Privacy Policy

Privacy Policy

Top Line / ESIMPLE

This Privacy Policy describes how Top Line (“Company”, “we”, “us”, “our”) collects, uses, stores, and protects personal data of users (“User”, “you”) when using the website https://esimple.pro/ and related B2C digital services under the ESIMPLE brand, in accordance with the General Data Protection Regulation (EU) 2016/679 (“GDPR”).

1. Data Controller

The data controller within the meaning of the GDPR is:

Top Line
Email: info@topline.tours

2. Categories of Personal Data We Process

2.1 Contractual and Registration Data

We may process the following personal data:

• first and last name;
• email address;
• phone number;
• residential address (including country of residence, where required);
• payment-related information (excluding full payment card details);
• any other information voluntarily provided by you.

Purposes:

• user identification;
• account creation and management;
• conclusion and performance of contracts;
• order processing and payments;
• customer support;
• legal and contractual communications.

Legal basis (GDPR):

• performance of a contract (Art. 6(1)(b));
• compliance with legal obligations (Art. 6(1)(c)).

2.2 Website and Technical Data (Cookies)

When you visit https://esimple.pro/, we may automatically collect:

• IP address;
• device type;
• browser type and version;
• operating system;
• date and time of access;
• pages viewed and interactions;
• referring websites.

Purposes:

• website functionality;
• session management;
• analytics and website optimization;
• statistical reporting.

Legal basis (GDPR):

• legitimate interest (Art. 6(1)(f));
• user consent (Art. 6(1)(a)) for non-essential cookies.

Third-party cookies are governed by the privacy policies of the respective providers.

2.3 Facebook (Meta Platforms) Data

We use Facebook / Meta Platforms, Inc. tools for analytics, marketing, and advertising purposes.

Depending on your cookie consent and interaction with the website, Meta may process:

• IP address;
• device and browser information;
• online identifiers (cookies, pixel IDs);
• website interaction data (e.g. page views, conversions);
• referral URLs.

Data may be collected via:

• Facebook Pixel;
• Meta Ads and Analytics tools.

Purposes:

• measuring advertising effectiveness;
• audience measurement and retargeting;
• marketing optimization.

Legal basis (GDPR):

• user consent (Art. 6(1)(a));
• legitimate interest (Art. 6(1)(f)), where applicable.

Data recipients:
Meta Platforms, Inc. acts as an independent data controller.

Meta may transfer data outside the EEA in accordance with GDPR safeguards, including Standard Contractual Clauses (SCCs).

You can manage or withdraw consent at any time via cookie settings or your Facebook account settings.

2.4 Billing and Accounting Data

We process:

• selected services or plans;
• transaction values and currencies;
• taxes and mandatory charges;
• payment status.

Purpose:

• billing;
• accounting and tax compliance.

Legal basis (GDPR):

• legal obligation (Art. 6(1)(c));
• performance of a contract (Art. 6(1)(b)).

2.5 Correspondence Data

We process personal data you provide through:

• email communications;
• contact forms;
• customer support requests.

Purpose:

• responding to inquiries;
• handling complaints and requests;
• service improvement.

Legal basis (GDPR):

• legitimate interest (Art. 6(1)(f));
• performance of a contract (Art. 6(1)(b)), where applicable.

2.6 Marketing Communications (B2C)

We may process:

• email address;
• phone number (if provided).

Purposes:

• service-related notifications;
• marketing and informational communications.

You may withdraw consent at any time.

Legal basis (GDPR):

• user consent (Art. 6(1)(a)).

3. Sources of Personal Data

Personal data is collected:

• directly from you;
• automatically through website usage;
• from payment service providers (to the necessary extent).

4. Data Sharing

We may share personal data with:

• payment service providers;
• hosting and IT providers;
• analytics and marketing providers (including Meta);
• public authorities where required by law.

We do not sell personal data.

5. Data Retention

Personal data is retained:

• only as long as necessary for the purposes stated;
• or as required by applicable law.

6. Your Rights Under GDPR

You have the right to:

• access your personal data;
• rectify inaccurate data;
• request erasure (“right to be forgotten”);
• restrict processing;
• data portability;
• object to processing;
• withdraw consent at any time;
• lodge a complaint with a supervisory authority.

7. Data Deletion Requests

You may request deletion of your personal data by contacting:

📧 info@topline.tours

Deletion will occur within a reasonable timeframe, unless retention is legally required.

8. Data Security

We implement appropriate technical and organizational measures to protect personal data from:

• unauthorized access;
• loss;
• alteration;
• unlawful disclosure.

9. Changes to This Policy

We may update this Privacy Policy periodically. The current version is always available on https://esimple.pro/.

10. Contact

For any privacy-related questions or requests:

📧 info@topline.tours