Privacy Policy

1. PURPOSE OF THE DATA COLLECTED AND CONSENT TO TREATMENT

We inform you that the data provided will be processed for the purpose of meeting your request and maintaining the relationship established in the forms you subscribe.

Acceptance of the privacy policy, through the established procedure, will be understood for all purposes as the provision of unequivocal consent of the User to the processing of personal data in the terms set out in this document, as well as the international data transfer that occurs exclusively due to the physical location of the facilities of the service providers and data processors that are set out in this document.

We process the information you provide us in order to provide the requested service and to carry out your billing. The data provided will be kept as long as the business relationship is maintained or for the time necessary to comply with legal obligations and meet the possible responsibilities that may arise from the fulfillment of the purpose for which the data was collected. The data will not be transferred to third parties except in cases where there is a legal obligation. You have the right to obtain information about whether we are treating your personal data, so you can exercise your rights of access, rectification, deletion and portability of data and opposition and limitation to its treatment at the email address info@top-on.com, attaching a copy of your ID or equivalent document. Likewise, and especially if you consider that you have not obtained full satisfaction in the exercise of your rights, you may file a claim with the national control authority by addressing this purpose to the Spanish Agency for Data Protection, C / Jorge Juan, 6 – 28001 Madrid.

2. COMPLIANCE WITH APPLICATION REGULATIONS

Top-on.com complies with the guidelines of Regulation (EU) 2016/679 General Data Protection (RGPD) and Organic Law 3/2018 of December 5, Protection of Personal Data and guarantee of digital rights (LOPDGDD ), ensuring the correct use and treatment of the User’s personal data.

Likewise, top-on.com informs that it complies with Law 34/2002 of July 11, on Services of the Information Society and Electronic Commerce and will request the User’s consent for the processing of their email for purposes commercial at all times.

On this website we only process low-risk data, we will never process personal data that includes data related to ethnic or racial origin, religious or philosophical political ideology, union affiliation, genetic and biometric data, health data, and data on people’s sexual orientation. , as well as any other data processing that involves high risk for the rights and freedoms of individuals.

Article 5.1.f of the General Data Protection Regulation (hereinafter, RGPD) determines the need to establish adequate security guarantees against unauthorized or illicit treatment, against the loss of personal data, destruction or accidental damage. This implies the establishment of technical and organizational measures aimed at ensuring the integrity and confidentiality of personal data and the possibility of demonstrating, as established in article 5.2, that these measures have been carried out (proactive responsibility).).

In addition, it must establish visible, accessible and simple mechanisms for the exercise of rights and have defined internal procedures to guarantee the effective attention of the requests received.

3. RIGHTS OF THE INTERESTED PARTIES

We inform you that the data provided will be processed for the purpose of meeting your request and maintaining the relationship established in the forms you subscribe.

Additionally, the User’s data will be processed for the purpose of sending commercial communications as long as the informed, specific, free and unequivocal consent has been given for this purpose.

The data controller will inform all workers about the procedure to address the rights of Users, clearly defining the mechanisms by which rights can be exercised (electronic means, reference to the Data Protection Officer, if any, etc. ) and taking into account the following:

  • Upon presentation of their national identity document or passport, the holders of personal data (Users) may exercise their rights of access, rectification, deletion, opposition, portability and limitation of treatment. The exercise of rights is free.
  • The person in charge of the treatment must respond to the Users without undue delay and in a concise, transparent, intelligible way, with a clear and simple language and retain proof of compliance with the duty to respond to the requests for the exercise of rights made.
  • If the request is submitted by electronic means, the information will be provided by these means whenever possible, unless the User requests it to be otherwise.
  • Requests must be answered within 1 month of receipt, and may be extended by another two months taking into account the complexity or number of requests, but in that case the User must be informed of the extension within a month from of receipt of the request, indicating the reasons for the delay.

RIGHT OF ACCESS: In the right of access, Users will be provided with a copy of the personal data that is available together with the purpose for which they have been collected, the identity of the recipients of the data, the anticipated retention periods or the criteria used to determine it, the existence of the right to request the rectification or deletion of personal data as well as the limitation or opposition to its treatment, the right to file a claim with the Spanish Agency for Data Protection and if the data has not been obtained from the User, any available information about its origin. The right to obtain a copy of the data cannot negatively affect the rights and freedoms of other Users.

 RIGHT OF RECTIFICATION: In the right of rectification, the data of the Users that were inaccurate or incomplete will be modified according to the purposes of the treatment. The User must indicate in the request what data they refer to and the correction to be made, providing, when necessary, supporting documentation for the inaccuracy or incompleteness of the data being processed. If the data has been communicated by the person in charge to other managers, they must notify them of the rectification of these unless it is impossible or requires a disproportionate effort, providing the User with information about said recipients, if requested.

 RIGHT OF SUPPRESSION: In the right of deletion, the data of the Users will be deleted when they express their refusal to treatment and there is no legal basis that prevents it, they are not necessary in relation to the purposes for which they were collected, they withdraw their consent provided and there is no other legal basis that legitimizes the treatment or it is illegal. If the deletion derives from the exercise of the User’s right to object to the processing of their data for marketing purposes, the User’s identifying data may be kept in order to prevent future processing. If the data has been communicated by the person in charge to other managers, they must notify them of the deletion of these unless it is impossible or requires a disproportionate effort, providing the User with information about said recipients, if requested.

 RIGHT OF OPPOSITION: In the right of opposition, when Users express their refusal to process their personal data before the person in charge, he will stop processing them as long as there is no legal obligation that prevents it. When the treatment is based on a mission of public interest or on the legitimate interest of the person in charge, upon a request to exercise the right of opposition, the person in charge will stop processing the data unless compelling reasons that prevail over the interests, rights and User’s freedoms or are necessary for the formulation, exercise or defense of claims. If the User objects to the treatment for direct marketing purposes, the personal data will no longer be processed for these purposes.

 PORTABILITY RIGHT: In the portability right, if the treatment is carried out by automated means and is based on consent or is carried out within the framework of a contract, Users can request to receive a copy of their personal data in a structured format, of common use and machine reading. Likewise, they have the right to request that they be transmitted directly to a new person in charge, whose identity must be communicated, when technically possible.

 RIGHT TO LIMIT TREATMENT: In the right to limit treatment, Users can request the suspension of the processing of their data to challenge its accuracy while the person in charge performs the necessary verifications or in the event that the treatment is carried out based on interest legitimate authority of the person in charge or in compliance with a mission of public interest, while verifying if these reasons prevail over the interests, rights and freedoms of the User. The User can also request the conservation of the data if he considers that the treatment is illegal and, instead of the deletion, requests the limitation of the treatment, or if the person responsible for the purposes for which they were collected, the User is no longer needing them. You need them for the formulation, exercise or defense of claims. The circumstance that the processing of the User’s data is limited must be clearly stated in the systems of the person in charge. If the data has been communicated by the person in charge to other controllers, they must notify them of the limitation of their treatment unless it is impossible or requires a disproportionate effort, providing the User with information about said recipients, if requested.

If the User’s request is not acted upon, the data controller will inform him, without delay and no later than one month after receiving it, of the reasons for his failure to act and of the possibility of filing a claim with the Agency. Spanish of Data Protection and to exercise legal actions.

Any modification of the Privacy Policy will be published at least ten days before its effective application. The use of the Web after said changes, will imply the acceptance of them.

4. RESPONSIBLE FOR THE FILE AND RESPONSIBLE FOR THE TREATMENT

The data controller is the owner of the website top-on.com.

As data managers hired by the aforementioned person in charge:

Hosting services provided by Acens Technologies, S.L.U. (Identified with the commercial brand HOSTALIA), with registered office in Barcelona, ​​C / San Rafael, 14 28108 Alcobendas (Madrid) Madrid Mercantile Registry Volume 23.654, book 0, page 155, section 8, Page M-424478, 1st entry, that provides web hosting services. You can consult the privacy policy and other legal aspects of said company at the following link: https://www.hostalia.com/legal/aviso-legal/

E-mail subscription services and newsletter delivery to The Rocket Science Group, LLC (Identified by the trademark “MailChimp”). Subscribing to the newsletter implies that the data entered is transferred to the servers of the aforementioned company, assuming an international transfer of data. This company is attached to the Privacy Shield:

https://www.privacyshield.gov/participant?id=a2zt0000000TO6hAAG&status=Active

Said data managers have been required to comply with the applicable regulatory provisions on data protection, at the time of their hiring.

5. MODIFICATION OF THE PRIVACY POLICY

Top-on.com reserves the right to modify its Privacy Policy, according to its own criteria, motivated by a legislative, jurisprudential or doctrinal change of the Spanish Agency for Data Protection.

6. LANGUAGE

The language applicable to this privacy policy is Spanish. Therefore, if there is any contradiction in any of the versions provided in other languages, the Spanish version will prevail.

7. SOCIAL NETWORKS

We inform you that Top-on® may have a presence on social networks. The treatment of the data that is carried out of the people who become followers on social networks (and / or carry out any link or connection action through social networks) of the official pages of Top-on® will be governed for this section, as well as for those conditions of use, privacy policies and access regulations that belong to the social network that is appropriate in each case and previously accepted by the user.

 

Top-on® will process your data for the purpose of correctly managing your presence on the social network, informing about activities, products or services of the provider, as well as for any other purpose that the regulations of Social Networks allow.

The publication of content is prohibited:

That they are allegedly illegal by national, community or international regulations or that they carry out allegedly illegal activities or contravene the principles of good faith.

That violate the fundamental rights of people, lack of courtesy in the network, annoy or may generate negative opinions in our users or third parties and in general whatever the content that Top-on® considers inappropriate.

And in general that contravene the principles of legality, honesty, responsibility, protection of human dignity, protection of minors, protection of public order, protection of privacy, consumer protection and intellectual and industrial property rights.

Likewise, Top-on® reserves the right to withdraw, without prior notice from the website or the corporate social network, those contents that are considered inappropriate.

In any case, if you send personal information through the social network, Top-on® will be exempt from responsibility in relation to the security measures applicable to this platform and the User, if he wants to know them, should consult the corresponding particular conditions of the network in question.