COOKIES AND PRIVACY POLICY - TOP GAMING LTD

Top Gaming proceeds to the data processing in accordance with applicable laws including but not limited to Regulation (EU) 2016/679 of the European Parliament and the Council of 27 April 2016 ("Regulation" or "GDPR") and subsequent amendments and additions, concerning the protection of individuals with regard to the processing of personal data and the free movement of such data. In accordance with Articles 13 and 14 of the aforementioned Regulation below is the information regarding the data identifying the data controller and the responsible data processor with regard to the processing of personal data with respect to contracts and the provision of services.

• The data controller is Top Gaming LTD - The Responsible for the data processing is Lawyer Ottavio Porto, of the Catanzaro Court, who assumes the role of DPO, pursuant to and for the purposes of the law.
• Processing methods and data access
  Data collected through the signing of standard documents in analogue and or digital format, cookies and navigation services, including geolocation information, are processed both in paper form and with computer and telematic tools and may be processed in aggregate form for statistical purposes and to verify the quality standards of support and maintenance services, excluding in this case the processing of identification data. Data collected by filling in online forms are processed electronically and by means of management information systems.
  The data can only be accessed by persons in charge, adequately trained and informed about their duties and the activities allowed to them on the data collected, who work on behalf of Top Gaming LTD and who are recipients of instructions and tasks given by the controller, by means of a letter of appointment. The data controller shall process the data for the above-mentioned purposes pursuing its own legitimate interests which shall not override the interests or rights and freedoms of the data subject.
  
  The data of customers and clients may be communicated to government agencies or authorities providing a government service on the occasion of specific requests and qualified powers of attorney. Contract and service activity data may be communicated to business consultants for administrative and accounting purposes and to lawyers for possible litigation management. The data, excluding those of a sensitive and judicial nature, may be disclosed to those (individuals or government agencies), even outside the European Union, in its legitimate interest and taking advantage of a right expressly granted by the specific legislation in force, requires a verification of the identity of the owner of the service provided by Top Gaming LTD, for investigative purposes or otherwise for the protection of its legitimate interest.
  The data may also be communicated or made accessible to companies controlled by and/or affiliated to Top Gaming Ltd to other subjects who deal with the maintenance of computer systems as well as to subjects who deal with specific stages of processing, in their capacity as managers of Top Gaming Ltd whose names can be verified at the request of the interested parties.
• The data may also be disclosed to the police or judicial authorities for the purpose of investigating or prosecuting offences committed by users of telematic services, where necessary.
• The data are not subject to disclosure, with the exception of data from companies and corporations for commercial reference purposes, or different and specific consents.
• The data may be processed in order to identify certain characteristics of certain types of recipients in order to convey communication and advertising activities targeted to the interests of the same recipients Top Gaming Ltd will keep the data of the interested parties in a form that permits identification of the same for a period of time not exceeding the achievement of the purposes for which the data were collected; they will therefore be kept until the existence of the existing contractual relationship or the consents given at the time of acceptance.
  Data strictly necessary for tax and accounting purposes, once the purpose for which they were collected no longer exists, will be kept for a period of 10 years as required by the relevant regulations.
  
  The interested party has the right to request, at any time, the modification of the arrangements governed by this policy through the exercise of the rights set out in the following paragraph.
• The data subject may exercise the rights set out in Articles 16 to 22 of European Regulation 679/16:
  
  The data subject shall have the right to obtain from the data controller the rectification of inaccurate personal data concerning him/her without undue delay. Taking into account the purposes of the processing, the data subject shall have the right to obtain the integration of incomplete personal data, including by providing a supplementary declaration. The data subject shall have the right to obtain from the controller the erasure of personal data concerning him/her without undue delay and the controller shall be obliged to erase without undue delay personal data if any of the following grounds exist: personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; the data subject withdraws the consent on which the processing is based accordingly; the data subject objects to the processing and there is no overriding legitimate ground for the processing; the personal data must be erased in order to comply with a legal obligation under Union or Member State law to which the data controller is subject.
  
  He has the right to obtain notification from the data controller in cases of rectification or erasure of your personal data. The controller shall notify each of the recipients to whom the personal data have been transmitted of any rectification or erasure or restriction of processing. The data controller shall inform the data subject of these recipients if the data subject so requests. The data subject shall have the right to receive in a structured, commonly used and machine-readable format the personal data concerning him/her that he/she has provided to a controller and shall have the right to transmit those data to another controller without hindrance from the controller to whom he/she has provided them. The data subject shall have the right to object at any time, on grounds relating to his or her particular situation, to the processing of personal data concerning him or her, including profiling on the basis of such provisions.
  
  The controller shall refrain from further processing the personal data unless he can demonstrate compelling legitimate grounds for processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims. Where personal data are processed for direct marketing purposes, the data subject shall have the right to object at any time to the processing of personal data concerning him or her carried out for such purposes, including profiling insofar as it is related to such direct marketing. If the data subject objects to the processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.
  
  Where personal data are processed for scientific or historical research purposes or for statistical purposes, the data subject shall, on grounds relating to his or her particular situation, have the right to object to the processing of personal data concerning him or her, except where the processing is necessary for the performance of a task carried out in the public interest. The data subject has the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him/her or significantly affects him/her in a similar way. Top Gaming Ltd, in compliance with the corresponding right of access to the data subject, has put in place procedures whereby data subjects may request the modification, updating or deletion without undue delay of their personal data or the restriction of the processing of their personal data for the following reasons, by way of non-exhaustive example, because the data are no longer necessary for the purposes for which they were collected, because the data subject has withdrawn consent, because the data subject objects to the processing, because the data are processed unlawfully.
  
  To exercise these rights, the data subject must send a written request to Top Gaming Ltd. Data subjects who consider that the processing of personal data relating to them carried out through this site is in breach of the provisions of the Regulation have the right to lodge a complaint with the Garante, as provided for by art. 77 of the Regulation itself, or to take legal action (art. 79 of the Regulation).
  
  

Cookie policy

Cookies are short text fragments (letters and/or numbers) that allow the web server to store information on the client (the browser, e.g. Internet Explorer, Chrome, Firefox, Opera...) to be reused during the same visit to the site (session cookies) or later, even days later (persistent cookies). Cookies are stored, according to user preferences, by the individual browser on the specific device used (computer, tablet, smartphone). Similar technologies, such as, for example, web beacons, transparent GIFs and all forms of local storage introduced with HTML5, can be used to collect information and usage of services. A cookie cannot retrieve any other data from the user's hard disk or transmit computer viruses or acquire email addresses. Each cookie is unique to the user's web browser. Some of the functions of cookies may be delegated to other technologies. In the following, the term 'cookies' refers to cookies and all similar technologies.

Various types of cookies can be distinguished according to their characteristics and use:

Technical cookies: These are cookies that are indispensable for the proper functioning of a website and are used to manage various services related to websites (such as, for example, a login or access to reserved functions on the sites). The duration of the cookies is strictly limited to the working session or they can be used for a longer period of time in order to remember the visitor's choices. Deactivation of technical cookies may affect the user and browsing experience of the website. Analytical cookies (analytics): These cookies are used to collect information on the use of the site. This information is used for anonymous statistical analysis in order to improve the use of the site and to make the content more interesting and relevant to the user's wishes. This type of cookie collects data in an anonymous form about the user's activity and how he or she arrived at the site. Analytical cookies are sent by the site itself or by third-party domains. They are also used to monitor the system and improve its performance and usability. Deactivating these cookies can be done without any loss of functionality and will be covered in detail later.


: These cookies are used to collect information about how users use the site in an anonymous form such as: pages visited, time spent, traffic origins, geographical origin, age, gender and interests for marketing campaigns. These cookies are sent from third-party domains outside the site.

Cookies to integrate products and functions of third party software: This type of cookie integrates functionalities developed by third parties within the pages of the Site such as icons and preferences expressed in social networks in order to share the content of the Site or for the use of third party software services (such as software to generate maps and other software offering additional services). These cookies are sent by third party domains and partner sites that offer their functionality between the pages of the Site.

Profiling cookies: These are those cookies necessary to create user profiles in order to send advertising messages in line with the preferences expressed by the user within the pages of the Site. We use cookies to collect information from visitors to our Site.

Our servers use the following types of cookies:

Technical session cookies: used for navigation and to facilitate access and use of the site. They are essential for accessing protected resources without having to re-enter your credentials each time you change pages. These cookies are automatically deleted when you close the browser.

Cookies to integrate products and functions of third party software: This type of cookie integrates functionalities developed by third parties within the pages of the Site such as icons and preferences expressed in social networks in order to share the content of the Site or for the use of third party software services (such as software to generate maps and other software offering additional services). These cookies are sent by third party domains and partner sites that offer their functionality between the pages of the Site.

Profiling cookies: These are those cookies necessary to create user profiles in order to send advertising messages in line with the preferences expressed by the user within the pages of the Site. We use cookies to collect information from visitors to our Site.

Persistent technical cookies: these are cookies useful for the correct use of the site by the user. They are used, for example, to store user preferences such as layout, language, etc. These preferences remain valid even after closing and reopening the browser.

Statistical or "analytics" cookies: these are used directly by the website owner to statistically analyse access/visits to the website and collect information in aggregate form.

Third party cookies: by visiting a website you may receive cookies from sites operated by other organisations ("third parties") that may reside in Italy or abroad.

It is however possible to deny consent and block third-party cookies by means of browser plug-ins, by searching on Google for 'block and delete third-party cookies'; as a result of the search you will get many guides that differ according to the operating system and browser used.

Please note that you can change your preferences by accessing the 'cookie management' page.

If you are a visitor to the Site (registered or not), the following types of personal data will be processed:

(a) automatically supplied data (browsing data):

the computer systems and software procedures used to operate this Site acquire, during their normal operation, certain personal data whose transmission is implicit in the use of Internet communication protocols. This information is not collected in order to be associated with identified interested parties, but by its very nature could, through processing and association with data held by third parties, allow users to be identified.
This category of data includes the IP addresses or domain names of the computers used by users who connect to the Site, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to your operating system and your computer environment.

This data is used for the sole purpose of obtaining anonymous statistical information on the use of the Site and to check its correct operation, and is deleted immediately after processing. The data could be used to ascertain responsibility in the event of hypothetical computer crimes to the detriment of the Site. Surfing data are processed for our legitimate interest to ensure the security of the Site, to check its correct functioning and to obtain statistics in relation to its use (art. 6, co. 1, let. f) of the Regulation).

b) data provided voluntarily:

• in e-mails/faxes spontaneously sent to our customer service: the optional, explicit and voluntary sending of your personal data to the e-mail addresses published on the Site entails the subsequent acquisition of such data, which are necessary to reply to the requests you send in relation to the Site (art. 6, co. 1, lett. b) of the Regulations). You are free not to provide such data. However, failure to provide them may make it impossible to obtain what you have requested;
• when you call our customer service: when you contact our customer service, we may process the personal data that you voluntarily provide us with during the telephone conversation or that we reasonably request in order to respond to your requests to provide you with what you require (Art. 6, co. 1, lett. b) of the Regulation). You are free not to provide such data. However, failure to provide them may result in the impossibility of obtaining what you have requested; We may store certain information (so-called Cookies) on your computer, laptop, tablet or other mobile device when you browse our websites, mobile sites or mobile applications.
  
  It is possible that, while browsing this Site, some user information (i.e. information that the user does not actively provide) may be passively collected by means of various technologies. The Company and third party service providers passively collect and use information in a variety of ways, such as:
  
  IP Address: The IP address is a number automatically assigned to the computer used by the user's Internet Service Provider (ISP). An IP address is automatically identified and recorded in the Company's server log files each time users access the Site, alongside the date of the visit and the page(s) visited. The collection of IP addresses is normal practice on the Internet and is done automatically by many websites. IP addresses are used for a variety of purposes, such as to calculate usage levels of the Site, to provide information to help diagnose server problems and to administer the Site.
  
  You can accept or reject cookies. Most browsers allow you to manage your preferences on the use of cookies at any time.
  
  To configure our own and third-party cookies, users can go to:
• Google Chrome: Tools - Settings - Show advanced settings - Content settings - Cookies - Block third-party cookies and site data
• Mozilla Firefox: Tools - Options - Privacy - History - Use custom settings for history (uncheck all boxes)
• Internet Explorer: Settings - Internet Options - Privacy - Internet Zone settings (move the navigation bar to 'Block all cookies')
• Safari: Settings - Preferences - Privacy - Block cookies (check "always") Safari (IOS): Settings - Safari - Block cookies Users may withdraw their consent to the use of cookies in their browser by using the options of the manufacturer of the browser used.
  
  Top Gaming Ltd may amend this cookie policy based on new legislative or regulatory requirements, or to ensure that the policy complies with the instructions published by the Italian data protection authority.
  When significant changes are made to this cookie policy, users will be notified by means of a notification on the site or by e-mail for registered users.
  
  If you wish to obtain further information on privacy and the use of cookies, please contact our Customer Service.