Information We Collect and How We Use It: When you visit our websites, we collect certain information about your visit, interaction with content, the site from which you arrived and to which you are heading, and some additional technical information about the device and system from which you are consuming the services. upon your choice to use a “click to call” service we may offer, the phone number from which you made the call may be collected for a limited time of up to 3 months.
The information is used to operate our websites, provide you with the services, improve them over time, monitor analytics and statistics and enable us to sync and resolve payment issued with our business partners (including clients, vendors and affiliates).
We will not share your information unless we are required to by law, or as required to provide you with our websites and services.
Last Updated: , 2020
2. Our Legal Bases of Processing
3. How we use your personal information
4. Consent, Choice, and Modifications
5. Purposes for the collection of information
6. Sharing Your Information with Third Parties
7. Links to and Interaction with Third Party Properties
8. Choices and Opt-Out
9. Your Rights
10. Information Security
11. Children’s Privacy
12. Non-US Users
14. Contact Us
2. Our Legal Bases of Processing. We process and use Personal Information in accordance with data protection laws. Our legal ground for processing your Personal Information will typically be one or more of the following:
2.2. Legitimate Interests. We may use some of your Personal Information where we have legitimate business grounds to do so. We use this Personal Information to operate, improve and promote the Services (for example, when we customize your experience of the Services or for analytics purposes) and to protect our business (for example, to prevent fraud or ensuring the Site security).
2.3. Legal Obligations. In some cases, our use of your personal information will be necessary to comply with regulatory obligations or legal requirements (for example, addressing complaints from users or authorities);
2.4. Consent. In certain cases. We will ask for your consent to process and use your Personal Information in order to provide additional services (for example, when you subscribe to our newsletters, create your user profile, provide us Personal Information to get tailored offers or add a review on a service or product). When we rely on consent as our legal basis of processing You may ask to withdraw your consent by sending us a request to [EMAIL ADDRESS]. Once we have verified your request, we will contact you.
3. Information We Process. When you visit the Site or use the Services we may collect certain information about your visit and usage of the Site and the Services, in one or more of the following ways:
3.1.4. User Profile and User Reviews. We may offer you to give a review to our Partners or to create a user profile in some of our Sites and provide us with additional information about you that will assist us in providing a customized experience for you.
3.2. Information We Collect from You. We collect information about your use of the Services and your interaction with the Site or the Services, as follows, and in the following ways:
3.2.1. Device Information: For delivering and compatibility purposes, so as for language, geographic location and time zone, we collect device information such as: device type and version, operating system type, language and version, and information that can be extracted out of a user agent, such as browser type and version, screen resolution.
3.2.2. Interactions and Usage: In order to provide the Services, operate the Site, and keep improving it, so as to be able to sync with our Partners and affiliates, we collect information about your interaction and use of the Services, such as: URLs from which you were directed to the Site and to which you are referred from the Site, internal URL’s of the Site in which you visited and your actions with respect to the Services (such as view or click), date/time stamp of Site use, timing for clicks and page-views.
3.2.3. Log Files: We collect information through server log files, but also by deploying tracking technologies within the Site, such as pixel tags. We do this to analyze trends, track user’s engagement and interaction with the Site and respective Services. The type of information collected may include internet protocol (IP) addresses that your Internet Service Provider allocated to your device. We collect IP for a limited time and for specific purposes. One, is to better understand your geographic location (country, region and language) and therefore be able to provide the Services in your own language and relevant to your place of origin. Second, we use automated tools to analyze IP addresses and flag those that are fraudulent.
3.2.4. Cookies and Similar Technologies. The Site may use “cookies” and other anonymous web tracking technologies (such as “web beacons” and “pixel tags”) implemented by us or by third-party service providers. A cookie is a small file containing a string of characters that is sent to your computer when you visit a website. When you visit the website again, the cookie allows that website to recognize your browser. Cookies may store your online preferences and other information about the interaction you make in the Site. You can reset your browser to refuse all cookies or to indicate when a cookie is being sent to your browser. However, some features or services, included in the Site, may not function properly without cookies, and some features may become unavailable for you in such a case. A pixel tag is a type of technology placed on a website for the purpose of tracking activity on websites, or when emails are opened or accessed (if applicable), and is often used in combination with cookies.
3.3. Information we receive from Third Parties. Like many Internet-based services, the Site and the Services are operated and provided in collaboration, sync, and interaction with third parties, including Partners, affiliates and other third parties. In order to enable and facilitate such sync, we may receive information from third parties, such as: an internal user identifier that our system generates to each user (not a unique identifier), and the summary of action taken by you (click, purchase, view, form submission or a phone call). In some Sites, you will be able – upon your choice – to consume the Service on a click-by-call basis. In which case, a third-party vendor/s facilitate the call transmission, tracking, and feedback for success. In such cases, the phone number from which you called may be provided to us (with no other information about you attached), for a limited time and for purposes of resolving referrals and successful calls with our Partners. Except for this purpose, we do not make any other use of such information, unless you will give us your explicit consent.
Some of the Services will require you to submit specific Personal Information. In such a case you can choose whether you want to use such Services or not. Be aware that even if you provided us with your Personal Information, you have the full right to withdraw such consent at any time (please refer to section 8 below to get further details about opting out and withdrawing consent).
To generally provide you with the Site, Services and constantly improve them. We will use your Information to: (a) administer and make available the Site and Services to you; (b) further develop and generally improve the Site and the Services; (c) counting and tracking purposes of referrals and ads (; (d) validation of users as human and anti-fraud monitoring (e) respond to your inquiries and other communications with you; (f) identify or authenticate your access and use of the Site.
6. Sharing Your Information with Third Parties.
We do not share Personal Information about you with third parties, except for the following circumstances:
6.3. Other Third Parties. We may send or otherwise share your Information to/with various third parties that help us with our business operations (for example, customer service operators and email or phone administration providers), that help us understand how our users use the Site and Services, operate them and to improve them. These third parties may have their own privacy policies that they adhere to, and we require them to make it available whenever their services are provided. We recommend you revisit such privacy policies when those third parties render their services directly to you. Also, these third parties may be based (and their servers may be located) anywhere in the world.
6.6. Merger, Sale or Bankruptcy. In the event that Top Web Accessibility or one of our affiliated entities is acquired by or merged with, a third party entity, or otherwise sells all or part of our/its assets, we may (and hereby reserve the right to) transfer or assign the Personal Information and other information we have collected or received. In such a case, we will require the acquiring entity to post its data practices and provide you with any of your rights as per the jurisdiction of your residency.
We may also share some non-Personal Information with the following type of third parties and under the following circumstances:
8.1. Cookies and Tracking Technologies. you may set your browser to refuse and/or block any cookies from the Site or third party services (for more details please refer to Section 2.1.1 hereof).
8.2. When applicable, review and update or request to remove your Personal Information from our servers (for more details please refer to Section 2).
9. Your Rights
As an EU based user, you may:
• Access the Personal Information that we keep about you. We will need to ask you to provide us certain credentials to make sure that you are who you claim you are. If you find that the Personal Information is not accurate, complete or updated, then please provide us the necessary information to correct it.
• Contact us if you want to withdraw your consent to the processing of your Personal Information. Exercising this right will not affect the lawfulness of processing based on consent before its withdrawal.
• Object to the processing of your Personal Information for direct marketing purposes, in case your Personal Information used for such purpose.
• Have a right to lodge a complaint with a data protection supervisory authority.
10. Information Security. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. For example, the Site is encrypted by using SSL and so as any other information at transport, we periodically review our information and data collection practices to ensure constant monitoring, we use third-party processing and serving services that implement various information security standards and certifications (at rest and transmission), and we monitor and filter access to data when it comes to personnel in our organization. Such systems and procedures reduce the risk of security breaches, but they do not provide absolute security, as there is no such thing when it comes to the world-wide network. Therefore, we cannot guarantee that the Site and our servers are immune to unauthorized access to the information stored therein and to other information security risks.
11. Children’s Privacy. The Site or the Services are not designed to attract children under the age of 16. Accordingly, we do not intend to collect Personal Information from anyone we know to be under 16. If we learn that we have collected Personal Information from a child under 16, we will use commercially reasonable efforts to delete that information as quickly as possible. If you believe that we might have any such information, please contact us at: [email protected]
12. Commitment. Protecting your privacy online is an evolving practice, and we use our best efforts to evolve our Site in a manner that meets these requirements and best practices as per all jurisdictions in which the Site is available.
13. Contact Us.
13.1. General Data Protection Regulation (GDPR) – European Representative. Pursuant to Article 27 of the General Data Protection Regulation (GDPR), Top Web Accessibility. has appointed European Data Protection Office (EDPO) as its GDPR representative in the EU. You can contact EDPO regarding matters pertaining to the GDPR by:
• Sending an email to [email protected]
is for data protection inquiries in accordance with your legal rights listed above. Any other inquiries sent to this email box will be ignored.