Nothing is changing about your current settings or how your information is processed. Rather, we’ve improved the way we describe our practices and how we explain the options you have to update, manage, export, and delete your data.
We’re making these updates as new data protection regulations (GDPR) come into effect in the European Union, and we’re taking the opportunity to make improvements for our users.
The revised policy is available here and will take effect on May 25, 2018
- 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 Travel Sim services. Top Connect is registered in Estonia with registration number 10668897 and registered offices at Väike-Paala St. 1, 11415 Tallinn. Top Connect as a provider of the TravelSim services, 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 personal identifiable information.
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 email@example.com) is the lead data protection supervisory authority for Top Connect as an Estonian data controller.
- 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 will collect personal data from you that is necessary for the purposes of supplying to you the service you subscribe to, such as name, postal address, email address, and telephone number. Top Connect may also collect information about your location. This information is based on the cell tower locations used to transmit your mobile phone call, or the local country access numbers dialed to use your phone card.
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 Travel Sim products and services. Children under the age of 16 in Estonia, or equivalent minimum age in the relevant jurisdiction, are not permitted to use TravelSim 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 TravelSim 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 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 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, QIWI, WebMoney, PayPal etc. electronic payment measures) 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, some of which are not located in the European Union, such as Ukraine and USA and Russia, (for which EU Commission has not adopted adequacy decision). While countries outside the EU do not always have strong data protection laws, we require all services providers to process your information in a secure manner and in accordance with Estonian and 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 as a TravelSim 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;
If you do not provide personal data referred in clause 2, Top Connect will not be able to provide its services to you.
- Community Functions
The website and services may make available to its users 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.
- 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 till it is necessary to provide TravelSim services or till 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 informationabout whether we hold personal information about you, and, if so, what that information is and why we are holding or using it.
– Request accessto your personal data (data subject access request). This enables you to receive a copy of the personal data we hold about you.
– Request correctionof the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected.
– Request erasureof 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 processingof 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-makingincluding profiling, that is not to be subject of any automated decision-making by us using your personal data or profiling of you.
– Request the restrictionof 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 transferof 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.
Top Connect is committed to allowing our customers to conduct their activities through any of the services we provide without being required to identify themselves. In some circumstances, such as providing us with credit card details, we obviously cannot deal with you anonymously. However, unless there are good practical or legal reasons that require you to be identified, we will give you the option of operating anonymously or pseudo-anonymously.
- Cookies, site tracking 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 TravelSim 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.
We use tracking software to monitor client traffic patterns and site usage to help us develop the design and layout of the websites. This software does not enable us to capture any personal data.
This website may contain links to other sites. Please be aware that Top Connect is not responsible for the privacy practices of such other sites. This privacy statement applies solely to information collected by this website.