Updated on 31 July 2019
As we are a company registered in the Republic of Estonia, the processing of your personal data shall be governed by the laws of the Republic of Estonia.
We will always be open and honest about the way in which we manage personal identifiable information. You have many rights that you can use to control your privacy and we respect those rights. We want to help you exercise your rights, so you will find details on how to do so below.
You have the right to make a complaint at any time to a supervisory authority. The Estonian Data Protection Inspectorate (registered offices at Väike-Ameerika 19, 10129 Tallinn, tel. +372 627 4135, e-mail firstname.lastname@example.org) is the lead data protection supervisory authority for Top Connect as being an Estonian data controller.
First and foremost, it is important for us to emphasize that we comply with all relevant data protection principles when processing your personal data. These principles relate to:
Personal data we collect and purpose for processing of personal data
Personal data means any information relating to an identified or identifiable natural person. You don´t have to give us any personal information in order to use most of our Website. However, we may collect personal information that you voluntarily provide to us when you request information about our services, submit questions to us, subscribe to our services and when you choose to submit your resume in relation to career opportunities posted on our Website. Any information you send us for the purpose of a job application will be treated by us with the greatest care and for that purpose only.
If you subscribe to our newsletter via our Website or otherwise provide us with your contact details, Top Connect may send you updates, newsletters or other alerts which may be of interest to you. For marketing purposes, we may monitor whether you open and/or click on URLs in our newsletters.
Top Connect will use your personal data for customer service, to provide you with information that you may request, and to customize your experience on the Website. Your personal data is used by Top Connect to respond to your requests, tailor offerings to you, and for general internal business purposes.
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 Top Connect or part of this company 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 visitors.
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.
Top Connect may process your personal data because (a) we need to perform a contract with you; (b) you have given us your consent to do so; (c) the processing is in our legitimate interests and it´s not overridden by your rights and/or (d) to comply with the law.
Our Website may contain links to third-party websites and applications that are not affiliated with us. We do not in any way endorse or make any representations about such third-party websites and applications. Any information you provide on third-party websites or services is provided directly to the operators of such services and is subject to those operators’ policies, if any, governing privacy and security, even if accessed through our Website. We are not responsible for the content or privacy and security practices and policies of third-party sites or services to which links or access are provided through the Website. We encourage you to learn about third parties’ privacy and security policies before providing them with information.
We may employ third party companies and individuals to facilitate our Website, to provide services on our behalf, to perform related services or to assist us in analyzing how our Website is used. These third parties have access to your personal data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
Under certain circumstances, we may be required to disclose your personal data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency). We also reserve the right to disclose personal data or other information that we believe, in good faith, is appropriate or necessary to (i) take precautions against liability, (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activity, (iii) investigate and defend ourselves against any third-party claims or allegations, (iv) protect the security or integrity of the services and any facilities or equipment used to make the services available, or (v) protect our property or other legal rights, enforce our contracts, or protect the rights, property, or safety of others.
We will notify visitors of inquiries made by public authorities to the maximum extent permitted by law through our communication channels.
We use automatically collected information and other information collected on our website and services through cookies and similar technologies. Cookie is a piece of data temporarily stored on the visitor’s hard drive containing information about the visitor. A cookie contains your contact information and information to allow us to identify your computer using our Website. 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. However, if you do not accept cookies, you may not be able to use some portions of our Website.
We use Google Analytics to measure and evaluate access to and traffic on the Website and create visitor navigation reports for our administrators. Google operates independently from us and has its own policies which we strongly suggest you review. Google may use the information collected through Google Analytics to evaluate visitors’ activity on our Website. For more information, see Google Analytics Privacy and Data Sharing.
We take measures to protect the technical information collected by our use of Google Analytics. The data collected will only be used on a need to know basis to resolve technical issues, administer the services and identify visitor preferences; but in this case, the data will be in non-identifiable form. We do not use any of this information to identify our visitors.
The Website may make available to its visitors’ chat rooms, forums, message boards, and/or other community functions. Remember that any information you disclose in these areas becomes public information and you should exercise caution when deciding to disclose your personal, financial or other information.
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.
However, please note that no electronic transmission or storage of information is 100% secure. Therefore, despite the security measures that we have put in place to protect personal data about you, we cannot guarantee that loss, misuse, or alteration of data will never occur. If we learn of a security systems breach, we will inform you and the authorities of the occurrence of the breach in accordance with applicable law.
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.
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.
We use collected statistical data for analysis for up to three years. Cookies are usually valid for a short term (a day, a week or a month), though in some cases they may remain valid for up to a year.
Under certain circumstances, by law you have the right to:
If you want to exercise any of these rights, then you may contact us through our Contact page or contact our DPO.
By using our Website, you consent to the collection and use of any personal data in the manner described.