This page describes how this site is managed with regard to the processing of personal data of users who consult them.
This information is provided in accordance with the current legislation on personal data for users who interact with the services of this site within the framework of EU Regulation 2016/679.
The information is given only for this site and not also for other websites that may be consulted by the user through our links.
Data Controller
TOP Consulting & Services
Via di Benedetto Croce 44, 00142 Rome (Italy)
Holder’s email address: info@topcs.it
Types of data processed
Navigation data
The computer systems and software procedures used to operate the site acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols.
This information is not collected to be associated with identified interested parties, but by its very nature could, through processing and association with data held by third parties, allow users to be identified.
This category of data includes the IP addresses or domain names of the computers used by users connecting to the site, the URI (Uniform Resource Identifier) notation addresses of the resources requested, the time of the request, the method used in submitting the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the user’s operating system and computer environment.
These data are used for the sole purpose of obtaining anonymous statistical information on the use of the site and to check its correct operation and are deleted after processing.
The data could be used to ascertain responsibility in case of hypothetical computer crimes against the site.
Data voluntarily provided by the user
The optional, explicit and voluntary sending of electronic mail to the addresses indicated on the site involves the subsequent acquisition of the sender’s address, necessary to respond to requests, as well as any other personal data included in the message.
Specific summary information will be progressively reported or displayed on the pages of the site prepared for particular services on request.
Cookies
A cookie is defined as a textual element that is placed on a computer’s hard drive only upon authorization.
Cookies have the function of streamlining web traffic analysis or signaling when a specific site is visited and allow web applications to send information to individual users.
No personal user data is acquired by the site in this regard.
No use is made of cookies to transmit information of a personal nature, nor are so-called persistent cookies of any kind, i.e. systems for tracking users, used.
The use of c.d. session cookies is strictly limited to the transmission of session identifiers (consisting of random numbers generated by the server) necessary to enable the safe and efficient exploration of the site.
The c.d. session cookies used in the site avoid the use of other computer techniques potentially prejudicial to the privacy of users’ browsing and do not allow the acquisition of personal identification data of the user.
Purpose of processing and data retention time
- Giving feedback to requests from interested parties, executing contractual and pre-contractual obligations and legal obligations.
- Use of data for promotional purposes by sending third-party commercial communications or conducting market studies.
For this purpose, it may be necessary to use data subjects’ data for normalization, deduplication, filtering and verification operations.
Communications will be sent by the HOLDER. - Profiling by analyzing personal data with automated tools to assess or predict aspects concerning the data subject.
With reference to data collected by the Holder for requests from the data subject, performance of contractual, pre-contractual or legal obligations: The Owner will retain the database for as long as necessary to manage the activities related to data processing.
With reference to advertising activities: data subjects’ data will be kept for as long as necessary for the execution of the activity, in any case avoiding indefinite storage and facilitating the exercise of their rights by the data subject.
The retention time is set at two years, unless the data subject takes actions confirming his or her willingness to allow the use of his or her data.
With reference to data collected for profiling purposes: data subjects’ data will be kept for one year.
Legal Bases that legitimize the processing of data
The legitimacy for the processing of your data in relation to the purposes of processing is based on the following:
- For the purpose of handling data subject requests and data subject participation in activities carried out by the Data Controller – Need to execute data subject requests.
- For the purpose of carrying out commercial communications of third party companies/market studies by the Holder also outside EU territory- Consent of the data subject
- For the purpose of profiling based on the interests and behaviors of the data subject- Consent of the data subject.
Details of the processing of Personal Data
Personal Data are collected for the following purposes and using the following services:
Contact user
Mailing list or newsletter (TOP Consulting & Services)
By registering for the mailing list or newsletter, the User’s email address is automatically added to a list of contacts to whom email messages containing information, including information of a commercial and promotional nature, related to TOP Consulting & Services may be sent.
The User’s email address may also be added to this list as a result of registering with TOP Consulting & Services or after making a purchase.
Personal Data Processed: first name; last name; email; phone number; Cookies; Usage Data.
Statistics
The services contained in this section allow the Data Controller to monitor and analyze traffic data and serve to track User behavior.
Google Analytics (Google Inc.)
Google Analytics is a web analytics service provided by Google Inc.
(“Google”).
Google uses the Personal Data collected for the purpose of tracking and examining the use of TOP Consulting & Services, compiling reports, and sharing them with other services developed by Google.
Google may use the Personal Data to contextualize and personalize ads in its advertising network.
Personal Data Processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Privacy Shield Adherent.
Facebook Ads conversion tracking (Facebook pixel) (Facebook, Inc.).
Facebook Ads conversion tracking (Facebook pixel) is a statistics service provided by Facebook, Inc.
that links data from the Facebook Ads Network with actions taken within TOP Consulting & Services.
The Facebook pixel monitors conversions that can be attributed to Facebook, Instagram, and Audience Network ads.
Personal Data Processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy.
Privacy Shield Adherent.
Advertisement
These types of services allow the use of User Data for marketing communication purposes in different forms of advertising, such as banner ads, also related to the User’s interests.
This does not mean that all Personal Data is used for this purpose.
Data and conditions of use are set out below.
Some of the services below may use Cookies to identify the User or use the technique of behavioral retargeting, i.e. displaying customized advertisements based on the User’s interests and behavior, also detected outside TOP Consulting & Services.
For more information on this, we suggest you check the privacy policies of the respective services.
In addition to the opt-out possibilities offered by the services below, the User may opt out with respect to the receipt of cookies related to a third-party service by visiting the Network Advertising Initiative’s opt-out page.
Direct Email Marketing (DEM) (TOP Consulting & Services)
TOP Consulting & Services uses User Data to send proposals of a commercial nature related to services and products provided by third parties or unrelated to the product or service provided by TOP Consulting & Services.
Personal Data Processed: email.
Facebook Audience Network (Facebook, Inc.)
Facebook Audience Network is an advertising service provided by Facebook, Inc. For an understanding of Facebook’s use of data, please see Facebook’s data policy.
To enable the operation of Facebook Audience Network, TOP Consulting & Services may use certain mobile device identifiers (including Android Advertising ID or Advertising Identifier for OS) or cookie-like technologies.
Among the ways in which Audience Network delivers advertising messages to the User is by using the User’s advertising preferences.
The User can control the sharing of his or her advertising preferences within Facebook’s Ad settings.
You may opt-out of certain Audience Network targeting features through your device settings.
For example, you may change the settings on advertising available for mobile devices, or follow the instructions applicable to Audience Network that may be found within this privacy policy.
Personal Data Processed: Cookies; Usage Data; unique device identifiers for advertising (Google Advertiser ID or IDFA identifier, for example).
Place of processing: United States – Privacy Policy – Opt Out.
Privacy Shield Adherent.
Remarketing and behavioral targeting
This type of services allows TOP Consulting & Services and its partners to communicate, optimize and serve advertisements based on the User’s past use of TOP Consulting & Services.
This activity is carried out by tracking Usage Data and the use of Cookies, information that is transferred to the partners to which the remarketing and behavioral targeting activity is linked.
In addition to the opt-out possibilities offered by the services below, the User may opt out with respect to receiving cookies related to a third-party service by visiting the Network Advertising Initiative opt-out page.
Remarketing Google Ads (Google LLC)
Remarketing Google Ads is a remarketing and behavioral targeting service provided by Google LLC that connects TOP Consulting & Services’ business with the Google Ads advertising network and the DoubleClick Cookie.
Users can opt out of Google’s cookies for ad personalization by visiting Google’s Ads Settings.
Personal Data Processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Privacy Shield Adherent.
Facebook Remarketing (Facebook, Inc.)
Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook, Inc.
which connects TOP Consulting & Services’ business with the Facebook advertising network.
Personal Data Processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Privacy Shield Adherent.
Facebook Custom Audience (Facebook, Inc.)
Facebook Custom Audience is a remarketing and behavioral targeting service provided by Facebook, Inc.
which connects TOP Consulting & Services’ business with the Facebook advertising network.
Personal Data Processed: Cookies; email.
Place of processing: United States – Privacy Policy – Opt Out.
Privacy Shield Adherent.
Remarketing with Google Analytics (Google LLC)
Remarketing with Google Analytics is a remarketing and behavioral targeting service provided by Google LLC that links the tracking activity performed by Google Analytics and its Cookies with the Google Ads advertising network and the Doubleclick Cookie.
Personal Data Processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Privacy Shield Adherent.
Recipients to whom the data will be disclosed
Data collected for requests from the data subject with respect to requests organized by the Controller may be disclosed to authorized data processors and responsible suppliers necessary for the processing of personal data.
Data collected for the implementation of advertising actions by the Owner and for profiling activities: there are no data communications to third party recipients, but the data may be processed by managers in charge of processing with specific legal act.
Rights of data subjects
Within the limits and conditions prescribed by law, the owner is obliged to respond to requests from the data subject regarding personal data concerning him or her.
In particular, according to current legislation:
1. The data subject shall have the right to obtain from the data controller confirmation as to whether or not personal data concerning him or her are being processed and, if so, to obtain access to the personal data and the following information:
- the purposes of processing;
- the categories of personal data in question;
- The recipients or categories of recipients to whom the personal data have been or will be disclosed, particularly if recipients in third countries or international organizations;
- when possible, the intended retention period of personal data or, if not possible, the criteria used to determine this period;
- the existence of the data subject’s right to request from the data controller the rectification or erasure of personal data or the restriction of the processing of personal data concerning him or her or to object to their processing;
- The right to file a complaint with a supervisory authority;
- where the data are not collected from the data subject, all available information about their origin;
- The existence of automated decision making, including profiling
2. The data subject has the right to obtain from the data controller the rectification of inaccurate personal data concerning him/her without undue delay.
Taking into account the purposes of the processing, the data subject has the right to obtain the integration of incomplete personal data, including by providing a supplementary declaration.
3. The data subject shall have the right to obtain from the data controller the erasure of personal data concerning him/her without undue delay, and the data controller shall be obliged to erase without undue delay the personal data within the limits and in the cases provided for by the current legislation.
The data controller shall notify each of the recipients to whom the personal data have been transmitted of any rectification or erasure or restriction of the processing within the limits and in the forms provided for by current legislation.
4. The data subject has the right to obtain from the data controller the restriction of processing.
5. The data subject shall have the right to receive in a structured, commonly used and machine-readable format personal data concerning him or her that have been provided to a data controller and shall have the right to transmit such data to another data controller without hindrance from the data controller to whom he or she has provided them.
The Data Protection Officer can be contacted at the following e-mail address: dpo@topcs.it
Last updated: September 13, 2021
- Rome
- Benedetto Croce Street, 44
- Milan
- Sarca Avenue, 336