PRIVACY POLICY AND COOKIES INFORMATION – Top Affiliation

PRIVACY POLICY AND COOKIE INFORMATION

This document serves the informative function according to articles 12 et seq. of Regulation (EU) 2016/679 (the “Regulation” or “GDPR”) on the processing of Personal Data collected on the websites of Advice Island Limited

DEFINITIONS

Personal Data: Any information concerning the Data Subjects, such as personal details, location, tax code, IBAN, as defined in Article 4 co.1 of the Regulation.
Data Subjects: Individuals whose Personal Data is collected and processed by the Data Controller through the Website (also referred to as “Users”).
Websites: Websites owned by Advice Island Limited
Products: Products and services offered to the public by the Data Controller through the Websites.

DATA CONTROLLER

In relation to the Websites and/or Products, the Data Controller is exclusively Advice Island Limited, with registered office at L3a/4a-240 Msida Road
GZR 1400 Gzira Malta

SOURCE OF PERSONAL DATA

Personal Data processed by the Data Controller is acquired directly from the Data Controller and/or through third parties specifically appointed for this purpose. Such data is freely provided by the Data Subject (e.g., through requests sent to the Data Controller using the designated contact forms) and/or is acquired by the computer systems responsible for the operation of the Website during its normal use.

PURPOSES AND LEGAL BASIS OF PROCESSING

1. Responding to Data Subject’s requests

Based on the existing Contract with the Data Subject or for the execution of pre-contractual measures taken at the request of the Data Subject, Personal Data is processed by the Data Controller to respond to the requests received – through forms, chat, or by sending communications to the contacts (including email addresses) listed on the Website.

2. Identification and registration of the User on the Website and creation of the account and/or profile (if applicable)

Based on the Contract with the Data Subject or for the execution of pre-contractual measures taken at the request of the Data Subject, Personal Data is processed by the Data Controller to identify the User and allow them to complete the registration procedure on the Website and create a personal account/profile.

3. Access to the Website and management of the account and/or profile (if applicable)

Based on the registration made, or based on the Contract with the Data Subject or for the execution of pre-contractual measures taken at the request of the Data Subject, Personal Data is processed by the Data Controller to allow the Data Subject to access the Website and modify/manage their personal account.

4. Compliance with legal obligations, as well as orders/decisions of Public Authorities and/or Supervisory Bodies

To fulfill a legal obligation to which the Data Controller is subject, Personal Data is processed by the Data Controller to comply with regulatory obligations, both national and supranational (e.g., obligations imposed by legislation aimed at combating money laundering, corruption, terrorism, the marketing of child pornography material, and tax evasion, etc.), and any orders and/or decisions of Public Authorities, Supervisory Bodies, and public security authorities.

5. Protection of business assets

Based on the legitimate interest of the Data Controller, Personal Data of the Data Subject may be processed by the Data Controller to establish liability in the event of cybercrimes against the Data Controller and/or the Website.

6. Sending the Data Subject information about the operation and characteristics of gaming services and the existence of new products and/or services related to them (if specific consent is required)

Subject to specific consent from the Data Subject and in line with any preferences expressed by the Data Subject, Personal Data will be processed for sending informative communications about the operation and characteristics of gaming services marketed by the Data Controller and companies of the Group (e.g., information regarding odds, jackpots, winning probabilities, minimum bets, any bonuses offered) and the existence of new products and/or services related to them.

7. Profiling (if specific consent is required)

Subject to specific consent from the Data Subject, Personal Data will be processed to profile the Data Subjects connected to sending information about the operation and characteristics of gaming services and the existence of new products and/or services related to them by the Data Controller. Profiling will be carried out by processing certain “clusters” (homogeneous groups consisting of profiles that show a degree of correlation), after analyzing the habits and interests expressed by the Data Subjects through the use of gaming services.

CATEGORIES OF PROCESSED DATA

The Personal Data that may be processed by the Data Controller for the purposes indicated in the previous paragraph belongs to the following categories:

Identifying and contact data: Name, surname, place and date of birth, email address, tax code, username, and password used to access the systems made available to the Data Subject by the Data Controller.
Connection data: IP address of the device used, time and duration of the connection.
Data suitable to reveal tastes, preferences, habits, interests: Browsing preferences, activities carried out on the Website.
Location data of the device used: (if the Website requires it and the User has activated this functionality).
Transaction data: (date and time, amount, method) where the Website provides for them.
Any other data voluntarily communicated to the Data Controller by the Data Subjects: (e.g., through the completion of the forms on the Website).

PROCESSING METHODS

The processing of Personal Data takes place through automated and manual tools, adopting methods strictly related to the purposes indicated and, in any case, in order to guarantee the security and confidentiality of the data.

LEGAL BASIS

The legal bases of the processing are those established by the Regulation, as indicated in the previous paragraph next to each purpose.

COMMUNICATION AND DISSEMINATION OF DATA

Personal Data may be disclosed to recipients, appointed under article 28 of the Regulation, who will process the data as Data Processors and/or as natural persons acting under the authority of the Data Controller and Data Processor, in order to comply with contracts or related purposes. Precise indications on the subjects to whom the data may be communicated will be provided at the time of registration on the Website, without prejudice to the communication made to comply with legal obligations. The data collected may also be disclosed to third parties, independent data controllers, for purposes related to the provision of the service offered through the Website. In any case, these subjects will have to guarantee the adoption of security and confidentiality criteria equal to those adopted by the Data Controller. Personal Data will not be disseminated.

TRANSFER OF DATA ABROAD

The processing of Personal Data by the Data Controller will take place within the territory of the European Union. If, in the future, the Data Controller intends to transfer Personal Data to countries outside the European Union, the transfer will take place only if there is an adequacy decision by the European Commission or, in the absence of such a decision, if the Data Controller and/or Data Processor have adopted adequate safeguards.

STORAGE PERIOD

Personal Data will be processed for the time strictly necessary to achieve the purposes indicated in the previous paragraph. Without prejudice to the subsequent obligations established by law, once the purposes of processing cease, the Data will be erased or anonymized.

DATA SUBJECT RIGHTS

The Data Subject may exercise the rights recognized by articles 15 to 21 of the Regulation, including, by way of example, the right to ask the Data Controller for access to their Personal Data, rectification, and erasure of the same or the limitation of processing, and to object to processing, as well as the right to data portability. The Data Subject also has the right to lodge a complaint with the Supervisory Authority.

AMENDMENTS

The Data Controller reserves the right to modify or simply update the content of this document, in part or in full, also due to changes in the applicable legislation. The Data Controller will inform the Data Subjects of such changes as soon as they are introduced and they will be binding as soon as they are published on the Website. The Data Subject is therefore invited to regularly access this section to check the publication of the most recent and updated Privacy Policy and Cookie Information.

RIGHTS OF THE DATA SUBJECT

Pursuant to art. 15-22, the Regulation gives Data Subjects the opportunity to exercise specific rights.

In particular, the Data Subject may obtain:

Confirmation of the existence of processing of Personal Data concerning him/her and, if so, access to such data.
The rectification of inaccurate Personal Data and the completion of incomplete Personal Data.
The erasure of Personal Data concerning him/her, in cases where this is permitted by the Regulation.
The restriction of processing, in the cases provided for by the Regulation.
The communication, to the recipients to whom the Personal Data have been transmitted, of the requests for rectification/deletion of the Personal Data and for the limitation of processing received from the Data Subject, unless this proves impossible or involves a disproportionate effort.
The receipt, in a structured, commonly used and machine-readable format, of the Personal Data provided to the Data Controller, as well as the transmission of the same to another data controller, and this at any time, including at the termination of any relations maintained with the Data Controller (so-called data portability).
The right to object at any time, for legitimate reasons, to the processing of Personal Data concerning him/her, even if pertinent to the purpose of the collection, as well as to the processing of Personal Data for the purpose of sending advertising material or direct sales or for carrying out market research or commercial communication and profiling, to the extent that it is related to direct marketing.
The right not to be subject to a decision based solely on automated processing (including profiling) which produces legal effects concerning him or her or similarly significantly affects him/her, unless such decision:
1. it is necessary for the conclusion or execution of a Contract between the Data Subject and the Data Controller;
2. is authorised by the law of the Union or of the Member State to which the Data Controller is subject;
3. is based on the explicit consent of the Data Subject.

Requests can be submitted to the email address info@topaffiliation.com, indicating in the subject “Privacy – exercise of Privacy rights”.

The Data Subject also has the right to lodge a complaint with the Data Protection Authority, as provided for by art. 77 of the Regulation, as well as to take legal action pursuant to art. 78 and 79 of the Regulation.

NATURE OF THE PROVISION

The provision of data is mandatory for the purposes referred to in points 1) to 5) of the paragraph “Purpose and legal basis of processing”. Any refusal by the Data Subject to provide the necessary information will make it impossible for the Data Controller to follow up on the interaction with the Site by the Data Subject and to respond to the Data Subject’s requests. On the other hand, the provision of data for the purposes described in points 6) and 7) of the paragraph “Purpose and legal basis of processing” is optional. The only consequence deriving from the refusal to provide the data will be the impossibility for the Data Subject to use the related services, without this entailing any further detrimental consequences.

CONSENT

Pursuant to art. 6, paragraph 1, letters b), c) and f) of the Regulation, consent is not required when the processing is necessary for the execution of a Contract to which the Data Subject is a party or for the execution of pre-contractual measures adopted at the request of the same, to comply with a legal obligation to which the Data Controller is subject or for the pursuit of the legitimate interest of the Data Controller or third parties, as provided for the purposes referred to in points 1) to 5) of the paragraph “Purpose and legal basis of the processing”. On the contrary, consent is specifically required where the provision of Personal Data is not necessary for the above requirements.

COOKIE

The Site uses so-called “cookies”, i.e. small text strings that websites send and store on the device used by the User for browsing, in order to be able to use them the next time the User visits. While browsing, the User may also receive cookies on their device that are sent by websites or web servers other than those of the Owner of the website being visited (i.e. belonging to so-called “third parties”). Cookies are uniquely assigned to the User and can only be read by the web server of the domain that sent them. Cookies can be used for different purposes such as, for example, performing computer authentication, monitoring sessions or storing information on specific configurations regarding Users accessing the server. It should be noted that cookies cannot be used to run programs or download viruses to the User’s computer, nor are they designed to automatically collect data from the User’s hard drive and illegally transmit the User’s personal data or the contents of their system to third parties.

In general, cookies can be “technical” or “profiling”.
⸱ Technical cookies: technical cookies are installed on the User’s browser in order to allow the correct functioning of the websites, identify the User when he logs in, analyze navigation in order to constantly optimize it and conduct analyses aimed at improving the appearance, functionality and security of the websites. In particular, technical cookies can be session cookies, designed to ensure normal navigation and use of the website, permanent, including, for example, analytics cookies, which are used to collect information, in aggregate form, on the number of Users who visit the website and how the interaction takes place, or functionality cookies, which allow the User to browse according to a series of selected criteria, such as language. The prior consent of Users is not required for the installation of these cookies.
⸱ Profiling cookies: profiling cookies are used to create profiles relating to the User and are used in order to send advertising messages (the so-called “profiling cookies”). banner) in line with the preferences expressed by the same in the context of navigation. Therefore, for the installation of these cookies, the legislation provides that the User must express a valid consent. Profiling cookies may be used for marketing/retargeting activities, for example to present Users with advertisements packaged by the owners on other sites, based on the use that Users make of the websites. Websites may also use pixel tags and web beacons, which are images embedded on the sites for the purpose of measuring and analyzing site usage, as well as third-party media widgets/plug-ins to enable the use of social networking sites and the sharing of content from the websites visited with their accounts. These interactive programs collect the IP address of the Users, the page visited on the website and configure cookies to allow the widgets/plug-ins to function properly. Users’ operations with such widgets/plug-ins are governed by the privacy policy of the third-party companies that provide them.

This Site uses only technical cookies with the purpose of allowing the User to browse the Site and provide the services requested.

The use of cookies can be avoided by the User by setting the appropriate settings of their browser. However, Users who choose to delete technical cookies from their device or to prevent their storage may not have all the features of the website visited available. In addition, even with all cookies disabled, your browser may continue to store less information that is necessary for the basic functionality of the Site.

If you wish to change your settings on the installation and use of cookies, please see the instructions below by selecting a web path depending on the browser you are using:

Browser

Cookie Settings

Chrome https://support.google.com/chrome/answer/95647?hl=it

Microsoft Internet Explorer https://support.microsoft.com/en-gb/windows/delete-and-manage-cookies-168dab11-0753-043d-7c16-ede5947fc64d

Mozilla Firefox https://support.mozilla.org/en-US/kb/enhanced-tracking-protection-firefox-desktop?redirectslug=enable-and-disable-cookies-website-preferences&redirectlocale=en-US

Safari https://support.apple.com/it-it/guide/safari/sfri11471/mac