This document contains information about the technologies that allow this Application to achieve the purposes described below. These technologies enable the Controller to collect and store information (for example by using Cookies) or to use resources (for example by executing a script) on the User’s device when the User interacts with this Application.
For simplicity, in this document these technologies are referred to collectively as “Tracking Tools,” unless there is a reason to differentiate them.
For example, although Cookies can be used in both web and mobile browsers, it would be inappropriate to speak about Cookies in the context of mobile applications, since those are Tracking Tools that require a browser. For this reason, within this document the term Cookie is used only to specifically indicate that particular type of Tracking Tool.
Some of the purposes for which Tracking Tools are used may also require the User’s consent. If consent is given, it can be freely withdrawn at any time by following the instructions contained in this document.
This Application uses Tracking Tools managed directly by the Controller (commonly called “first-party” Tracking Tools) and Tracking Tools that enable services provided by third parties (commonly called “third-party” Tracking Tools). Unless otherwise specified within this document, such third parties have access to their respective Tracking Tools.
The duration and expiration of Cookies and other similar Tracking Tools may vary depending on what is set by the Controller or by each third-party provider. Some of them expire at the end of the User’s browsing session.
In addition to what is stated in the description of each of the categories listed below, Users can obtain more detailed and updated information on duration, as well as any other relevant information—such as the presence of other Tracking Tools—in the privacy policies of the respective third-party providers (via the links provided) or by contacting the Controller.
Activities Strictly Necessary to Ensure the Functioning of This Application and the Provision of the Service
This Application uses Cookies commonly referred to as “technical” Cookies or other similar Tracking Tools to perform activities strictly necessary to ensure the operation or provision of the Service.
Third-party Tracking Tools
Traffic Optimization and Distribution
These services allow this Application to distribute its content via servers located in different territories and to optimize its performance.
The Personal Data processed depends on the characteristics and implementation method of these services, which by their nature filter communications between this Application and the User’s browser.
Given the distributed nature of this system, it is difficult to determine the locations where content is transferred, which may contain the User’s Personal Data.
Cloudflare (Cloudflare Inc.)
Cloudflare is a traffic optimization and distribution service provided by Cloudflare Inc.
Cloudflare’s integration involves filtering all traffic to this Application—i.e., communications between this Application and the User’s browser—also allowing the collection of statistical data on such traffic.
Personal Data processed: Tracking Tool and various types of Data as specified in the service’s privacy policy.
Place of processing: United States – Privacy Policy.
Hosting and Backend Infrastructure
These services are intended to host data and files that allow this Application to function, enable its distribution, and provide a ready-to-use infrastructure to deliver specific features of this Application.
Some of the services listed below may operate on geographically distributed servers, making it difficult to determine the actual location where Personal Data is stored.
Namecheap Hosting (Namecheap INC.)
Namecheap Hosting is a hosting service provided by Namecheap INC.
Personal Data processed: Usage Data; Tracking Tool; various types of Data as specified in the service’s privacy policy.
Place of processing: USA – Privacy Policy.
Other Activities Involving the Use of Tracking Tools
Measurement
This Application uses Tracking Tools to measure traffic and analyze User behavior in order to improve the Service.
Heat Mapping and Session Recording
Heat mapping services are used to identify areas of this Application with which Users interact most frequently, to detect which areas attract the most interest. These services allow the monitoring and analysis of traffic data and help track User behavior. Some of these services may record sessions and make them available for later viewing.
Hotjar Heat Maps & Recordings (Hotjar Ltd.)
Hotjar is a heat mapping and session recording service provided by Hotjar Ltd.
Hotjar respects generic “Do Not Track” headers, meaning the browser can indicate to the script not to collect any User data. This setting is available in all major browsers. More information on opting out of Hotjar is available at the relevant link.
Personal Data processed: Usage Data, Tracking Tool, and various types of Data as specified in the service’s privacy policy.
Place of processing: Malta – Privacy Policy – Opt Out.
Anonymized Analytics Services
These services allow the Controller to process and manage statistics in anonymous form through the use of first-party Tracking Tools.
Google Analytics with IP Anonymization
Google Analytics is a web analytics service provided by Google LLC or Google Ireland Limited, depending on the location where this Application is used (“Google”). Google uses the collected Personal Data to track and examine the use of this Application, compile reports, and share them with other services developed by Google. Google may use Personal Data to contextualize and personalize ads within its advertising network.
This integration anonymizes your IP address. Anonymization works by shortening the IP address of Users within the borders of EU Member States or other countries that are part of the European Economic Area agreement. Only in exceptional cases will the full IP address be sent to Google servers and shortened within the United States.
Personal Data processed: Usage Data and Tracking Tool.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
Analytics
The services in this section allow the Data Controller to monitor and analyze traffic data and track User behavior.
Google Analytics
Google Analytics is a web analytics service provided by Google LLC or Google Ireland Limited, depending on where this Application is used (“Google”). Google uses the collected Personal Data to track and examine the use of this Application, compile reports, and share them with other Google services. Google may also use Personal Data to contextualize and personalize ads within its advertising network.
Personal Data processed: Usage Data and Tracking Tool.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
Facebook Ads Conversion Tracking (Facebook Pixel)
Facebook Ads conversion tracking (Facebook Pixel) is a statistics service provided by Facebook, Inc. or Facebook Ireland Ltd, depending on where this Application is used. It connects data from the Facebook ads network with actions performed within this Application. The Facebook Pixel monitors conversions that can be attributed to ads on Facebook, Instagram, and the Audience Network.
Personal Data processed: Usage Data and Tracking Tool.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Targeting and Advertising
This Application uses Tracking Tools to provide personalized commercial content based on User behavior and to manage, deliver, and track advertisements.
Advertising
These services allow the use of User Data for commercial communication purposes. These communications are displayed on this Application in the form of banners and other advertising formats, including based on the User’s interests.
This does not mean that all Personal Data is used for this purpose. Data and terms of use are provided below.
Some of the services listed may use Tracking Tools to identify the User or use behavioral retargeting, i.e., displaying personalized ads based on the User’s interests and behavior, also detected outside this Application.
In addition to the opt-out features offered by the services listed below, Users may opt out by visiting the Network Advertising Initiative opt-out page.
Users can also disable certain advertising features via device configuration options, such as mobile device advertising settings or general advertising settings.
Facebook Lookalike Audience
Facebook Lookalike Audience is an advertising and behavioral targeting service provided by Facebook, Inc. or Facebook Ireland Ltd, depending on where this Application is used. It uses Data collected through Facebook Custom Audience to show ads to Users with behaviors similar to Users already in a Custom Audience list, based on their previous use of this Application or interaction with relevant content on Facebook’s apps and services.
Users can choose not to use Facebook cookies for ad personalization by visiting the opt-out page.
Personal Data processed: Usage Data and Tracking Tool.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
Facebook Audience Network
Facebook Audience Network is an advertising service provided by Facebook, Inc. or Facebook Ireland Ltd, depending on where this Application is used. To understand how Facebook uses data, please consult Facebook’s data policy.
To enable Audience Network, this Application may use certain mobile device identifiers (including Android Advertising ID or Advertising Identifier for iOS) or technologies similar to cookies.
The User can control the sharing of their advertising preferences in Facebook Ad settings. The User may opt out of certain Audience Network targeting functions through their device settings.
Personal Data processed: Usage Data, unique device identifiers for advertising (e.g., Google Advertiser ID or IDFA), and Tracking Tool.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
Remarketing and Behavioral Targeting
These services allow this Application and its partners to communicate, optimize, and deliver ads based on the User’s past use of this Application.
This activity is facilitated by tracking Usage Data and using Tracking Tools to collect information that is then transferred to partners who manage remarketing and behavioral targeting activities.
Some services offer remarketing based on email address lists.
In addition to opt-out features, Users may opt out by visiting the Network Advertising Initiative opt-out page.
Users can also disable certain advertising features via device configuration options.
Facebook Custom Audience
Facebook Custom Audience is a remarketing and behavioral targeting service provided by Facebook, Inc. or Facebook Ireland Ltd, depending on where this Application is used. It links the activity of this Application with Facebook’s advertising network.
Users can choose not to use Facebook cookies for ad personalization by visiting the opt-out page.
Personal Data processed: email and Tracking Tool.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
Facebook Remarketing
Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook, Inc. or Facebook Ireland Ltd, depending on where this Application is used. It links the activity of this Application with Facebook’s advertising network.
Personal Data processed: Usage Data and Tracking Tool.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
How to Manage Preferences and Give or Withdraw Consent
There are several ways to manage preferences related to Tracking Tools and to give or withdraw consent where required:
- Users can manage preferences directly through their device settings (e.g., prevent the use or storage of Tracking Tools).
- If consent is required, the User can give or withdraw consent by setting preferences in the cookie notice or updating preferences through the tracking settings widget, if available.
- Users can remove previously stored Tracking Tools using browser or device functions.
- Tracking Tools stored in the browser’s local memory can be removed by clearing browsing history.
For third-party Tracking Tools, Users can manage preferences and withdraw consent by visiting the relevant opt-out link (if available), using the tools described in the third party’s privacy policy, or contacting the third party directly.
Finding Tracking Tool Settings
Users can find information on managing Cookies in common browsers at:
- Google Chrome
- Mozilla Firefox
- Apple Safari
- Microsoft Internet Explorer
- Microsoft Edge
- Brave
- Opera
Users can also manage Tracking Tools for mobile apps by disabling them through device settings, such as mobile advertising settings or general tracking settings.
Advertising Industry Initiatives for Consent Management
Users may use resources such as:
- YourOnlineChoices (EU)
- Network Advertising Initiative (USA)
- Digital Advertising Alliance (USA)
- DAAC (Canada)
- DDAI (Japan)
These services allow Users to manage tracking preferences for most advertising tools. The Controller recommends using these resources in addition to the information provided in this document.
The Digital Advertising Alliance also provides an app called AppChoices to help Users control behavioral advertising on mobile applications.
Data Controller
Controller email address: office@shoptopon.com
Since the use of third-party Tracking Tools on this Application cannot be fully controlled by the Controller, any specific references to third-party Tracking Tools are indicative only. For complete information, Users are invited to consult the privacy policies of the respective third-party services listed in this document.
Given the objective difficulty of identifying tracking technologies, Users are encouraged to contact the Controller if they would like further information about the use of these technologies on this Application.
Definitions and Legal References
Personal Data (or Data): Any information that, directly or indirectly, even in connection with any other information (including a personal identification number), makes a natural person identified or identifiable.
Usage Data: Information automatically collected through this Application (including third-party applications integrated into it), such as: IP addresses, domain names, URI addresses, request time, method used to submit the request to the server, file size received in response, response status code, country of origin, browser and OS characteristics, time spent on each page, and navigation path details.
User: The individual using this Application who, unless otherwise specified, coincides with the Data Subject.
Data Subject: The natural person to whom the Personal Data refers.
Tracking Tool: Any technology—e.g., Cookies, unique identifiers, web beacons, embedded scripts, e-tags, fingerprinting—that makes it possible to track Users, for example by collecting or storing information on the User’s device.
European Union (EU): Unless otherwise specified, any reference to the EU includes all current EU and EEA member states.
Legal references: This privacy notice is drafted based on multiple legal systems, including Articles 13 and 14 of Regulation (EU) 2016/679 (GDPR).
Unless otherwise specified, this privacy notice applies exclusively to this Application.