Privacy Policy

Privacy Policy of toptenia.com

TOPTENIA is committed to maintaining strong protections for our customers, products, and company. We believe in building and maintaining trust, reducing risk and simply doing what is right.


Last Update: July 30, 2018

TOPTENIA, Inc. and its subsidiaries (collectively “TOPTENIA”) are committed to protecting your privacy and providing you with a positive experience on our websites and in using our information services.

This Privacy Statement applies to TOPTENIA websites that link to or reference this Statement and describes how we handle personal information and the choices available to you regarding the collection, use, access, and how to update and correct your personal information. Additional information on our personal information practices may be provided in offer descriptions, supplemental privacy statements, or notices provided prior to or at the time of data collection.


Types of Data Collected:

Among the types of Personal Data that this Application collects, by itself or through third parties, there are Cookies, Usage Data, email address, first name, last name, and username.

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 the case of Usage Data, collected automatically when using this Application.

Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application 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 this Application or by the owners of third-party services used by this Application serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.

Users are responsible for any third-party Personal Data obtained, published or shared through this Application and confirm that they have the third party’s consent to provide the Data to the Owner.


Mode and place of processing the Data:

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 this Application (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.


The legal basis of the processing:

The Owner may process Personal Data relating to Users if one of the following applies:

  • Users have given their consent for one or more specific purposes. Note: Under some legislation, the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
  • provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
  • processing is necessary for compliance with a legal obligation to which the Owner is subject;
  • processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
  • processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.


Place:

The Data is processed at the Owner’s operating offices and in any other places where the parties involved in the processing are located.

Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

If broader protection standards are applicable, Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.

If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.


Retention time:

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

Therefore:

  • Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
  • Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after the expiration of the retention period.


The purposes of processing:

The Data concerning the User is collected to allow the Owner to provide its Services, as well as for the following purposes: Analytics, Interaction with external social networks and platforms, Contacting the User, Advertising, SPAM protection, Content commenting, Displaying content from external platforms, Handling payments, Managing contacts and sending messages, Registration and authentication, Traffic optimization and distribution, Remarketing and behavioral targeting and Hosting and backend infrastructure.

Users can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective sections of this document.


Use of Cookies and other Web Technologies:

Like many websites, TOPTENIA uses automatic data collection tools, such as cookies, embedded web links, and web beacons. These tools collect certain standard information that your browser sends to our website. Examples include your browser type and the address of the website from which you arrived at our website.

They may also collect information about:

  • Your Internet Protocol (IP) address. This is a number automatically assigned to your computer or device whenever you connect to the Internet. It is a unique address assigned by your Internet service provider or IT department on a TCP/IP network. Among other things, the IP address allows web servers to locate and identify your device.
  • Clickstream behavior. This includes, for example, the pages you view and the links you click. These tools help make your visit to our website easier, more efficient, and more valuable by providing you with a customized experience and recognizing you when you return.

Our website includes widgets. Widgets are interactive mini-programs that run on our site to provide specific services from other companies. Examples include displays of news, opinions, videos, and more. Personal information, such as your email address, may be collected through widgets. Widgets may also set cookies to enable them to function properly. Information collected by a widget is governed by the privacy policy of the company that created the widget.

Some web browsers may give you the ability to enable a “do not track” feature that sends signals to the websites you visit, indicating that you do not want your online activities tracked. This is different from blocking or deleting cookies, as browsers with a “do not track” feature enabled may still accept cookies.

No industry standard currently exists on how companies should respond to “do not track” signals, although one may develop in the future. TOPTENIA website does not currently recognize and respond to “do not track” signals. If we do in the future, we will describe how in this Privacy Statement.

We partner with third parties to display advertising on our website or to manage our advertising on other sites. Our third-party partners may use cookies or similar technologies in order to provide you with advertising based on your browsing activities and interests.

Personal Data collected for the following purposes and using the following services:


Advertising

  • Google AdSense, Facebook Instant Articles, Amazon Affiliate Network, and Google Ad Manager. 
  • Personal Data: Cookies and Usage Data.

Analytics

  • Google Analytics, and MonsterInsight Analytics.
  • Personal Data: Cookies and Usage Data.

Contacting the User

  • Mailing List or Newsletter.
  • Personal Data: email address, first name, and last name.

Content commenting

  • Disqus and Facebook Comments.
  • Personal Data: Cookies, Usage Data and various types of Data as specified in the privacy policy of the service
  • Comment system managed directly
  • Personal Data: email address, first name, last name, and username.

Displaying content from external platforms

  • Gravatar
  • Personal Data: email address and Usage Data
  • YouTube video widget and Vimeo video
  • Personal Data: Cookies and Usage Data.

Interaction with external social networks and platforms

  • Facebook Like button and social widgets, Pinterest “Pin it” button and social widgets, Twitter Tweet button, and social widgets and AddThis
  • Personal Data: Cookies and Usage Data.

Registration and authentication

  • WordPress.com Single Sign-On.
  • Personal Data: various types of Data as specified in the privacy policy of the service.

SPAM protection

  • Akismet.
  • Personal Data: various types of Data as specified in the privacy policy of the service.

Remarketing and behavioral targeting

  • Remarketing through Google Analytics for Display Advertising and Google Ad Manager Audience Extension.
  • Personal Data: Cookies and Usage Data.

The rights of Users:

Users may exercise certain rights regarding their Data processed by the Owner.

Users entitled to broader protection standards may exercise any of the rights described below. In all other cases, Users may inquire with the Owner to find out which rights apply to them.

In particular, Users have the right to do the following:

  • Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
  • Object to the processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
  • Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
  • Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
  • Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
  • Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
  • Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User’s consent, on a contract which the User is part of or on pre-contractual obligations thereof.
  • Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Details about the right to object to the processing:

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights:

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.

Applicability of broader protection standards:

While most provisions of this document concern all Users, some provisions expressly only apply if the processing of Personal Data is subject to broader protection standards.

Such broader protection standards apply when the processing:

  • is performed by an Owner based in the EU;
  • concerns the Personal Data of Users who are in the EU and is related to the offering of paid or unpaid goods or services, to such Users;
  • concerns the Personal Data of Users who are in the EU and allows the Owner to monitor such Users’ behavior taking place in the EU.

Linked Websites:

We may provide links to other third-party websites and services that are outside our control and not covered by this Privacy Statement. We encourage you to review the privacy statements posted on those websites (and all websites) you visit.

For more information, please read our Terms of Use and Copyright statements.


Children’s Privacy:

TOPTENIA encourages parents and guardians to take an active role in their children’s online activities. TOPTENIA does not knowingly collect personal information from children without appropriate parental or guardian consent. If you believe that we may have collected personal information from someone under the applicable age of consent in your country without proper consent, please let us know using the methods described in the Contact Us section and we will take appropriate measures to investigate and address the issue promptly.


Additional information:

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 this Application 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, this Application 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, this Application and any third-party services may collect files that record interaction with this Application (System logs) use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy:

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

Changes to this privacy policy:

The Owner reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page and possibly within this Application 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. Users may be subject to different protection standards and broader standards may, therefore, apply to some.


We value your opinions. Should you have questions or comments related to this Privacy Statement, please email our privacy team.

Contact information:
Privacy and Data Controller Team
Toptenia — 96 Mowat Ave, Toronto ON M6K 3M1 Canada.

Owner contact email: [email protected]