Privacy and Cookie Policy of Topigs Norsvin

This Privacy and Cookie Policy was last updated on March 17, 2022. 
We (‘Topigs Norsvin’ or ‘we’ or ‘our’) deeply respect and value your privacy. In this Privacy and Cookie Policy, we inform you about how we process your personal data that we collect through your use of our websites and related services. This Policy also contains information about how we process your data if we have contact in another way, such as by e-mail. 

Scope and acceptance of this Privacy Policy 
By using our websites and related services and/or having contact with us (by e-mail), you agree that we can collect, use, disclose and store your personal data, as described in this Privacy Policy. 

This Privacy and Cookie Policy is applicable to all parts of the websites managed by Topigs Norsvin and to all correspondence between us. 

Collection, Use and Handling of Personal Data

How do we collect your personal data?

We collect your personal data in the following circumstances:

1. When you provide personal data to us directly, for example by subscribing to our newsletter or other publication or when you register for an event;
2. When you visit our website;
3. When you use our social media channels;
4. When we are in touch, for example via e-mail.

We collect the following personal data:

• Data we automatically collect:
  When you visit and/or use our websites, we automatically collect the personal data provided by your computer, mobile device or other device that gives you access to our websites. This data may be collected using cookies. For more information regarding the use of cookies we refer you to the section about cookies. The collected information consists of the following:

• • browser information;
  • duration of your visit;
  • web pages you visit;
  • hyperlinks you select;
  • information about your connection, such as your IP-address.

• Personal data you provide (such as subscribing to our newsletter):
  • name;
  • address;
  • postal code;
  • place of residence;
  • country;
  • (mobile) phone number;
  • email address;
  • other information.

How do we use your personal data:
We process your personal data based on the following legal grounds:

A. for the performance of a contract (for example by subscribing to our newsletter);

B. for the purpose of our legitimate interests, including marketing purposes;

C. for compliance with legal obligations.

We process your personal data for the following purposes, based on the noted legal grounds:

Sharing of personal data:

We may share your personal data with third parties in accordance with this Privacy Policy and relevant law and regulations. We solely share your data in the following circumstances: 

We may use third-party processors to process your personal data. We process your personal data on secured Pardot and Salesforce.com servers in the European Union. Pardot and Salesforce.com act as processors of Topigs Norsvin. Your personal data may be transferred to servers in the United States. Topigs Norsvin has signed contractual model clauses approved by the European Commission with Pardot and Salesforce.com. For more information we refer you to the Privacy Policy of Pardot and the Privacy Policy of Salesforce.com. 

Your personal data may be shared with other domestic and/or foreign entities of Topigs Norsvin for marketing purposes. These entities may be situated outside the European Union in a country without an adequate level of protection of personal data. Topigs Norsvin will provide appropriate safeguards, such as model contracts for the transfer of personal data to third countries or other measures as provided by the GDPR for a legitimate transfer of personal data outside the European Union. If you do not want your personal data to be shared, you may send an email to info@topigsnorsvin.us. 

We may disclose your personal data to third parties, if such disclosure is required by a court, law or legislation (for example for holders of intellectual property, supervisory authorities, Tax and Customs administration, the police and other legal entities). 

We will not disclose your personal information to law enforcement, other government officials, or other third parties without a subpoena, court order or substantially similar legal procedure, except when we believe in good faith that the disclosure of information is necessary and legitimate to protect the safety or rights of a third party or to protect our rights. 

Retention of personal data: 
We will retain your personal data for the period necessary to fulfill the purposes of processing your personal data. Personal data linked to an account may be retained until the deletion of the account, unless a longer retention period is required for our services, a dispute or as permitted by law. 

Security of your personal data: 
We take reasonable organisational and technical measures to help secure your personal data and to help prevent unauthorized access, illegal processing or distribution, as well as accidental loss, modification or destruction. 

Links to other websites: 
Our website has links to websites maintained by third-parties that may apply other terms & conditions for the processing of personal data. We are not responsible for the content or processing of personal data via these websites or the operation of such websites and you should review the terms and privacy policy applicable to such websites before providing any personal data through such websites. This Privacy Policy does not extend to these websites. 

Rights of data subjects: 
You have the right to request information about and to verify the accuracy of your personal data processed by us. You may submit this request by the following email address: info@topigsnorsvin.us, or by mail: 

Topigs Norsvin USA, 12750 Nicollet Ave. S. Suite 300 Burnsville, MN 55337 

If you believe that we have inaccurate, incomplete, out-of-date personal data about you, or if you suspect that we incorrectly processed your personal data, you may ask us at any time to correct that information. Through the abovementioned contact details or the displayed opt-out-possibilities you may object to the use of your personal data for marketing purposes. You may request us to restrict the processing of your personal data. You may also request us to transfer your personal data to another controller. Objections and insight requests, correction, deletion or transfer will be executed, in accordance with the law, notwithstanding exceptions, within four weeks. 

Complaints: 
If you have a complaint related to the processing of personal data by Topigs Norsvin, please submit your complaint to info@topigsnorsvin.us. We will review complaints and questions within four weeks. If you are not satisfied with the outcome of the complaint, you may contact your national Data Protection Authority (‘DPA’) and file a complaint. 

Do-Not-Track Disclosure: 
At this time, our websites are not set up to honor web browser do-not-track settings.  Do-not-track is a privacy preference that users can set in their web browsers. When a user activates the do-not-track settings in browsers that offer this setting, the browser sends a message to websites or applications requesting them not to track the user. For more information about do-not-track matters, please visit www.allaboutdnt.org. 

Disclaimers and Related Matters

Ownership: 
The Topigs Norsvin websites are operated by, and the contents of such websites are owned by, Topigs Norsvin or individual legal entities affiliated with Topigs Norsvin. The use of the name ‘’Topigs Norsvin‘’ on this website is intended to include each said legal entity either individually or jointly. 

Intellectual property: 
The information, images, lay-out, documents, audio, video, text and software on the Topigs Norsvin websites are protected by copyright and other protective laws. Any copying, downloading, publishing, or distribution of the information or content on the websites is not permitted without the prior written permission of Topigs Norsvin. 

Liability: 
Although reasonable care has been exercised to help ensure the correctness and completeness of the information provided on the websites, Topigs Norsvin disclaims any liability for any inaccuracies on the websites. Topigs Norsvin is not liable for any damage resulting from the use of information on its websites. TOPIGS NORSVIN DOES NOT WARRANT THAT THE FUNCTIONAL ASPECTS OF ITS WEBSITES OR THEIR USE WILL BE UNINTERRUPTED OR ERROR FREE OR THAT THE WEBSITES OR THE SERVERS THAT MAKE ANY OF THEM AVAILABLE ARE FREE OF VIRUSES OR OTHER HARMFUL COMPONENTS. TOPIGS NORSVIN SHALL NOT BE LIABLE FOR ANY DIRECT, INCIDENTAL, CONSEQUENTIAL, INDIRECT, OR PUNITIVE DAMAGES ARISING OUT OF YOUR ACCESS TO, OR USE OF, ANY OF THE WEBSITES OR ANY OF THE FEATURES THEREOF.  TOPIGS NORSVIN SPECIFICALLY DISCLAIMS ANY EXPRESS OR IMPLIED WARRANTIES CONCERNING SUCH MATTERS, INCLUDING, WITHOUT LIMITATION, ANY WARRANTIES OF TITLE, NON-INFRINGEMENT, MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE. YOU ACKNOWLEDGE THAT YOUR USE OF THE TOPIGS NORSVIN WEBSITES IS AT YOUR OWN RISK. 

Children’s Privacy and Age Limitations: 

The Topigs Norsvin websites are intended for use by persons 18 years of age or older.  We do not knowingly allow use of the websites by any person that we believe to be younger than 18. Topigs Norsvin also does not knowingly collect any personally identifiable information from any persons under 18 years of age and if we discover that we have been provided any such information, we will delete this information from our records. 

Additional Privacy Notices to California Residents: 

The following additional privacy notices for California residents (the “California Notice”) supplement the information contained in the other portions of the Company’s Privacy Policy and apply solely to individuals who reside in the State of California (“California consumer” or “you”). The Company adopts this California Notice to comply with the California Consumer Privacy Act and its related regulations (the “CCPA”) and other applicable California laws. 

Overview of Consumer Rights Under the CCPA 

Under the CCPA, California consumers have certain rights regarding their personal information, including: 

• The right to know the categories of personal information that the Company has collected and the categories of sources from which we obtained such information.
• The right to know the Company’s business purposes for sharing personal information.
• The right to know the categories of third parties with whom the Company shared personal information.
• The right to access the specific pieces of personal information that the Company has collected and the right to delete your personal information.
• The right to not be discriminated against if a California consumer exercise their rights under the CCPA.

The provisions below of this California Notice provide further details about these rights and how you may exercise them.

Information We Collect

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California consumer, household, or device (collectively, “personal information”). 

Personal information does not include: 

• Publicly available information from government records.
• De-identified or aggregated California consumer information.
• Information excluded from the CCPA’s scope, including:
  • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; and
  • Personal information covered by certain other laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

We have collected the following categories of personal information from California consumers within the last twelve (12) months:

Sources of Personal Information

In addition to sources of personal information addressed elsewhere in this Privacy Policy, we obtain the categories of personal information listed above from the following categories of sources: 

• Directly From You. For example, from forms you complete or products and services you purchase or from communications with you such as when you contact the Company (whether in person, by mail, by phone, online, via electronic communication or by other means) including our customer support service. 
• Indirectly From You. For example, from observing your actions on our websites or from products or services that you have purchased from the Company, if you have enabled such functionality, such as telemetry services.
• From Others.
  • From third party service providers. For example, if you choose to make an electronic payment directly to the Company, or through a linked website or app, or through an affiliate of ours, the Company may receive personal information about you from third parties such as payment services providers, for the purposes of that payment.
  • From affiliates. We may collect personal information about you from our affiliates or others acting on their behalf.
• From Public Sources. For example, we may collect information from public records.

Uses of Personal Information

In addition to uses of personal information addressed elsewhere in this Privacy Policy, we may use or disclose the personal information we collect for one or more of the following business purposes: 

• To fulfill the reason that you provided the information. For example, if you share your name and contact information to request a price quote, request to be contacted by us or an affiliate, or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we may use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product or service orders or to process returns. 
• To perform services such as customer service, order fulfillment, payment processing, financing and advertising, marketing or analytic services. 
• To advance our commercial or economic interests, such as by helping you to buy, rent, lease, join, subscribe to, provide, or exchange products, information, or services, or enabling or effecting, directly or indirectly, a commercial transaction. 
• To verify or maintain quality or safety standards or improve or upgrade a product or service provided or controlled by or for us. 
• To provide, support, personalize and develop our websites, products and services such as to perform warranty related services or other post-sale activities such as product or service monitoring or repairs. 
• To create, maintain, customize and secure your account (if any) with us. 
• To process your requests, purchases, transactions and payments and prevent transactional fraud. 
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses. 
• To personalize your experience on our websites and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our websites, third-party sites and via mail, email or text message (with your consent, where required by law). 
• To help maintain the safety, security and integrity of our websites, products and services, databases and other assets and business. 
• For testing, research and analysis purposes, including to develop and improve our websites, products and services. 
• To respond to law enforcement requests and as required by applicable law, court order or governmental regulations. 
• As described to you when collecting your personal information or as otherwise set forth in the CCPA or applicable law. 
• To send you information relevant to your past purchases and interests, subject to compliance with applicable laws regarding direct marketing. 
• To otherwise use as reasonably necessary and proportionate to achieve our operational or notified purpose for collecting personal information and as compatible with the context in which we collected the information. 
• To perform services on behalf of a CCPA-covered business or its service provider, such as customer service, order fulfillment, payment processing, financing and advertising, marketing, or analytic services. 
• To review and audit our business interactions with you. 
• To detect or prevent security incidents or other illegal activity. 
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of a bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our websites’ users, including California consumers, is among the assets transferred. 

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated or incompatible purposes without providing you notice. 

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. 

• Disclosures of Personal Information for a Business Purpose.

In the preceding twelve (12) months, the Company has disclosed the following categories of personal information for a business purpose:

• Identifiers
• Personal information categories described in Cal. Civ. Code § 1798.80(e)
• Internet or other similar network activity
• Geolocation data
• Sensory data
• Professional or employment-related information

The categories of third parties to which we may disclose personal information collected by us include the following:

• Service providers
• Affiliates
• Recipients of data from cookies placed on our websites (such as Google Analytics)
• Sales of Personal Information.

The Company does not sell personal information to third parties. 

Exercising Your CCPA Rights and Choices

The sections below describe how you may exercise your rights under the CCPA.

• Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past twelve (12) months. Once we receive and confirm your verifiable consumer request (see “Exercising Access, Data Portability and Deletion Rights” below), we will disclose to you: 

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
• If we disclosed your personal information for a business purpose, a list disclosing the personal information categories that each category of recipient obtained.

As allowed by the CCPA, we do not provide these access and data portability rights (i) for business-to-business personal information or (ii) as to personal information collected from the Company’s California-based employees, job applicants or contractors when provided or collected in such employee, job applicant or contractor capacities. 

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see “Exercising Access, Data Portability and Deletion Rights” below), we will delete (and direct our service providers to delete) your personal information from our (and service provider) records, unless an exception applies. 

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to: 

• Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you. 
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities. 
• Debug products or services to identify and repair errors that impair existing intended functionality. 
• Exercise free speech, ensure the right of another California consumer to exercise their free speech rights, or exercise another right provided for by law. 
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.). 
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent. 
• Enable solely internal uses that are reasonably aligned with California consumer expectations based on your relationship with us, such as future field campaigns or product safety issues. 
• Comply with a legal obligation. 
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it. 

As allowed by the CCPA, we do not provide these deletion rights (i) for business-to-business personal information or (ii) as to personal information collected from the Company’s California-based employees, job applicants or contractors when provided or collected in such employee, job applicant or contractor capacities. 

Exercising Access, Data Portability and Deletion Rights

To exercise the access, data portability and deletion rights described above, you should submit a verifiable consumer request to us by one of the following methods:

• Emailing us at: info@topigsnorsvin.us
• By postal mail at: Topigs Norsvin USA, 12750 Nicollet Ave. S. Suite 300 Burnsville, MN 55337

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of a minor child for whom you are a parent or legal guardian. 

You may only make a verifiable consumer request for access or data portability twice within a twelve (12) month period. The verifiable consumer request must: 

• Provide sufficient information that allows us to reasonably verify that you are the person about whom we collected personal information or an authorized representative, which may include:
  • Your name
  • Your address
  • Additional information depending upon the type of request and the sensitivity of the information involved with such request
  • Describe your request with sufficient detail to enable us to properly understand, evaluate and respond to such request.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or your authority to make the request and confirm that the personal information involved with the request relates to you. 

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. 

Response Timing and Format of Verifiable Consumer Request

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. 

Any disclosures we provide will only cover the twelve (12) month period immediately preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance. 

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. 

Non-Discrimination 

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA or other applicable law, we will not as a result of you exercising any of your rights under the CCPA: 

• Deny you goods or services;
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
• Provide you a different level or quality of goods or services; or
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time. 

Other California Privacy-Related Disclosures 

Sharing Personal Information for Direct Marketing Purposes. 
Before sharing personal information of California consumers with third parties for direct marketing purposes we will obtain opt-in consent from the applicable California consumers or provide such California consumers with a cost-free method to opt out. 

California Do-Not-Track Disclosure. 
At this time, our websites are not set up to honor web browser do-not-track settings.  Do-not-track is a privacy preference that users can set in their web browsers. When a user activates the do-not-track settings in browsers that offer this setting, the browser sends a message to websites or applications requesting them not to track the user. For more information about do-not-track matters, please visit www.allaboutdnt.org. 

Information on Marketing Disclosures. 
California Civil Code Section 1798.83 permits our users who are California residents to request and obtain from us once a year, free of charge, information about the personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us at Topigs Norsvin USA, 12750 Nicollet Ave. S. Suite 300 Burnsville, MN 55337. 

Content Removal Requests for Users Under 18 Years Old. 
If you are a user of our websites under 18 years of age and reside in California, you may request and obtain removal of, content or information that you have posted on our websites.    You may send us any such requests by one of the following methods: (i) by email (writing “Privacy Policy – Removal Request” in the subject line) at [info@topigsnorsvin.us.]; or (ii) by writing to us at Topigs Norsvin USA, 12750 Nicollet Ave. S. Suite 300 Burnsville, MN 55337.  We will review the request and respond promptly.  You should be aware that a request to remove content or information posted by you on our websites does not ensure or require complete or comprehensive removal of such content or information from our databases. 

Complaints 
If you have any complaint about use of our websites, you may contact us by email at  [info@topigsnorsvin.us.], or by postal mail at Topigs Norsvin USA, 12750 Nicollet Ave. S. Suite 300 Burnsville, MN 55337. In accordance with California Civil Code Section 1789.3, California residents may also file complaints with the Complaint Assistance Unit, Division of Consumer Services, California Department of Consumer Affairs by postal mail at 1625 North Market Road, Suite N112, Sacramento, CA 95834 or by telephone at 800-952-5210. 

Changes to Our California Notice 
We reserve the right to amend this California Notice at our discretion and at any time. When we make changes to this California Notice, we will post the updated California Notice on our websites and update the California Notice’s effective date. Your continued use of our websites following the posting of changes constitutes your acceptance of such changes. 

Assignment: 
We may assign our rights and duties under this Privacy Policy, including, without limitation, our rights in information collected through the websites, to any third party at any time without notice to you, and such assignment rights shall include the ability to make an assignment in connection in connection with any sale, merger, acquisition, divestiture or liquidation of all or part of our business or assets related to the websites, all or substantially all of our business or assets, or as part of any reorganization or restructuring of our business. 

Amendments: 
Topigs Norsvin may at any time amend the terms of this Privacy Policy, without notice at any time and for any reason. Amendments will go into effect as soon as they have been published on our websites. Whenever we change this Privacy Policy, we will post the updated Privacy Policy on the websites, and we will note at the top of this Privacy Policy the date of the last update, which should alert you to changes in this Privacy Policy since your prior visit to the Topigs Norsvin websites 

This Privacy Policy has been translated into English. If the English version of the Privacy Policy shows discrepancies with the Dutch version, the Dutch version is decisive.