Connectivity reinvented

privacy-policy Website Privacy Policy

This revised Privacy Policy is available here and will take effect on May 25, 2018 since a new data protection regulations (GDPR) come into effect in the European Union, and we’re taking the opportunity to make improvements for our users.
This privacy policy sets out how Top Connect OÜ uses and protects any information that you might give Top Connect OÜ when you use our website.
Top Connect OÜ is committed to ensuring that your privacy is protected. Should we ever ask you to provide any information by which you can be identified when using our website, then you can be assured that it will only be used in accordance with this privacy statement.
Top Connect reserves the right to change the terms of this Privacy Policy. Any changes will be posted on this page. You should check this page regularly to ensure that you are happy with any changes. Notification will be sent also by email, if your email is available for Top Connect.

Data controller

OÜ Top Connect (referred to as “Top Connect”, “we”, “us” or “our” in this policy) is the data controller of all personal data that is collected and processed for providing services. Top Connect is registered in Estonia with registration number 10668897 and registered offices at Väike-Paala St. 1, 11415 Tallinn. Top Connect is committed to providing you with privacy safeguards that are consistent with your right to choose whether to provide information about yourself, and if you do provide it, the nature and quality of that information.
Top Connect will always be open and honest about the way in which we manage your personal data.
You have the right to make a complaint at any time to a supervisory authority. The Estonian Data Protection Inspectorate (registered offices at 19 Väike-Ameerika St., 10129 Tallinn, tel. + 372 627 4135, e-mail is the lead data protection supervisory authority for Top Connect as an Estonian data controller.
By using the website and services, you agree to the collection and use of your personal data in accordance with this Privacy Policy. It’s important you understand that by using our services, you give us consent to collect, use, disclose, and retain your personal data. We will never read or listen to the content you are sharing privately. You can be sure that we will only use your information as described in this Policy. If you do not agree with this Privacy Policy, please do not use the website or our services.

Personal data we collect and purpose for processing of personal data

Personal data means any information relating to an identified or identifiable natural person.
Top Connect may collect personal data from you that is necessary for the purpose of supplying to you the service you subscribe to or for the purpose of billing for provided services, such as name, postal address, email address, and telephone number.
In certain jurisdictions, we may ask for a government issued personal identification number (ID) in limited circumstances including when setting up a wireless account and activating your device as required by law.
Except as provided herein, Top Connect will not provide your personal data to any other person unless we ask you and you agree, or unless we are forced to do so by law.

Children’s personal data

We understand the importance of taking extra precautions to protect the privacy and safety of children using services. Children under the age of 16 in Estonia, or equivalent minimum age in the relevant jurisdiction, are not permitted to use services, unless their parent provided verifiable consent. If we learn that we have collected the personal information of a child under 16, or equivalent minimum age depending on jurisdiction, outside the above circumstances we will take steps to delete the information as soon as possible. If at any time a parent needs to access, correct, or delete data associated with child, they may contact us through our Contact page.

Processing of special categories of personal data

Top Connect will not collect or use information revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation, or any other information considered sensitive.

Non-personal Information

Top Connect may automatically collect non-personal information about you. This includes but not limited to technical information about your mobile device, system and application software, and peripherals, the type of internet browser and IP address you use and the site, which linked you to the website. This information is used to assist Top Connect in providing you with an effective website.
Top Connect uses non-personally identifiable information for internal purposes and to help us interact with visitors to the website. Top Connect may also share non-personally identifiable information in the aggregate form with third parties to illustrate trends and patterns. You cannot be personally identified from this information.

What do we use for and disclose your personal date

Top Connect may use your personal data for customer service, to provide you with information that you may request, and to customize your experience on the website or with the service. Your personal data is used by Top Connect to respond to your requests, process your transactions, tailor offerings to you, and for general internal business purposes.
Top Connect will use your financial information (bank’s account number, payment card number and other electronic payment measure’s data) to bill you for products or otherwise process your transactions. By making a purchase on the website or using the services, you consent to Top Connect providing your financial information to Top Connect’s billing service providers (credit card processor Adyen) and to such third parties as Top Connect determines for processing your transactions. These third parties may include the credit card companies and banking institutions used to process the transaction. We require all third parties to have appropriate technical and operational security measures in place to protect your personal data, in line with Estonian and EU law on data protection rules.
Top Connect operates businesses in multiple jurisdictions. We require all services providers to process your information in a secure manner and in accordance with EU law on data protection. We utilize standard means under EU law to legitimize data transfers outside the EU.
If you have given additionally your consent, Top Connect may use your personal data to contact you with information it thinks you would be interested in. If you do not want to receive this information, indicate that Top Connect may not do so at the point on the website, where you give Top Connect your personally identifiable information. If you change your mind later, you may contact us through our Contact page. Email messages will also provide you with an opportunity to opt-out of receiving this information. Please note that changes to your preferences may not be effective immediately. Please note that your removal from these communications will only apply to the processing of your data in the future and not to data that have already been processed as provided in this Privacy Policy.
If Top Connect or part of this company as a department is sold to or merges with, another company, or declares bankruptcy, some or all of the data collected from you may be transferred to a third party as a result of the transfer of assets. Top Connect may also disclose your data when Top Connect determines it necessary to comply with applicable laws or protect the interests or safety of Top Connect or other website or service users.

Legal ground for processing personal data

Legal grounds for processing your personal data are:
– processing is necessary for the performance of a contract to which the you are a party or in order to take steps at your request prior to entering into a contract;
– processing is necessary for compliance with a legal obligation to which Top Connect is subject;
– by accepting this privacy policy, you give consent for the processing of your personal data for sending you our information and offers.
If you do not provide personal data referred in clause 2, Top Connect will not be able to provide its services to you.

Personal data security

Top Connect will take reasonable steps to ensure that the data we collect from you, use or disclose is accurate, complete and up-to-date.
Top Connect will take all reasonable steps to ensure that the personal identifiable information we hold about you is protected from misuse and loss or from unauthorized access, modification or disclosure.
The data you provide to us is protected using SSL (Secure Socket Layer) technology. SSL is the industry standard method of encrypting personal information and credit card details so that they can be securely transferred over the Internet.
Top Connect will also take reasonable steps to destroy or de-identify your personal data when we no longer need it and it is not necessary retain data to comply with applicable laws.
Please note that we retain personal data until it is necessary to provide TravelSim services or until we have a legal obligation to process it.
To determine the appropriate retention period, we consider the amount, nature and sensitivity of the personal data and the purposes for which we process it. We must also consider periods for which we might need to retain personal data in order to meet our legal obligations or to deal with complaints, queries and to protect our legal rights in the event of claims being made.

Your Data Protection Rights

Under certain circumstances, by law you have the right to:
– Request information about whether we hold personal information about you, and, if so, what that information is and why we are holding or using it.
– Request access to your personal data (data subject access request). This enables you to receive a copy of the personal data we hold about you.
– Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected.
– Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing.
– Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation, which makes you want to object to processing on this ground. You also have the right to object when we are processing your personal information for direct marketing purposes.
– Object to automated decision-making including profiling, that is not to be subject of any automated decision-making by us using your personal data or profiling of you.
– Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
– Request transfer of your personal data in an electronic and structured form to you or to another party (commonly known as a right to “data portability”). This enables you to take your data from us in an electronically useable format and to be able to transfer your data to another party in an electronically useable format.
– Withdraw consent. Then you have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your data for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so.
If you want to exercise any of these rights, then you may contact us through our Contact page, or contact our Data Protection Officer by post at: Data Protection Officer, Top Connect OÜ, Väike-Paala St. 1, Tallinn 11415 Estonia.
You can check and correct some of your personal data details after logging onto the website with your account as well.

Cookies and links

A cookie is a piece of data temporarily stored on the user’s hard drive containing information about the user. A cookie contains your contact information and information to allow us to identify your computer using services. The cookie helps the user to save time. For instance, by setting a cookie on our site, you do not have to log in using your account more than once during each visit, thereby saving time while on our site. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.
Our website might contain links to other websites. However, once you have used these links to leave our site, you should note that we do not have any control over 3rd party website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites which are not governed by this privacy statement. You should refer to the privacy statement applicable to the 3rd party website that you visit.