PRIVACY POLICY
The purpose of this privacy policy is to provide natural persons (data subjects) -
TOPPC.EE customers (persons who purchase goods and services from TOPPC.EE and visit the TOPPC.EE website) with information about the purposes, scope, protection, processing period and data subject's rights regarding the processing of their personal data in accordance with Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (hereinafter - GDPR GDPR).
Who processes your personal data?
The personal data controller is a
limited liability company "DATEKS GRUPA", registered in Latvia,
registration No 40103229720 (hereinafter - TOPPC.EE).
Contact information of the Data Controller TOPPC.EE - legal/office address: 9 Zemitāna Street, Riga, LV-1012, Latvia; phone +371 67275758; e-mail:
dpo@toppc.ee.
What personal data of customers does TOPPC.EE process?
No. |
Category of personal data |
Examples |
1 |
Identification data |
Name, surname, personal identification number, signature. |
2 |
Contact |
Address, phone, e-mail. |
3 |
Identity document details |
Passport or identity card details. |
4 |
Position |
Profession, occupational classification code, position held. |
5 |
Settlement data |
Name of the credit institution or other settlement institution, current account number, whether the payment was made by payment card, country of residence, amount of payment, etc., payment details as specified in the bank payment order. |
6 |
Remuneration |
Payment or consideration for goods or services made on the basis of a contract for the transfer of goods, an enterprise agreement or other transaction, incl. estimated tax payments |
7 |
Commitment performance data |
Information on commitments, incl. the amount of the debt, payment discipline, timing of payments. |
8 |
Video surveillance data |
Video image of a person, incl. appearance, behaviour, movements, location, time of recording, date. |
9 |
Device data |
Information about the device (type, model, manufacturer, serial no., etc. characteristics). |
10 |
Order data |
The goods ordered, their technical details, quantities, prices, discounts granted, date and time of order. |
11 |
Consent and communication choices |
Your consent to receive marketing and/or other communications, information about subscribing to and/or unsubscribing from communications. |
12 |
Browsing data |
Pages viewed, products viewed, date and time of viewing, duration of browsing, products placed in the shopping basket and/or wish list, date and time of insertion, ad banner clicks, other clicks and interest in content, information about where users come to the website from, including but not limited to affiliate link statistics. |
13 |
Technical data |
IP address, session ID, browser used, device type, resolution. |
14 |
Registration, login and account technical/administration details |
User ID, account status (active, blocked, etc.), IP address, technical details of account login and account activity. Created or captured automatically (including through cookies or similar technologies) when you register, log in or use your TOPPC.EE account (e.g. technical data). |
15 |
Delivery address |
The address specified by the Customer for delivery of the Devices and other goods purchased. |
16 |
Leasing data |
Information about the payment method of the Customer's Order, i.e. whether the person has an approved leasing application for the purchase of goods sold by TOPPC.EE. |
17 |
Korespondence |
Sarakste. |
For what purposes does TOPPC.EE process the personal data of its Customers?'
TOPPC.EE processes personal data of its
Customers for the following purposes:
for TOPPC.EE'
s financial and accounting records. Personal data is processed for:
- for payment (identification data, order data, payment data, device data);
- control of the use of tangible assets and settlement with advance payers (identification data, order data, device data)
- calculation and payment of wages to employees (identification data, order data)
- banking transactions and records (identification details, payment details, remuneration)
- bookkeeping and record-keeping (identification data, contact details, order data, remuneration, performance data, payment data);
- monthly, quarterly and annual reporting to public authorities (identification data, remuneration)
- What is the legal basis for processing the above personal data?
- given that financial and accounting records are strictly regulated by laws and regulations, the legal basis for the processing of these personal data is the legal obligation laid down in laws and regulations - Article 6(1)(c) GDPR;
- for the performance of a contract to which the data subject is a party or for taking measures at the request of the data subject before the conclusion of the contract - Article 6(1)(b) GDPR;
- TOPPC.EE's legitimate interests - Article 6(1)(f) of the GDPR, i.e. to ensure efficient financial and business accounting.
for the sale of goods and provision of services The personal data are processed:
- to conclude a sales contract and place an order, including concluding a distance contract (identification details, contact details, title, order details, billing details)
- ensuring the right of withdrawal (identification data, contact details, payment details, order details, device details) provided for in the laws and regulations governing consumer protection;
- organising the delivery of goods (identification details, contact details, order details, delivery address)
- execution of the leasing contract (identification data, contact details, order data) if the Customer has chosen to use a leasing service provider for the purchase of the goods;
- Provision of hardware maintenance services (identification data, contact details, device data)
- What is the legal basis for processing the above personal data?
- the fulfilment of legal obligations imposed by laws and regulations (Article 6(1)(c) GDPR), incl. ensuring the right of withdrawal;
- for the performance of a contract to which the data subject is a party or for taking measures at the request of the data subject before the conclusion of the contract (Article 6(1)(b) GDPR);
- TOPPC.EE for the pursuit of legitimate interests (Article 6(1)(f) GDPR), including providing evidence of the placing, execution and delivery of an order, improving customer service and the quality of delivery of goods.
the fulfilment of warranty obligations for goods and services, and for after-sales service. Customer personal data is processed:
- for the warranty voucher (device data)
- for the acceptance of goods and warranty repairs (identification data, contact details, device data)
- delivery of the goods for warranty repairs or after warranty repairs have been completed (identification details, contact details, delivery address, device details)
- What is the legal basis for processing the above personal data?
- the fulfilment of legal obligations imposed by laws and regulations (Article 6(1)(c) GDPR), incl. the fulfilment of obligations to guarantee goods and services under laws and regulations;
- for the performance of a contract to which the data subject is a party (Article 6(1)(b) GDPR);
- TOPPC.EE for the purposes of legitimate interests (Article 6(1)(f) GDPR), including to provide evidence of acceptance of goods and fulfilment of warranty obligations.
TOPPC.EE
to protect your interests and handle legal matters. Personal data are processed:
- referrals to law enforcement authorities and courts, including. debt recovery and police referrals related to property damage (identification data, contact details, device data, CCTV data, order data, billing data, fulfilment data);
- handling complaints and requests, providing answers (identification data, contact details, device data, CCTV data, order data, billing data, fulfilment data)
- What is the legal basis for processing the above personal data?
- the fulfilment of legal obligations imposed by laws and regulations (Article 6(1)(c) GDPR), incl. providing the requested information to the competent public authorities;
- For the purposes of TOPPC.EE's legitimate interests (Article 6(1)(f) GDPR), including the provision of evidence, detection and prevention of criminal offences to protect TOPPC.EE's financial interests, use of data in legal proceedings where necessary, debt recovery.
administering sales promotion measures The personal data are processed:
- for marketing campaigns, promotion of goods and services (identification data, contact details)
- for the administration of the affiliate software (order data, browsing data);
- for sending commercial communications (contact details, consent and communication preferences)
- What is the legal basis for processing the above personal data?
- The Customer has provided consent to the processing of his/her personal data (Article 6(1)(a) GDPR), i.e. to receive commercial communications, which is valid until revoked. The Customer is entitled at any time to opt-out of receiving further commercial communications by using the contact details of TOPPC.EE indicated in paragraph 1 or in the manner indicated in the commercial communication received.
- for the performance of a contract to which the data subject is a party or for taking measures at the request of the data subject before the conclusion of the contract (Article 6(1)(b) GDPR);
- TOPPC.EE's legitimate interests (Article 6(1)(f) GDPR), including advertising TOPPC.EE's goods and services, promoting the sale of goods.
for the functionality of the www.TOPPC.EE website. Personal data is processed:
- For the creation and maintenance of a customer profile on TOPPC.EE (identification data, contact details, order data, delivery address, correspondence, billing data, leasing data, fulfilment data, consent and communication preferences, registration, browsing data, login and account technical/administration data);
- administration of cookies to ensure the functionality of the website, to analyse the history of visits to social networks (device data, browsing data, technical data). For more information see TOPPC.EE cookie policy.
- What is the legal basis for processing the above personal data?
- The customer has given consent to the processing of his/her personal data (Article 6(1)(a) GDPR);
- TOPPC.EE's legitimate interests (Article 6 (1) (f) GDPR), including providing evidence that a visitor to TOPPC.EE's website has accepted a particular category of cookies; improving the quality of services provided by TOPPC.EE's website; promoting the sale of TOPPC.EE's goods and services.
to maintain the data processing and protection system The personal data are processed:
- To inform the customer about the processing of personal data (identification data, contact details) by TOPPC.EE;
- data for incident investigation (identification data, position, contact details, device data, order data) in case of an incident;
- informing data subjects (identification data, contact details) if TOPPC.EE would be obliged to do so due to a data incident;
- handling of applications and complaints from data subjects (identification data, device data, order data, contact details);
- What is the legal basis for processing the above personal data?
- the fulfilment of legal obligations imposed by laws and regulations (Article 6(1)(c) GDPR), incl. provision of information requested by the competent public authorities, informing data subjects;
- For the purposes of TOPPC.EE's legitimate interests (Article 6(1)(f) GDPR), including providing evidence that TOPPC.EE has taken all necessary security measures; improving the security and quality of information systems.
By carrying out video surveillance in the office of TOPPC.EE, personal data are processed for the purposes of the legitimate interests of TOPPC.EE (Article 6 (1) (f) GDPR), i.e. for the prevention and detection of criminal offences in connection with the protection of TOPPC.EE property. In cases where TOPPC.EE is required to process personal data by law or contract, or as a precondition for entering into a contract, TOPPC.EE cannot ensure the sale of goods and provision of services without processing all necessary personal data.
Who are the recipients of personal data?
- state and local authorities in cases where TOPPC.EE provides the requested information in compliance with the legal requirements of these authorities;
- courts and law enforcement authorities when TOPPC.EE provides personal data for the protection of its own interests or the interests of third parties, for the prevention and detection of criminal offences;
- legal aid providers when you need them TOPPC.EE
- auditors and auditors carrying out financial and accounting audits and/or audits of TOPPC.EE;
- the postal and courier service provider, ensuring the delivery and return of the goods ordered by the Customer;
- credit institutions when administering settlements
- manufacturer-authorised repairers for warranty repairs or other repair and maintenance work on devices for which only an authorised repairer is authorised to carry out such work;
- The leasing company chosen by the Customer in case the Customer wishes to purchase goods by engaging a leasing service to provide details of the goods ordered by the Customer;
- the telecommunications service provider to inform the Customer about the performance of the service;
- marketing service providers that receive data about individual cookies (see cookie policy for details);
- personal data may also be provided to other TOPPC.EE cooperation partners, if this is necessary for the performance of specific functions or tasks and if these partners provide TOPPC.EE with appropriate guarantees regarding the processing and protection of personal data.
- TOPPC.EE keeps personal data as long as there is a legal basis for TOPPC.EE to keep personal data:
- within the retention periods laid down in the laws and regulations governing financial and accounting records;
- as long as TOPPC.EE, its customer or supplier can exercise its legitimate interests (e.g. to file objections, to bring or pursue legal action, the product warranty is valid, etc.) in accordance with the procedure established by external laws and regulations;
- as long as a contractual obligation exists between TOPPC.EE and the Customer. For example, the Customer places orders and makes payments through the profile created on the website;
- CCTV data is stored for 30 days. In case of suspicion of criminal offences, personal data is necessary for the protection of legitimate interests of TOPPC.EE or third parties or a request from law enforcement authorities, the data is stored as necessary.
TOPPC.EE does not transfer personal data to third countries or international organisations
By contacting the controller - TOPPC.EE, using the contact information provided in Section 1 of this Privacy Policy, the data subject, i.e. the Customer, is entitled under the GDPR to request from TOPPC.EE:
- access to the data subject's personal data, to provide the Controller with the data subject's personal data held by the Controller;
- rectification or erasure of personal data concerning the data subject;
- restrict (temporarily suspend) the processing of some or all of the data subject's personal data;
- to stop automated processing of the data subject's personal data (automated individual decision-making in relation to the Customer). TOPPC.EE does not carry out profiling;
- request portability of personal data in the cases set out in the GDPR.
The data subject, i.e. the Customer, has the following rights in relation to the processing of personal data carried out by
TOPPC.EE, if
the processing is based on the data subject's consent:
- If the processing of personal data is based on the data subject's consent, the data subject has the right to choose to what extent and what data to submit to TOPPC.EE, as well as at any time to withdraw consent to the processing of personal data in whole or in part by asking TOPPC.EE to stop processing all or certain part of the data subject's personal data. The withdrawal of consent shall not affect the lawfulness of the processing of the data subject's personal data carried out prior to the withdrawal;
- Taking into account that TOPPC.EE needs to unambiguously identify the data subject who withdraws consent to the processing of personal data in whole or in part, the data subject may submit the withdrawal, which contains the data subject's identification data, including name, surname, date, as well as the extent to which the data subject's consent to data processing is withdrawn, in one of the following ways: 1) by sending a self-signed revocation to the address provided in this Privacy Policy 1.2) by sending a revocation signed with a secure electronic signature to the e-mail address of TOPPC.EE indicated in paragraph 1 of this Privacy Policy; 3) by coming in person to the office of TOPPC.EE indicated in paragraph 1 of this Privacy Policy and presenting an identity document; 4) by using the links indicated in the commercial communication or cookie communication.
The data subject, i.e. the Customer, has the right to obtain from TOPPC.EE information about the fact of transfer of the data subject's personal data to third parties and about the persons (natural or legal) and/or state institutions to which TOPPC.EE has provided any information related to the personal data of a particular data subject (unless such information is provided on the basis of a request by the subject of operational activity or other competent institution and the law directly prohibits disclosure of the relevant information).
- In case of any questions regarding the processing or protection of personal data by TOPPC.EE, the data subject, i.e. the Customer, has the right to contact TOPPC.EE using the contact details of TOPPC.EE specified in Section 1 of this Privacy Policy.
- In case of disagreement in relation to the processing of personal data by TOPPC.EE, the data subject has the right to lodge a complaint with the supervisory authority - the Data State Inspectorate.
- TOPPC.EE may make changes to this Privacy Policy if the amount, type or circumstances under which personal data is processed change. In such case, TOPPC.EE will provide data subjects with the relevant information. This is the Customer Privacy Policy as of: 08.03.2023.