TOP Group is committed to protecting our customer privacy and takes its responsibility regarding the security of customer information very seriously. We will be clear and transparent about the information we are collecting and what we will do with that information.
This Policy sets out the following:
- What personal data we collect and process about you in connection with your relationship with us as a customer/user and through your use of our website, mobile applications and online services;
- Where we obtain the data from;
- What we do with that data;
- How we store the data;
- Who we transfer/disclose that data to;
- How we deal with your data protection rights;
- And how we comply with the data protection rules.
- All personal data is collected and processed in accordance with EU data protection laws.
TOP Group is the “data controller” of all personal information that is collected and used about TOP Group customers. TOP Group is registered in Italy with VAT ID IT05261320872.
What personal data we collect
Personal data means any information relating to you which allows us to identify you, such as your name, contact details, tournament registration reference number, payment details and information about your access to our website.
We may collect personal data from you when you register out tournament o purchase any item (either directly or indirectly through our trusted third party partners), create a TOP account, use our website and / or App and other websites accessible through our website and / or App, participate in a survey or competition, or when you contact us.
Specifically, we may collect the following categories of information:
a. Name, home address, e-mail address, telephone number;
b. Advance user information, which includes your nationality, date of birth, gender, DCI number;
c. Information about your purchases of our products and services or our trusted partners’ products and services;
d. Information about your use of our website and/or App;
e. The communications you exchange with us or direct to us via letters, emails, chat service, calls, and social media.
f. Location, including real-time geographic location of your computer or device through GPS, Bluetooth, and your IP Address, along with crowd-sourced Wi-Fi hotspot and cell tower locations, if you use location-based features and turn on the Location Services settings on your device and computer.
What do we use your personal data for, why and for how long
Your data may be used for the following purposes:
a. Providing products and services you request: we use the information you give us to perform the services you have asked for in relation to your tournament or item purchased;
b. Contacting you in the event of a tournament change or cancellation: we send you communications about the services you have asked for and any changes to such services. These communications are not made for marketing purposes and cannot be opted-out of;
c. Credit or other payment card verification/screening: we use your payment information for accounting, billing and audit purposes and to detect and / or prevent any fraudulent activities;
e. Customer Services communications: we use your data to manage our relationship with you as our customer and to improve our services and enhance your experience with us;
f. Provide tailored services: we use your data to provide information we believe is of interest to you, prior to, during, and after your purchase or tournament with us and to personalise the services we offer to you;
g. Marketing: from time to time we will contact you with information regarding special promotions and ancillary products via e-communications. You will have the choice to opt in or opt out of receiving such communications by indicating your choice in your user area. You will also be given the opportunity on every e-communication that we send you to indicate that you no longer wish to receive our direct marketing material.
We will only process your personal data where we have a legal basis to do so. The legal basis will depend on the reasons we have collected and need to use your personal data for.
In most cases we will need to process your personal data so we can enter into our contract of carriage with you.
We may also process your personal data for one or more of the following:
- To comply with a legal obligation;
- You have consented to us using your personal data (e.g. for marketing related uses);
We will not retain your data for longer than is necessary to fulfil the purpose it is being processed for. To determine the appropriate retention period, we consider the amount, nature and sensitivity of the personal data, the purposes for which we process itand whether we can achieve those purposes through other means.
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 a claim being made.
When we no longer need your personal data, we will securely delete or destroy it. We will also consider if and how we can minimise over time the personal data that we use, and if we can anonymise your personal data so that it can no longer be associated with you or identify you, in which case we may use that information without further notice to you.
Security of your personal data
We follow strict security procedures in the storage and disclosure of your personal data, and to protect it against accidental loss, destruction or damage.
All payment details are transmitted over SSL across dedicated network infrastructure.
You will have the option to stay signed-in into your private area by checking the “keep me logged in” box. This option will only apply to the computer / device and the browser that you're using when you select the box. If you do not wish to stay signed on a particular browser, simply sign out of your private area on that browser.
When our use of your personal data is based on your consent, you have the option to withdraw your consent to our processing and delete your personal data at any time by clicking on the “delete” buttons provided in your private area.
We keep your personal information contained in your private area for as long as you hold the account. You may delete your Top account by clicking on the “delete” button provided in the Settings of your account. Please note that general retention periods apply to any personal data we collected to enter into a contract with you or to perform that contract or because we have a legal obligation to process it.
For Parents Concerning the Privacy of Information on Their Children
Children under 13 are not allowed to use our services. If you are based in the EEA you may only use our serices if you are over the age at which you can provide consent to data processing under the laws of your country or if verifiable parental consent for your use of our services has been provided to us. If you are a parent and you learn that your child is using Ultimate Guitar and you don't want them to, please contact us.
Cookies and site tracking
Cookies are small text files that are transferred to your computer's hard drive through your web browser to enable us to recognise your browser and help us to track visitors to our site; thus enabling us to understand better the products and services that will be most suitable to you. A cookie contains your contact information and information to allow us to identify your computer when you travel around our site for the purpose of helping you accomplish your reservation. Most Web browsers automatically accept cookies, but, if you wish, you can change these browser settings by accepting, rejecting and deleting cookies. The "help" portion of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. If you choose to change these settings, you may find that certain functions and features will not work as intended. The cookies we use do not detect any information stored on your computers.
For more information about cookies and how to stop cookies being installed visit the following website: http://www.allaboutcookies.org.
Your Data Protection Rights
Under certain circumstances, by law you have the right to:Request information about whether we hold personal information about you, and, if so, what that information is and why we are holding/using it.
Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
Object to processing of your personal information 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 where we are processing your personal information for direct marketing purposes.
Object to automated decision-making including profiling, that is not to be subject of any automated decision-making by us using your personal information or profiling of you.
Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
Request transfer of your personal information 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. In the limited circumstances where you may 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 information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
If you want to exercise any of these rights, then please submit a completed request by email.
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.