Privacy Policy
1. Controller
The data controller for personal data collected through top-gadget-europe.com is:
SBC Performance LLC
30 N Gould St, Sheridan, WY 82801-6317, US
Email: privacy@top-gadget-europe.com
2. Data We Collect
| Category | Data Types | Source |
|---|---|---|
| Account & Order Data | Name, email address, billing & delivery address, phone number, order history, payment method type (not card numbers) | You provide this when ordering |
| Technical Data | IP address, browser type, device identifiers, pages visited, session duration, referral source | Collected automatically via cookies & server logs |
| Marketing Data | Email address, communication preferences | Provided with your explicit consent |
| Support Data | Content of messages you send us, correspondence history | You provide this when contacting us |
We do not collect sensitive categories of personal data (e.g. health data, biometric data, racial or ethnic origin).
3. Legal Basis for Processing (GDPR Article 6)
- Performance of a contract (Art. 6(1)(b)): Processing your order, managing delivery, handling returns and warranty claims.
- Legal obligation (Art. 6(1)(c)): Keeping financial records for the period required by tax and accounting laws (7 years).
- Legitimate interests (Art. 6(1)(f)): Fraud prevention, IT security, analytics to improve our services, and direct marketing to existing customers for similar products (with opt-out available).
- Consent (Art. 6(1)(a)): Sending you newsletters, using non-essential cookies, and targeted advertising via Google Ads. Consent can be withdrawn at any time.
4. How We Use Your Data
- Processing and fulfilling your orders
- Communicating about your order status, shipping, and returns
- Providing customer support
- Sending promotional emails (with your consent, opt-out available in every email)
- Improving the Site through analytics
- Detecting and preventing fraud and abuse
- Complying with legal obligations
5. Cookies
We use cookies and similar tracking technologies. For detailed information about the cookies we use, please see our Cookie Policy.
6. Sharing Your Data
We do not sell your personal data. We share data only with trusted third parties as necessary:
| Recipient | Purpose | Location |
|---|---|---|
| Payment processors (e.g. Stripe, PayPal) | Processing payments securely | EU / USA (SCCs) |
| Shipping carriers (e.g. DHL, DPD, PostNL) | Order delivery | EU |
| Google LLC (Analytics & Ads) | Site analytics, advertising | USA (SCCs / DPF) |
| Email service provider | Transactional & marketing emails | EU / USA (SCCs) |
| SBC Performance LLC (parent entity) | Business operations | USA (SCCs) |
Where data is transferred outside the European Economic Area (EEA), we ensure appropriate safeguards are in place, including Standard Contractual Clauses (SCCs) as approved by the European Commission.
7. Retention Periods
| Data Category | Retention Period |
|---|---|
| Order & financial records | 7 years (legal / tax obligation) |
| Account data (inactive accounts) | 3 years after last activity |
| Marketing preferences & email list | Until you unsubscribe or withdraw consent |
| Analytics data | 26 months (Google Analytics default) |
| Support correspondence | 3 years after resolution |
8. Your Rights
Under the GDPR, you have the following rights:
- Right of access (Art. 15): Request a copy of the personal data we hold about you.
- Right to rectification (Art. 16): Request correction of inaccurate or incomplete data.
- Right to erasure (Art. 17): Request deletion of your personal data (“right to be forgotten”), subject to legal retention obligations.
- Right to restriction (Art. 18): Request that we limit the processing of your data in certain circumstances.
- Right to data portability (Art. 20): Receive your data in a structured, machine-readable format.
- Right to object (Art. 21): Object to processing based on legitimate interests, including direct marketing.
- Right to withdraw consent: Withdraw any previously given consent at any time, without affecting the lawfulness of processing before withdrawal.
To exercise any of these rights, contact us at: privacy@top-gadget-europe.com. We will respond within 30 days. You also have the right to lodge a complaint with your national data protection authority.
9. Security
We implement appropriate technical and organisational measures to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access. This includes SSL/TLS encryption for data transmission, access controls, and regular security assessments.
10. Children’s Privacy
Our Site and services are not directed to individuals under 18 years of age. We do not knowingly collect personal data from children. If you believe we have inadvertently collected such data, please contact us immediately at privacy@top-gadget-europe.com.
11. Changes to This Policy
We may update this Privacy Policy from time to time. Material changes will be communicated via notice on the Site. The date at the top of this page indicates the most recent revision. Continued use of the Site after updates constitutes acceptance.
12. Contact
SBC Performance LLC
30 N Gould St, Sheridan, WY 82801-6317, US
Email: privacy@top-gadget-europe.com