(1) Purposes of data processing
The Users’ personal data will be processed by TOP for the following processing purposes:
(a) contractual obligations (Article 24, paragraph 1, letter b) of the Privacy Code), i.e. in order to give execution to the general conditions of the Website, being accepted by the User during the registration process, as well as fulfil specific requests of the User. Subject to the User giving TOP a specific and optional consent to its data processing for marketing purposes pursuant to paragraph 2 below, any contact data (name, surname, email address) will be used by TOP for the sole purpose of ascertaining the identity of the relevant User (also by means of validation of the email address), avoiding frauds or infringements, and contact the User only for services reasons;
(b) accounting-administrative purposes (Article 24, paragraph 1, letter 1-ter) of the Privacy Code), i.e. in order to carry out organisational, administrative, financial and accounting activities, as internal organisational activities and activities aimed at fulfilling contractual and pre-contractual obligations;
(c) legal obligations (Article 24, paragraph 1, letter a) of the Privacy Code), or in order to fulfil obligations provided by the law or the European laws and regulations.
Providing the personal data for the processing purposes specified above is optional but necessary, since failing to provide the same imply the impossibility to register to the Website. A star in the registration form identifies the personal data, which are necessary for purporting the processing purposes described under this paragraph 1.
(2) Purposes of data processing: marketing (dispatch of marketing material, direct sale and commercial communication)
With the free and optional User’s consent, some User’s personal data (name, surname and email address) may be processed by TOP also for marketing purposes (dispatch of marketing material, direct sale and commercial communication) or in order for TOP to contact the relevant User by means of email for proposing to the same to purchase products and/or services offered by TOP and/or third parties companies, present offers, promotions and commercial opportunities.
Giving consent to personal data processing for such purpose is free and optional and, in the event such consent is missing, the possibility to register to the Website is not prevented in any manner whatsoever. In the event that such consent has been granted, the relevant User may revoke the same at any time whatsoever upon request to TOP pursuant to the methods specified under paragraph 5 below. The relevant User may also easily oppose to the sending of further marketing communications (by email) also clicking on the specific revocation link for revoking the consent, which is included in each marketing email. Once revoked the consent, TOP will send to the User an email message in order to confirm that the consent has been actually revoked.
TOP hereby informs that, following the exercise of the right to object to the sending of commercial communications via email, it is possible that the relevant User continues receiving further marketing messages due to technical and/or operative reasons (e.g. the contact list has already been formed before the receipt by TOP of the objection request). In the event that the relevant User continues receiving marketing messages once elapsed 24 hours from the exercise of the objection right, please flag such issue to TOP, using the contacts specified under paragraph 5 below.
(3) Processing methods
Users’ personal data processing will be carried out by manual and IT instruments, applying logics strictly connected to the purposes and, in any case, so that the safety and confidentiality of the relevant data is guaranteed.
(4) Data disclosure and dissemination
TOP’s employees and/or workers appointed to manage personal data may become aware of any Users’ personal data. Such subjects, who are formally appointed by TOP as “persons in charge for the processing”, will process the relevant User’s data exclusively for the purposes specified under this policy and in compliance with the provisions of the Privacy Code.
Furthermore, third parties which may process personal data for the account of TOP may become aware of any Users’ personal data in their capacity as “third parties data supervisors”, including but not limited to, providers of logistics and IT services functional for the Website operational, outsourcing or cloud computing services providers, professionals and advisors. Any users have the right to obtain a list of the data supervisors (if any) appointed by TOP upon a specific request to be made to TOP pursuant to the modalities specified under paragraph 5 below.
(5) Data subjects’ rights
Pursuant to Article 7 of the Privacy Code, TOP hereby informs that any Users has the right to obtain the indication of: (i) the source of the personal data; (ii) the purposes and methods of the processing; (iii) the logic applied to the processing, if the latter is carried out with the help of electronic means; (iv) the identification data concerning data controller and data processors; and (v) the entities or categories of entity to whom or which the personal data may be communicated and who or which may get to know said data in their capacity as designated data processor(s) or person(s) in charge of the processing. Furthermore, data subjects have the right to obtain: (a) updating, rectification or, where interested therein, integration of the data; (b) erasure, anonymization or blocking of data that have been processed unlawfully, including data whose retention is unnecessary for the purposes for which they have been collected or subsequently processed; and (c) certification to the effect that the operations as per letters (a) and (b) have been notified, as also related to their contents, to the entities to whom or which the data were communicated or disseminated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected. Users have the right to object, in whole or in part on legitimate grounds, to the processing of personal data concerning him/her, even though they are relevant to the purpose of the collection. Users may exercise such rights by contacting TOP by the following methods: (i) sending a registered letter with return receipt to the registered office of TOP; or (ii) sending an email message to the address firstname.lastname@example.org or a fax to the following No.: (+39) 02 36769264.
(6) Registration by “Connect with Facebook”
TOP hereby informs that Users registered to Facebook may register to the Website by using the service “Connect with Facebook”. Data that may be communicated to TOP by means of the service “Connect with Facebook” are the following: name, surname, profile image, email address in which the User is contactable by Facebook (with “actual” address or proxy address proxymail.facebook.com), address and date of birth. TOP will process such data exclusively for the purposes specified under this policy, in compliance with the consents provided by the relevant User from time to time. By adhering the service “Connect with Facebook” and clicking on the key “Consent”, the User gives its consent to the circumstance that the above mentioned data are transferred from the Facebook platform to TOP. TOP will use such data in order to facilitate the registration procedure, filling in advance the registration form fields with the data communicated by Facebook. Users that use the Facebook Connect service could access to the Website using the credentials normally used in order to access to Facebook. For further information on the service “Connect with Facebook” and for amending the relevant privacy settings related to such service, please consult the following Internet websites: www.facebook.com/help/405977429438260/ and www.facebook.com/about/privacy/your-info-on-other.
(7) Registration by “Connect with Twitter”
TOP hereby informs that Users registered to Twitter may register to the Website by using the service “Connect with Twitter”. Data that may be communicated to TOP by means of the service “Connect with Twitter” are the following: name, surname, profile image. TOP will process such data exclusively for the purposes specified under this policy, in compliance with the consents provided by the relevant User from time to time. By adhering the service “Connect with Twitter” and clicking on the key “Consent”, the User gives its consent to the circumstance that the above mentioned data are transferred from the Twitter platform to TOP. TOP will use such data in order to facilitate the registration procedure, filling in advance the registration form fields with the data communicated by Twitter. Users that use the Twitter Connect service could access to the Website using the credentials normally used in order to access to Twitter. For further information on the service “Connect with Twitter” and for amending the relevant privacy settings related to such service, please consult the following Internet websites: https://twitter.com/privacy.