Privacy Policy

Last updated: 17 march 2020

On this page you can find information on our policies regarding the collection, use and disclosure of personal data when you use our Service.
We use personal data of users to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, the terms used herein have the same meanings as in our Terms and Conditions accessible via the following link:


Service is website operated by Top Transitions Company.

Personal Data means data about a living individual which can be used for the identification of this individual.

Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself, for example, the duration of a page visit.

Cookies are system files stored on user`s device.

Data Controller means the natural or legal person who either alone or jointly with other persons determines the purposes for which and the manner in which any personal data are to be collected and processed.
For the purpose of this Privacy Policy, we perform the function of a Data Controller of your Personal Data.

Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller.
We may use the services of various Service Providers in order to process your data more effectively.

Data Subject (or User) is any living individual using our Service who possesses Personal Data.

Information Collection and Use

We collect several different types of information to provide and improve our Service to you.

Types of Data Collected:

Personal Data

While using our Service, we may ask you to provide us with certain Personal Data that can be used to identify you. Personal Data may include, but are not limited to:
User first name and last name.
E-mail address.
Location, address, etc.
Usage data, cookies.
We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us. You need to follow a special link and then act in accordance with suggested instructions in order to unsubscribe from any newsletters from us.

Usage Data

Usage Data is the information on the way users gain access and use the Service. These data include but are not limited to:
IP-address of user`s device;
The type of Internet browser used;
The version of a browser;
Service page visited by user;
The date and time of user visiting pages of the Service;
The time spent by user on pages of the Service;
Unique device identifiers, etc.

Tracking and Cookies Data

We use tracking technologies (cookies and other types of data) to track user activity on our Service web site and we hold certain information.
Cookies are special files with a small amount of data that contain an anonymous unique identifier. These files are sent to your browser from a website and stored on your device. Apart from that other tracking technologies are also used (like tags, beacons and scripts). They are used to improve and analyze our Service.
User can refuse from receiving cookies or make settings that determine the moment when a cookie is being sent at any time. However, if a user doesn`t accept cookies, some functions of our Service may be unavailable to him.
Examples of cookies we use:
Session cookies that are used by us to operate our Service;
Preference cookies allow to remember user preferences and settings;
Security cookies are used for information security purposes.

Use of Data

Top Transitions uses the collected data for the following purposes:

  • To provide and maintain our Service.
  • To notify users about changes introduced to our Service.
  • To allow users to participate in interactive features of our Service.
  • To provide timely customer support.
  • To gather analysis or valuable information that we need to improve our Service.
  • To monitor the usage of our Service.
  • To detect, prevent and address technical issues.
  • To provide users with news, special offers and general information about other goods, services and events. Offered goods and services are similar to those that user has already purchased or enquired about. The provision of such information is terminated at the request of the user.

Legal Basis for Processing Personal Data under the General Data Protection Regulation (GDPR)

Top Transitions Company legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.
Top Transitions Company reserves the right to collect and process your Personal Data according to the following reasons:

  • Users have given us permission to do so;
  • We need to perform a contract with users;
  • Collecting and processing user Personal Data protects our legal interests and doesn`t violate user rights;
  • We need user Personal Data for payment processing purposes;
  • We need user Personal Data to comply with legal requirements.

Retention of Data

Top Transitions Company will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Personal Data of our users to the extent necessary to comply with effective legal agreements and policies, to resolve disputes as well as to comply with our legal obligations, for example, if we are required to retain your data in accordance with the requirements of applicable laws.
Top Transitions Company will also retain Usage Data for internal analysis purposes. Usage Data are generally retained for a shorter period of time, except when these data are used to strengthen the security or to improve the functionality of our Service, or when retention of data is set forth by applicable law for longer periods.

Data Transfer

User personal information, including Personal Data, may be transferred to – and stored on – computers located outside user state jurisdiction. Accordingly, the legal requirements for the protection of personal data may differ from those that are effective in user state jurisdiction.
Please note that we transfer the data, including Personal Data, to Netherlands and process it there.
Your consent to this Privacy Policy followed by the submission of your Personal Data represents your agreement to that transfer.
Top Transitions Company will take all the steps reasonably necessary to ensure that user data is treated securely and in accordance with this Privacy Policy. We also guarantee that no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place.

Data Disclosure

Data Disclosure for Law Enforcement Bodies

Under certain circumstances that are determined by applicable law, Top Transitions Company may be required to disclose user Personal Data if required to do so by law or in response to valid requests by public authorities – a court, legal enforcement bodies or a government institutions.

Legal Requirements

Top Transitions Company may disclose your Personal Data in accordance with applicable law due to the following reasons:

  • To comply with a legal obligation;
  • To protect and defend the legitimate interests or property of Top Transitions Company;
  • To prevent or investigate possible wrongdoing in regard to the use of the Service;
  • To protect the personal safety of users of the Service or the public;
  • To be protected from legal liability.

Data Security

The security of user data has a great significance to Top Transitions Company. However you should keep in mind that no method of transmission over the Internet or method of electronic storage is 100% secure. We strive to use more and more effective and economic means of the best possible Personal Data protection, although we cannot guarantee its absolute security.

“Do Not Track” Signals

“Do Not Track” is a preference you can set in your web browser to inform websites that you do not want to be tracked. We do not support “Do Not Track” option.
You can enable or disable this option by visiting the settings page of your web browser.

User Data Protection Rights under the General Data Protection Regulation (GDPR)

Certain data protection rights apply for the residents of the European Economic Area (EEA). Top Transitions Company aims to take reasonable steps to allow users of the Service to correct, amend, delete or limit the use of their Personal Data.
If you wish to be informed about what Personal Data we hold about you and if you want them to be removed from our systems, please contact us.
In certain circumstances, users have the following data protection rights:

  • The right to access, update or delete Personal Data stored by us. Whenever made possible, customers can access, update or request deletion of their Personal Data directly within their account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
  • The right of rectification. Users have the right to have their personal information rectified if that information is inaccurate or incomplete.
  • The right to object. Users have the right to object to their Personal Data being processed by our Service.
  • The right of restriction. Users have the right to request that we restrict the processing of their personal information.
  • The right to data portability. Users have the right to be provided with a copy of the information we have on them in a structured, machine-readable and commonly used format.
  • The right to withdraw consent. Users also have the right to withdraw their consent allow us to store and process their personal information at any time.
  • Please note that we may ask you to verify your identity before responding to such requests.
  • You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. Please contact your local data protection authority in the European Economic Area (EEA) to get more detailed information or to make a complaint.

Service Providers

We may employ third party companies and individuals to facilitate our Service, provide the Service on our behalf, perform Service-related services or assist us in analyzing how our Service is used.
These third parties have access to the Personal Data of users only to perform these tasks on our behalf and are obligated not to disclose or use them for any other purpose.


We may use third-party Service Providers to monitor and analyze the use of our Service.

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the collected data to track and monitor the use of our Service. These data can be transferred to other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
You can opt out of having made your activity on the Service available to Google Analytics. For doing that you need to install the Google Analytics opt-out browser add-on that prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page:


Yandex.Metrica is a free web service which is the property of Yandex Company designed to assess web traffic and analyze user behavior. The collected data may be transferred to other Yandex services. This information may be used to contextualize and personalize the ads of its own advertising network.
For more information on the privacy practices of Yandex, please visit the Privacy Policy web page:

Behavioral Remarketing

Top Transitions Company uses behavioral remarketing services to advertise on third party websites to you after you visited our Service. We and our third-party vendors use cookies to inform, optimize and show ads of our Service.

Google AdWords

Google AdWords is a remarketing service provided by Google Inc.
You can opt-out of Google Analytics for display advertising and customize the Google Display Network ads by visiting the Google Ads Settings page:
Google also recommends installing the Google Analytics Opt-out Browser Add-on that can be downloaded following the link: Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page:


Twitter remarketing service is provided by Twitter Inc.
You can opt-out from Twitter’s interest-based ads by following the instructions provided on this page:
You can learn more about the privacy practices and policies of Twitter by visiting their Privacy Policy page:


Facebook remarketing service is provided by Facebook Inc.
You can get more detailed information about interest-based advertising from Facebook by visiting this page:
To opt-out from Facebook`s interest-based ads, please, visit the following page: and follow the instructions given there.
Facebook adheres to the Self-Regulatory Principles for Online Behavioural Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook through the Digital Advertising Alliance on the following pages: (in the USA), (in Canada), (in Europe). You can also opt-out using your mobile device settings.
For more information on the privacy practices of Facebook, please visit Facebook’s Data Policy page:


We may provide paid products and/or services within the Service. In that case, we use third-party services for payment processing (e.g. payment processors).
We will not store or collect user payment card details. That information is provided directly to our third-party payment processors who perform payment processing. The use of user personal information is governed by their Privacy Policy. The payment processors whose services are used by us adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. PCI-DSS requirements ensure the highest level of security in terms payment information processing.
We work with GumRoad payment processor which privacy policy is provided on the following page:

Links to Other Sites

The pages of our Service may contain links to other sites that are operated by third parties. If you click a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of such site before using it.
Please, note that we have no control over and assume no responsibility for the content, privacy policies or practices of any third party web sites.

Children’s Privacy

Our Service does not address anyone under the age of 18.
We consciously avoid collecting as well as processing personally identifiable information from anyone under the age of 18. We recommend you to contact us if you are a parent or guardian and you are aware that your Child has provided us with Personal Data. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

Changes to This Privacy Policy

We reserve the right to amend our Privacy Policy, if necessary. We will notify users of any changes by posting the new Privacy Policy on this page.
We will let users know a prominent notice on our Service and/or via email, prior to the change becoming effective. After the change becoming effective, the “effective date” will be changed, indicated at the top of this Privacy Policy. We recommend you to review this Privacy Policy on a regular basis to be aware of any amendments.
Changes to this Privacy Policy are effective starting from the moment when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, please contact us using the following means:
By e-mail:;
On our contact page: