Privacy policy

Welcome to TOPPIN!!! The purpose of this policy is to inform you about the various processing carried out by TOPPIN through this application and affecting your personal data in accordance with the provisions of the applicable data protection laws. Throughout this policy we may refer to you directly or by the words “user” or “data subject”.

 

Contact details

 You are visiting the TOPPIN application owned by TOPPIN GLOBAL COMPANY S.L,  residing at C/ALGEPSERS, with N.I.F. B16886756, PUERTA 1, 46980, PATERNA, VALENCIA, hereinafter THE HOLDER.

You can contact the HOLDER/TOPPIN by any of the following means:

Contact e-mail:  privacy@topping.es

 

Purposes of the processing of your personal data

The main purpose of the processing of personal data of TOPPIN users is to provide and improve the service. The other purposes are set out below. Read on for more information:

  • Creating, registering and managing accounts, offering our services and responding to different user requests.
  • Display and recommend the different user profiles to other TOPPIN users.
  • Administration of sweepstakes, contests, discounts and other offers and, where appropriate, communicate with users to inform them about our products or services.
  • Interacting and consulting with users to improve the quality of our products or services.
  • Informing users of our benefits, sweepstakes, opportunities and new products and services.
  • Identify and deal with those violations and inappropriate conduct or conduct contrary to good faith and our terms of use, as well as store information related to violations of our terms of use, in order to prevent recurrence.
  • To understand the behavior of the surfer within the application in order to detect possible computer attacks on the application.
  • To protect and exercise our rights or respond to claims of any kind.

 

Legal basis for processing

  • Consent of users, provided to treat your data for the purposes indicated. The refusal to provide such consent will lead to the impossibility of processing your data for the purposes mentioned, and therefore TOPPIN can not provide its service to users of the application.
  • Compliance with applicable legal obligations. In this case, the data subject may not refuse the processing of personal data.
  • Legitimate interest on the part of TOPPIN to protect our image, business and track record by preventing attacks on our application In this case, the data subject may not refuse the processing of personal data, but may exercise, where appropriate, the rights recognized in this privacy policy.

 

Data retention periods or criteria

The personal data provided will be kept for the time necessary to fulfill the purposes for which they were initially collected.

Once the data are no longer necessary for the processing in question, they will be kept duly blocked in order to, where appropriate, make them available to the competent Public Administrations and Bodies, Judges and Courts or the Public Prosecutor’s Office, during the period of limitation of actions that may arise from the relationship maintained with the client and/or the legally established retention periods.

 

Automated decisions and profiling

TOPPIN does not make automated decisions or profiles. However, we inform you that through our algorithms, if you have selected to search for profiles that are close to your location, only that location will be used for those strict purposes. No profiling is done based on tastes or interests, but it will be the user who directly selects the users who are of interest based on the hobbies that each one publishes and personalizes in the application.

 

Destinatarios

For the duration of the processing of your personal data, the organization may transfer them to the following recipients:

  • Judges and Courts.
  • State Security Forces and Corps.
  • Other authorities or competent public bodies, when the responsible has the legal obligation to provide personal data.
  • Banks and Financial Institutions.
  • Payment processing and telecommunications companies.

For the provision of the service we can hire third parties who must have access to your data to enable the operation of the application. Such access is secure and is covered by a contract of processing. We carry out a prior evaluation process of suppliers to ensure that they have adequate measures for the protection of personal data. We carry out a prior evaluation process of suppliers to ensure that they have adequate measures in place to protect personal data

 

International data transfer

 TOPPIN does not make international transfers of personal data. Our servers are hosted within the European Union. However, you should know that the application has a universal scope so that any user anywhere in the world can use it. This may involve an international transfer of data from your place of residence to Spain. This transfer is consented to by the user by downloading the application and accepting the terms, conditions and this privacy policy.

 

Rights

You may at any time and free of charge exercise your rights of access, rectification and deletion, as well as request to limit the processing of your personal data, oppose to it, request the portability of these (whenever technically possible) or withdraw the consent given, and where appropriate, where appropriate, not to be subject to a decision based solely on automated processing, including profiling.

To do so, you may use the forms provided by the organization, or send a letter to the postal address or e-mail address indicated above. We may request a photocopy of your ID card or equivalent document, in order to prove your identity when there are reasonable doubts about it and we can not do it by other means.

In case you feel that your rights concerning the protection of your personal data have been violated, especially when you have not obtained satisfaction in the exercise of your rights, you can file a complaint with the competent Data Protection Control Authority.

In case you do not wish to receive more information about our services, you can unsubscribe by sending an email to the address mentioned at the begining of this policy, with subject “UNSUBSCRIBE” or by clicking on the mail section *to unsubscribe*.

 

Veracity

 The interested party guarantees that the data provided are true, accurate, complete and up to date; undertaking to inform of any change with respect to the data provided, through the channels provided for this purpose and indicated in point one of this policy. The user will be responsible for any damage or harm, both direct and indirect, that may be caused as a result of non-compliance with this obligation.

In the event that the user provides data of third parties, he/she declares that he/she has the consent of the interested parties and undertakes to transfer the information contained in this clause, exempting the organization from any liability arising from failure to comply with this obligation..

 

Social Network

 Social Networks are part of the daily life of many Internet users, and for them the Entity has created different profiles in some of them.

All users who visit our application have the opportunity to join our social networks or groups.

However, you should keep in mind that, unless we request your data directly (for example, through marketing actions, contests, promotions, or any other valid way), your data will belong to the corresponding Social Network, so we recommend that you carefully read your terms of use and privacy policies, as well as, be sure to configure your preferences regarding the processing of data.

On the other hand, when you log in to our application with your Facebook or Goole account, you give them permission to share with us certain data from your profile. In case you delete the application from your Facebook settings, or from your Apple ID, do not forget to delete your TOPPIN account as well..

 

Type of information we collect

The type of information we collect and process will depend at all times on the way in which you interact with us, the service or the source of data collection. We inform you that the data we obtain comes directly from you or from those sources that the interested party has wished to share directly with us when creating their account through external platforms or social networks or by linking the latter to the application.

  • Identifying information: such as your first and last name, email address, postal address, telephone number and other similar contact information.
  • User data: such as passwords and other security information for authentication and access, IP address or location.
  • Academic and professional data: Education and/or qualifications.
  • Employment details: Occupation.
  • Economic-financial data. Banking data, credit cards.
  • Personal characteristics data. Language.
  • Data of the device through which you connect (unique identifier, model and operating system).
  • Special category data: sexual orientation.
  • Location data (wifi access points, longitude, latitude…). We will only have access to this data while the application is in use or even in the background if you have authorized it in your privacy settings. If you have enabled location services and want to disable them, you must do it from the settings of the application itself.
  • Other: image.

Personal data means any data that identifies or makes a person identifiable either directly or indirectly. The personalization of the profile by the user, indicating tastes, introducing a personal description or other individualizing features, will depend exclusively on the interested party. Further personalization of the profile by you is completely voluntary and is not required by TOPPIN. TOPPIN only determines as obligatory those data strictly necessary for the creation and management of your profile.  TOPPIN will not be responsible for the personal data and information that users of the application exchange with each other and warns of the danger of providing personal information to strangers. .

 

Profile verification

 In case you voluntarily decide to verify your profile, we inform you that a facial recognition technology will be used to compare the selfie sent with the photos of your profile. After sending and once the profile has been verified, it will appear on the profile that it is verified and, therefore, others will know that it is really you.

 

Privacy Settings

 Within the settings tab, you can manage your account and profile, the data you want other users to see and the notifications you want to receive. TOPPIN applies privacy by design and by default, so we will ask you for any permission to access other features of your device such as location, camera or similar. .

 

Modifications / updates

This privacy policy may be modified/updated according to the established legal requirements or in order to adapt this policy to any changes. For this reason, we advise users to periodically visit our privacy policy.

If you have questions about this policy, you can contact TOPPIN through the means of contact indicated at the beginning of this policy. .