Privacy Policy

  1. Introduction

1.1    We are committed to safeguarding the privacy of our website visitors and service users.

1.2    This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.

1.3    We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website and services, we will ask you to consent to our use of cookies when you first visit our website.

1.4    In this policy, "we", "us" and "our" references to toppersdeal.com and “you” and “User” mean any person submitting any data to us or our agent or the Website.

  1. Credit

2.1    This document was created using a template from SEQ Legal (https://seqlegal.com/free-legal-documents/privacy-policy).

  1. How we use your personal data

3.1    In Section 3 we have set out:

(a)    the general categories of personal data that we may process;

(b)    [in the case of personal data that we did not obtain directly from you, the source and specific categories of that data];

(c)    the purposes for which we may process personal data; and

(d)    the legal bases of the processing.

3.2    We may process data about your use of our website and services ("usage data"). The usage data may include [your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use]. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analyzing the use of the website and services. The legal basis for this processing is [consent] OR [our legitimate interests, namely [monitoring and improving our website and services]].

3.3    We may process [your account data] ("account data").The account data may [include your name and email address]. The account data may be processed [for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you]. The legal basis for this processing is [consent] OR [our legitimate interests, namely [the proper administration of our website and business]] OR [the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract].

3.4    We may process [your information included in your personal profile on our website] ("profile data").[ The profile data may include [your name, address, telephone number, email address, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details].] The profile data may be processed for [the purposes of enabling and monitoring your use of our website and services]. The legal basis for this processing is [consent] OR [our legitimate interests, namely [the proper administration of our website and business]] OR [the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract].

3.5    We may process [your personal data that are provided in the course of the use of our services] ("service data"). The service data may be processed [for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you]. The legal basis for this processing is [consent] OR [our legitimate interests, namely [the proper administration of our website and business]] OR [the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract].

3.6    We may process [information that you post for publication on our website or through our services] ("publication data"). The publication data may be processed [for the purposes of enabling such publication and administering our website and services]. The legal basis for this processing is [consent] OR [our legitimate interests, namely [the proper administration of our website and business]] OR [the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract].

3.7    We may process [information contained in any enquiry you submit to us regarding goods and/or services] ("enquiry data"). We do not sell or rent your personal information to third parties for their marketing purposes without your explicit consent.

3.8    We may process [information relating to our customer relationships, including customer contact information] ("customer relationship data").The customer relationship data may include [your name, your employer, your job title or role, your contact details, and information contained in communications between us and you or your employer]. The source of the customer relationship data is [you or your employer].] The customer relationship data may be processed [for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers]. The legal basis for this processing is [consent] OR [our legitimate interests, namely [the proper management of our customer relationships]].

3.9    We may process [information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website] ("transaction data").[ The transaction data may include [your contact details, your card details and the transaction details].The source of the transaction data is [you and/or our payment services provider]. The transaction data may be processed [for the purpose of supplying the purchased goods and services and keeping proper records of those transactions]. The legal basis for this processing is [the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely [the proper administration of our website and business]].

3.10  We may process [information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters] ("notification data"). The notification data may be processed [for the purposes of sending you the relevant notifications and/or newsletters]. The legal basis for this processing is [consent] OR [the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract].

3.11  We may process [information contained in or relating to any communication that you send to us] ("correspondence data"). The correspondence data may include [the communication content and metadata associated with the communication].[ Our website will generate the metadata associated with communications made using the website contact forms]. The correspondence data may be processed [for the purposes of communicating with you and record-keeping]. The legal basis for this processing is [our legitimate interests, namely [the proper administration of our website and business and communications with users]].

3.12  We may process [identify the general category of data]. This data may include [list specific items of data]. The source of this data is [identify source].] This data may be processed for [specify purposes]. The legal basis for this processing is [consent] OR [our legitimate interests, namely [specify legitimate interests]] OR [the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract].

3.13  We may process [any of your personal data identified in this policy] were necessary for [the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure]. The legal basis for this processing is our legitimate interests, namely [the protection and assertion of our legal rights, your legal rights and the legal rights of others].

3.14  We may process [any of your personal data identified in this policy] were necessary for [the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice]. The legal basis for this processing is our legitimate interests, namely [the proper protection of our business against risks].

3.15  In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process [any of your personal data] where such processing is necessary [for compliance with a legal obligation to which we are subject, or] in order to protect your vital interests or the vital interests of another natural person.

3.16  Please do not supply any other person's personal data to us, unless we prompt you to do so.

  1. Providing your personal data to others

4.1    We may disclose [your personal data] to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.

4.2    We may disclose [your personal data] to [our insurers and/or professional advisers] insofar as reasonably necessary for the purposes of [obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure].

4.3    We may disclose [specify personal data category or categories] to [our suppliers or subcontractors].

4.4    Financial transactions relating to [our website and services] [are] OR [may be] handled by our payment services providers, [identify PSPs]. We will share transaction data with our payment services providers only to the extent necessary for the purposes of [processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds].

4.5    We may disclose [your enquiry data] to [one or more of those selected third party suppliers of goods and services identified on our website] for the purpose of [enabling them to contact you so that they can offer, market and sell to you relevant goods and/or services]. [Each such third party will act as a data controller in relation to the enquiry data that we supply to it; and upon contacting you, each such third party will supply to you a copy of its own privacy policy, which will govern that third party's use of your personal data].

4.6    In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. [We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure]

  1. Retaining and deleting personal data

5.1 In Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

5.2    Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

5.3    We will retain your personal data as follows:

(a)   Your personal data will be retained for a minimum period of 3 years even if you are not using it.

5.4    Your actual order details may also be stored with us and you may access this information by logging into your account on the Website. Here you can view the details of your orders that have been completed, those which are open and those which are shortly to be dispatched and administer your address details, bank details and any newsletter to which you may have subscribed. You undertake to treat the personal access data confidentially and not make it available to unauthorized third parties. We cannot assume any liability for the misuse of passwords unless this misuse is our fault.

5.5    Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

  1. Amendments

6.1    We may update this policy from time to time by publishing a new version on our website.

6.2    You should check this page occasionally to ensure you are happy with any changes to this policy.

6.3    We [may] OR [will] notify you of [changes] OR [significant changes] to this policy [by email or through the private messaging system on our website].

  1. Your rights

7.1    In Section 7, we have summarized the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

7.2    Your principal rights under data protection law are:

(a)    the right to access;

(b)    the right to rectification;

(c)    the right to erasure;

(d)    the right to restrict processing; and

(e)    the right to complain to supervisory authority.

  1. About cookies

8.1    A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

8.2    Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

8.3    Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

  1. Our details

9.1    We are Toppersdeal.com, a service provided by INTENSE ESERVICES CREATION PRIVATE LIMITED, Gurgaon, Haryana, India. In this Privacy Policy, references to “you” and “User” mean any person submitting any data to us or our agent or the Website.

9.2    We are registered in India under registration number U51909HR2018PTC076818 and our registered office is at 16, Rajendra Park, Gurugram, Gurgaon, Haryana, India, 122001.

If you have any comments or suggestions, we would be pleased to receive them at our Gurgaon address or at our email address wecare@toppersdeal.com.