
Targeted Advertising:
Yes
Third-parties:
Meta Platforms, Inc.
Inferences drawn from other personal information
Sold or Shared
Targeted Advertising
Personal Data processed: First name; Last name; Phone number; Data communicated while using the service + 6
Personal Information collected or disclosed:
first name
last name
phone number
Data communicated while using the service
answers to questions
user content
profile picture
date of the message
time the message was sent
sender of the message
Sensitive Personal Information collected or disclosed
To know more about your rights in particular to opt out of certain processing activities and to limit the use of your sensitive personal information (“Limit the Use of My Sensitive Personal Information”) you can refer to the “Your privacy rights under US state laws” section of our privacy policy.
We won’t process your Information for unexpected purposes, or for purposes that are not reasonably necessary to and compatible with the purposes originally disclosed, without your consent.
What are the sources of the Personal Information we collect?
We collect the above-mentioned categories of Personal Information, either directly or indirectly, from you when you use toppy.it.
For example, you directly provide your Personal Information when you submit requests via any forms on toppy.it. You also provide Personal Information indirectly when you navigate toppy.it, as Personal Information about you is automatically observed and collected.
Finally, we may collect your Personal Information from third parties that work with us in connection with the Service or with the functioning of toppy.it and features thereof.
Your privacy rights under US state laws
You may exercise certain rights regarding your Personal Information. In particular, to the extent permitted by applicable law, you have:
the right to access Personal Information: the right to know. You have the right to request that we confirm whether or not we are processing your Personal Information. You also have the right to access such Personal Information;
the right to correct inaccurate Personal Information. You have the right to request that we correct any inaccurate Personal Information we maintain about you;
the right to request the deletion of your Personal Information. You have the right to request that we delete any of your Personal Information;
the right to obtain a copy of your Personal Information. We will provide your Personal Information in a portable and usable format that allows you to transfer data easily to another entity – provided that this is technically feasible;
the right to opt out from the Sale of your Personal Information; We will not discriminate against you for exercising your privacy rights.
the right to non-discrimination.
Additional rights for Users residing in California
In addition to the rights listed above common to all Users in the United States, as a User residing in California, you have:
The right to opt out of the Sharing of your Personal Information for cross-context behavioral advertising;
The right to request to limit our use or disclosure of your Sensitive Personal Information to only that which is necessary to perform the services or provide the goods, as is reasonably expected by an average consumer. Please note that certain exceptions outlined in the law may apply, such as, when the collection and processing of Sensitive Personal Information is necessary to verify or maintain the quality or safety of our service.
Additional rights for Users residing in Virginia, Colorado, Connecticut, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island and Montana
In addition to the rights listed above common to all Users in the United States, as a User residing in Virginia, Colorado, Connecticut, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island and Montana you have
The right to opt out of the processing of your personal information for Targeted Advertising or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you;
The right to freely give, deny or withdraw your consent for the processing of your Sensitive Personal Information. Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and processing of Sensitive Personal Information is necessary for the provision of a product or service specifically requested by the consumer. In Maryland, your Sensitive Personal Information will be collected or processed only if strictly necessary to provide or maintain a specific product or service requested by you.
In Minnesota and Maryland Users also have the right to obtain a list of the specific third parties to which the controller has disclosed the consumer's personal data
* Note that in some states like Minnesota you have the following specific rights connected to profiling:
The right to question the results of the profiling;
The right to be informed of the reason that the profiling resulted in the decision; if feasible
The right to be informed of what actions the consumer might have taken to secure a different decision and the actions that the consumer might take to secure a different decision in the future;
The right to review personal data used in the profiling;
If inaccurate, the right to have the data corrected and the profiling decision reevaluated based on the corrected data;
Additional rights for users residing in Utah and Iowa
In addition to the rights listed above common to all Users in the United States, as a User residing in Utah and Iowa, you have:
The right to opt out of the processing of your Personal Information for Targeted Advertising;
The right to opt out of the processing of your Sensitive Personal Information. Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and processing of Sensitive Personal Information is necessary for the provision of a product or service specifically requested by the consumer.
How to exercise your privacy rights under US state laws
To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided in this document.
For us to respond to your request, we must know who you are. We will not respond to any request if we are unable to verify your identity and therefore confirm the Personal Information in our possession relates to you. You are not required to create an account with us to submit your request. We will use any Personal Information collected from you in connection with the verification of your request solely for verification and shall not further disclose the Personal Information, retain it longer than necessary for purposes of verification, or use it for unrelated purposes.
If you are an adult, you can make a request on behalf of a child under your parental authority.
How to exercise your rights to opt out
In addition to what is stated above, to exercise your right to opt-out of Sale or Sharing and Targeted Advertising you can also use the privacy choices link provided on toppy.it.
If you want to submit requests to opt out of Sale or Sharing and Targeted Advertising activities via a user-enabled global privacy control, such as for example the Global Privacy Control (“GPC”), you are free to do so and we will abide by such request in a frictionless manner.
How and when we are expected to handle your request
We will respond to your request without undue delay, but in all cases within the timeframe required by applicable law. Should we need more time, we will explain to you the reasons why, and how much more time we need.
Should we deny your request, we will explain to you the reasons behind our denial (where envisaged by applicable law you may then contact the relevant authority to submit a complaint).
We do not charge a fee to process or respond to your request unless such request is manifestly unfounded or excessive and in all other cases where it is permitted by the applicable law. In such cases, we may charge a reasonable fee or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind them.
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 toppy.it 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, toppy.it 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, toppy.it and any third-party services may collect files that record interaction with toppy.it (System logs) or 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.
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 toppy.it 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.
Definitions and legal references
Personal Data (or Data)
/ Personal Information (or Information)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Sensitive Personal Information
Sensitive Personal Information means any Personal Information that is not publicly available and reveals information considered sensitive according to the applicable privacy law.
Usage Data
Information collected automatically through toppy.it (or third-party services employed in toppy.it), which can include: the IP addresses or domain names of the computers utilized by the Users who use toppy.it, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.
User
The individual using toppy.it who, unless otherwise specified, coincides with the Data Subject.
Data Subject
The natural person to whom the Personal Data refers.
Data Processor (or Processor)
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.
Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of toppy.it. The Data Controller, unless otherwise specified, is the Owner of toppy.it.
toppy.it (or this Application)
The means by which the Personal Data of the User is collected and processed.
Service
The service provided by toppy.it as described in the relative terms (if available) and on this site/application.
Sale
Sale means any exchange of Personal Information by the Owner to a third party, for monetary or other valuable consideration, as defined by the applicable privacy US state law. Please note that the exchange of Personal Information with a service provider pursuant to a written contract that meets the requirements set by the applicable law, does not constitute a Sale of your Personal Information.
Sharing
Sharing means any sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's Personal Information by the business to a third party for cross-context behavioral advertising, whether for monetary or other valuable consideration, including transactions between a business and a third party for cross-context behavioral advertising for the benefit of a business in which no money is exchanged, as defined by the California privacy laws. Please note that the exchange of Personal Information with a service provider pursuant to a written contract that meets the requirements set by the California privacy laws, does not constitute sharing of your Personal Information.
Targeted advertising
Targeted advertising means displaying advertisements to a consumer where the advertisement is selected based on Personal Information obtained from that consumer’s activities over time and across nonaffiliated websites or online applications to predict such consumer’s preferences or interests, as defined by the applicable privacy US state law.
European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Cookie
Cookies are Trackers consisting of small sets of data stored in the User's browser.
Tracker
Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on the User’s device.
Legal information
This policy has been prepared based on provisions of multiple legislations.
This policy relates solely to toppy.it, if not stated otherwise within this document.
