Privacy Policy

Last updated: July 11, 2026

This Privacy Policy explains how TopHotelsList.com collects, uses, stores, and protects personal data when you visit or interact with the website.

TopHotelsList.com is an independent travel-information and hotel-recommendation website. We publish editorial hotel guides and may include links to third-party hotel-booking platforms and other travel services.

1. Who We Are

TopHotelsList.com is operated by:

Instant Media Access
c/o Billo ILY 237-S
Birger Jarlsgatan 37
SE-114 45 Stockholm
Sweden

Email: info@tophotelslist.com

Instant Media Access is the data controller for personal data processed directly through TopHotelsList.com. This means that we determine why and how such personal data is processed.

References in this Privacy Policy to “TopHotelsList.com,” “we,” “us,” or “our” refer to Instant Media Access.

2. Scope of This Privacy Policy

This Privacy Policy applies to personal data processed through TopHotelsList.com.

It does not apply to hotels, booking platforms, affiliate partners, advertisers, social-media platforms, embedded-content providers, or other third-party websites and services. Those third parties process personal data under their own privacy policies.

TopHotelsList.com does not operate a hotel-booking service and does not directly process hotel reservations, payments, cancellations, or refunds.

3. Personal Data We Collect

The personal data we collect depends on how you use the website.

3.1 Information collected automatically

When you visit TopHotelsList.com, certain technical information may be collected automatically by our servers, hosting providers, security services, content-delivery systems, analytics providers, or similar technologies.

This information may include:

  • your Internet Protocol address;
  • browser type and version;
  • device type;
  • operating system;
  • approximate geographical location based on your IP address;
  • language and time-zone settings;
  • referring website or source;
  • pages viewed;
  • links clicked;
  • date and time of access;
  • time spent on pages;
  • technical error information;
  • security and fraud-prevention information;
  • cookie identifiers and similar online identifiers;
  • your cookie-consent preferences.

Some of this information may constitute personal data because it can be associated with a particular device or individual.

3.2 Information you provide directly

If you contact us by email, we may collect:

  • your name;
  • your email address;
  • the contents of your message;
  • any information or files you choose to provide;
  • records of our correspondence with you.

Please do not send sensitive personal data, payment-card information, passport details, medical information, or other confidential information unless it is genuinely necessary.

3.3 No memberships or user accounts

TopHotelsList.com does not offer memberships, user profiles, or the ability to create or sign in to an account.

We therefore do not intentionally collect usernames, passwords, profile information, or account-registration data.

3.4 No direct booking or payment data

TopHotelsList.com does not directly process hotel bookings or payments.

We do not ordinarily receive or store:

  • full payment-card details;
  • bank-account information;
  • passport numbers;
  • travel-document details;
  • hotel account passwords;
  • complete reservation records;
  • information submitted directly to a hotel or booking provider.

If you make a reservation after clicking a link on TopHotelsList.com, the booking provider or hotel is responsible for processing the information you submit to it.

4. Cookies and Similar Technologies

TopHotelsList.com may use cookies, pixels, local storage, scripts, tags, and similar technologies.

These technologies may be used for purposes such as:

  • operating and securing the website;
  • remembering privacy and cookie choices;
  • preventing fraud and malicious activity;
  • understanding how visitors use the website;
  • measuring website performance;
  • identifying technical problems;
  • measuring clicks on affiliate links;
  • attributing bookings or conversions to an affiliate referral.

Where required by law, non-essential cookies and similar technologies will not be activated until you have provided consent.

You can accept, reject, or manage non-essential cookies through the cookie-consent interface available on the website. You can also withdraw or change your consent at any time through the Cookie Settings link.

Additional information about the individual cookies and technologies used on the website is available in our Cookie Policy.

5. How and Why We Use Personal Data

We may process personal data for the following purposes.

Operating and delivering the website

We process technical data to load pages, display content, maintain website functionality, and provide requested features.

The legal basis is our legitimate interest in operating and providing a functioning website.

Website security and fraud prevention

We may process IP addresses, access logs, device information, and security events to:

  • protect the website;
  • prevent unauthorized access;
  • detect malicious traffic;
  • investigate attacks or abuse;
  • maintain backups;
  • diagnose technical problems.

The legal basis is our legitimate interest in protecting the website, our systems, and our visitors.

Responding to communications

If you contact us, we process your contact information and the contents of your message to respond, investigate your request, and maintain appropriate records.

The legal basis is generally our legitimate interest in communicating with visitors and handling enquiries. Where your request concerns a potential agreement, the processing may also be necessary to take steps at your request before entering into an agreement.

Analytics and website improvement

Where enabled and permitted by your consent, we may use analytics technologies to understand:

  • which pages are visited;
  • how visitors reach the website;
  • how visitors navigate between pages;
  • which content is most useful;
  • how the website performs across devices;
  • where technical improvements are needed.

Where legally required, the legal basis for non-essential analytics is your consent.

Aggregated information that can no longer reasonably identify an individual may be used for statistical, editorial, and business-planning purposes.

Affiliate-link measurement

TopHotelsList.com contains affiliate links. When you click an affiliate link, information about that referral may be processed so that the relevant affiliate network or booking partner can determine whether a booking or other qualifying action resulted from the referral.

Depending on the technology used and your location, affiliate tracking may be based on your consent.

We also have a legitimate commercial interest in funding the website through disclosed affiliate relationships. However, this does not override any legal requirement to obtain consent before storing or accessing non-essential information on your device.

Compliance with legal obligations

We may process personal data when necessary to:

  • comply with applicable laws;
  • respond to lawful requests from authorities;
  • comply with accounting or recordkeeping requirements;
  • establish, exercise, or defend legal claims;
  • investigate suspected unlawful conduct.

The legal basis is compliance with a legal obligation or our legitimate interest in protecting our legal rights.

6. Affiliate Links and Booking Partners

TopHotelsList.com may earn a commission when a visitor clicks an affiliate link or completes a booking or other qualifying action through a third-party provider.

Affiliate partners may include hotel-booking platforms, travel services, affiliate networks, and tracking providers, including Klook and other partners that may be added or replaced over time.

When you click an affiliate link:

  1. you leave TopHotelsList.com or are redirected through an affiliate-tracking domain;
  2. the destination provider may collect your IP address, device information, referral information, cookie identifiers, and browsing activity;
  3. the destination provider may place cookies or similar technologies on your device;
  4. the provider processes any booking, account, or payment information you submit;
  5. we may receive a report showing that a click, booking, or commission occurred.

Affiliate reports are generally aggregated or pseudonymous. They may include information such as:

  • the date of a click or transaction;
  • the destination or product category;
  • an affiliate transaction identifier;
  • the booking or transaction value;
  • the commission payable;
  • the general country or market associated with the transaction.

We do not ordinarily receive your complete payment-card details, passport information, booking-platform password, or full account credentials.

Third-party booking providers are independently responsible for their own data processing. You should read the destination provider’s privacy policy before submitting personal data or completing a reservation.

7. How We Share Personal Data

We may share personal data with carefully selected service providers where this is necessary to operate, secure, maintain, or analyse the website.

These recipients may include:

Hosting and technical providers

Providers that host the website, store backups, deliver content, provide domain-name services, manage email, or support website infrastructure.

Security and performance providers

Providers that protect the website against malicious traffic, improve loading performance, detect errors, or provide content-delivery and firewall services.

Analytics providers

Analytics providers may process website-usage information where analytics have been enabled and, where required, you have given consent.

Cookie-consent providers

A consent-management provider may process your consent choices and related technical information so that we can remember and demonstrate your privacy preferences.

Affiliate networks and booking partners

Affiliate partners may process referral information when you click an affiliate link. They may also provide us with reports concerning clicks, conversions, and commissions.

Professional advisers

We may share information with accountants, lawyers, insurers, technical consultants, or other professional advisers where reasonably necessary.

Public authorities

We may disclose personal data where required by law, court order, regulatory request, or another legally binding obligation.

Business transfers

If all or part of the website or its operations are sold, transferred, reorganized, or merged, relevant information may be transferred as part of that transaction, subject to applicable privacy law.

We do not rent personal data to third parties.

We do not sell personal data in the ordinary sense of exchanging personal data directly for money. However, certain U.S. privacy laws define “sale,” “sharing,” or “targeted advertising” broadly. Some uses of advertising, analytics, or affiliate technologies could fall within those broader definitions. Where applicable, you may use our Cookie Settings or contact us to exercise an opt-out right.

8. International Data Transfers

Instant Media Access is based in Sweden, within the European Economic Area.

Some service providers, affiliate partners, or booking platforms may be located outside Sweden or the EEA, including in the United States or Asia. Personal data may therefore be processed in countries with privacy laws that differ from those in your country.

Where we are responsible for transferring personal data outside the EEA, we use an appropriate legal transfer mechanism where required. Depending on the recipient and destination, this may include:

  • a European Commission adequacy decision;
  • approved Standard Contractual Clauses;
  • supplementary technical and organizational safeguards;
  • another transfer mechanism permitted by applicable law.

Third-party booking providers may separately transfer the information you submit to them. Their transfers are governed by their own privacy policies.

9. Data Retention

We retain personal data only for as long as reasonably necessary for the purpose for which it was collected.

The relevant retention period depends on:

  • the nature and sensitivity of the information;
  • why the information was collected;
  • security and fraud-prevention requirements;
  • applicable legal and accounting obligations;
  • whether the information is needed to resolve a dispute;
  • whether the information is needed to establish or defend a legal claim.

Routine server and security logs are retained for the shortest period reasonably necessary to operate and protect the website, unless a longer period is required to investigate a security incident.

Email correspondence may be retained until the enquiry has been resolved and for a reasonable period afterward in case follow-up is required.

Cookie-consent records may be retained for as long as necessary to remember your choices and demonstrate compliance with applicable consent requirements.

Information held by analytics providers, affiliate networks, or booking partners is retained according to their own settings and privacy policies.

When personal data is no longer required, we will delete it, anonymize it, or securely isolate it unless continued retention is required by law.

10. Data Security

We use reasonable technical and organizational measures designed to protect personal data against:

  • unauthorized access;
  • accidental loss;
  • misuse;
  • alteration;
  • disclosure;
  • destruction.

These measures may include access restrictions, encrypted connections, software updates, backups, security monitoring, firewall services, and limitations on who can access personal data.

No method of transmitting or storing information online is completely secure. We therefore cannot guarantee absolute security.

11. Your Rights Under European Data-Protection Law

If the GDPR applies to the processing of your personal data, you may have the following rights.

Right of access

You may ask whether we process your personal data and request a copy of the relevant information.

Right to rectification

You may ask us to correct inaccurate personal data or complete incomplete information.

Right to erasure

You may ask us to delete personal data in circumstances where we no longer have a valid reason to retain it.

The right to deletion is not absolute. We may retain information where required by law or where it is necessary to establish, exercise, or defend legal claims.

Right to restriction

You may ask us to restrict the processing of your personal data in certain circumstances.

Right to data portability

Where processing is based on consent or a contract and carried out by automated means, you may have the right to receive information you provided in a structured, commonly used, and machine-readable format.

Right to object

You may object to processing based on our legitimate interests.

If personal data were used for direct marketing, you would have the right to object to that use at any time. TopHotelsList.com does not currently operate an email marketing membership or subscriber service.

Right to withdraw consent

Where processing is based on consent, you may withdraw your consent at any time.

Withdrawing consent does not affect the lawfulness of processing that occurred before the withdrawal.

Cookie consent can be changed through the Cookie Settings interface.

Right to lodge a complaint

You have the right to lodge a complaint with a data-protection authority.

Because the website operator is established in Sweden, the relevant supervisory authority is:

Swedish Authority for Privacy Protection
Integritetsskyddsmyndigheten — IMY

You may also be entitled to contact the supervisory authority in the EU or EEA country where you live or work.

12. How to Exercise Your Privacy Rights

To exercise a privacy right or ask a question about our handling of personal data, contact:

Email: info@tophotelslist.com

Postal address:

Instant Media Access
c/o Billo ILY 237-S
Birger Jarlsgatan 37
SE-114 45 Stockholm
Sweden

Please describe:

  • the right you wish to exercise;
  • the information or processing concerned;
  • any details that may help us locate the relevant records.

We may request reasonable information to verify your identity before acting on a request. This is intended to prevent personal data from being disclosed, altered, or deleted at the request of an unauthorized person.

We will respond within the period required by applicable law. Under the GDPR, this is normally within one month, although the period may be extended for particularly complex or numerous requests.

13. Information for United States Residents

Residents of certain U.S. states may have privacy rights under state law, subject to eligibility requirements and thresholds that may not apply to every website or business.

Depending on the applicable law, these rights may include the right to:

  • know what categories of personal information are collected;
  • request access to personal information;
  • request correction of inaccurate information;
  • request deletion;
  • obtain a portable copy of certain information;
  • opt out of certain sales or sharing;
  • opt out of targeted advertising;
  • limit certain uses of sensitive personal information;
  • appeal the denial of a privacy request;
  • receive equal service without unlawful discrimination for exercising a privacy right.

TopHotelsList.com does not intentionally collect sensitive personal information for the purpose of inferring characteristics about visitors.

We do not sell personal information in the ordinary sense of exchanging it directly for money.

Where an applicable U.S. privacy law treats particular analytics, advertising, or affiliate activities as a “sale,” “sharing,” or use for “targeted advertising,” you may submit an opt-out request through Cookie Settings or by emailing info@tophotelslist.com.

We will not unlawfully discriminate against you for exercising an applicable privacy right.

Browser “Do Not Track” signals

Some browsers offer a “Do Not Track” setting. Because there is not currently a universally accepted technical standard for interpreting these signals, TopHotelsList.com does not currently change its practices solely in response to a standard browser Do Not Track signal.

You can control non-essential cookies using our Cookie Settings interface and through your browser settings.

14. Visitors From Other Countries

Visitors in countries outside the EEA and the United States may have additional rights under their local privacy laws.

Where such a law applies to our processing, we will respond to valid privacy requests as required by that law.

You may contact info@tophotelslist.com to request access, correction, deletion, withdrawal of consent, or information about how your data is processed.

15. Children’s Privacy

TopHotelsList.com is a general travel-information website and is not directed to children.

We do not knowingly collect personal data directly from children under the age of 13. The website does not offer user accounts or memberships.

If you believe that a child has provided personal data to us, please contact info@tophotelslist.com. We will investigate the matter and delete the information where required.

16. Automated Decision-Making

TopHotelsList.com does not use personal data to make automated decisions that produce legal effects or similarly significant effects concerning individual visitors.

Hotel rankings and editorial recommendations are not personalized using legally significant automated profiling of individual visitors.

17. Third-Party Links and Embedded Content

Our articles may contain links to:

  • hotels;
  • booking platforms;
  • affiliate partners;
  • tourism websites;
  • maps;
  • videos;
  • social-media platforms;
  • other third-party resources.

Some pages may also contain embedded content. Embedded content can behave as though you visited the third-party provider directly. The provider may collect your IP address, device information, cookie identifiers, viewing activity, or other information.

We do not control third-party privacy practices. You should review the privacy policy and cookie information of the relevant provider before interacting with its content or submitting personal data.

18. Changes to This Privacy Policy

We may update this Privacy Policy when:

  • our website or business practices change;
  • we add or remove service providers;
  • we introduce new analytics, advertising, or affiliate technologies;
  • applicable laws or regulatory guidance change;
  • clarification is otherwise necessary.

The latest version will be published on this page with a revised “Last updated” date.

Material changes may also be communicated through a notice on the website or through the cookie-consent interface where appropriate.

19. Contact Us

Questions, concerns, or privacy requests may be sent to:

Instant Media Access
c/o Billo ILY 237-S
Birger Jarlsgatan 37
SE-114 45 Stockholm
Sweden

Email: info@tophotelslist.com

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