Privacy Policy

Version 1.1

Effective Date: 25th May 2018

Date of Last Revision: 25th May 2018

This privacy policy (“Privacy Policy”) governs the data collection practices of top10freespins (“top10freespins”, we”, “our” or “us”) as they relate to how users (“you”) interact with the website top10freespins.com together with its subdomains, features, and services available thereon, the “Website”).

This Privacy Policy provides important information & disclosures around how and why we collect, share and use your data. The sub-headings and sections below are for not to be used for interpretive purposes but are solely placed to help with navigating the Privacy Policy.

ACCEPTANCE OF THE TERMS: BY ACCESSING OR USING THE WEBSITE OR OUR SERVICES, YOU AGREE TO THE TERMS AND CONDITIONS SET FORTH IN THIS PRIVACY POLICY , INCLUDING TO THE COLLECTION AND PROCESSING OF THE INFORMATION. IF YOU DISAGREE TO ANY TERM PROVIDED HEREIN, YOU MAY NOT USE THE WEBSITE OR SERVICE. YOUR USE OF THIS WEBSITE INDICATES ACCEPTANCE OF THIS PRIVACY POLICY.

  1. INFORMATION COLLECTED AND STORED

In general, we receive and collect your data because:

(a) You have provided it to us;
(b) We collect it from you in accordance with the provisions contained hereunder; and/or
(c) Third parties we engage (such as data analytics providers) collect it from you on our behalf.

1.1 Information You Give Us:

There are instances where you may be providing us with personal information related to your usage of the site. These are:

  • Filing a “Contact Us” request: by sending us a “Contact Us” request via an online form, by sending an email to an email address that we display, by using a feedback or reporting feature, or by other means, you may be required to provide us with certain personal information, such as your name and email address.
  • Commenting & Subscribing: parts of the Website may offer users the opportunity to leave comments on blog posts, reviews & articles. You may also be able to subscribe to various newsletters operated by us. In each of the foregoing cases, your interaction (such as responding on the blog forum, subscribing to a newsletter, or participating in a survey) may require you to provide certain personal information such as your name and email address.
  • Social Registration: in some cases, you may be able to use social registration to comment, register or sign up to using your Facebook login. If you do so, you authorize us to access certain Facebook account information, such as your public Facebook profile(consistent with your privacy settings in Facebook).
  • Lead Generation: the Website lists and compares various businesses and commercial entities (collectively, “Partners”) and their respective products and/or services (collectively, “Products”). For more information regarding a Partner’s Product g, or to pursue a transaction with a Partner, you would click through to the Partner’s website or landing page. Such pages may prompt you for additional information such as your name, email address or phone number (“Landing Page Info”). We are not responsible for the privacy practices of any such third parties, and once you leave the Website via a link or enable a third-party service, you should check the applicable privacy policy of the third-party site carefully. Your information is governed by their privacy statements.

1.2 Information We Automatically Collect From You:

Apart from any personal data you maybe be supplying to us as listed in 1.1, we collect additional technical and aggregated information about you that is non-personal non-identifiable information which may be made available or gathered via your use of the Website.

  • Behavioural, Device and Usage Data: we deploy various tracking technologies on the Website (which may include 3rd party technologies) to help us collect aggregated trend data and usage analytics. We do this to analyse trends to help optimise our Website and track user movement and user clicks through to other websites. The type of data may include (but is not limited to) internet protocol (IP) addresses, MAC address, device type, browser type, browser version, operating system type, screen resolution, user agent, user identifier, user language, URLs and traffic channels (such as the previous URLs or platforms you visited), keyword searches and bids, city, region code, country, latitude, Internet Service Provider (ISP), date/time stamp of Website use, referring/exit pages, clicks, timing for clicks and page-views, and clicked pages.
  • Cookies and Other Tracking Technologies. The Website may use “cookies” and other tracking technologies (such as “web beacons” and “pixel tags”). Please refer to our Cookie Policy for more information.
  • Information We Get from 3rd Parties:

We may receive additional data from 3rd parties that help us with our business operations, that help us understand how our users use the Website, and to provide general analytics with regards to Website usage. Such data is in most cases aggregated, non-personal, non-identifiable data.

1.3.1 Website Analytics: We receive a variety of anonymised, aggregated site usage analytics data from web site analytics companies, such as Google Analytics, Bing SearchAds or Google AdWords.

 

  1. HOW YOUR PERSONAL DATA IS USED
    • Partners and Products. We may send or otherwise share your Landing Page Info to/with the Partner about whom (or about whose Product) you wanted to receive more information or with which you have expressed interest in pursuing a transaction. You acknowledge that: (a) the Partners may contact you using the Landing Page Info which you submitted; (b) we do not control the way in which Partners may contact you, or the subject matter of such contact; and (c) each Partner is required to have its own privacy policy, and so it won’t necessarily adhere to this Privacy Policy and (d) Partners may be based (and their servers may be located) anywhere in the world. We may also contact you to discuss and share information about Partners and their respective Products, as well as about partners, products, and services listed on other websites that are affiliated with us. The way in which we contact you may be via email, phone, cell phone, and/or text messages (SMS/MMS), and we may contact you using Landing Page Info as well as personal information collected from you as described in Section ‎1.1
    • To Generally Provide You With the Website: We will use your personal information to: (a) administer and make available the Website to you; (b) further develop and generally improve the Website; (c) send you updates, promotions, offerings, or other news of/about the Website; (d) respond to your inquiries and other communications with you; (e) identify or authenticate your access and use of the Website; and/or (f) send you advertisements or other third party marketing content.
    • Transfer To Affiliates: We may send or otherwise share your personal information to/with our affiliated entities for the purpose of storing such information on our behalf, or for other processing needs. These affiliated entities may be based (and their servers may be located) anywhere in the world. We require these affiliated entities to agree to process such personal information in accordance with this Privacy Policy and applicable law.
    • Third Parties: We may send or otherwise share your personal information to/with various third parties that help us with our business operations, that help us understand how our users use the Website, and to provide general analytics with regards to Website usage. These 3rd parties will have their own privacy policies. For more information on how we share data with 3rd parties, please see 3. Sharing Data with 3rd
    • Enforcement: We may share your personal information with any third party if we believe that disclosure of such information is helpful or reasonably necessary to: (a) comply with any applicable law, regulation, legal process, or governmental request; (b) enforce the Privacy Policy, including investigations of potential violations thereof; (c) detect, prevent, or otherwise address fraud or security issues; and/or (d) protect against harm to the rights, property or safety of our company , our affiliated entities, our users, yourself, and/or the public.

 

  1. SHARING DATA WITH THIRD PARTIES

We may share your information, solely to the extent needed to enforce our policies (including our policies and agreements), and investigations of potential violations thereof, including without limitations, investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud, security or technical issues

We may share your information to respond to user’s support requests; to respond to claims the rights of third-parties were violated including to respond to claims that contact information (e.g. name, email address, etc.) of a third-party has been posted or transmitted without their consent or as a form of harassment.

We will share your information, solely to the extent needed to comply with any applicable law, regulation, legal process or governmental request (i.e., to comply with courts injunction, comply with tax authorities, etc.).

We will we will share your information, solely to the extent needed to establish or exercise our rights to defend against legal claims.

We will share your information, solely to the extent needed to prevent harm to the rights, property or safety of us, our users, yourself or any third party; or for the purpose of collaborating with law enforcement agencies or in case we find it necessary in order to enforce intellectual property or other legal rights.

We may share your data with our parent company, any subsidiaries, joint ventures, or other companies under common control solely if and when applicable or necessary for the purposes described in this Privacy Policy.

We may share Information, including personal information, in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, consolidation or asset sale). In the event of the above, our affiliated companies or acquiring company will assume the rights and obligations as described in this Privacy Policy.

We may disclose your personal information to third parties upon your explicit consent, in order to enable said partners to complete various functions (e.g., Trust Pilot sending you a rating questionnaire regarding our services). Please note that once we share your information with third party, that information becomes subject to the other third party’s privacy practices.

We may share your data to other third parties (such as ad networks, advertising companies, service providers, media and other interested parties) for the purpose of developing or delivering advertising and enhancing the users’ experience (as specified below).

For avoidance of doubt, we may transfer and disclose Non-personal information to third parties at our own discretion, all subject to this Privacy Policy  and compliance with applicable laws.

If we combine personal information with non-personal Information, the combined information will be treated as personal information for as long as it remains combined.

  1. HOW LONG DO WE KEEP YOUR DATA FOR?

We may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion. Please note that unless you instruct us otherwise we retain the information we collect for as long as needed to provide our Service and to comply with our legal obligations, resolve disputes and enforce our agreements.

  1. YOUR RIGHTS

By law, you have a number of rights when it comes to your personal information. Further information and advice about your rights can be obtained from the data protection regulator in your country.

  1. The right to object to processing: You have the right to object to certain types of processing, including processing for direct marketing (i.e. if you no longer want to be contacted with potential opportunities).
  2. The right to be informed: You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we’re providing you with the information in this Privacy Policy.
  3. The right of access: You have the right to obtain access to your information (if we’re processing it), and certain other information (similar to that provided in this Privacy Policy). This is so you’re aware and can check that we’re using your information in accordance with data protection law.
  4. The right to rectification: You are entitled to have your information corrected if it’s inaccurate or incomplete.
  5. The right to erasure: This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information where there’s no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions.
  6. The right to restrict processing: You have rights to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information, but may not use it further. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in future.
  7. The right to data portability: You have rights to obtain and reuse your personal information for your own purposes across different services. For example, if you decide to switch to a new provider, this enables you to move, copy or transfer your information easily between our IT systems and theirs safely and securely, without affecting its usability.
  8. The right to lodge a complaint: You have the right to lodge a complaint about the way we handle or process your personal information with your national data protection regulator.
  9. The right to withdraw consent: If you have given your consent to anything we do with your personal information, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal information with your consent up to that point is unlawful). This includes your right to withdraw consent to us using your personal information for marketing purposes.

We usually act on requests and provide information free of charge, but may charge a reasonable fee to cover our administrative costs of providing the information for:

  • baseless or excessive/repeated requests, or
  • further copies of the same information.

Alternatively, we may be entitled to refuse to act on the request.

Please consider your request responsibly before submitting it. We’ll respond as soon as we can. Generally, this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we’ll come back to you and let you know.

MINORS

You represent and warrant that you are at least eighteen (18) years of age and of legal competence to enter into this Privacy Policy .  We do not use the Website to knowingly solicit data from or market to children under the age of eighteen (18). We request that such individuals do not provide personal information through our Website . We reserve the right to request proof of age at any stage so that we can verify that minors under the age of eighteen (18) are not using the Website. If you become aware or have any reason to believe that a child under the age of eighteen (18) has shared any information with us, please contact us and we take reasonable steps to ensure that such information is deleted from our files.

DIRECT MARKETING

We may share your email address, name and/or mobile phone number, should these have been collected, with our marketing partners and/or internally with the purpose of providing you marketing offers, deliver newsletters and rating questionnaires on our behalf.

You can opt out at any time from receiving such communications by either following the “unsubscribe” links at the bottom of electronic communications, following the op-out instructions on any mobile communications or by contacting us directly through our Contact US form or emailing us at [email protected]

COOKIES, WEB BEACONS AND THIRD-PARTY COOKIES

When you use our Website, we use “Cookies” for various purposes. A “Cookie” is a small piece of information that a website assigns and stores on your computer while you are viewing a website. The cookies used by the Website are created per session and do not include any personal information about you. For more information regarding how the Website uses cookies, please refer to our Cookie Policy.

FURTHER QUESTIONS?

If you have any questions about this Policy, please contact us at [email protected]