{"id":42502,"date":"2024-04-06T13:47:41","date_gmt":"2024-04-06T13:47:41","guid":{"rendered":"https:\/\/topii.com\/?page_id=42502"},"modified":"2024-04-06T13:48:26","modified_gmt":"2024-04-06T13:48:26","slug":"app-pp-all-en-2","status":"publish","type":"page","link":"https:\/\/topii.com\/app-pp-all-en-2\/","title":{"rendered":"Pol\u00edtica de Privacidad y Pol\u00edtica de Cookies de la Aplicaci\u00f3n EN"},"content":{"rendered":"\t\t<div data-elementor-type=\"wp-page\" data-elementor-id=\"42502\" class=\"elementor elementor-42502\" data-elementor-post-type=\"page\">\n\t\t\t\t<div class=\"elementor-element elementor-element-f00f20d e-flex e-con-boxed cmsmasters-block-default e-con e-parent\" data-id=\"f00f20d\" data-element_type=\"container\">\n\t\t\t\t\t<div class=\"e-con-inner\">\n\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t<div class=\"elementor-element elementor-element-3cc0ecf0 e-flex e-con-boxed cmsmasters-block-default e-con e-parent\" data-id=\"3cc0ecf0\" data-element_type=\"container\">\n\t\t\t\t\t<div class=\"e-con-inner\">\n\t\t\t\t<div class=\"elementor-element elementor-element-3799aef1 cmsmasters-block-default cmsmasters-sticky-default elementor-widget elementor-widget-text-editor\" data-id=\"3799aef1\" data-element_type=\"widget\" data-widget_type=\"text-editor.default\">\n\t\t\t\t<div class=\"elementor-widget-container\">\n\t\t\t<style>\/*! elementor - v3.21.0 - 08-05-2024 *\/\n.elementor-widget-text-editor.elementor-drop-cap-view-stacked .elementor-drop-cap{background-color:#69727d;color:#fff}.elementor-widget-text-editor.elementor-drop-cap-view-framed .elementor-drop-cap{color:#69727d;border:3px solid;background-color:transparent}.elementor-widget-text-editor:not(.elementor-drop-cap-view-default) .elementor-drop-cap{margin-top:8px}.elementor-widget-text-editor:not(.elementor-drop-cap-view-default) .elementor-drop-cap-letter{width:1em;height:1em}.elementor-widget-text-editor .elementor-drop-cap{float:left;text-align:center;line-height:1;font-size:50px}.elementor-widget-text-editor .elementor-drop-cap-letter{display:inline-block}<\/style>\t\t\t\t<p><strong>Privacy Policy<\/strong><\/p><p>Last update: April 06, 2024<\/p><p>This Privacy Policy describes our policies and procedures regarding collecting, using, and disclosing your information when you use the Service. It also informs you of your privacy rights and how the law protects you.<\/p><p>We use your personal information to provide and improve the Service. By using the Service, you consent to this Privacy Policy&#8217;s collection and use of information.<\/p><p><strong>Interpretation and definitions<\/strong><\/p><p><strong>Interpretation<\/strong><\/p><p>Words whose initial capital letters are capitalized have the meanings defined below. The following definitions will have the same meaning regardless of whether they appear singular or plural.<\/p><p><strong>Definitions<\/strong><\/p><p>For this Privacy Policy:<\/p><ul><li><strong>An account is a unique account created for you to access our service or portions of our s<\/strong>ervice.<\/li><li><strong>Affiliate <\/strong>means an entity that controls is controlled by or is under common control with a party, where \u00abcontrol\u00bb means ownership of 50% or more of the shares, interests, or other securities entitled to vote for the election of directors or other management authority.<\/li><li><strong>Application <\/strong>refers to Topii, the software provided by the Company.<\/li><li><strong>Business<\/strong>, for purposes of the CCPA\/CPRA, refers to the Business as the legal entity that collects Consumers&#8217; personal information and determines the purposes and means of the processing of Consumers&#8217; personal data or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of Consumers&#8217; personal information, that does business in the State of California.<\/li><li><strong>CCPA <\/strong>and <strong>CPRA <\/strong>refer to the California Consumer Privacy Act (the \u00abCCPA\u00bb) as amended by the California Privacy Rights Act of 2020 (the \u00abCPRA\u00bb).<\/li><\/ul><ul><li><strong>Company <\/strong>(referred to as \u00abthe Company,\u201d \u00abWe,\u201d \u00abUs,\u201d \u00abWe,\u00bb or \u00abOur\u00bb in this Agreement) refers to <strong>TOPii Fide Europe, S.L.U.<\/strong>, a company incorporated and existing under the laws of the Kingdom of Spain, with registered office at Calle Vel\u00e1zquez 76, bajo Izquierdo, 28001, Madrid, Spain and Spanish Tax Identification Number B-01980382, which is registered in the Commercial Registry of Madrid, volume 41110, folio 99, page M-728985. Email: dpo@topii.com<\/li><\/ul><p>In providing the Services, the Company acts in the name and on behalf of the electronic money institution Sefide, EDE, S.L.U. (\u00ab<strong>Sefide<\/strong>\u00ab), as Sefide&#8217;s authorized agent. Sefide is a company incorporated and existing under the laws of the Kingdom of Spain, with a registered office at Avenida de la Ciencia 2-3\u00ba, 18006, Granada, Spain, and Spanish Tax Identification Number B-93205474, which is registered in the Mercantile Registry of Granada, volume 1559, folio 143, page GR-46879. E-mail address: info@sefide.es.<\/p><p>More information about Sefide can be found at: <a href=\"https:\/\/sefide.com\/\">https:\/\/sefide.com\/.<\/a><br \/><br \/><\/p><p>Sefide is licensed by the Bank of Spain (Entity Code No. 6705) and operates under the supervision of the Bank of Spain, with an address at Calle de Alcal\u00e1, 48, 28014, Madrid, Spain.<\/p><p>In addition, in providing the Money Transfer Service, the Company acts for and on behalf of MoneyGram International, S.A. (\u00ab<strong>MoneyGram<\/strong>\u00ab) as MoneyGram&#8217;s authorized agent. MoneyGram is a company incorporated and existing under the laws of Belgium, with a registered office at Rue Joseph Stevens 7, 1100, Brussels, Belgium.<\/p><p>More information about MoneyGram can be found at https:\/\/www.moneygram.com.<\/p><p>MoneyGram is licensed by the National Bank of Belgium (Entity Code No. 0671.690.653) and operates under the supervision of the National Bank of Belgium.<\/p><ul><li>For the GDPR, the Company is the Data Controller.<\/li><li>For purposes of the CCPA\/CPRA, a <strong>consumer <\/strong>is defined as a natural person who is a resident of California. A resident, as defined in the Act, includes (1) any natural person in the U.S. for other than a temporary or transitory purpose and (2) any natural person domiciled in the U.S. who is outside the U.S. for a temporary or transitory purpose.<\/li><li><strong>The country <\/strong>refers to Spain.<\/li><li>For the purposes of the GDPR (General Data Protection Regulation), the data controller refers to the Company as the legal entity that, alone or jointly with others, determines the purposes and means of processing Personal Data.<\/li><li><strong>Device: <\/strong>any device that can access the Service, such as a computer, cell phone, or digital tablet.<\/li><li><strong>Do Not Track <\/strong>(DNT) is a concept promoted by the U.S. regulatory authorities, particularly the Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism that allows Internet users to control the tracking of their online activities through websites.<\/li><li><strong>GDPR <\/strong>refers to the EU General Data Protection Regulation.<\/li><li><strong>Personal data <\/strong>is any information relating to an identified or identifiable natural person.<\/li><\/ul><p>For the GDPR, Personal Data means any information relating to You, such as a name, an identification number, location data, online identifier, or one or more factors specific to physical, physiological, genetic, mental, economic, cultural, or social identity.<\/p><p>For purposes of the CCPA\/CPRA, Personal Data means any information that identifies, relates to, describes, or can be associated with You or can reasonably be linked, directly or indirectly, to You.<\/p><ul><li><strong>Service <\/strong>refers to the Application.<\/li><li><strong>Service Provider <\/strong>means any natural or legal person who processes data on behalf of the Company. It refers to third-party companies or persons employed by the Company to facilitate the Service, provide the Service on behalf of the Company, perform services related to the Service, or assist the Company in analyzing how the Service is used. For the GDPR, Service Providers are considered Data Processors.<\/li><li><strong>Usage Data <\/strong>means data collected automatically, whether generated by the use of the Service or from the Service&#8217;s infrastructure (for example, the duration of the visit to a page).<\/li><li><strong>You <\/strong>are the natural person accessing or using the Service or the company or other legal entity on behalf of which such natural person is accessing or using the Service, as applicable.<\/li><\/ul><p>Under the GDPR, You may be referred to as the Data Subject or the User, as You are the individual using the Service.<\/p><p>The Application allows the User to access the services described in the Terms and Conditions (the \u00ab<strong>Services<\/strong>\u00ab). The Terms and Conditions governing the Services (the \u00abTerms and Conditions\u00bb), of which this Policy forms a part, can be found at https:\/\/www.topii.es\/terms_and_conditions.<\/p><p>Likewise, the creation and operation of the Electronic Money Account is governed by Sefide&#8217;s Electronic Money Account Opening Agreement, applying the personal data processing policy contained in the Electronic Money Agreement, which the User can consult here: https:\/\/sefide.com\/politica-de-privacidad\/.<\/p><p>The MoneyGram Money Transfer Terms of Service govern the Money Transfer Services and apply to the personal data processing policy contained in the Terms of Service, which the User can consult here: https:\/\/www.moneygram.com\/intl\/privacy-notice.<\/p><p>\u00a0<\/p><p><strong>Collection and use of your personal data<\/strong><\/p><p><strong>Types of data collected<\/strong><\/p><p><strong>Personal data<\/strong><\/p><p>When using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include, but is not limited to:<\/p><ul><li>E-mail address<\/li><li>Name and surname<\/li><li>Telephone number<\/li><li>Address, State, Province, Zip\/Postal Code, City<\/li><li>Usage Data<\/li><\/ul><p><strong>Usage Data<\/strong><\/p><p>Usage Data is collected automatically when you use the Service.<\/p><p>Usage Data may include information such as the Internet Protocol address (e.g., IP address) of your device, browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.<\/p><p>When you access the Service by or through a mobile device, we may collect certain information automatically, including, but not limited to, the type of mobile device you use, the unique identifier of your mobile device, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.<\/p><p>We may also collect information that your browser sends whenever you visit our Service or when you access the Service by or through a mobile device.<\/p><p><strong>Information collected during the use of the application<\/strong><\/p><p>In order to register and create the User&#8217;s account (the \u00ab<strong>Account<\/strong>\u00ab) in the Application (a necessary requirement to access the Services), the Company will collect, through the corresponding form, specific personal data of the User (identification data, biometric data, contact data, passwords, cell phone number), the provision of which will be mandatory, as indicated in the different registration screens of the Application.<\/p><p>In order to Use the Services, the User must also provide the financial data related to the valid means of payment (the \u00ab<strong>Means of Payment<\/strong>\u00ab) associated with their Account, as well as, if applicable, other passwords or codes required for each specific transaction, or biometric data (facial recognition) to authorize transactions, as indicated on the different screens of the Application.<\/p><p>If the User fails to provide all mandatory data by this Privacy Policy (or if the User fails to pass the identity verification checks of the Application, or those that the Company may perform by the Terms and Conditions), the User will not be able to register on the Application and use the Services, as indicated above.<\/p><p>The Company will collect information on the data of transactions made using the Services, such as where they are made, when they are made, the amounts of the transactions, the Means of Payment used, the description of the transaction, the amount of the Incentive, etc.<\/p><p>The Company will also collect information about the User&#8217;s general use of the Application and the User&#8217;s activity within the Application, such as:<\/p><ul><li>Sections of the Application consulted.<\/li><li>Complaints or inquiries.<\/li><li>User interaction with the Application.<\/li><li>Incentives applied.<\/li><li>Searches performed.<\/li><li>Establishment profile visits.<\/li><li>Physical visits to an Establishment (in case the User has granted the corresponding geolocation permissions in the Application to do so).<\/li><\/ul><p>In general, the information collected referred to in this clause remains anonymous. It does not personally identify the User, nor is it stored in association with any other information that links it to the User. You can consult more details by accessing our Cookies Policy, which is included below.<\/p><p>However, if the User voluntarily enters additional information, or if the User checks the corresponding boxes allowing geolocation or the sending of own or third-party commercial communications, the corresponding information on the use of the Application will be associated with the rest of the personal data provided by the User and will be treated as personal data, for the processing that the Company will carry out by the purposes and legitimacy of the processing in question, as detailed below.<\/p><p>Once the Application is installed on a Device, the Company will automatically collect technical information about it, including the Device&#8217;s unique device identifier and IP address, as well as, if permitted by the User, the device&#8217;s geolocation data.<\/p><p>The information collected referred to in this clause remains anonymous, i.e., it does not personally identify the User, nor is it stored in association with any other information that links it to the User. You can consult more details by accessing our Cookies Policy, which is included below.<\/p><p>Notwithstanding the foregoing, if the User voluntarily enters additional information, the Device information will be associated with the other personal data provided by the User and treated as personal data for the processing that the Company will carry out by virtue of the purposes and legitimacy of the processing in question as detailed below (for example, in relation to geolocation data).<\/p><p>The User must take into account that, in case they do not allow the technical data of the Device to be treated as personal data (such as geolocation data), they may not be able to enjoy the Services with all their functionalities (for example, they will not be able to consult nearby Establishments available according to their location).<\/p><p><strong>Use of your personal data<\/strong><\/p><p>The Company may use Personal Data for the following purposes:<\/p><ul><li><strong>To provide and maintain our <\/strong>Service, including monitoring the use of our Service.<\/li><li><strong>To manage Your Account: <\/strong>to manage Your registration as a user of the Service. The Personal Data You provide may give You access to different functionalities of the Service that are available to You as a registered user.<\/li><li><strong>To contact You: <\/strong>To contact You by email, phone calls, SMS or other equivalent forms of electronic communication, such as push notifications from a mobile application about updates or informational communications related to contracted features, products or services, including security updates, when necessary or reasonable for implementation.<\/li><li><strong>Provide you with <\/strong>news, special offers, and general information about other products, services, and events we offer that are similar to those you have already purchased or inquired about unless you have opted out of receiving such information.<\/li><li><strong>Manage Your Requests: <\/strong>To fulfill and manage Your requests to Us.<\/li><li><strong>For Business Transfers: <\/strong>We may use Your Information to evaluate or carry out 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 Data We hold about users of Our Service is among the assets transferred.<\/li><li><strong>For Other Purposes<\/strong>: We may use Your Information for other purposes, such as analyzing data, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.<\/li><\/ul><p>We may share your personal information in the following situations:<\/p><ul><li><strong>With Service Providers: <\/strong>We may share your personal information with Service Providers to monitor and analyze the use of our Service and contact you.<\/li><li><strong>For Business Transfers: <\/strong>We may share or transfer Your Personal Information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or part of Our business to another company.<\/li><li><strong>With Affiliates: We <\/strong>do not share Your Information with Our affiliates.<\/li><li><strong>With business partners: We <\/strong>do not share Your information with Our business partners.<\/li><li><strong>With other users: <\/strong>When you share personal information or otherwise interact in public areas with other users, such information may be viewed by all users and may be publicly distributed externally.<\/li><li><strong>With Your Consent<\/strong>: We may disclose Your personal information for any other purpose with Your consent.<\/li><\/ul><p><strong>Messages and Communications<\/strong><\/p><p>Topii is committed to maintaining the privacy and security of your communication. All messages sent through our application are protected to ensure that only you and the intended recipient can access the shared content. We have no ability to read or access the content of your messages.<\/p><p>\u00a0<\/p><p>To ensure reliable delivery of messages, including those containing attachments or communications regarding services such as remittance requests or transfers, we store messages securely on our servers. These are kept as long as necessary to ensure effective delivery, especially in cases where the receiving device may be temporarily offline.<\/p><p>\u00a0<\/p><p>In addition, we collect and store the minimum technical information necessary for the efficient operation of our services. This includes authentication identifiers, session tokens, and other data essential for message and service management. We strive to limit this information to the minimum that is strictly necessary to provide our services securely and efficiently.<\/p><p><strong>Service Communications<\/strong><\/p><p>As part of our services, Topii sends communications through messages that may include details about transactions performed, such as remittances or transfers. These communications are intended to keep you informed about the status of your requests and provide relevant information about the services you use.<\/p><p><strong>Contact list<\/strong><\/p><p>To make it easier for you to find your contacts on Topii and improve your user experience, our application may request access to your device&#8217;s address book. We use secure methods to process this information, ensuring the privacy of your contacts. This process is entirely optional and is carried out only with your explicit consent.<\/p><p><strong>Retention of your personal data<\/strong><\/p><p>The Company will retain Your Personal Data only for as long as necessary for the purposes set forth in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain Your Data to comply with applicable law), resolve disputes, and enforce our legal agreements and policies.<\/p><p>The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except where this data is used to enhance the security or improve the functionality of Our Service or where We are legally required to retain this data for longer periods of time.<\/p><p><strong>Transfer of your personal data<\/strong><\/p><p>Your information, including Personal Data, is processed at the Company&#8217;s operating offices and at any other location where the parties involved in the processing are located. This means that this information may be transferred to and maintained on computers located outside your state, province, country, or other governmental jurisdiction where data protection laws may differ from those in your jurisdiction.<\/p><p>Your consent to this Privacy Policy, followed by your submission of such information, represents your agreement to such transfer.<\/p><p>The Company will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data to an organization or country will take place unless there are adequate controls in place that include the security of your data and other personal information.<\/p><p><strong>Delete your personal data.<\/strong><\/p><p>You have the right to delete or request that we assist you in deleting the Personal Data we have collected about you.<\/p><p>Our Service may offer you the ability to delete certain information about yourself within the Service.<\/p><p>You may update, modify, or delete your information at any time by logging into your account if you have one and visiting the account settings section that allows you to manage your personal information. You may also contact us to request access to, correct, or delete any personal information you have provided to us.<\/p><p>Please note, however, that we may need to retain certain information when we have a legal obligation or a legal basis to do so.<\/p><p><strong>Disclosure of your personal data<\/strong><\/p><p><strong>Commercial operations<\/strong><\/p><p>If the company is involved in a merger, acquisition, or asset sale, your Personal Data may be transferred. We will notify you before your Personal Data is transferred and becomes subject to a different Privacy Policy.<\/p><p><strong>Compliance with the law<\/strong><\/p><p>In certain circumstances, the Company may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency).<\/p><p><strong>Other legal requirements<\/strong><\/p><p>The Company may disclose your Personal Data in the good faith belief that such action is necessary to:<\/p><ul><li>Fulfilling a legal obligation<\/li><li>Protect and defend the rights or property of the company.<\/li><li>Prevent or investigate possible irregularities in connection with the Service.<\/li><li>Protect the personal safety of Service users or the public.<\/li><li>Protection against legal liability<\/li><\/ul><p><strong>Security of your personal data<\/strong><\/p><p>The security of your Personal Data is important to us, but please remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.<\/p><p><strong>Detailed information on the processing of your personal data<\/strong><\/p><p>Service Providers that We use may have access to Your Personal Data. These third-party providers collect, store, use, process, and transfer information about Your activity on Our Service in accordance with their Privacy Policies.<\/p><p><strong>Analytics<\/strong><\/p><p>We may use third-party service providers to monitor and analyze the use of our Service.<\/p><ul><li><strong>Google Analytics<\/strong><\/li><\/ul><p>Google Analytics is a web analytics service provided by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the data collected to contextualize and personalize the advertisements of its own advertising network.<\/p><p>You can turn off certain Google Analytics features through your mobile device settings, such as your device&#8217;s advertising settings, or by following the instructions provided by Google in its Privacy Policy: <a href=\"https:\/\/policies.google.com\/privacy\">https:\/\/policies.google.com\/privacy.<\/a><\/p><p>For more information about Google&#8217;s privacy practices, please visit Google&#8217;s privacy and terms webpage: <a href=\"https:\/\/policies.google.com\/privacy\">https:\/\/policies.google.com\/privacy.<\/a><\/p><ul><li><strong>Firebase<\/strong><\/li><\/ul><p>Firebase is an analytics service provided by Google Inc.<\/p><p>You can opt out of certain Firebase features through your mobile device settings, such as your device&#8217;s advertising settings, or by following the instructions provided by Google in its Privacy Policy: <a href=\"https:\/\/policies.google.com\/privacy\">https:\/\/policies.google.com\/privacy.<\/a><\/p><p>We also recommend that you consult Google&#8217;s policy for the protection of your data: <a href=\"https:\/\/support.google.com\/analytics\/answer\/6004245\">https:\/\/support.google.com\/analytics\/answer\/6004245.<\/a><\/p><p>For more information about the type of information Firebase collects, please visit the How Google uses data when you use our partners&#8217; sites or apps web page: <a href=\"https:\/\/policies.google.com\/technologies\/partner-sites\">https:\/\/policies.google.com\/technologies\/partner-sites.<\/a><\/p><ul><li><strong>EMMA<\/strong><\/li><\/ul><p>Its privacy policy is available at <a href=\"https:\/\/emma.io\/politica-de-privacidad\/\">https:\/\/emma.io\/politica-de-privacidad\/.<\/a><\/p><p><strong>E-mail marketing<\/strong><\/p><p>We may use your personal data to contact you and send you newsletters, promotional or marketing materials, and other information that may be of interest to you. You may opt out of receiving any or all of these communications from us by following the unsubscribe link or instructions contained in any email we send you or by contacting us.<\/p><p>We may use email marketing service providers to manage and send emails to you.<\/p><ul><li><strong>Mailchimp<\/strong><\/li><\/ul><p>Mailchimp is an email marketing service provided by The Rocket Science Group LLC.<\/p><p>For more information about Mailchimp&#8217;s privacy practices, please visit their privacy policy: <a href=\"https:\/\/mailchimp.com\/legal\/privacy\/\">https:\/\/mailchimp.com\/legal\/privacy\/.<\/a><\/p><ul><li><strong>EMMA<\/strong><\/li><\/ul><p>Its privacy policy is available at <a href=\"https:\/\/emma.io\/politica-de-privacidad\/\">https:\/\/emma.io\/politica-de-privacidad\/.<\/a><\/p><p><strong>Usage, performance, and miscellaneous<\/strong><\/p><p>We may use third-party service providers to maintain and improve our Service.<\/p><ul><li><strong>FreshDesk<\/strong><\/li><\/ul><p>FreshDesk is a customer service software. The service is operated by Freshworks, Inc.<\/p><p>The FreshDesk service may collect information from your device.<\/p><p>The information collected by FreshDesk is maintained in accordance with its Privacy Policy: <a href=\"https:\/\/www.freshworks.com\/privacy\/\">https:\/\/www.freshworks.com\/privacy\/.<\/a><\/p><p><strong>GDPR Privacy<\/strong><\/p><p><strong>Legal basis for the processing of personal data under the GDPR<\/strong><\/p><p>We may process Personal Data under the following conditions:<\/p><ul><li><strong>Consent: <\/strong>You have given Your consent to the processing of Personal Data for one or more specific purposes.<\/li><li><strong>Execution of a contract: The <\/strong>provision of Personal Data is necessary for the execution of an agreement with You and for any pre-contractual obligation thereof.<\/li><li><strong>Legal obligations: <\/strong>The Processing of Personal Data is necessary to comply with a legal obligation to which the Company is subject.<\/li><li><strong>Vital Interests: <\/strong>The Processing of Personal Data is necessary to protect Your vital interests or those of another natural person.<\/li><li><strong>Public Interest: <\/strong>The Processing of Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.<\/li><li><strong>Legitimate interests: <\/strong>The Processing of Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.<\/li><\/ul><p>In any case, the Company will be happy to assist in clarifying the specific legal basis that applies to the processing, and in particular, whether the provision of Personal Data is a legal or contractual requirement or a necessary requirement to enter into a contract.<\/p><p><strong>Your rights under the GDPR<\/strong><\/p><p>The Company undertakes to respect the confidentiality of your Personal Data and to guarantee you the exercise of your rights.<\/p><p>You have the right, under this Privacy Policy, and by law if you are located within the EU, to:<\/p><ul><li><strong>Request access to your personal information.<\/strong> Right to access, update, or delete information we have about you. Where possible, you can access, update, or request deletion of your personal data directly from the settings section of your account. If you are unable to perform these actions yourself, please get in touch with us for assistance. This also allows you to receive a copy of the Personal Data we hold about you.<\/li><li><strong>Request corrections to the personal information we have about you.<\/strong> You have the right to have any incomplete or inaccurate information we have about you corrected.<\/li><li><strong>Object to the processing of your Personal Data. <\/strong>This right exists where we rely on a legitimate interest as a legal basis for our processing and there is something in your particular situation that leads you to object to the processing of your Personal Data on this ground. You also have the right to object when we process your Personal Data for direct marketing purposes.<\/li><li><strong>Request deletion of your Personal Data.<\/strong> You have the right to ask us to erase or delete your Personal Data when there is no good reason for us to continue processing it.<\/li><li><strong>Request the transfer of your Personal Data.<\/strong> We will provide you, or a third party you have chosen, with your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information for whose use you have initially given us your consent or where we have used the information to perform a contract with you.<\/li><li><strong>Withdraw your consent.<\/strong> You have the right to withdraw your consent to the use of your Personal Data. If you withdraw your consent, we may not be able to provide you with access to certain specific features of the Service.<\/li><\/ul><p><strong>Exercising your GDPR data protection rights<\/strong><\/p><p>You may exercise your rights of access, rectification, cancellation and opposition by contacting us. Please note that we may ask you to verify your identity before responding to such requests. If you make a request, we will do our best to respond to you as soon as possible.<\/p><p>You have the right to lodge a complaint with a data protection authority about our collection and use of your personal data. For more information, if you are located in the European Economic Area (EEA), please get in touch with your local data protection authority in the EEA.<\/p><p><strong>CCPA\/CPRA Confidentiality Notice<\/strong><\/p><p>This privacy notice section for California residents supplements the information contained in Our Privacy Policy and applies exclusively to all visitors, users, and other persons residing in the State of California.<\/p><p><strong>Categories of personal data collected<\/strong><\/p><p>We collect information that identifies, relates to, describes, references, can be associated with, or could reasonably be linked, directly or indirectly, to a particular Consumer or Device. The following is a list of categories of personal information that we may collect or may have collected from California residents in the past twelve (12) months.<\/p><p>Please note that the categories and examples listed below are as defined in the CCPA\/CPRA. This does not mean that all examples of that category of personal information have, in fact, been collected by Us, but it reflects Our good faith belief, to the best of Our knowledge, that some of that applicable category information can be and may have been collected. For example, specific categories of personal information would only be collected if You provided such personal information directly to Us.<\/p><ul><li><strong>Category A: Identifiers.<\/strong><\/li><\/ul><p>Examples: A real name, alias, mailing address, unique personal identifier, online identifier, Internet protocol address, email address, account name, driver&#8217;s license number, passport number, or other similar identifiers.<\/p><p>Picked up: Yes.<\/p><ul><li><strong>Category B: Categories of personal information listed in the California Customer Records Act (Cal. Civ. Code \u00a7 1798.80(e)). Code \u00a7 1798.80(e)).<\/strong><\/li><\/ul><p>Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver&#8217;s license or state identification card number, insurance policy number, education, employment, work history, bank account number, credit card number, debit card number or any other financial information, medical information or health insurance information. Some personal information in this category may overlap with other categories.<\/p><p>Picked up: Yes.<\/p><ul><li><strong>Category C: Classification features protected under Californian or federal law.<\/strong><\/li><\/ul><p>Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including family genetic information).<\/p><p>Collections: No.<\/p><ul><li><strong>Category D: Commercial information.<\/strong><\/li><\/ul><p>Examples: Records and history of products or services purchased or considered.<\/p><p>Collections: No.<\/p><ul><li><strong>Category E: Biometric information.<\/strong><\/li><\/ul><p>Examples: Genetic, physiological, behavioral and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, for example, fingerprints, facial and voice prints, iris or retinal scans, keystroke, gait or other physical patterns, and sleep, health or exercise data.<\/p><p>Collections: No.<\/p><ul><li><strong>Category F: Internet or other similar network activity.<\/strong><\/li><\/ul><p>Examples: Interaction with our Service or advertising.<\/p><p>Picked up: Yes.<\/p><ul><li><strong>Category G: Geolocation data.<\/strong><\/li><\/ul><p>Examples: Approximate physical location.<\/p><p>Picked up: Yes.<\/p><ul><li><strong>Category H: Sensory data.<\/strong><\/li><\/ul><p>Examples: Sound, electronic, visual, visual, thermal, olfactory, or similar information.<\/p><p>Collections: No.<\/p><ul><li><strong>Category I: Professional or employment-related information.<\/strong><\/li><\/ul><p>Examples: Current or past work history or performance evaluations.<\/p><p>Collections: No.<\/p><ul><li><strong>Category J: Nonpublic educational information (under the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).<\/strong><\/li><\/ul><p>Examples: Educational records directly related to a student maintained by an educational institution or a party acting on its behalf, such as grades, transcripts, class rosters, student schedules, student identification codes, student financial information, or student disciplinary records.<\/p><p>Collections: No.<\/p><ul><li><strong>Category K: Inferences drawn from other personal information.<\/strong><\/li><\/ul><p>Examples: A profile that reflects a person&#8217;s preferences, characteristics, psychological tendencies, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.<\/p><p>Collections: No.<\/p><ul><li><strong>Category L: Sensitive personal information.<\/strong><\/li><\/ul><p>For example, Account login and password information and geolocation data.<\/p><p>Picked up: Yes.<\/p><p>Under the CCPA\/CPRA, personal information does not include:<\/p><ul><li>Publicly available information from government records<\/li><li>De-identified or aggregated consumer information<\/li><li>Information excluded from the scope of the CCPA\/CPRA, such as:<ul><li>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.<\/li><li>Personal information covered by certain industry-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or the California Financial Information Privacy Act (FIPA), and the Driver&#8217;s Privacy Protection Act of 1994.<\/li><\/ul><\/li><\/ul><p><strong>Sources of personal information<\/strong><\/p><p>We obtain the categories of personal information listed above from the following categories of sources:<\/p><ul><li><strong>Directly from you<\/strong>. For example, from forms you fill out on our Service and preferences, you express or provide through our Service.<\/li><li><strong>Indirectly from you<\/strong>. For example, you can observe your activity on our Service.<\/li><li><strong>Automatically from you<\/strong>. For example, through cookies that we or our service providers place on your device when you browse our Service.<\/li><li><strong>From service providers<\/strong>. For example, third-party providers to monitor and analyze the use of our Service, or other third-party providers we use to provide the Service to you.<\/li><\/ul><p><strong>Use of personal information<\/strong><\/p><p>We may use or disclose the personal information we collect for \u00abbusiness purposes\u00bb or \u00abcommercial purposes\u00bb (as defined in the CCPA\/CPRA), which may include the following examples:<\/p><ul><li>To operate our Service and provide it to you.<\/li><li>To provide you with assistance and respond to your inquiries, including investigating and resolving your problems and monitoring and improving our Service.<\/li><li>To fulfill or satisfy the reason, you provided the information to us. For example, if you share your contact information to ask a question about our Service, we will use that personal information to respond to your inquiry.<\/li><li>Respond to law enforcement requests as required by applicable law, court order, or government regulation.<\/li><li>As described to you when we collect your personal information or as otherwise set forth in the CCPA\/CPRA.<\/li><li>For administrative and internal audit purposes.<\/li><li>Detect security incidents and protect against malicious, deceptive, fraudulent, or illegal activities, including, where necessary, prosecuting those responsible for such activities.<\/li><li>Other non-recurring uses.<\/li><\/ul><p>Please note that the above examples are illustrative and are not intended to be exhaustive. For more details on how we use this information, please refer to the section \u00abUse of your personal data.\u00bb<\/p><p>If we decide to collect additional categories of personal information or use the personal information we collect for materially different, unrelated, or incompatible purposes, we will update this Privacy Policy.<\/p><p><strong>Disclosure of personal information<\/strong><\/p><p>We may use or disclose, and may have used or disclosed in the last twelve (12) months, the following categories of personal information for business or marketing purposes:<\/p><ul><li>Category A: Identifiers<\/li><li>Category B: Categories of personal information listed in the California Customer Records Act (Cal. Civ. Code \u00a7 1798.80(e)). Code \u00a7 1798.80(e))<\/li><li>Category F: Internet or other similar network activity<\/li><li>Category G: Geolocation data<\/li><li>Category L: Sensitive personal information<\/li><\/ul><p>Please note that the categories listed above are as defined in the CCPA\/CPRA. This does not mean that all instances of that category of personal information have, in fact, been disclosed, but it reflects our good faith belief, to the best of our knowledge, that some of that information in the applicable category can be and may have been disclosed.\u00a0\u00a0\u00a0\u00a0<\/p><p>When we disclose personal information for business or commercial purposes, we enter into a contract describing the purpose and requiring the recipient to maintain the confidentiality of the personal information and not to use it for any purpose other than the performance of the contract.<\/p><p><strong>Sharing personal information<\/strong><\/p><p>We may share, and have shared in the last twelve (12) months, Your personal information identified in the categories above with the following categories of third parties:<\/p><ul><li>Service providers<\/li><li>Our subsidiaries<\/li><li>Our business partners<\/li><li>Third-party providers to whom you or your agents authorize us to disclose your personal data in connection with the products or services we provide to you.<\/li><\/ul><p><strong>Sale of personal information<\/strong><\/p><p>As defined in the CCPA\/CPRA, \u00absell\u00bb and \u00absale\u00bb mean to sell, rent, lease, assign, disclose, divulge, disclose, make available, transfer, or otherwise communicate orally, in writing, or by electronic or other means, a Consumer&#8217;s personal information by the Company to a third party for monetary consideration. This means that we may have received some benefit in exchange for sharing personal information, but not necessarily an economic benefit.<\/p><p>We do not sell personal information as the term \u00absell\u00bb is commonly understood. We do allow service providers to use your personal information for the business purposes described in our Privacy Policy for activities such as advertising, marketing, and analytics, and these may be considered a sale under the CCPA\/CPRA.<\/p><p>We may sell and have sold in the last twelve (12) months the following categories of personal information:<\/p><ul><li>Category A: Identifiers<\/li><li>Category B: Categories of personal information listed in the California Customer Records Act (Cal. Civ. Code \u00a7 1798.80(e)). Code \u00a7 1798.80(e))<\/li><li>Category F: Internet or other similar network activity<\/li><li>Category G: Geolocation data<\/li><li>Category L: Sensitive personal information<\/li><\/ul><p>Please note that the categories listed above are as defined in the CCPA\/CPRA. This does not mean that all examples of that category of personal information were, in fact, sold, but it reflects our good faith belief, to the best of our knowledge, that some of that information in the applicable category can be and may have been shared in exchange for value.<\/p><p><strong>Sale of personal data of children under 16 years of age<\/strong><\/p><p>We do not knowingly collect personal information from children under the age of 16 through our Service, although some third-party websites to which we link may do so. These third-party websites have their own terms of use and privacy policies, so we encourage parents and legal guardians to monitor their children&#8217;s use of the Internet and instruct them never to provide information on other websites without your permission.<\/p><p>We do not sell the personal information of consumers we know are under the age of 16 unless we receive affirmative authorization (the \u00abright to opt-out\u00bb) from the consumer who is between the ages of 13 and 16 or from the parent or guardian of a consumer under the age of 13. Consumers who agree to the sale of personal information may object to future sales at any time. To exercise the right to opt out, you (or your authorized representative) may send us a request by contacting us.<\/p><p>If you have reason to believe that a child under the age of 13 (or 16) has provided us with personal information, please get in touch with us with sufficient details to enable us to delete such information.<\/p><p><strong>Your rights under CCPA\/CPRA<\/strong><\/p><p>The CCPA\/CPRA gives California residents specific rights regarding their personal information. If you are a California resident, you have the following rights:<\/p><ul><li><strong>Right to Notice.<\/strong> You have the right to be notified of the categories of Personal Data being collected and the purposes for which it is being used.<\/li><li><strong>Right to Know\/Access.<\/strong> Under the CCPA\/CPRA, you have the right to request that we disclose to you information about our collection, use, sale, disclosure for marketing purposes, and sharing of personal information. Once we receive and confirm your request, we will communicate it to you:<ul><li>Categories of personal information we collect about you<\/li><li>The categories of sources of the personal information we collect about you are as follows<\/li><li>Our business or commercial purposes for collecting or selling such personal information<\/li><li>The categories of third parties with which we share such personal information<\/li><li>Specific personal information we collect about you<\/li><li>If we sell your personal information or disclose it for marketing purposes, we will let you know:<ul><li>Categories of personal information sold<\/li><li>Categories of personal information disclosed<\/li><\/ul><\/li><\/ul><\/li><li><strong>Right to refuse to sell or share your personal information (opt-out).<\/strong> You have the right to ask us not to sell your personal information. To opt-out, please see the \u00abDo not sell my personal data\u00bb section or contact us.<\/li><li><strong>Right to Correct Personal Data.<\/strong> You have the right to correct or amend any inaccurate Personal Data we have collected about you. Once we receive and confirm your request, we will use commercially reasonable efforts to fix (and will direct our service providers to correct) your Personal Data unless an exception applies.<\/li><li><strong>Right to restrict the use and disclosure of Sensitive Personal Information.<\/strong> You have the right to request to limit the use or disclosure of certain Sensitive Personal Information that we have collected about you, unless an exception applies. To order this, please see the section \u00abLimiting the Use or Disclosure of My Sensitive Personal Data\u00bb or contact us.<\/li><li><strong>Right to delete Personal Data.<\/strong> You have the right to request deletion of Your Personal Data in certain circumstances, subject to certain exceptions. Once we receive and confirm your request, we will delete (and direct our service providers to delete) Your Personal Data from our records unless an exception applies. We may deny your request for deletion if retaining the information is necessary for us or our service providers to be able to:<ul><li>Complete the transaction for which we collected the personal information, provide a good or service you requested, take reasonably anticipated actions in the context of our ongoing business relationship with you, or otherwise fulfill our contract with you.<\/li><li>Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activities, or prosecute those responsible for such activities.<\/li><li>Debug products to identify and repair bugs that affect intended functionality.<\/li><li>She was exercising freedom of speech, guaranteeing the right of another consumer to exercise their free speech rights, or exercising another right provided by law.<\/li><li>Comply with the California Electronic Communications Privacy Act (Cal. Penal Code \u00a7 1546 et. seq.).<\/li><li>Participate in public or peer-reviewed scientific, historical, or statistical research in the public interest that complies with all other applicable ethics and privacy laws when deletion of the information could make it impossible or seriously impair the conduct of the research if you have previously given your informed consent.<\/li><li>Allow only internal uses that reasonably conform to consumers&#8217; expectations based on their relationship with us.<\/li><li>Fulfill a legal obligation.<\/li><li>Make other internal and lawful uses of that information that are consistent with the context in which you provided it.<\/li><\/ul><\/li><li><strong>Right to be free from discrimination.<\/strong> You have the right not to be discriminated against for exercising any of your rights as a consumer, including:<ul><li>Deny you goods or services<\/li><li>They were charging different prices or rates for goods or services, including the use of discounts or other benefits or the imposition of penalties.<\/li><li>Providing you with a different level or quality of goods or services<\/li><li>Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.<\/li><\/ul><\/li><\/ul><p><strong>Exercising your CCPA\/CPRA Data Protection Rights<\/strong><\/p><p>See the \u00abDo Not Sell My Personal Information\u00bb section and the \u00abLimit the Use or Disclosure of My Sensitive Personal Information\u00bb section for more information on how to opt-out and limit the use of the sensitive information collected.<\/p><p>In addition, to exercise any of your rights under the CCPA\/CPRA, and if you reside in California, you may contact us:<\/p><ul><li>By e-mail: dpo@topii.com<\/li><\/ul><p>Only you or a person registered with the California Secretary of State whom you authorize to act on your behalf may make a verifiable request regarding your personal information.<\/p><p>Your application must:<\/p><ul><li>Provide sufficient information to allow us to reasonably verify that you are the person about whom we collect personal information or an authorized representative.<\/li><li>Please describe your request in sufficient detail so that we can understand, evaluate, and respond to it appropriately.<\/li><\/ul><p>We cannot respond to your request or provide you with the requested information if we cannot:<\/p><ul><li>Verify your identity or authority to make the request<\/li><li>And confirm that the personal information refers to you.<\/li><\/ul><p>We will disclose and provide the requested information free of charge within 45 days of receipt of your verifiable request. The time period for providing the requested information may be extended once for an additional 45 days when reasonably necessary and upon notice.<\/p><p>Any disclosures we provide will only cover the 12-month period prior to receipt of the verifiable request.<\/p><p>For data portability requests, we will select a format for providing your personal information that is readily usable and allows you to transmit the information from one entity to another without hindrance.<\/p><p><strong>Please do not sell my personal data.<\/strong><\/p><p>As defined in the CCPA\/CPRA, \u00absell\u00bb and \u00absale\u00bb mean to sell, rent, lease, assign, disclose, divulge, disclose, make available, transfer, or otherwise communicate orally, in writing, or by electronic or other means, a Consumer&#8217;s personal information by the Company to a third party for monetary consideration. This means that we may have received some benefit in exchange for sharing personal information, but not necessarily an economic benefit.<\/p><p>We do not sell personal information as the term \u00absell\u00bb is commonly understood. We do allow service providers to use your personal information for the business purposes described in our Privacy Policy for activities such as advertising, marketing, and analytics, and these may be considered a sale under the CCPA\/CPRA.<\/p><p>You have the right to opt out of the sale of your personal information. Once we receive and confirm a verifiable request from you, we will stop selling your personal information. To exercise this right, please get in touch with us.<\/p><p>Service Providers with whom we partner (e.g., our analytics or advertising partners) may use technology in the Service that sells personal information as defined in the CCPA\/CPRA. If you wish to opt out of the use of your personal information for interest-based advertising purposes and these potential sales as described in the CCPA\/CPRA, you may do so by following the instructions below.<\/p><p>Please note that any opt-out is specific to the browser you use. You may have to opt out of all browsers you use.<\/p><p><strong>Website<\/strong><\/p><p>If applicable, click on the \u00abPrivacy Preferences\u00bb, \u00abUpdate Privacy Preferences\u00bb or \u00abDo Not Sell My Personal Data\u00bb buttons on the Service to review your privacy preferences and opt-out of cookies and other technologies that we may use. Please note that you will need to opt-out from each browser you use to access the Service.<\/p><p>In addition, you may opt out of receiving personalized advertisements served by our Service Providers by following our instructions presented in the Service:<\/p><ul><li>NAI&#8217;s opt-out platform: <a href=\"http:\/\/www.networkadvertising.org\/choices\/\">http:\/\/www.networkadvertising.org\/choices\/<\/a><\/li><li>EDAA&#8217;s opt-out platform <a href=\"http:\/\/www.youronlinechoices.com\/\">http:\/\/www.youronlinechoices.com\/<\/a><\/li><li>The DAA Opt-Out Platform: <a href=\"http:\/\/optout.aboutads.info\/?c=2&amp;lang=EN\">http:\/\/optout.aboutads.info\/?c=2&amp;lang=EN<\/a><\/li><\/ul><p>Opting out will place a cookie on your computer that is unique to the browser you use to opt-out. If you change browsers or delete the cookies stored by your browser, you will have to opt out again.<\/p><p><strong>Mobile devices<\/strong><\/p><p>Your mobile device may offer you the ability to opt out of the use of information about the applications you use in order to provide you with advertisements tailored to your interests:<\/p><ul><li>\u00abOpt out of Interest-Based Ads\u00bb or \u00abOpt out of Ads Personalization\u00bb on Android devices.<\/li><li>\u00abLimit ad tracking\u00bb on iOS devices.<\/li><\/ul><p>You can also stop the collection of location information from your mobile device by changing your mobile device preferences.<\/p><p><strong>To limit the use or disclosure of my sensitive personal data<\/strong><\/p><p>If you reside in California, you have the right to limit the use and disclosure of your sensitive personal information to the use necessary to provide the services or supply the goods reasonably expected by an average consumer requesting such services or goods.<\/p><p>We collect, use, and disclose sensitive personal information as necessary to provide the Service. For more information about how we use your personal information, please see the \u00abUse of Your Personal Information\u00bb section or contact us.<\/p><p><strong>Do Not Track\u00bb Policy required by the California Online Privacy Protection Act (CalOPPA)<\/strong><\/p><p>Our Service does not respond to Do Not Track signals.<\/p><p>However, some third-party websites track your browsing activities. If you visit these websites, you can set your browser preferences to inform the websites that you do not want to be tracked. You can turn DNT on or off by visiting your browser&#8217;s preferences or settings page.<\/p><p><strong>Your California Privacy Rights (California Shine the Light Act)<\/strong><\/p><p>Pursuant to California Civil Code Section 1798 (California&#8217;s Shine the Light law), California residents who have an established business relationship with us may request information once a year about the disclosure of their Personal Information to third parties for their direct marketing purposes.<\/p><p>If you would like to request more information under California&#8217;s Shine the Light law, and if you are a California resident, you may contact us using the contact information provided below.<\/p><p><strong>Privacy Rights of Minor Users in California (California Business and Professions Code Section 22581)<\/strong><\/p><p>California Business and Professions Code section 22581 allows California residents under the age of 18 who are registered users of online sites, services, or applications to request and obtain removal of content or information they have posted.<\/p><p>To request deletion of such data, and if you are a California resident, you may contact us using the contact information provided below, and include the e-mail address associated with your account.<\/p><p>Please note that your request does not guarantee complete or comprehensive removal of content or information posted online and that removal may not be permitted or required by law in certain circumstances.<\/p><p><strong>Children&#8217;s Privacy<\/strong><\/p><p>Our Service is not directed to children under the age of 13. We do not knowingly collect personally identifiable information from children under the age of 13. If you are a parent or guardian and you know that your child has provided us with Personal Data, please get in touch with us. If we become aware that we have collected Personal Data from anyone under the age of 13 without verification of parental consent, we will take steps to delete that information from our servers.<\/p><p>If we need to rely on consent as the legal basis for processing your information and your country requires parental consent, we may require parental consent before collecting and using that information.<\/p><p><strong>Links to other websites<\/strong><\/p><p>Our Service may contain links to other websites that we do not operate. If you click on a third-party link, you will be directed to that third-party&#8217;s site. We strongly encourage you to review the Privacy Policy of each site you visit.<\/p><p>We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.<\/p><p><strong>Changes to this privacy policy<\/strong><\/p><p>We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.<\/p><p>We will notify you by email and by a prominent notice on our Service before the change becomes effective, and we will update the \u00abLast Updated\u00bb date at the top of this Privacy Policy.<\/p><p>We encourage you to review this Privacy Policy for changes periodically. Changes to this Privacy Policy will be effective when posted on this page.<\/p><p><strong>Contact us<\/strong><\/p><p>If you have any questions about this Privacy Policy, you may contact us:<\/p><ul><li>By e-mail: dpo@topii.com<\/li><li>Visiting this page of our website: https:\/\/www.topii.com\/contact<\/li><\/ul>\t\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t","protected":false},"excerpt":{"rendered":"<p>Privacy Policy Last update: April 06, 2024 This Privacy Policy describes our policies and procedures regarding collecting, using, and disclosing your information when you use the Service. It also informs you of your privacy rights and how the law protects you. We use your personal information to provide and improve the Service. 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