Privacy Policy

This privacy policy will explain how our organization uses the
personal data we collect from you when you use our website.

Last updated 6 August 2020

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us.

We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to
us when expressing an interest in obtaining information about us
or our products and services, when participating in activities
on the Services or otherwise contacting us.

The personal information that we collect depends on the context
of your interactions with us and the Services, the choices you
make and the products and features you use. The personal
information we collect can include the following:

Publicly Available Personal Information. We collect the first name,
maiden name, last name, and nickname; phone numbers; email
addresses; business email; business phone number; and other
similar data.

Payment Data. We collect data necessary to process your payment
if you make purchases. All personal information that you
provide to us must be true, complete and accurate, and you must
notify us of any changes to such personal information.

Information automatically collected

Some information — such as IP address and/or browser and device
characteristics — is collected automatically when you visit our
Services.

We automatically collect certain information when you visit, use
or navigate the Services. This information does not reveal your
specific identity (like your name or contact information) but
may include device and usage information, such as your IP
address, browser and device characteristics, operating system,
language preferences, referring URLs, device name, country,
location, information about how and when you use our Services
and other technical information. This information is primarily
needed to maintain the security and operation of our Services,
and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through
cookies and similar technologies.

Online Identifiers. We collect tools and protocols, such as IP
(Internet Protocol) addresses; cookie identifiers, or others
such as the ones used for analytics and marketing; and other
similar data.

2. HOW DO WE USE YOUR INFORMATION?

We process your information for purposes based on legitimate
business interests, the fulfilment of our contract with you,
compliance with our legal obligations, and/or your consent.

We use personal information collected via our Services for a
variety of business purposes described below. We process your
personal information for these purposes in reliance on our
legitimate business interests, in order to enter into or perform
a contract with you, with your consent, and/or for compliance
with our legal obligations. We indicate the specific processing
grounds we rely on next to each purpose listed below. We use the
information we collect or

  • To send you marketing and promotional communications. We
    may use the personal information you send to us for our marketing
    purposes if this is in accordance with your marketing
    preferences. You can opt-out of our marketing emails at any
    time (see the “WHAT ARE YOUR PRIVACY RIGHTS” below).
  • Fulfil and manage your orders. We may use your information
    to fulfil and manage your orders, payments, returns, and
    exchanges made through the Services.
  • Deliver targeted advertising to you. We may use your
    information to develop and display content and advertising
    (and work with third parties who do so) tailored to your
    interests and/or location and to measure its effectiveness.
  • Request Feedback. We may use your information to request
    feedback and to contact you about your use of our Services.
  • To protect our Services. We may use your information as part
    of our efforts to keep our Services safe and secure (for
    example, for fraud monitoring and prevention).
  • To enforce our terms, conditions and policies for Business
    Purposes, Legal Reasons and Contractual.
  • To respond to legal requests and prevent harm. If we receive
    a subpoena or other legal request, we may need to inspect
    the data we hold to determine how to respond.
  • To deliver services to the user. We may use your information
    to provide you with the requested service.
  • To respond to user inquiries/offer support to users. We may
    use your information to respond to your inquiries and solve
    any potential issues you might have with the use of our
    Services.
  • For other Business Purposes. We may use your information for
    other Business Purposes, such as data analysis, identifying
    usage trends, determining the effectiveness of our
    promotional campaigns and to evaluate and improve our
    Services, products, marketing and your experience. We may
    use and store this information in aggregated and anonymized
    form so that it is not associated with individual end-users
    and does not include personal information. We will not use
    identifiable personal information without your consent.

3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

We only share information with your consent, to comply with
laws, to provide you with services, to protect your rights, or
to fulfil business obligations.

We may process or share data based on the following legal basis:

  • Consent: We may process your data if you have given us
    specific consent to use your personal information in a
    specific purpose.
  • Legitimate Interests: We may process your data when it is
    reasonably necessary to achieve our legitimate business
    interests.
  • Performance of a Contract: Where we have entered into a
    contract with you, we may process your personal information
    to fulfil the terms of our contract.
  • Legal Obligations: We may disclose your information where we
    are legally required to do so in order to comply with
    applicable law, governmental requests, a judicial
    proceeding, court order, or legal processes, such as in
    response to a court order or a subpoena (including in
    response to public authorities to meet national security or
    law enforcement requirements).
  • Vital Interests: We may disclose your information where we
    believe it is necessary to investigate, prevent, or take
    action regarding potential violations of our policies,
    suspected fraud, situations involving potential threats to
    the safety of any person and illegal activities, or as
    evidence in litigation in which we are involved.

4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

We may use cookies and other tracking technologies to collect
and store your information.

We may use cookies and similar tracking technologies (like web
beacons and pixels) to access or store information.

Specific information about how we use such technologies and how
you can refuse certain cookies is set out in our Cookie Policy.

5. HOW LONG DO WE KEEP YOUR INFORMATION?

We keep your information for as long as necessary to fulfil the
purposes outlined in this privacy policy unless otherwise
required by law.

We will only keep your personal information for as long as it is
necessary for the purposes set out in this privacy policy unless
a longer retention period is required or permitted by law (such
as tax, accounting or other legal requirements). No purpose in
this policy will require us keeping your personal information
for longer than 2 years. When we have no ongoing legitimate
business need to process your personal information, we will
either delete or anonymize it, or, if this is not possible (for
example, because your personal information has been stored in
backup archives), then we will securely store your personal
information and isolate it from any further processing until
deletion is possible.

6. HOW DO WE KEEP YOUR INFORMATION SAFE?

We aim to protect your personal information through a system of
organizational and technical security measures. We have
implemented appropriate technical and organizational security
measures designed to protect the security of any personal
information we process. However, please also remember that we
cannot guarantee that the internet itself is 100% secure.
Although we will do our best to protect your personal
information, the transmission of personal information to and
from our Services is at your own risk. You should only access
the services within a secure environment.

7. DO WE COLLECT INFORMATION FROM MINORS?

We do not knowingly collect data from or market to children
under 18 years of age.

We do not knowingly solicit data from or market to children
under 18 years of age. By using the Services, you represent that
you are at least 18 or that you are the parent or guardian of
such a minor and consent to such minor dependent’s use of the
Services. If we learn that personal information from users less
than 18 years of age has been collected, we will deactivate the
account and take reasonable measures to promptly delete such
data from our records. If you become aware of any data we have
collected from children under age 18, please contact us at{‘ ‘}
[email protected]

8. WHAT ARE YOUR PRIVACY RIGHTS?

In some regions, such as the European Economic Area, you have
rights that allow you greater access to and control over your
personal information. You may review, change, or terminate your
account at any time. In some regions (like the European Economic
Area), you have certain rights under applicable data protection
laws. These may include the right (i) to request access and
obtain a copy of your personal information, (ii) to request
rectification or erasure; (iii) to restrict the processing of
your personal information; and (iv) if applicable, to data
portability. In certain circumstances, you may also have the
right to object to the processing of your personal information.
To make such a request, please use the contact details provided
below. We will consider and act upon any request in accordance
with applicable data protection laws.

If we are relying on your consent to process your personal
information, you have the right to withdraw your consent at any
time. Please note however that this will not affect the
lawfulness of the processing before its withdrawal.

If you are resident in the European Economic Area and you
believe we are unlawfully processing your personal information,
you also have the right to complain to your local data
protection supervisory authority. You can find their contact
details here:{‘ ‘}

http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm

. Cookies and similar technologies: Most Web browsers are set to
accept cookies by default. If you prefer, you can usually choose
to set your browser to remove cookies and to reject cookies. If
you choose to remove cookies or reject cookies, this could
affect certain features or services of our Services. To opt-out
of interest-based advertising by advertisers on our Services
visit{‘ ‘}

http://www.aboutads.info/choices/

.

9. DATA BREACH

A privacy breach occurs when there is unauthorized access to or
collection, use, disclosure or disposal of personal information.
You will be notified about data breaches when Top Companions
believes you are likely to be at risk or serious harm. For
example, a data breach may be likely to result in serious
financial harm or harm to your mental or physical well-being. In
the event that Top Companions becomes aware of a security breach
which has resulted or may result in unauthorized access, use or
disclosure of personal information Top Companions will promptly
investigate the matter and notify the applicable Supervisory
Authority not later than 72 hours after having become aware of
it unless the personal data breach is unlikely to result in a
risk to the rights and freedoms of natural persons.

10. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile
applications include a Do-Not-Track (“DNT”) feature or setting
you can activate to signal your privacy preference not to have
data about your online browsing activities monitored and
collected. No uniform technology standard for recognizing and
implementing DNT signals has been finalized. As such, we do not
currently, respond to DNT browser signals or any other mechanism
that automatically communicates your choice not to be tracked
online. If a standard for online tracking is adopted that we
must follow in the future, we will inform you about that
practise in a revised version of this privacy policy.

11. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

Yes, if you are a resident of California, you are granted
specific rights regarding access to your personal information.
California Civil Code Section 1798.83, also known as the “Shine
The Light” law, permits our users who are California residents
to request and obtain from us, once a year and free of charge,
information about categories of personal information (if any) we
disclosed to third parties for direct marketing purposes and the
names and addresses of all third parties with which we shared
personal 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 using the
contact information provided below.

If you are under 18 years of age, reside in California, and have
a registered account with the Services, you have the right to
request removal of unwanted data that you publicly post on the
Services. To request removal of such data, please contact us
using the contact information provided below, and include the
email address associated with your account and a statement that
you reside in California. We will make sure the data is not
publicly displayed on the Services, but please be aware that the
data may not be completely or comprehensively removed from our
systems.

12. DO WE MAKE UPDATES TO THIS POLICY?

Yes, we will update this policy as necessary to stay compliant
with relevant laws. We may update this privacy policy from time
to time. The updated version will be indicated by an updated
“Revised” date and the updated version will be effective as soon
as it is accessible. If we make material changes to this privacy
policy, we may notify you either by prominently posting a notice
of such changes or by directly sending you a notification. We
encourage you to review this privacy policy frequently to be
informed of how we are protecting your information.

13. HOW CAN YOU CONTACT US ABOUT THIS POLICY?

If you have questions or comments about this policy, you may
contact our Data Protection Officer (DPO), by
email at{‘ ‘}

[email protected]
{‘ ‘}

HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM
YOU?

Based on the laws of some countries, you may have the right to
request access to the personal information we collect from you,
change that information, or delete it in some circumstances. To
request to review, update, or delete your personal information,
please submit a request form by clicking here. We will respond
to your request within 30 days. ​

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