Privacy Policy

Dear User, Dear Customer,

information is provided below relating to the processing of personal data carried out through our website www.topline.fashion (hereinafter the "Site" ), or otherwise carried out in relation to the use of our products and services, pursuant to the Regulation (EU) no. 2016/679 (hereinafter the "Regulation" or "GDPR" ). The data controller is the company, Top Line Srl (hereinafter "supplier" , "Top Line Group" , "our" or the "Company" ), with registered office in Via della Castrina, 19 24060 Chiuduno (BG), who can be contacted at info@topline.fashion (hereinafter,"Supplier" or the "Company" ).

We provide this information not only to fulfill the legal obligations regarding the protection of personal data provided for by the GDPR, but also because we believe that the protection of personal data is a fundamental value of our business and we want to provide you with any information that can help you protect your privacy and control the use that is made of your data.

Data Protection Officer

The Data Protection Officer of Top Line Srl, who is the figure in charge of monitoring compliance with the Regulation, is available to respond to your requests on how we process your data and can be contacted at the email address info@topline.fashion .

Categories of personal data processed

allow the conclusion and establishment of the contractual relationship with Top Line or when you visit, consult, request or use the services and/or products of Top Line we collect and use your personal data (i.e. any information that is able to identify you directly or indirectly). We list below the categories of personal data we process about you:

• Identification, contact and access data , such as name, surname, username, email address, postal address, telephone number, username and password, any profile image where set by you;
• Product data such as data relating to the products licensed to you and/or services subscribed to by you;
• Information for billing and payment data , such as any VAT number, tax code, address, and possibly the company name;
• Navigation data , such as connection data; IP addresses, domain names and other parameters relating to the browser and operating system you use; log data; data relating to licenses, installations and configurations; data relating to registrations made, interaction and transaction processes, performance indicators; data relating to navigation flows and page views; usage and feature counts;
• Usage Data of the online services provided by Top Line Srl. The Usage Data relating to the different products and/or services purchased by you may be interconnected for lawful and transparent purposes, listed in the following paragraph.

Purpose of the treatment

The processing of the categories of personal data referred to in the table above is carried out by the Company, in carrying out its economic and commercial activities, for specific purposes, as better described below.

1. Contractual and Legal Purposes

1. Allow you to browse the Site;
2. Registration and account management (including any account checks and recovery of the credentials of the same, where applicable) and use of the functions connected to the account itself;
3. Execution of the activities necessary for the conclusion and execution of the contract for the purpose of supplying the service/product requested or purchased by you, also through the Site;
4. Handling inquiries related to registration for webinars and events, preparation of quotes, order processing, provision of assistance and support;
5. Management of any complaints and requests, sending of service communications and updates, both through traditional communication tools such as paper mail and through remote communication tools, such as email, chat, telephone, SMS, chatbots, banners, notification systems and other remote communication tools;
6. Customer assistance activities and support for the use of the Services by individual Customers, tutorship activities and management of tickets opened for assistance purposes, also through Usage Data;
7. Fulfillment of the obligations deriving from the law in force, regulations or community legislation (e.g. tax and accounting obligations) or management and response to requests from the competent administrative and tax authorities as well as from the judicial authority.

The purposes listed above are jointly defined as the "Contractual and Legal Purposes" and the express consent of the interested party is not required. The provision of your personal data for the aforementioned purposes is necessary and mandatory so that in case of refusal we will not be able to continue the contractual relationship with you and the relative supply of the requested services.

2. Legitimate Interest Purposes

8. For statistical analysis and research with respect to the products purchased and the services provided to you and their use, also for the purpose of improving and developing the products and services themselves. In compliance with the principle of minimization, where possible, this activity will take place after anonymization and aggregation of the data collected;
9. To evaluate your satisfaction with the products purchased and the services provided by Top Line, or the resolution of any difficulties and problems relating to their use: e.g. "caring" initiatives to help you make the best use of the product or service, also in terms of churn prevention and improvement of the customer experience;
10. To enforce and defend the Company's rights, also in the context of credit recovery procedures and assignment of credits to authorized companies, also through third parties and to prevent and counter any fraud;
11. To carry out a potential merger, sale of assets, sale of a company, business unit or financial transaction by communicating and transferring data to the third party(ies) involved;
12. To send via email, pursuant to article 130, paragraph 4 of Legislative Decree 196/2003 ( "Privacy Code" ), marketing communications on services or products similar to those covered by the contract concluded with Top Line, it being understood that, in at any time, you will have the possibility to object to the sending of such communications;
13. To perform customer segmentation activities, to which it is possible to send communications for Marketing Purposes on the basis of what is indicated in this information, based on non-invasive categories of belonging, such as, among others, the professional category to which they belong, the city/province /region in which it is based, the type of product or service purchased. This customer segmentation activity could also be carried out on platforms of third-party suppliers, through interconnection activities with data belonging to the third-party platform. In this case, communications for Marketing Purposes will be sent in compliance with the consents expressed by you and in compliance with what is indicated in this information. In this context, the data could also be used to detect profiles of similar customers.

The described "Purposes of Legitimate Interest" do not require your specific consent as they fall within the exception provided for by art. 6, paragraph 1, lett. f) of the GDPR. In any case, in compliance with the GDPR, the Company has carried out a thorough balancing of interests aimed at protecting and guaranteeing the privacy and fundamental rights of the data subjects.

3. Marketing Purposes

14. To send you updates on news and commercial offers of Top Line products and services, also after interconnection of the Usage Data and analysis of your behavior both with respect to navigation of the Site and, more generally, to the use of services and products or to invite you to participate in events, conduct market research or other commercial and customer satisfaction initiatives both through traditional communication channels such as paper mail or a telephone call from an operator and through automated communication tools such as email, chat, messages (SMS), chatbots and other remote communication tools;
15. To communicate your personal data to its sales network, for sending marketing communications and for other commercial initiatives such as those indicated in letter n).

The processing of your data for "Marketing Purposes" is not mandatory. Your prior consent is therefore required, which the Company will request from time to time in the most appropriate forms for each of the activities described above. The consent expressed can always be revoked by you without any consequence with respect to the contractual relationships existing with the Company.

Communication, dissemination and transfer of data

In compliance with the principle of finality and minimization, your personal data may be communicated to the following third parties who carry out activities functional to those relating to the product or service purchased, such as: (a) third party suppliers of assistance and consultancy services for the Company with reference to the activities of the sectors (by way of example only) technological, accounting, administrative, legal, insurance, (b) in cases where the contractual relationship provides for the intervention of commercial partners, the Company may share some of your personal data with own distributors, resellers; (c) banks and credit institutions; (d) debt collection company; (e) subjects and public authorities whose right of access to your personal data is expressly recognized by law, by regulations or measures issued by the competent authorities; (f) prospective purchasers of the Company and entities resulting from the merger or any other form of transformation concerning the Company; (g) public databases and credit information systems.

For Marketing Purposes, and subject to your specific consent, your personal data may also be disclosed to third parties and commercial partners in charge of marketing campaigns carried out on behalf of the Company.

Depending on the case, these recipients process your data as independent data controllers, processors or persons in charge of processing. The complete and updated list of subjects who process data as data processors is available upon request to the Data Protection Officer, according to the contact methods indicated in this statement.

Transfer of your personal data outside the EU territory

Without prejudice to the above, your personal data may be freely transferred within the Community territory. However, where, for the purposes indicated, the Company needs to transfer your personal data outside the European Union to countries not considered adequate by the European Commission (e.g. the United States), the Company will adopt the necessary measures to protect your data personal data, in compliance with the legal guarantees in accordance with the applicable legislation and in particular with articles 45 and 46 of the GDPR.

In the event that you wish to receive further information regarding the existing guarantees and request a copy of them, you can contact the Data Protection Officer according to the methods indicated in this statement.

Methods of data processing

Your personal data is processed by the Company with electronic and manual systems according to the principles of correctness, loyalty and transparency established by the applicable legislation on the protection of personal data and protecting your privacy through technical and organizational security measures to guarantee a level of adequate security.

These treatments take place at the Company's headquarters and/or at the external Data Processors who carry out the treatment on behalf of the company. With reference to the Usage Data, in compliance with the purposes described and, where necessary, with your express consent, the analysis activities can be carried out, also by interconnecting your data relating to the different products and services you purchase during online use of the services themselves. For usage statistics, the Company uses tools that allow the collection of Usage Data. With specific reference to the collection of Usage Data on the website, among others, the Company uses analytical tools such as:

1. Web and customer analytics;
2. Analytics and document search;
3. Querying and Dashboarding.

Data Retention

The data will be kept for the period of time necessary to achieve the purposes for which such data were collected, as stated in this statement. In any case, the following retention terms will apply with reference to data processing for the purposes set out below:

1. for the Contractual and Legitimate Interest Purposes, the data is kept for a period equal to the duration of the supply of the services requested by you and for the following 10 years (period in which the statute of limitations matures for any contractual liability asserted by the customer against Top Line), except in cases where retention for a subsequent period is required for any disputes, requests from the competent authorities or pursuant to applicable legislation;
2. for Marketing Purposes, the data is kept for a period of 24 months from the date on which the consent is given or renewed when purchasing a new Top Line product or service or the date of the last contact with you, to be understood, among others, the termination of the contractual relationship, participation in a Company event, use of a product or service provided by the Company or the opening of a newsletter (collectively referred to as the " Last Contact" ).

Change of choices and withdrawal of consent

If you change your mind, you can change the consent given for marketing purposes at any time by contacting us according to the methods set out in this information, or independently by accessing directly within your account in the Options -> Company -> Privacy section or, if you do not no longer want to receive our commercial communications, using the unsubscribe link available at the bottom of our commercial communications. Failure to issue or withdraw consent does not affect the use of our services in any way.

Rights of the interested parties

In relation to the data processing described in this statement, you can exercise the rights provided by the GDPR (articles 15-21) at any time, including:

• receive confirmation of the existence of your personal data and access their content (right of access);
• update, modify and/or correct your personal data (right to rectification);
• request the cancellation or limitation of the processing of your personal data processed in violation of the law including those whose retention is not necessary in relation to the purposes for which the data were collected or otherwise processed (right to be forgotten and right to limitation ), without prejudice to a prevailing public interest or a legal obligation of the Company to preserve them;
• object to the processing, including profiling (right to object), without prejudice to the existence of an overriding legitimate reason for the Company to continue processing;
• revoke consent, where given, to marketing activities;
• propose a complaint to the Supervisory Authority (Guarantor for the protection of personal data www.garanteprivacy.it ) in the event of a violation of the regulations on the protection of personal data;
• receive an electronic copy of the personal data concerning you, to transfer them to yourself or to a different service provider, in the event that the Company carries out the processing of such data on the basis of your consent or on the basis of the circumstance that the processing is necessary for the provision of the services requested by you and the data is processed using automated tools (right to data portability).

Pursuant to article 2-terdecies of the Privacy Code, in the event of death, the aforementioned rights relating to your personal data can be exercised by those who have an interest of their own, or act for your protection as an agent, or for family reasons worthy of protection. You can expressly prohibit the exercise of some of the rights listed above by the assignees by sending a written declaration to the Company at the email address indicated below. The declaration may be revoked or modified later in the same manner.

To exercise your rights regarding the protection of personal data at any time and free of charge, you can contact the Data Protection Officer, who can be contacted by sending a request to the address info@topline.fashion , or by sending the communication by post to:

Top Line Srl
Via della Castrina, 19
24060 CHIUDUNO (BG)
ca: Data Protection Officer

When contacting the Company, be sure to include your name, email/postal address and/or telephone number(s) to ensure your request can be handled properly.

Changes and Updates

This information may be subject to changes also as a result of any regulatory changes and/or additions. The changes will be notified to the interested parties and the constantly updated information text will be available on the website www.topline.fashion .

 

 

Chiuduno, 02/03/2020