3-Privacy Policy

INTRODUCTION

Our Privacy Policy outlines how we collect, use, and process your personal data when you visit our website or use our services. We are committed to protecting your privacy and being transparent about our data practices.

What personal data do we collect? How do we use it?

• Group 1: when provided, your name, your company name, your email, and your telephone; to communicate with you
• Group2: a unique and anonymous visitor identification number, and an event code to understand which path our visitors are following on our website

The legal basis for processing your data?

• Consent: In some instances, we may rely on your explicit consent as the legal basis for processing your data. When we collect sensitive personal data or engage in marketing activities, we will obtain your consent before processing your data. You have the right to withdraw your consent at any time by contacting us or adjusting your preferences in your account settings. If you would like us to erase your data from our database, please write to support.privacy@tothetop.io from the email address you wish to be erased, with the subject "no thanks" or "unsubscribe".
• Contractual Necessity: If you enter into a contract with us or request our services, we may process your data to fulfill our contractual obligations to you. This includes processing your data to provide you with the products or services you requested, to communicate with you about your account, or to invoice you for services rendered.
• Legal Obligations: We may process your data to comply with legal obligations to which we are subject. This includes fulfilling our obligations under applicable laws and regulations, responding to lawful requests from government authorities, or assisting in legal investigations.
• Legitimate Interests: We may process your data for our legitimate business interests, provided that such processing does not override your rights and interests. Our legitimate interests may include improving our products and services, analyzing website usage data to enhance user experience, preventing fraud or illegal activities, and conducting marketing activities that are relevant to you.

How DO we share your data with third parties?

We do not share your data with any third party other than:

• Group1 data is stored by different SaaS providers we use for CMS, CRM, Mail, Billing
• Group 2 data is shared with Google Analytics

How DO we protect your data?

• Data Minimization: We only collect and process personal data that is necessary for the purposes for which it was collected. We minimize the amount of personal data we collect and anonymize or pseudonymize data whenever possible.
• Data Security Measures: We implement technical and organizational measures to protect your data against unauthorized access, disclosure, alteration, or destruction. This includes firewalls, access controls, and regular security assessments.
• Employee Training: Our employees undergo training on data protection and privacy practices to ensure they handle personal data appropriately and comply with relevant laws and regulations.
• Third-Party Contracts: When we engage third-party service providers to process personal data on our behalf, we enter into data processing agreements that require them to implement appropriate security measures and comply with data protection laws.
• Incident Response Plan: We have established procedures to promptly respond to data breaches or security incidents. This includes notifying affected individuals and authorities, as well as taking steps to mitigate the impact of the breach.

How long DO we retain your data?

• Group 1: We keep that data indefinitely, including if you've asked us to opt-out of our promotional mail, for the very reason that we need to maintain a blacklist to avoid contacting you again. You can ask us to erase your data, but please note that you may still receive promotional or transactional mail if you have provided us with your contact information at a fair or filled out one of our forms. If you would like us to erase your data from our database, just write from the email you wish that we erase to privacy.out@tothetop.io, with the subject "out".
• Group 2: are retained for 14 months by Google Analytics

COOKIE POLICY

We use cookies and similar tracking technologies to improve your browsing experience and analyze website traffic. By clicking "Accept" on the cookie banner or continuing to use our website, you consent to the use of cookies and tracking technologies as described in our Cookie Policy.

Our Cookie Policy explains how we use cookies and similar technologies on our website. Cookies are small text files that are stored on your device when you visit a website, helping us analyze website traffic and user behavior.

Please have a look at our Cookie Policy [hyperlink to cookie policy] to learn about the types of cookies we use, their purposes, and how you can manage your cookie settings.

DATA RETENTION

We'll keep your personal data for as long as necessary to fulfill the purposes outlined in our Privacy Policy, unless a more extended retention period is required or permitted by law.

We have configured data retention settings within Google Analytics to delete user-level and event-level data after 30 days automatically.

GDPR AND OTHER REGULATIONS

If you are located in the European Union or subject to the General Data Protection Regulation (GDPR), you have specific rights regarding the processing of your personal data.

We comply with the requirements of the GDPR and other applicable data protection laws. If you have questions or concerns about our data practices or your rights under the GDPR, please write to support.privacy@tothetop.io from the email address you wish us to erase, with the subject "GDPR" and include your question.

USER RIGHTS

You have the right to:

• access your personal data
• correct your personal data
• delete your personal data

In order to use those right, please contact customer support using the link at the bottom of this page.