Your access to and use of this Site and the Service is subject to TopTracker’s Terms and Conditions.
When you interact with us through the Site or the Service, we may collect Personal Data and other information from you, as further described below.
Information We Collect
When you interact with TopTracker through the Site or services, we collect automatically certain information, including via cookies. Please read the “Site Visitors” section below for more information.
How we use that information
To Provide The Services And Respond To Requests
For Marketing Purposes
We may use your contact details to tell you about services we believe will be of interest to you, upcoming events or other promotions. If we do so, each marketing communication we send you will contain instructions permitting you to "opt out" of receiving future marketing communications. Note however that as user of our services you cannot opt out of some administrative communications that are reasonably necessary to the services, such as service notifications. In addition, if at any time you wish not to receive any future marketing communications or you wish to have your name deleted from our mailing lists, please contact us as indicated below.
Where required by applicable law (for example, if you are an individual in the EU), we will only send you marketing information by email if you consent to us doing so at the time you provide us with your Personal Data. When you provide us with your consent to be contacted for marketing purposes, you have the right to withdraw your consent at any time by following the instructions to “opt-out” of receiving marketing communication in each marketing email we send you or by contacting us as indicated below.
As Necessary For Certain Legitimate Interests
We use your Personal Data for the legitimate interests described below:
- To send administrative information to you, for example, information regarding the Site and changes to our terms, conditions, and policies.
- To respond to your inquiries and fulfill your requests, such as to send you requested materials and newsletters, as well as information and materials regarding our products and services.
- To conduct analytics on how the Site and our Service are being used by you for our internal purposes (namely for providing, maintaining, benchmarking and improving our offerings, identifying usage trends and determining the effectiveness of our promotional campaigns) and to inform our marketing strategy and personalize our communications with you (including providing information on our features and other marketing and service-related announcements relevant to the content and features you engage with).
- To supplement the information that we collected from you with information obtained from third parties (described above) in order to update, expand and analyze our records, and provide products and services that may be of interest to you.
- To prevent fraud or criminal activity, misuses of our products or services, and ensure the security of our IT systems, architecture and networks.
- To (a) comply with legal obligations and legal process, (b) respond to requests from public and government authorities including public and government authorities outside your country of residence; (c) enforce our terms and conditions; (d) protect our operations; (e) protect our rights, privacy, safety or property, and/or that of you or others; and (f) allow us to pursue available remedies or limit the damages that we may sustain.
- If you ask us to delete your data and we are required to fulfil your request, to keep basic data to identify you and prevent further unwanted processing.
For individuals in the EU, please see the “EU Individuals” section below for information on our legitimate interests and your rights.
As a visitor to our Site, our servers record information (“log data”), including information that your browser automatically sends whenever you visit the Site. This log data includes your Internet Protocol (“IP”) address (from which we understand the country you are connecting from at the time you visit the Site), browser type and settings, the date and time of your request.
Where the information that we collect automatically on our Site is Personal Data, our legal basis for the use of this information is that it is necessary for the purposes of our legitimate interests in maintaining the safe operation of our Site as well as in learning how Site visitors interact with our Site to improve your use of it.
Non-Identifiable or Aggregated Data
When you interact with TopTracker through the Site or Service, we receive and store certain personally non-identifiable information. Such information, which is collected passively using various technologies, cannot presently be used to specifically identify you. TopTracker may store such information itself or such information may be included in databases owned and maintained by TopTracker affiliates, agents or service providers. This Site may use such information and pool it with other information to track, for example, the total number of visitors to our Site, the number of visitors to each page of our Site, the domain names of our visitors’ Internet service providers, and how our users use and interact with the Service. Also, in an ongoing effort to better understand and serve the users of the Service, TopTracker often conducts research on its customer demographics, interests and behavior based on the Personal Data and other information provided to us. This research may be compiled and analyzed on an aggregate basis. TopTracker may share this non-identifiable and aggregate data with its affiliates, agents and business partners, but this type of non-identifiable and aggregate information does not identify you personally. TopTracker may also disclose aggregated user statistics in order to describe our Service to current and prospective business partners, and to other third parties for other lawful purposes.
Our Disclosure of Your Personal Data and Other Information
TopTracker is not in the business of selling your information. We consider this information to be a vital part of our relationship with you. There are, however, certain circumstances in which we may share your Personal Data with certain third parties without further notice to you, as set forth below:
As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets.
Agents, Consultants and Related Third Parties
TopTracker, like many businesses, sometimes hires other companies to perform certain business-related functions. Examples of such functions include mailing information, maintaining databases, billing and processing payments. When we employ another company to perform a function of this nature, we only provide them with the information that they need to perform their specific function.
TopTracker may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of TopTracker or any related company, (iii) act in urgent circumstances to protect the personal safety of users of the Site or the public, or (iv) protect against legal liability.
TopTracker’s related company Toptal is the data controller for processing your Personal Data. The data controller is responsible for deciding how Personal Data about you is used. Please see the “Contacting TopTracker” section below to find out how to contact us, which also provides the contact details of our representative in the EU for purposes of the General Data Protection Regulation.
Subject to applicable EU law, you have the following rights in relation to your Personal Data:
- Right of access. If you ask us, we will confirm whether we are processing your Personal Data and, if so, provide you with a copy of that Personal Data along with certain other details. If you require additional copies, we may need to charge a reasonable fee.
- Right to rectification. If your Personal Data is inaccurate or incomplete, you are entitled to ask that we correct or complete it. If we shared your Personal Data with others, we will tell them about the correction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so you can contact them directly.
- Right to erasure. You may ask us to delete or remove your Personal Data, such as where you withdraw your consent. If we shared your data with others, we will tell them about the erasure where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data with so you can contact them directly.
- Right to restrict processing. You may ask us to restrict or ‘block’ the processing of your Personal Data in certain circumstances, such as where you contest the accuracy of the data or object to us processing it. We will tell you before we lift any restriction on processing. If we shared your Personal Data with others, we will tell them about the restriction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so you can contact them directly.
- Right to data portability. You have the right to obtain your Personal Data from us that you consented to give us or that was provided to us as necessary in connection with our contract with you. We will give you your Personal Data in a structured, commonly used and machine-readable format. You may reuse it elsewhere.
Right to object. You may ask us at any time to stop processing your Personal Data, and we will do so:
- If we are relying on a legitimate interest to process your Personal Data -- unless we demonstrate compelling legitimate grounds for the processing or
- If we are processing your Personal Data for direct marketing.
- Rights in relation to automated decision-making and profiling. You have the right to be free from decisions based solely on automated processing of your Personal Data, including profiling, which produce a significant legal effect on you, unless such profiling is necessary for entering into, or the performance of, a contract between you and us, or with your explicit consent. We are not currently processing your Personal Data for such type of automated decision-making, including profiling, but if we elect to do so in the future we will provide you with notice and choice, in accordance with EU data protection law.
- Right to withdraw consent. If we rely on your consent to process your Personal Data, you have the right to withdraw that consent at any time, but this will not affect any processing of your data that has already taken place.
- Right to lodge a complaint with the data protection authority. If you have a concern about our privacy practices, including the way we handled your Personal Data, you can report it to the data protection authority that is authorized to hear those concerns.
You may exercise your rights by contacting us as indicated under “Contacting TopTracker” section below.
Our policy is to keep your Personal Data only for as long as is reasonably necessary to fulfil the purposes for which it was collected and processed, including for the purposes of satisfying any legal, regulatory, accounting or reporting requirements. If you have elected to receive marketing communications from us, we retain information about your marketing preferences until you opt out of receiving these communications and in accordance with our policies.
To determine the appropriate retention period for your Personal Data, we will consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we use your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances we may anonymize your Personal Data so that it can no longer be associated with you, in which case it is no longer Personal Data.
You can use the Site without providing any Personal Data. If you choose not to provide any Personal Data, you may not be able to use certain features of the Service.
Links to Other Web Sites
TopTracker takes reasonable steps to protect the Personal Data provided via the Site from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet, email or other electronic transmission is ever fully secure or error free, so you should take special care in deciding what information you send to us in this way.
You may contact us as follows: by email at firstname.lastname@example.org, or by post at:
If you are an individual in Serbia, you can also contact email@example.com. The email address will contact our privacy team in addition to a Serbian representative pursuant to requirements in the Law on Personal Data Protection.
If you are an individual in the EU, you can also contact VeraSafe, who has been appointed as representative in the EU for data protection matters, pursuant to Article 27 of the General Data Protection Regulation for Toptal and its related company TopTracker. You may contact VeraSafe directly about the processing of your Personal Data by using this contact form. Alternatively, VeraSafe can be contacted at:
VeraSafe Czech Republic s.r.o Klimentská 46 Prague 1, 11002 Czech Republic VeraSafe Ireland Ltd Unit 3D North Point House North Point Business Park New Mallow Road Cork T23AT2P Ireland