TOP-Students™ Website Privacy Policy
1. Introduction
This Website Privacy Policy ("Website Privacy Policy") provides information about the collection, storage, use, sharing, disclosure and transfer ("Processing") by TOP-Students™ ("we") of information that relates to an identified or identifiable individual, as defined by applicable data protection laws ("Personal Data") in connection with visitors ("Visitors" or "you") to the TOP-Students™ website that refers or links to this Privacy Policy. It also informs you of your privacy rights in connection with such Processing of your Personal Data.
2. Scope of the Website Privacy Policy
This Privacy Policy applies to the Processing of Personal Data of Visitors in connection with their visit to our Site only.
3. Who is responsible for processing your personal data?
TOP-Students™ is responsible for the processing of your Personal Data.
For the purposes of the Personal Data Processing activities identified in this Website Privacy Policy, TOP-Students™ is considered the Data Controller, as defined by applicable data protection law.
If you have any questions about this Website Privacy Policy or our data protection practices in accordance with Article 27 of the General Data Protection Regulation ("GDPR"), you may contact us. See how to contact us below.
4. What Personal Data do we process about you and how?
TOP-Students™ collects and processes Personal Data that directly identifies you (e.g. name, email, contact details, etc.) and indirectly identifies you (e.g. unique identifiers, behavioral data, etc.), from various sources.
We collect and process Personal Data about you:
When you provide this personal data directly to us When you contact us, request information, or provide us with your feedback via our Site, we may collect the following categories of Personal Data about you:
- Identification and contact data: First and last name, email address.
- Any other Personal Data you choose to provide voluntarily: Personal Data in the information request or feedback you send us
When you provide this personal data indirectly to us
We may collect Personal Data about you with the help of third parties. For more information about this Processing, please refer to our Platform Privacy Policy.
When you use our Site and this personal data is collected automatically
When you visit or interact with our Site, we may collect or generate via cookies the following categories of Personal Data about you:
- Unique identifiers: IP address, cookie identifiers, device identifiers, web beacons, pixels, and other similar technologies (as described in our "Cookie Policy") :
- Technical and device data: Domain server, type of device/operating system/browser used to access the Sites, local and language settings; session recording, heat maps and scrolls; screen resolution, ISP, referral or exit pages; and date and time of your visit. :
- Digital behavioral data: Interactions with the web page (clicks, navigation, zooms and other interactions), web page/referral source through which you accessed the Site, and statistics associated with the interaction between the device or browser and the Site. :
5. Why do we use your Personal Data?
We process your Personal Data for various purposes, including to administer our Site, develop and improve the performance of our Site, respond to your requests, for our legitimate interest and to respond to a regulator's request or to defend a legal claim in order to comply with applicable laws.
Below, you will find a summary of the purposes for which we process your Personal Data with the legal basis for that processing:See more
- Communicating with you and informing you of TOP-Students™ products, services and events (collectively - "Marketing Communications") as described in more detail in the Platform Privacy Policy: Consent or legitimate interest
- Administering and protecting our Site, preventing and investigating fraud and other abuses: Legitimate interest and compliance with a legal obligation
- Analyzing, developing, improving and optimizing the use, functionality and performance of our Site. Personalizing or customizing your experience: Consent or legitimate interest
- Responding to your requests and answering your questions, such as sending a requested report: Legitimate interest
- Protecting the rights, safety, property or operations of TOP-Students™, you, or others: Compliance with a legal obligation
- Responding to a regulator's request, law enforcement authorities, other government officials or your requests as a data subject: Compliance with a legal obligation
- Resolving disputes and defending a legal claim: Compliance with a legal obligation
6. How long do we retain your Personal Data?
Your Personal Data will be stored by us and our service providers in accordance with applicable data protection laws and guidance from data protection authorities to the extent necessary for the processing purposes set out in this Website Privacy Policy. Thereafter, we will delete your personal data in accordance with our Data Retention Policy or take steps to properly anonymize the Personal Data, unless we are legally required to retain your personal data for longer (for example, to comply with legal, tax, accounting or audit obligations).
Below, you will find a summary of data retention linked to each processing purpose:
- Processing purpose: Data retention
- Administering and protecting our Site, preventing and investigating fraud and other abuses: The time necessary to administer and protect our Sites then archived in accordance with applicable law or regulation
- Personalizing or customizing your experience: 13 months
- Responding to your requests and answering your questions, such as sending a requested report: 2 years from the request
- Communicating with you and informing you of Marketing Communications: 2 years from your last contact or as soon as you request that we stop contacting you for that purpose
- Analyzing, developing, improving and optimizing the use, functionality and performance of our SitePersonalizing or customizing your experience: 13 months
- Protecting the rights, safety, property or operations of TOP-Students™, you, or others: In accordance with applicable law or regulation
- Responding to your data protection requests and requests or communications from law enforcement authorities or other government officials: The time necessary to respond to the request or communication then archived in accordance with applicable law or regulation
- Resolving disputes and defending a legal claim: In the event of a dispute, until the dispute is settled; in the event of a legal claim, for the duration of the proceedings and until all ordinary and extraordinary means of appeal regarding the decision rendered have been exhausted.
7. When and with whom do we share your Personal Data?
Your Personal Data is shared for business and commercial purposes within TOP-Students™ and with third parties such as service providers, and, upon request and in accordance with legal requirements, with governmental, judicial and law enforcement entities.
In connection with one or more of the purposes described in the sections above, we may disclose your personal data to:
TOP-Students™ subsidiaries and affiliated companies
We may share, disclose and transfer your Personal Data with future subsidiaries and affiliated companies for all purposes mentioned in Section 5 above.
Service providers
We may share your Personal Data with third parties (including our subsidiaries) to perform services complementary to ours, namely: hosting, data analytics, consulting, development, support, marketing and advertising, data and cybersecurity. Our service providers may perform the services on our behalf, according to our instructions, in accordance with our agreement and in compliance with appropriate technical and organizational security measures to protect your personal data. A list of these providers is available upon request. See how to contact us below.
Other third parties
We may disclose your Personal Data to third parties, including governmental authorities or public authorities, courts, intergovernmental or supranational bodies for legal proceedings or the protection of life and safety where we believe that access, use, preservation or disclosure of the information is reasonably necessary, including:
- To comply with laws, regulations, legal proceedings or to respond to legal requests;
- To enforce or apply our agreements;
- To protect the rights, interests, property or safety of TOP-Students™, our customers, you and others;
- In connection with claims, disputes or litigation;
- To protect you and others against fraudulent, abusive or unlawful use of the Site, and other fraudulent activities.
8. How do we transfer your Personal Data internationally?
Your Personal Data may be accessed, processed and stored in other countries in which TOP-Students™ operates, including countries outside the European Economic Area (EEA).
TOP-Students™ has put in place safeguards to ensure an adequate level of data protection when your Personal Data is transferred to countries outside the EEA, such as:
- an adequacy decision by the European Commission;
- the European Commission's Standard Contractual Clauses for the transfer of Personal Data.
The list of countries to which your Personal Data may be transferred is available upon request. See how to contact us below.
9A. How do we secure your Personal Data?
We use industry-standard security measures, both physical, procedural and electronic, to protect your Personal Data that we hold and that of our service providers. However, please note that we cannot and do not guarantee the absolute protection and security of all Personal Data that we store or that third parties store.
TOP-Students™ ("TOP-Students™", "we", "our" or "us") uses certain monitoring and tracking technologies, such as cookies, beacons, pixels, tags and scripts (collectively, "Cookies"). These technologies enable us to maintain, provide and improve our website and customer-facing platform (together: "Website & Platform"), and to offer our customers a better experience (such as tracking preferences, better securing our Website & Platform, identifying technical issues, and tracking and improving the overall performance of our Website & Platform).
This page contains information about what Cookies are, the Cookies used on our Website & Platform, how to disable Cookies in your browser, and some useful links to further explore the topic. If you have additional questions about the use of Cookies on our Website & Platform, or about the use of Content Square Cookies in our Services, please send an email to contact@top-students.com.
What are Cookies?
Cookies are small text files that are stored on your computer or mobile device by the browser (for example, Google Chrome or Safari). They allow websites to store things like user preferences. You can think of Cookies as providing a kind of memory for the website, so that it can recognize you when you return and respond appropriately.
How do we use Cookies?
TOP-Students™ uses several different types of Cookies on our website:
Performance Cookies: these Cookies help us secure and maintain our Website & Platform, and to remember your preferences for tools found on the Website & Platform, so that you do not have to reset them on each visit._
Analytics Cookies: these Cookies are used by the analytics services we use to tell us whether you have visited the Website & Platform in the past, and provide information about your use of our Website & Platform. In particular, this allows us to track how many individual users we have and how frequently they visit the Website & Platform. Your browser will tell us whether you have these Cookies and, if not, we generate new ones. Unless you are logged into our Platform, we cannot use these Cookies to identify individuals.
Registration Cookies: these Cookies allow us to know whether you are logged in or not. We generate them when you register and log into our Platform. Our servers use these Cookies to determine which account you are logged into and whether you are authorized to access a particular service. When you are logged into our Platform, we combine information from your Registration Cookies with Analytics Cookies to identify which parts of our Platform you have used.
Third-Party Integration Cookies: on certain pages of our Website & Platform, other organizations may also set their own Cookies. They do this to track the performance of their applications integrated into our Website & Platform or to personalize their services for you. Due to the way Cookies work, we cannot access these Cookies, nor can the other organization access the data in the Cookies we use on our Website & Platform.
The cookies we use
| Service | Type | Description | Link for more information |
|---|---|---|---|
| NextAuth | Authentication | Used to manage user sessions and authentication | NextAuth Documentation |
| TikTok | Marketing | Used for conversion tracking and advertising targeting | TikTok Cookies Policy |
| Marketing | Used for conversion tracking and advertising targeting | Facebook Cookie Policy | |
| Google Ads | Marketing | Used for conversion tracking and advertising targeting | Google Ads Cookie Policy |
| PostHog | Analytics | Used for site traffic analytics | PostHog |
| Vercel Analytics | Analytics | Used for site traffic analytics | Vercel Analytics |
How can you disable Cookies?
On our site, cookies are not enabled by default. You can disable / enable them by accepting / refusing on the popup that appears when you arrive on the site.
In addition, all modern web browsers allow you to change your Cookie settings. You can generally find these settings in the 'Options' or 'Preferences' menu of your browser. You can use the 'Help' option of your browser for more details. To understand these settings, the following links may be useful:
Cookie settings in Internet Explorer
Cookie settings in Safari Web and iOS
If you are primarily concerned about third-party Cookies generated by advertisers, and you live in the United States, Canada or Europe, you can also opt out of the collection of your data by our advertising partners participating in the Digital Advertising Alliance. Opt out by visiting:
www.aboutads.info/choices (for users in the United States)
www.youradchoices.ca/choices (for users in Canada)
www.yourchoicesonline.com (for users in Europe)
9bis. TOP-Students™ Mobile Application — Tracking and App Tracking Transparency (ATT)
Data collected in the mobile application
When you use the TOP-Students™ mobile application (iOS / Android), we collect the following data for analytics and personalization purposes:
Email address — linked to your user identity Name — linked to your user identity Behavioral data — application usage events (app opening, login, progress, training sessions, etc.) This data is transmitted to PostHog (PostHog privacy policy), our analytics tool, hosted in Europe.
App Tracking Transparency (iOS)
In accordance with Apple's requirements, the mobile application requests your explicit permission before collecting data related to your identity (email, name), via the App Tracking Transparency (ATT) mechanism on iOS 14.5 and above.
If you accept: your email and name are transmitted to PostHog to personalize your experience and analyze your usage. If you decline: no personally identifiable data (email, name) is transmitted. Only anonymous usage data may be collected. You can change your choice at any time in: iOS Settings > Privacy & Security > Tracking > TOP-Students™
App Tracking on Android
On Android, analytics tracking is active from the moment you use the application. Your email and name are transmitted to PostHog for analytics and personalization purposes.
In accordance with the GDPR, you have the right at any time to object to this processing by contacting us at the address indicated in section 12. We will then stop transmitting your data to PostHog as soon as possible.
10. What are your privacy rights and how can you exercise them?
You have rights regarding the Personal Data we process about you. You may choose to object to our Processing of your Personal Data, restrict our use of your Personal Data, delete it, modify or correct it, or access your Personal Data by contacting us.
Subject to applicable data protection laws, you have privacy rights with respect to the Personal Data we process about you:
- request confirmation that we are processing your Personal Data;
- request a copy of the Personal Data we hold about you;
- request that we update the Personal Data we hold about you or that we correct such data if it is inaccurate or incomplete;
- restrict the way in which we use your Personal Data (for example, if we have no legal right to continue to use it, if your Personal Data is inaccurate or unlawfully held);
- object to our Processing of your Personal Data in connection with your particular situation or if your personal data is processed by us for direct marketing purposes, object at any time to the processing of your personal data for such marketing purposes;
- withdraw the consent you have given us to process your Personal Data where we process it on the basis of your consent;
- request that we delete the Personal Data we hold about you; and
- lodge a complaint with the competent data protection authority regarding our Processing of your Personal Data.
To exercise one or more of the rights mentioned above, please contact us as indicated in Section 12 below. Please note that as part of your request as a data subject, we may require additional information and documents, including Personal Data, in order to authenticate and validate your identity and process your request. This additional data will then be retained by us for legal purposes (for example, as evidence of the identity of the person submitting the request), in accordance with Sections 5 and 6 above.
11. Children's Privacy
Our Site is not designed to attract children under the age of 16. We do not knowingly collect Personal Data from children and do not wish to do so. If we learn that a person under the age of 16 is using our Site, we will prohibit and attempt to block such use and will make reasonable efforts to promptly delete any Personal Data we hold about that person. If you believe we may hold such data, please contact us as indicated in Section 12 below.
12. How to contact us?
You can contact us regarding this Website Privacy Policy or our Processing of your Personal Data at TOP-Students™@gmail.com.
13. Updates and changes to this Website Privacy Policy
The "Effective Date" at the top of this web page indicates when this Website Privacy Policy was last revised. We may update and modify this Website Privacy Policy from time to time. Any changes will take effect when we post a revised version of this Website Privacy Policy on our Site. Your use of our Site is subject to the terms of this Website Privacy Policy that is posted on our Site at the time of your visit. We encourage you to regularly review this Website Privacy Policy to stay informed about how we manage your Personal Data.
14. External links
We are not responsible for the privacy practices of other websites that our Site may contain links to. We encourage you to be careful when leaving our Site for the website or application of a third party and to read the privacy policies of each website or service you visit.