Privacy Notice


We at Gulltopp care about your privacy. Therefore, we always collect and process your personal data responsibly and with your privacy in mind. This Privacy Notice describes how Gulltopp collects, uses and in other ways processes your personal data when you use any of our products services (the “Services”). Examples of use of our Services are when you visit or place orders and purchase with us, as well as when you contact us. This Privacy Notice also describes your rights in relation to our use of your personal data, and how to exercise those rights.

This Privacy Notice applies to all personal data that Gulltopp processes. It is therefore important that you read and understand this Privacy Notice.

“We”, “our”, or “us” means Gulltopp registered with the Dutch companies register under the registration number 71841164 and with our postal address located at Concordiastraat 23, Sassenheim, the Netherlands. For the purposes of EU data protection law, such as EU Regulation 2016/679 (“GDPR”), we are a data controller in respect of the personal data we receive from you, or otherwise collect about you, and we are responsible for ensuring that we use your personal data in compliance with applicable data protection laws.


1.1. Device information

This Privacy Notice describes how your personal information is processed when you visit, place orders and purchase at (the “Site”). When you visit the Site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about our individual web pages and/or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as “Device Information”.

We collect Device Information using the following technologies:

Cookies are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit

Log files
Log files track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.

Web beacons, tags, and pixels
These are electronic files used to record information about how you browse the Site.

1.2. Order Information

In addition to Device Information, when you make a purchase or attempt to make a purchase through the Site, we collect “Order Information”. “Order Information” includes the following personal data categories concerning you.

Contact- and identification information
This category of personal data refers to name, billing and shipping address, email address, mobile phone number.
Payment information
This category of personal data refers to credit and debit card data (card number, validity date, and CVV code).

Personal data referred to in this Privacy Policy includes both Device Information and Order Information.


2.1. Device Information
We use the Device Information that we collect for the following purposes:

  • Improve and optimize the Site (for example, by generating analytics about how our customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns). We rely on our legitimate interest when processing personal data for this purpose.
  • Risk assessments and fraud prevention through order screening. We rely on our legitimate interest when processing personal data for this purpose.

2.2. Order Information
We use the Order Information that we collect for the following purposes:

  • Carrying out placed orders and purchases through the Site. This includes processing your payment information, arranging for shipping, and providing you with invoices and/or order confirmations, as well as communicating with you in relation to your orders. We rely on the fulfillment of our contractual obligations with you when processing personal data for this purpose.
  • Risk assessments and fraud prevention through order screening. We rely on our legitimate interest when processing personal data for this purpose.
  • Comply with applicable laws, such as bookkeeping regulations. We rely on the basis of legal obligation when processing personal data for this purpose.

When in line with the preferences you have shared with us, we may provide you with information or advertising relating to our products or services. We may use both Device and Order information for this purpose. We rely on our legitimate interest when processing personal data for this purpose after you have placed an order. You may at any time object to this processing and revoke your consent (see Section 3.).


In cases where Gulltopp processes your personal data based on your consent or explicit consent (for example in case you provide us with special categories of personal data), you can at any time revoke this consent by contacting us. Revoking consent will not lead to any detriment for you, as we do not require this type of information to provide our Services.


“Profiling” means automated processing of personal data to evaluate certain personal aspects relating to you, for example in order to analyse or predict aspects of your financial situation or your preferences, such as purchase interests. We use profiling based on the personal data we have about you in order to take individual or automated decisions about you, for the following purposes:

Decisions with legal or similarly significant effect

Automated decision making with legal effects, or automated decisions with similarly significant effect, means that some decisions in our Services are solely based on automatic means, without any interaction from any of our employees, and care carried out with significant impact on you as a consumer. By making such decisions in an automated fashion, Gulltopp increases objectivity and transparency in the decisions when offering those Services.

We use this type of automated decision making when we decide whether you pose a fraud risk, if our processing reveals that you display behaviour consistent with fraudulent conduct, that your behaviour is inconsistent with your previous use of our Services, or that you appear to have deliberately hidden your true identity.

Decisions without legal or similarly significant effect

[Company] makes the decisions without legal or similarly significant effects for you when predicting what marketing content would be of interest to you. We use your personal information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at You can always object to this and deregister from the marketing and this profiling, by contacting us.

Please note that we do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser.


We may also share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.

  • Logistics and transportation companies – e.g. to deliver parcels
  • Suppliers and subcontractors – e.g. factories
  • Companies providing checkout solutions and payment processing services


We always strive to process your personal data within the EU/EEA. In certain situations, your personal data may however be transferred to, and processed in, a destination outside of the EU/EEA. In this respect we ensure that an adequate level of protection is maintained, and that suitable safeguards are adopted in accordance with applicable data protection legislation requirements, such as the GDPR, when we transfer your data outside the EU/EEA. These safeguards consist of ensuring that the third country is subject to an adequacy decision by the European Commission (Canada), or ensuring that the recipient is registered with the US Privacy Shield (the United States). In connection to our Services, the only personal data that is being transferred outside of EU/EEA refers to Google LLC having servers located in these respective states.


When you place an order through the Site, we will maintain your Order Information for our records unless and until you ask us to delete this information.


  • Right to be informed – You have the right to be informed about how we process your information. We do this through this Privacy Notice, other information on our website, and by answering questions sent to us.

  • Right to access your data – You may request a copy of your personal data if you would like to know what information we process about you. This copy of your personal data can also be transmitted in a machine readable format (i.e. “data portability”).

  • Right to rectification – You have the right to correct inaccurate or incomplete information about yourself.

  • Right to restrict processing of your data or object to our processing – If you believe your information is incorrect or you believe we use your data unlawfully, you have the right to ask us to stop the processing . You may also object to our processing where you believe there are circumstances that would make such processing unlawful. Furthermore, you can always object to us using your data for direct marketing.

  • Right to challenge an automated decision – You have the right to challenge an automated decision made by us. See Section 4 for more information on how we use automated decisions.

  • Right to withdraw consent – As set out in Section 3, where we process your data based on consent or explicit consent, you may withdraw this consent at any time.  

  • Right to erasure – You have the right to request deletion of your personal data, for example when it is no longer necessary for us to process the data for the purpose it was collected, or when you have withdrawn your consent. As described in more detail in Sections 3 and 7 above, Gulltopp however needs to adhere to certain legal obligations preventing us from immediately deleting some of your personal data. 

  • Right to lodge a complaint – You have the right to lodge a complaint with your national supervisory Data Protection Authority (“DPA”). Complaints to the Dutch DPA can be made using this link:


We at Gulltopp constantly work to improve our offerings, in order for you to get you the best user experience possible. This includes both changes in existing Services and new Services over time. It’s therefore important that you read this Privacy Notice each time you use any of our Services, since the processing of your personal data can differ since you last used one of our Services.


Gulltopp is registered in the Dutch companies register under the registration number 71841164 with our postal address located at Concordiastraat 23, Sassenheim, the Netherlands. Should you have any enquiries concerning data protection matters or would like to exercise your rights as described above, you can reach us at

Gulltopp is subject to Dutch data protection legislation. Visit for further information on Gulltopp.