Privacy Policy


In the following, Top Tellers Ltd will be called “Top Tellers” for short.

Top Tellers takes data protection very seriously and treats personal data of users confidentially and in accordance with legal regulations. The personal data are handled carefully and collected, processed and used in accordance with the legal data protection regulations. The aim of collecting personal data is the ongoing optimization of our websites, the communication options offered, the online offers and the design of our products and services.

Version: v1.1.0 from May 11, 2020


This data protection declaration explains the type, scope and purpose of the collection and use of personal data by Top Tellers when you visit our website and when you use the communication options and online offers. By using this website and the information and services provided by Top Tellers, you agree to this privacy policy.

The main scope of this data protection declaration therefore relates to the use of general Top Tellers websites and direct or indirect communication with Top Tellers. Individual Top Tellers portfolio elements require special regulations and contractual agreements with regard to data protection due to their technical and technical characteristics. As a rule, these are suites and technical services offered by Top Tellers, the use of which requires a separate contract with separate data protection agreements. Likewise, specific regulations with regard to data protection can be made within the scope of individual implementations and customer-specific projects.

This data protection declaration does not apply to websites, online services and / or other products and online offers of third parties. The websites operated by Top Tellers and other online offers could contain links to external websites of third parties, which we neither influence nor control. Despite careful control of the content, we assume no liability for the content of external links or for compliance with the legal data protection regulations on the linked websites.

Top Tellers reserves the right to amend this data protection declaration at any time. Basically, users must assume that the websites, products and services of Top Tellers are subject to ongoing technical and professional developments, which also bring about an adaptation of this data protection declaration. For this reason, we recommend that you review the relevant data protection declarations in the currently valid versions at regular intervals.

Definitions of the terms used (eg “personal data” or “processing”) can be found in Art. 4 GDPR. You can find the General Data Protection Regulation on the web at various publicly available information sources and stately authorities.

Dealing With Communication Data

If users connect with Top Tellers as website operator or as provider of online offers and services through the offered contact options, the information provided is stored so that it can be used for further processing and answering the actual request. Without your consent, this data will not be passed on to third parties.

With regard to the archiving of business documents, we comply with the legal retention requirements.

The archiving obligation includes the following documents: Business documents such as books, records and accounting documents, inventories, annual financial statements, management reports, the opening balance as well as the work instructions and other organizational documents necessary for their understanding , the commercial or business letters received, reproductions of the commercial or business letters sent, other documents, as far as they are for taxation (Sales tax) are important – even those that only refer to invoices.

From the legislator’s point of view, the documents listed have an obligation to archive not only in paper form, but also in the form of emails and other electronic communication options. This also applies to all letters that prepare, conduct, close or cancel a transaction. Examples are invoices, orders, order confirmations, payment documents and contracts.

The communication channels are categorized by Top Tellers as far as possible with reasonable effort and technical aids and archived at the level of fiscal years. The business communication information that can be automatically identified is saved at least until the expiry of the tax retention period (7 years) and at most until the end of product liability (10 years). In general, it should be noted that the deletion of archived data is based on entire fiscal years, which can slightly shift the exact retention period. Due to backup and archiving processes, the stored data can remain in our systems for a further 12 months.

Dealing With Comments And Posts

If a user leaves contributions or comments on the websites operated by Top Tellers and other online content, the user’s IP address is saved. This is due to the legitimate interest of Top Tellers in the sense of the GDPR and serves the security of us as the website operator. Should a contribution or comment by users violate applicable law, we can be prosecuted for why we have an interest in the identity of the comment or contribution author.


As part of the use of Top Tellers websites and other online offers, so-called cookies are set on the client side. The use of cookies corresponds to the state of the art. The purpose of cookies is to design user-friendly, effective and secure applications.

Cookies are small files that are stored locally on users’ end devices as part of the use of websites and online offers.

Cookies can contain various data, such as IP addresses, browser type, browser version, the page visited, time and date of the visit, the time spent on these pages, unique assignment features of your device and other diagnostic data.

We differentiate between the following types of cookies:

General cookies: Cookies for basic technical implementation of services and functionalities such as identity verification, service continuity and location
security. Support cookies: Cookies that support interactive services such as chat support and customer feedback tools.

Advertising cookies: Anonymous information for recommendations of relevant products and services

Analytics cookies : Cookies for the collection of anonymous data about the use of websites and the functionality to optimize online offers, products and services.
If the use of cookies is not desired, the user can make the appropriate browser settings. Users can be informed about the setting of cookies, the setting of cookies can be deactivated entirely and individual cookies can be allowed as required. The deactivation of cookies can restrict the functionality of websites and online offers.

Web Tracking

The websites and other portfolio elements of Top Tellers use
the service “Google Analytics”, which is offered by Google Inc. (1600 Amphitheater Parkway Mountain View, CA
94043, USA) due to the legitimate interests of optimizing and analyzing online offers , The service (Google Analytics) uses cookies that are created on users’ end devices.

The information collected by the cookies is
usually sent to a Google server in the USA and stored there.

Google LLC complies with European data protection law and is certified under the Privacy Shield Agreement:
The websites operated by Top Tellers and other online offers use technologies for IP anonymization by the transfer of information to Google Analytics. The IP address of users within the member states of the EU and the European Economic Area and in the other contracting states of the agreement will be shortened. Only in individual cases is the IP address initially sent to a Google server in the United States and abbreviated there.

This shortening eliminates the personal reference of IP addresses to specific users. The user’s IP address transmitted by the browser is not combined with other data stored by Google.

As part of the agreement on the order data agreement, which Top Tellers as a website operator has concluded with Google Inc., the website uses the information collected to evaluate website usage and website activity and provides services related to internet usage.

The data collected by Google on our behalf is used to evaluate the use of our online offer by individual users, e.g. B. to create reports on the activity on the website to improve our online offer.

Using browser settings, users have the option of preventing cookies from being stored on their end devices. It should be noted that the general deactivation of cookies can have a negative impact on the user-friendliness and functionality of websites.

Furthermore, by using browser plug-ins, users can prevent the information collected by cookies (including the IP address) from being sent to Google Inc. and used by Google Inc. The link to the plugins is:

Data Storage Web Shops

Certain Top Tellers products and services can be obtained from end customers and partners via corresponding web shops operated by Top Tellers.

We would like to point out that for the purpose of a simpler purchasing process and for subsequent contract processing by the web shop operator in the form of client-side cookies, certain purchasing process and session-relevant information such as the IP address of the connection holder, client ID, user ID, browser ID, node ID, partner affiliate ID, shopping cart product ID can be saved temporarily.

Depending on the webshop and area of application, personal information such as the name and address of the buyer can also be temporarily stored.

Cookies are pieces of information stored locally on the end device of the user, which can be created and read out when using online offers and websites. The primary goal of the cookies we use is to increase the user-friendliness of applications. However, the temporary storage of information in temporary cookies is also imperative for technical reasons with regard to the mapping of sessions and processes.

Further information on the handling of cookies can be found below in this data protection declaration.

In addition, the following data is also stored with us for the purpose of contract execution:

  • Customer data such as name, date of birth, billing address, delivery address etc.
  • Payment information such as credit cards, bank account number etc.
  • Documents such as business records, certificates etc.
  • Personal preferences and attitudes
  • Marketing-relevant information such as interests of customers and
  • Users, segmentation etc.
  • Communication data such as evaluations, messages etc.

The information provided by users is necessary to fulfill the contract or to carry out pre-contractual measures. Without this data, contracts and services cannot be concluded. In principle, the information and documents you provide will not be passed on to third parties without your consent.

Exceptions to this are the transmission of credit card data and other payment information to the processing banking institutions and payment service providers for the purpose of payment, the transmission of relevant information to commissioned transport companies and other logistics partners for the delivery of goods, and the forwarding of relevant data to commissioned external tax and law firms Fulfillment of tax and legal obligations. In the case of external partners and subcontractors used by Top Tellers, the information relevant for the fulfillment of the contract is made available to external partners. The cooperation of Top Tellers with external partners is contractually regulated, which is why they are also obliged to comply with this data protection declaration.

Data processing takes place on the basis of the legal provisions of Section 96 (3) TKG and Art 6 (1) lit a (consent) and / or lit b (necessary to fulfill the contract) of the GDPR.

After the purchase process is canceled, the data stored by us will be deleted. In the event of a contract being concluded, all data from the contractual relationship will be saved at least until the end of the tax retention period (7 years) and up to the expiry of product liability (10 years). In the case of sales transactions, data such as name, address, purchased goods and purchase date are generally saved until the end of product liability (10 years). Due to backup and archiving processes, the stored data can remain in our systems for a further 12 months in both cases.

Data Storage Top Tellers Services

Top Tellers develops and operates a range of local and central services. Due to their technical and technical characteristics, these Top Tellers portfolio elements require separate regulations and contractual agreements with regard to data protection. As a rule, these are suites and technical services offered by Top Tellers, the use of which requires a separate contract with separate data protection agreements.

In principle, the products and services in question can also be marketed as customer-specific “white label” solutions, with Top Tellers essentially providing the technological platform. For technical reasons, the products in question are nevertheless integrated with the basic service, as otherwise no maintenance and operating measures would be possible. This integration takes place via activation of the product.

The act of activating a product developed on the basis of Top Tellers suites is an exception to separate regulations and contractual agreements. Product activation is a technical process that is essential for the operation of the product. The following information is recorded:

Time at the time of activation
Domain or another unique identification feature to enable activation
Time and transaction metadata for maintenance and operational measures such as product updates, process and session-relevant information such as client ID, user ID, browser ID, node ID etc.

Technical Access Data

Visiting our website and using the offered communication options and online offers.
On the part of Top Tellers, due to the legitimate interest (details on legitimate interests can be found in the GDPR), data about access to our websites and other online offers is collected and stored in the form of log files and logs. Access is collected for security reasons, e.g. B. Abuse cases.

The following information is recorded:

  • Visited website & services
  • Time at the time of access
  • Amount of transmitted data sent
  • transaction metadata
  • Interaction metadata from users
  • Source / reference for forwarded requests and navigation
  • Process and session relevant information such as client ID, user ID,
  • Browser ID, node ID etc.
  • Browser used
  • Operating system used
  • IP address used.

The log files and logs are kept for a period of 6 months and then deleted. Due to backup and archiving processes, the log files and logs can also remain in our systems for a further 12 months, so that there is a maximum retention period of 18 months.

Basically, log files and protocols are not passed on to third parties. An exception to this is the legally required release of log files and protocols on request from state investigative authorities. If data have to be saved for reasons of evidence, they are excluded from deletion until the incident has been finally clarified.

Due to technical circumstances, separate treatment of certain user data cannot be guaranteed, since log files, protocols and backups generally encompass entire systems.

Rights Of Users

The users of the Top Tellers websites and other online offers have the right to request free information about the data stored by Top Tellers of the applicant.

Users also have the right to information, correction, deletion, restriction, data portability, revocation and objection.

If users assume that the processing of their data violates data protection law or that the data protection claims have otherwise been violated, the user can submit a complaint to us via or to the responsible data protection authority.

Deletion Of Data

If your request does not conflict with a legal obligation to store data (e.g. data retention), you have the right to have your data deleted.

Data stored by us will be deleted if they are no longer required for their intended purpose and there are no statutory retention periods.

If deletion cannot be carried out because the data is required for permitted legal purposes , data processing is restricted. In this case, the data will be blocked and not processed for other purposes.

Right To Object

Users of this website can exercise their right to object and object to the processing of their personal data at any time.

If you would like a correction, blocking, deletion or information about the personal data stored about you, or if you have any questions regarding the collection, processing or use of your personal data or if you want to revoke your consent, please contact the following email address:

Contact Information

Link to the contact form:
Gender advice In order to improve readability, we ask for your
understanding that gender-specific wording is largely avoided.

Of course, both genders are addressed equally!