PRIVACY POLICY
INFORMATION ON THE PROCESSING OF PERSONAL DATA
This page describes how the website is managed with regard to the processing of the personal data of
users who visit it. This Privacy Policy is provided pursuant to Article 13 of Italian Legislative Decree No.
196/2003 concerning the processing of personal data and Article 13 of European Regulation (EU)
2016/679 concerning privacy protection, to those who interact with the website’s online services,
accessible electronically at:
Home
which corresponds to the homepage of the official website.
This Privacy Policy applies exclusively to the TOPFLIGHT SPA website and does not apply to any other
websites that users may access through links. This Privacy Policy also draws inspiration from
Recommendation No. 2/2001, adopted on 17 May 2001 by the European data protection authorities
gathered within the Working Party established under Article 29 of Directive 95/46/EC. The
Recommendation identifies certain minimum requirements for the online collection of personal data
and, in particular, the methods, timing and nature of the information that data controllers must provide
to users when they access web pages, regardless of the purpose of their visit. The Recommendation
and a summary description of its objectives are provided on other pages of this website.
THE DATA CONTROLLER
Following consultation of this website, data relating to identified or identifiable persons may or may not
be processed.
The Data Controller responsible for such processing is:
TOPFLIGHT SPA
Via Sebastiano Veniero 8
20148 Milan, Italy
Email address: topflight@topflight.it
TYPES OF DATA PROCESSED
The Personal Data collected by this Application, either independently or through third parties, include
Cookies, Usage Data, name, email address and website.
Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically
when using this Application.
Unless otherwise specified, all Data requested by this Application are mandatory. If the User refuses to
provide them, it may be impossible for this Application to provide the Service. Where this Application
1indicates that certain Data are optional, Users are free not to provide such Data without this affecting
the availability or operation of the Service.
Users who are uncertain about which Data are mandatory are encouraged to contact the Data
Controller.
Any use of Cookies or other tracking tools by this Application or by the owners of third-party services
used by this Application, unless otherwise specified, is intended to provide the Service requested by the
User, in addition to the other purposes described in this document and in the Cookie Policy, where
available.
The User accepts responsibility for any Personal Data relating to third parties obtained, published or
shared through this Application and guarantees that they have the right to disclose or distribute such
Data, releasing the Data Controller from any liability towards third parties.
PROCESSING METHODS
The Data Controller adopts appropriate security measures to prevent unauthorised access, disclosure,
alteration or destruction of Personal Data.
Processing is carried out using IT and/or electronic tools, according to organisational procedures and
methods strictly related to the purposes indicated. In addition to the Data Controller, in certain cases,
the Data may be accessible to individuals involved in the organisation of this Application, including
administrative, sales, marketing and legal personnel and system administrators, as well as external
parties such as third-party technical service providers, postal couriers, hosting providers, IT companies
and communication agencies. Where necessary, such parties may be appointed as Data Processors by
the Data Controller.
An up-to-date list of Data Processors may be requested from the Data Controller at any time.
Legal basis for processing
The Data Controller processes Personal Data relating to the User when one of the following conditions
applies:
– the User has given consent for one or more specific purposes. Note: under certain jurisdictions, the
Data Controller may be permitted to process Personal Data without the User’s consent or another legal
basis specified below until the User objects to such processing. However, this does not apply where the
processing of Personal Data is governed by European data protection legislation;
– processing is necessary for the performance of a contract with the User and/or for the
implementation of pre-contractual measures;
– processing is necessary for compliance with a legal obligation to which the Data Controller is subject;
– processing is necessary for the performance of a task carried out in the public interest or in the
exercise of official authority vested in the Data Controller;
– processing is necessary for the purposes of the legitimate interests pursued by the Data Controller or
by a third party.
2The User may always ask the Data Controller to clarify the specific legal basis applicable to each
processing activity and, in particular, whether processing is based on the law, required by a contract or
necessary to enter into a contract.
Place of processing
The Data are processed at the Data Controller’s operating offices and in any other locations where the
parties involved in the processing are located. For further information, please contact the Data
Controller.
The User’s Personal Data may be transferred to a country other than the country in which the User is
located. For further information regarding the place of processing, the User may refer to the section
containing details about the processing of Personal Data.
The User is entitled to obtain information regarding the legal basis for any transfer of Data outside the
European Union or to an international organisation governed by public international law or established
by two or more countries, such as the United Nations, as well as information regarding the security
measures adopted by the Data Controller to protect the Data.
Where any of the transfers described above takes place, the User may refer to the relevant sections of
this document or request information from the Data Controller using the contact details provided at the
beginning of this document.
Retention period
The Data are processed and retained for the period required for the purposes for which they were
collected.
Therefore:
Personal Data collected for purposes related to the performance of a contract between the Data
Controller and the User will be retained until the performance of that contract has been completed.
Personal Data collected for purposes related to the legitimate interests of the Data Controller will be
retained until such interests have been satisfied. The User may obtain further information regarding the
legitimate interests pursued by the Data Controller in the relevant sections of this document or by
contacting the Data Controller.
Where processing is based on the User’s consent, the Data Controller may retain the Personal Data for a
longer period, until such consent is withdrawn. Furthermore, the Data Controller may be required to
retain Personal Data for a longer period in order to comply with a legal obligation or an order issued by
an authority.
At the end of the retention period, the Personal Data will be deleted. Consequently, once this period has
expired, the rights of access, erasure, rectification and data portability may no longer be exercised.
PURPOSES OF PROCESSING
The User’s Data are collected to allow the Data Controller to provide its Services, as well as for the
following purposes: analytics and, where applicable, registration and authentication.
3For further detailed information regarding the purposes of processing and the Personal Data
specifically relevant to each purpose, the User may refer to the relevant sections of this document.
DETAILS OF PROCESSING
Personal Data are collected for the following purposes and through the following services:
Browsing Data
The services contained in this section allow the Data Controller to monitor and analyse traffic data and
are used to track the User’s behaviour.
USER RIGHTS
Users may exercise certain rights regarding the Data processed by the Data Controller.
In particular, the User has the right to:
– withdraw consent at any time. The User may withdraw previously given consent to the processing
of their Personal Data;
– object to the processing of their Data. The User may object to the processing of their Data where
processing is carried out on a legal basis other than consent. Further details regarding the right to
object are provided in the section below;
– access their Data. The User has the right to obtain information regarding the Data processed by the
Data Controller, certain aspects of the processing and a copy of the Data being processed;
– verify and request rectification. The User may verify the accuracy of their Data and request that they
be updated or corrected;
– obtain restriction of processing. Where certain conditions apply, the User may request that the
processing of their Data be restricted. In such cases, the Data Controller will not process the Data for
any purpose other than their storage;
– obtain the erasure or removal of their Personal Data. Where certain conditions apply, the User may
request that the Data Controller erase their Data;
– receive their Data or have them transferred to another data controller. The User has the right to
receive their Data in a structured, commonly used and machine-readable format and, where technically
feasible, to have such Data transferred to another data controller without hindrance. This provision
applies where the Data are processed using automated means and the processing is based on the
User’s consent, on a contract to which the User is a party or on pre-contractual measures connected
with that contract;
– lodge a complaint. The User may lodge a complaint with the competent personal data protection
supervisory authority or take legal action.
4DETAILS REGARDING THE RIGHT TO OBJECT
Where Personal Data are processed in the public interest, in the exercise of official authority vested in
the Data Controller or for the purposes of the legitimate interests pursued by the Data Controller, Users
have the right to object to such processing on grounds relating to their particular situation.
Users are informed that where their Data are processed for direct marketing purposes, they may object
to the processing without providing any reason. To determine whether the Data Controller processes
Data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to exercise these rights
To exercise their rights, Users may submit a request using the Data Controller’s contact details provided
in this document. Requests may be submitted free of charge and will be handled by the Data Controller
as soon as possible and, in any event, within one month.
Legal defence
The User’s Personal Data may be used by the Data Controller in legal proceedings or during the
preparatory stages of possible legal proceedings in order to defend against misuse of this Application
or the related Services by the User.
The User declares that they are aware that the Data Controller may be required to disclose the Data by
order of public authorities.
Specific information notices
At the User’s request, in addition to the information contained in this Privacy Policy, this Application
may provide the User with additional and contextual information notices concerning specific Services or
the collection and processing of Personal Data.
System logs and maintenance
For operational and maintenance purposes, this Application and any third-party services used by it may
collect system logs, namely files that record interactions and may also contain Personal Data, such as
the User’s IP address.
Information not contained in this Policy
Further information regarding the processing of Personal Data may be requested from the Data
Controller at any time using the contact details provided.
Response to “Do Not Track” requests
This Application does not support “Do Not Track” requests.
To determine whether any third-party services used by this Application support such requests, the User
is invited to consult their respective privacy policies.
5Changes to this Privacy Policy
The Data Controller reserves the right to make changes to this Privacy Policy at any time by informing
Users on this page and, where possible, through this Application. Where technically and legally feasible,
the Data Controller may also send a notification to Users through one of the contact details held by the
Data Controller.
Users are therefore requested to consult this page regularly and refer to the date of the most recent
update shown at the bottom.
Where changes affect processing activities whose legal basis is consent, the Data Controller will obtain
the User’s consent again, where necessary.
COOKIES
What Cookies Are
Cookies are small text files that websites visited by the User send to the User’s device, such as a
computer, laptop, tablet or smartphone. They are stored on the device and subsequently sent back to
the same websites the next time the same User visits them.
When browsing this website, you may receive only Cookies sent directly by our website.
For the purposes of this Policy, Cookies are divided into two main categories: “technical” Cookies and
“profiling” Cookies.
With regard to Cookies, Users are informed that this website exclusively uses technical Cookies known
as “analytics” Cookies to statistically analyse visits to the website, as well as technical browsing or
session Cookies.
These Cookies are used exclusively for statistical purposes and collect information in aggregate form. In
particular, the analytics Cookies used on this website are Google Cookies based on the ga.js JavaScript
library.
Browsing or session Cookies allow Users to navigate the website more easily. No Personal Data relating
to Users are collected by the website in this regard.
Cookies are not used to transmit information of a personal nature.
The website uses Google Analytics to collect information regarding how Users use the website.
Google Analytics generates statistical and other information through Cookies stored on Users’
computers. The information generated in relation to our website is used to produce reports concerning
website usage.
Google will store and use this information. Google’s Privacy Policy is available at the following address:
6http://www.google.com/privacypolicy.html
COOKIES USED
Preferences
These Cookies allow our website to store information that changes the way the website behaves or
appears, such as your preferred language or the geographical area in which you are located.
The loss of information stored in a preference Cookie may make the website experience less functional
but should not prevent the website from operating.
Most Google Users have a preference Cookie called “NID” in their browsers. The browser sends this
Cookie when requests are made to Google websites.
The NID Cookie contains a unique ID used by Google to store your preferences and other information,
such as your preferred language, for example Italian, the number of search results you wish to be
displayed on each page, for example 10 or 20, and whether you wish to enable Google’s SafeSearch
filter.
Advertising
The use of these Cookies requires the User’s express and informed consent pursuant to Article 122,
paragraph 1, of the Italian Privacy Code.
By accessing the website’s homepage at https://www.topflight.it, viewing the Cookie information
banner displayed on the website and reading the information provided, the User gives their specific
consent to the use of Cookies.
Configuring an internet browser, such as Explorer, Firefox or Chrome, to accept the use of Cookies is
also considered valid consent by the User pursuant to Article 122, paragraph 2, of the Italian Privacy
Code.
We use Cookies such as the NID and SID Cookies to help personalise advertisements on Google
properties, such as Google Search.
The main Cookie used for advertising on third-party websites is called “id” or “IDE” and is stored in
browsers under the doubleclick.net domain.
In some cases, an advertising Cookie may be set on the domain of the website being visited. In the case
of the DoubleClick product, a “__gads” Cookie may be set on the website’s domain.
Unlike Cookies set on Google domains, this Cookie cannot be read by Google when you visit other
websites. It can be used, for example, to measure interactions with advertisements on the domain.
Conversion Cookies are not used by Google to target personalised advertisements and are retained for
a limited period. The “Conversion” Cookie is intended for this purpose and is generally set under the
googleadservices.com domain.
7DoubleClick and Google Analytics Cookies may also be used for this purpose.
Session Status
The website collects information regarding how Users interact with it. This information may concern the
pages most frequently visited by Users and any error messages they receive from particular pages.
We use these “session status Cookies” to improve our Services and our Users’ browsing experience.
Blocking or deleting these Cookies will not make the website unusable.
These Cookies may also be used to measure the effectiveness of PPC advertising, meaning Pay Per Click
advertising, and affiliate advertising.
The use of session Cookies, which are not stored permanently on the User’s computer and disappear
when the browser is closed, is strictly limited to the transmission of session identifiers consisting of
random numbers generated by the server. These identifiers are necessary to allow the website to be
browsed securely and efficiently.
The session Cookies used on this website avoid the use of other IT techniques that could potentially
compromise the confidentiality of Users’ browsing activities and do not allow the collection of
personally identifiable information relating to the User.
HOW TO DISABLE COOKIES
Should you wish to block Cookies, please note that doing so may negatively affect the usability of
certain websites. Most browsers allow you to reject or accept Cookies.
To configure Cookie preferences for this website, select:
Cookie Settings
The following provides practical information on how to disable Cookies in the browser you are using.
Microsoft Internet Explorer
Click the “Tools” icon in the top-right corner and select “Internet Options”.
In the pop-up window, select “Privacy”. You can then adjust your Cookie settings.
Google Chrome
Click the wrench icon in the top-right corner and select “Settings”.
Then select “Show advanced settings” or “Under the hood” and change the “Privacy” settings.
8Mozilla Firefox
From the drop-down menu in the top-left corner, select “Options”.
In the pop-up window, select “Privacy”. You can then adjust your Cookie settings.
Safari
From the settings drop-down menu in the top-right corner, select “Preferences”.
Select “Security”. You can then adjust your Cookie settings.
Considering that the current level of development of automatic control mechanisms does not make
them completely free from errors or malfunctions, this document, published at:
Privacy Policy
constitutes the Privacy Policy of this website and may be subject to updates.
Last updated: 16 July 2026
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