1. Introduction
This app is developed and operated by Ishara Dilshan, and we take your privacy very seriously. This privacy policy details how we collect, use, and protect your information.
For further information, please contact us at the following contact details:
Developer Name: Ishara Dilshan
Contact Email: mohamed.aroos@gmail.com
2. Information we collect
When you use our apps, we or our partners (such as TopOn Advertising SDK) may collect the following information:
2.1 Information you provide directly
Contact information (such as email address);
Other information you provide when you communicate with us.
2.2 Information collected automatically
TopOn Advertising SDK may automatically collect the following information to provide personalized advertising services:
Device information: device model, operating system, unique device identifier (such as Android ID, advertising identifier);
Network information: IP address, operator information;
Application usage data: page visit records, click behavior, session duration.
3. How we use your information
The information we collect with TopOn Ad SDK will be used for the following purposes:
Provide personalized advertising experience;
Improve application functions and user experience;
Analyze usage behavior and optimize services;
Prevent fraudulent activities and protect system security.
4. Data Sharing
We do not sell your personal data, but may share it in the following circumstances:
Share with partners: We use TopOn Ad SDK to provide advertising services, and TopOn SDK may collect and process relevant data. Please refer to TopOn Privacy Policy for more details.
Legal requirements: If required by law or government, we will provide relevant information.
Service providers: Work with payment, data analysis or cloud storage service providers.
5. Data Security
We and TopOn SDK use industry-standard technology and management measures to protect your information from unauthorized access, disclosure or loss.
6. User Rights
You have the following rights to your data:
View or correct data: You can contact us at any time to view or update your data;
Refuse ad personalization: Disable ad personalization in device settings (such as turning off Android advertising identifier);
7. Children's Privacy
Our app is not intended for children under the age of 13. If we discover that we have collected children's information without their consent, we will delete it immediately.
8. Contact Us
If you have questions about the Privacy Policy or wish to exercise your rights, please contact us at:
Developer Name: Ishara Dilshan
Email: mohamed.aroos@gmail.com
9. Updates to the Privacy Policy
We may update this Privacy Policy from time to time. Please pay attention to this page and the TopOn official privacy policy, and we recommend that you check it regularly to understand the latest policies.
The following is the privacy policy of TopOn.
In order to further improve our privacy policy and services, we will revise this Privacy Policy from time to time. If this Privacy Policy is significantly modified, we will publish an announcement through the TopOn website before the new Privacy Policy takes effect.
Data protection and ensuring the trust of business partners and you are at the core of TopOn's business principles. Therefore, compliance with applicable data protection regulations is our important task. This policy has been updated and complies with the requirements of applicable data protection laws, including the EU General Data Protection Regulation ("GDPR"), the United States Children's Online Privacy Protection Act ("COPPA"), the California Consumer Privacy Act ("CCPA"), the Virginia Consumer Data Protection Act ("VCDPA"), the Colorado Privacy Act ("CPA"), the Utah Consumer Privacy Act ("UCPA"), the Connecticut Data Protection Act ("CDPA"), the Brazilian General Data Protection Law ("LGPD") and other laws and regulations related to personal information protection. If our cooperation with you is subject to the provisions of European data protection laws, TopOn is the data controller of your personal information under European data protection laws. For the purpose of this Privacy Policy, the processor ("Processor") under GDPR, VCDPA, CPA, CDPA and UCPA, the service provider ("Service Provider") under CCPA, and the "personal information processor" refers to the controller ("Controller") under GDPR, VCDPA, CPA, CDPA and UCPA, and the company ("Business") under CCPA.
2. How and why we collect user information
This Privacy Policy describes TopOn's information collection and use behavior in the following scenarios:
Based on the nature of the user's use of TopOn services or the services provided by any of TopOn's business partners, we may collect information directly or through our business partners (e.g., mobile application developers, programmatic advertising trading platforms, advertising aggregation platforms, advertising demand-side platforms, and traffic supply-side platforms). For example:
(1) When we provide traffic monetization services and mobile advertising aggregation tools to mobile application developers, mobile application developers will embed our SDK in their mobile applications, and we will obtain user information through the SDK;
(2) When we cooperate with programmatic advertising trading platforms and traffic supply-side platforms, programmatic advertising trading platforms or traffic supply-side platforms may share user information with us when they send advertising demands to our demand-side platforms;
(3) Our advertisers, advertising demand-side platforms, programmatic advertising trading platforms or the third-party attribution platforms they use will share user information with us;
In the process of providing TopOn services, we do not establish direct contact with users. We will obtain the user's authorization and consent for the collection and use of personal information through TopOn's business partners (such as mobile application developers using TopOn's SDK, programmatic advertising trading platforms, advertising aggregation platforms, advertising demand-side platforms, traffic supply-side platforms, etc.). In the cooperation agreement with TopOn's business partners, we have required them to promise and guarantee the legitimacy of the data source, and they will inform users of the specific circumstances of our processing of personal information in accordance with the requirements of applicable laws, and obtain the user's effective consent (obtain separate consent required by applicable laws when necessary), and ensure that users can revoke such consent at any time.
TopOn services may link to third-party websites, applications or other third-party content. Please note that we cannot control the processing of user information by third parties, and that third parties may have privacy protection regulations that are different from those described in this privacy policy.
When we collect personal information such as name and email address of business representatives of partners, our purpose is to communicate with them for business purposes, including necessary communication to fulfill the contract between us and partners.
3. Personal information we may collect
When you browse advertisements using TopOn services or use services provided by TopOn's business partners, we and/or our business partners may collect your information. App developers may choose to share their collected personal information with us through our SDK. For more information about how app developers collect, use, and share your personal information and whether you agree to the developer's use of your relevant personal information, please check the privacy policy of the relevant app developer. Please note that we will require our partners to obtain your full consent in advance for the personal information that may be collected and shared during the service process before using our services through our cooperation agreement.
When we collect information through the SDK, the types of information we collect may include:
Location Information
[Required information] IP address
[Optional information] Country, time zone and locale (country and preferred language)
Device/Advertising ID
[Required information] Android ID, OAID, IDFV, mobile advertising identifiers (such as Apple IDFA, Google Advertising ID and Amazon ID)
[Optional information] International Mobile Equipment Identity (IMEI), MAC address, International Mobile Subscriber Identity (IMSI)
Note: If you restrict your device or application from obtaining your device/advertising ID in accordance with Article 7 of this policy, we will not collect the corresponding information;
Device Information
[Required information] Device manufacturer, device model, device operating system information, device type, device screen information, device network information, hardware serial number, device sensor information, Limit Ad Tracking (LAT) status, phone boot time, phone user name summary, device storage capacity information
[Optional information]
CPU type, device battery information, device volume and font size, whether it is an emulator, system build type, system build label, system build user, radio firmware version, system boot program version number, hardware name, host address, system development code, system source control version number, device display version number, device substrate name
Application Information
[Required information] TopOn partner's application package name, application version and features, SDK version
[Optional information]
Whether it is downloaded from the app store, list of installed applications;
Special note: For download ads, we will determine whether you have installed the product promoted by the ad before displaying it. If you have installed it, we will not display the ad (we call it display filtering), and notify the server to no longer return the corresponding ad the next time your device requests an ad, thereby improving the user experience. TopOn will only report the relevant information of the "display filtered" ads in this scenario, and will not collect information about other installed apps.
Usage Data
[Required Information] When you interact with the advertisements we promote, we will collect information about your interaction with the advertisement, such as browsing or clicking on the advertisement.
Additional Information
[Optional information] Device event information (such as system crashes, system activity), timestamp, date and time you made the request, source URL, user agent.
Permission application
Special note: If you use a developer application that integrates TopOn SDK, TopOn SDK will apply for corresponding permissions through the developer application. The developer should inform you of TopOn SDK, subject name, type and purpose of processing personal information, privacy policy, etc., and obtain your consent before using TopOn SDK to carry out relevant business functions. Because different SDK versions may have certain differences in the information fields collected and whether they are optional, the specific collection situation shall be based on the SDK version connected to the developer application you actually use. Developers must ensure that users agree to the "Privacy Policy" before initializing TopOn SDK. TopOn SDK users will only collect information and apply for permissions after agreeing to the "Privacy Policy".
List of Android operating system application permissions:
INTERNET Mobile network request
ACCESS_WIFI_STATE Get WIFI network changes
AD_ID Mobile Google Advertising ID
(2) When you browse or click on an advertisement promoted by us, download and use the product promoted by the advertisement (such as an application), we will collect the following information from advertisers, advertising demand-side platforms, programmatic advertising trading platforms or the third-party attribution platforms they use:
Location Information
[Required information] IP address
[Optional information] Country, city;
Device/Advertising ID
[Required information] IMEI, OAID, IDFV, mobile advertising identifiers (such as Apple IDFA, Google Advertising ID and Amazon ID), MAC address;
Device Information
[Required information] Device manufacturer, device model, device operating system information, device language, device type, device network information, device operator;
Application Information
[Optional information] TopOn partner's application package name and application version;
Usage Data
[Required information] Timestamp of the installation event or other event.
Additional Information
【Optional information】User agent;
(3) When TopOn acts as a demand-side platform (“DSP”), programmatic advertising trading platforms and traffic supply-side platforms may transmit personal information to us through technologies such as APIs, which may include:
Location information
[Required information] IP address
[Optional information] Country, time zone and locale (country and preferred language);
Device/advertising ID
[Required information] International Mobile Equipment Identity (IMEI), Android ID, OAID, IDFV, mobile advertising identifiers (such as Apple IDFA, Google Advertising ID and Amazon ID), MAC address;
Device information
[Required information] Device screen information, device manufacturer, device model, device operating system information, device type, device network information, Limit Ad Tracking (LAT) status;
Application information
[Required information] TopOn partner's application package name, application version and features;
Usage data
[Required information] When you interact with the ads we promote, we will collect information about your interaction with the ads we promote, such as browsing and clicking on the relevant information of the ads;
Other information
[Optional information] Information transmitted by other advertising information exchange platforms or intermediary platforms, user agents.
(4) For partners using Google Ad Manager monetization services, in order to improve our service capabilities, we will collect the advertising performance data related to your Google Ad Manager monetization through Google API Services and display it on your account page in our backend, subject to your explicit authorization. The fields and scope of the data we obtain will be subject to your authorization.
We promise that the use of Google API Services, the collection and use of the collected information will comply with the Google API Service User Data Policy (https://developers.google.com/terms/api-services-user-data-policy#additional_requirements_for_specific_api_scopes), including the restrictive use requirements announced by Google policies. You can learn about all data processing activities involved in our service process through this policy (https://www.toponad.com/en/privacy-policy).
(5) When we provide TopOn services to our business partners, we may collect the name, position, email address, contact address, and user name and password, and IP address used by the contact person who uses the TopOn service on behalf of such business partner.
We will cooperate with partners with good reputations such as programmatic advertising trading platforms, advertising demand-side platforms, and traffic supply-side platforms. After receiving an advertising request with your personal information, the advertising information exchange platform or the media platform will transfer your personal information to TopOn to build your profile, personalize your advertising experience, and then serve you advertising on the Internet, if permitted by law.
Exemption from obtaining consent for processing personal information in accordance with the law
In accordance with the requirements of applicable laws, we have contractually agreed that our business partners (such as mobile application developers and advertisers using TopOn's SDK) will obtain the consent of users or their employees for the processing described in this Privacy Policy on our behalf. Users or their employees may withdraw their consent at any time. Please also understand that, in the following circumstances, according to laws and regulations, we do not need to obtain your authorization and consent to process your personal information:
(1) Necessary to conclude or perform a contract according to your request;
(2) Necessary to perform statutory duties or statutory obligations, such as statutory duties or statutory obligations directly related to national security, national defense security, criminal investigation, prosecution, trial and execution of judgments;
(3) Necessary to respond to public health emergencies, or to protect the life, health and property safety of natural persons in an emergency;
(4) Process personal information within a reasonable scope for news reporting, public opinion supervision and other activities for the public interest;
(5) Process your personal information that you have disclosed yourself, or other personal information that has been legally disclosed (such as legal news reports, government information disclosure and other channels) within a reasonable scope;
(6) Other circumstances stipulated by laws and regulations.
Special note: According to the law, if the information cannot be identified to a specific individual alone or in combination with other information, it does not constitute personal information. When your information can be used to identify you alone or in combination with other information, or when we use data that is not linked to any specific individual in combination with your personal information, we will treat it as your personal information and process and protect it in accordance with this Privacy Policy.
If you are located in the European Economic Area, we will use your personal information based on the "legitimate interests" stipulated in the GDPR, if necessary. Our legitimate interests include the following: monitoring and preventing fraud, eliminating technical obstacles to system operation, and ensuring the correct and secure operation of systems and processes.
About sensitive personal information
Sensitive personal information generally refers to personal information that, once leaked or illegally used, is likely to infringe on the personal dignity of a natural person or endanger personal or property safety. Its scope will vary according to the provisions of different applicable laws.
We will not collect your sensitive personal information without your consent. Our business partners will transfer or authorize us to process your sensitive personal information to us only after fully informing you of the necessity of processing sensitive personal information and the impact on personal rights and interests and obtaining your consent in accordance with the law.
4. How we use users’ personal information
We use users’ personal information as follows:
Types of Personal Information
Usage
Including all types of personal information described in Article 3, Paragraphs (1) to (3) of this Privacy Policy
Based on device information, your device will be identified by us from other devices, and we will use your device information to place advertisements on your device in an automated decision-making manner. We use de-identification technology and recommendation algorithms based on machine learning, model prediction, etc. to generate labels, features, and profiles for you or your interests, and based on the profiles and the calculation results of the recommendation algorithms, we will place personalized advertisements or behavioral advertisements related to you that match your interests, preferences, approximate location, or other characteristics. Our recommendation algorithms do not identify the real identity of a specific natural person.
We will also perform secondary processing on aggregated data in accordance with data security technologies such as de-identification and anonymization commonly implemented in the industry to form a database of features and labels that cannot identify the real identity of a specific natural person, conduct group analysis, and optimize algorithm training models to better understand and analyze your usage trends and hobbies, so as to improve the quality of our TopOn services and develop our new products.
Contact information, etc. includes all types of personal information described in Article 3 (4) of this Privacy Policy
We may collect and use the personal information of users who use TopOn services on behalf of our partners (such as employees of our mobile application developers or advertisers) for business contacts with them or direct marketing to them (such as sending marketing emails).
Sensitive personal information
We will not collect your sensitive personal information without your consent.
Our business partners will transfer or authorize us to process your sensitive personal information only after fully informing you of the necessity of processing sensitive personal information and the impact on personal rights and interests and obtaining your consent in accordance with the law.
5. How we share and disclose users’ personal information
Subject to applicable laws, we may share personal information with third parties for the following purposes and scenarios:
(1) Sharing
When we purchase advertising traffic from mobile app developers to provide them with monetization services, or when we act as a programmatic advertising trading platform or traffic supplier platform, we may share users’ personal information with our business partners in order to fulfill our contractual obligations to our business partners, including reporting to them the performance and effectiveness of the ads that users interact with, including statistics on traffic quality, and for anti-fraud purposes. The personal information we share is personal information related to the performance and effectiveness of ads, such as device information, clicks, impressions, installations, or activations. These business partners may use this user’s personal information to count users’ interactions with ads/websites, evaluate the performance and effectiveness of ads that users view or interact with, identify areas of interest to users, better understand website and app traffic usage or user behavior to improve their services. Our business partners’ use of the information we disclose is subject to their privacy policies.
We may also use third-party technical service providers (such as cloud service providers) to process personal information in order to ensure the correct and appropriate operation of systems and processes and to store data.
We may also share aggregated or anonymized information with other third parties in accordance with the terms of this Privacy Policy.
Third-party type
Advertisers, advertising agencies, advertising attribution service providers, advertising demand-side platforms, and TopOn’s affiliated companies
Information Type
① Location information: IP address;
② Device/advertising ID: International Mobile Equipment Identity (IMEI), Android ID, OAID, IDFV, mobile advertising identifiers (such as Apple IDFA, Google Advertising ID and Amazon ID), MAC address;
③ Device information: device manufacturer, device model, device operating system information, device type, device screen information, device battery information, device volume and font size, whether it is a simulator, device network information, device sensor information, Limit Ad Tracking (LAT) status, mobile phone power-on time, mobile phone user name summary;
④ Application information: TopOn partner's application package name, application version and features, whether it is downloaded from the App Store, SDK version;
⑤ Usage data: When you interact with the advertisements we promote, we will collect your interaction with the advertisement, such as browsing and clicking on the relevant information of the advertisement;
⑥ Other information: user agent.
Purposes and methods of processing
①Used for advertising attribution;
②Used for monitoring the quality of advertising delivery;
③Used for precise delivery
In particular, if a mobile app developer only chooses to use our aggregation tool services but does not choose our programmatic advertising trading services or does not sell its in-app advertising space to us, other advertising SDKs integrated in our SDK need to obtain the consent of the mobile app developer, and the relevant information will be collected by the third-party advertising SDK.
(2) Disclosure
We may disclose your personal information in accordance with the law to comply with a subpoena, other similar legal process or government request; or when we believe that disclosure of relevant personal information is required by law or necessary to protect our rights, property, the rights, property and safety of others, we may disclose your personal information, including disclosure to consultants, law enforcement agencies, and judicial supervision agencies. We may also transfer your personal information to a third party that acquires some or all of our property, equity, or acquires some or all of our business by merger, acquisition, reorganization or other means.
For the purposes of this Privacy Policy, our affiliates may also obtain users' personal information.
6. International Transfer
If you are located in the European Economic Area, the information we collect about you will be transferred to countries outside the European Economic Area or will be remotely accessed in such countries, including the United States and other countries that have not been determined by the European Commission to provide an adequate level of protection for personal information, but we will provide appropriate protection for such personal information in accordance with the requirements of applicable laws. If required by law, our business partners (such as mobile app developers and advertisers using TopOn's SDK) will obtain your consent to transfer your personal information outside the European Economic Area, including to TopOn, TopOn's affiliates or other recipients under this Privacy Policy. You can withdraw your consent at any time.
7. Your information rights
If you are located in the European Economic Area, you have the following rights (subject to a few exceptions provided for by the GDPR): (i) access, modify or delete personal information; (ii) limit or refuse to process your personal information; and (iii) request an electronic copy of your personal information to another person or third party. At the same time, you have the right to lodge a complaint with the local data protection authority in the European Economic Area regarding the processing of your personal information.
If you are a resident of California, USA, you have the following rights from January 1, 2020:
(i) exercise relevant consumer rights, such as: requesting to know, disclose, obtain and delete data collected in the past 12 months by sending an email to privacy@toponad.com; and (ii) requesting a ban on the sale of your data.
If you are a resident of Virginia, United States (effective January 1, 2023), or if you are a resident of Colorado or Connecticut, United States (effective July 1, 2023), you may exercise the following personal information rights with respect to us:
Confirmation of whether we are processing your personal information and access to that personal information;
Correct inaccuracies in your personal information;
Delete your personal information;
Obtain a copy of the personal information you have provided to us; and
Request that we object to processing your personal information for (i) personalized advertising, (ii) sale of your personal information, or (iii) profiling that has a significant legal or similar impact on you.
As provided in the VCDPA, CPA, and CDPA, you have the right to exercise these rights without discrimination.
You may exercise your personal information rights described above (i) by sending a written request to privacy@toponad.com; and (ii) by clicking on this link to request an opt-out of personalized advertising, an opt-out of the sale of your personal information, or an opt-out of profiling that has a significant legal or similar impact on you. If you fail to provide us with effective feedback when exercising the above rights, we may refuse to exercise your rights. If you disagree, you can further send a written complaint to privacy@TopOn.com.
If you are a resident of Utah, USA, starting from December 31, 2023, you can exercise the following personal information rights to us:
Confirm whether we are processing your personal information and access it;
Delete your personal information;
Obtain a copy of the personal information you provided to us; and
Request to refuse us to process your personal information for the following purposes: (i) personalized advertising, or (ii) sell your personal information.
As provided by the UCPA, you have the right to exercise the above rights without discrimination.
Personalized advertising settings
Regardless of the country or region you are located in, you can opt out of interest-based advertising in the following ways.
Guidelines for opting out
You can choose to opt out of receiving interest-based advertising or behavioral advertising sent by TopOn on devices that support relevant functions by following the guidelines below.
Your iOS mobile device may provide a "Do Not Track Ads" setting. On Android devices, your settings may allow you to "stop receiving interest-based ads." If you have enabled this setting on your device, TopOn will not use the application information collected from your device to infer your interests or provide advertising services to the target device based on your inferred interests.
Your mobile web browser may also provide a "Do Not Track" browser setting. If your browser has enabled this setting, TopOn will not use the mobile web browser information collected from your browser to infer your interests or provide advertising services to the target device based on your inferred interests. If you have any questions about your information rights, please contact privacy@toponad.com.
8. Security of User Personal Information
Protecting the security of your personal information is our top priority. We will take strict security measures to prevent your personal information from being accessed, used, disclosed or destroyed without authorization. We will take physical, technical and administrative measures that comply with relevant laws and industry standards. For example, we will use firewalls, encryption technology and other automated software designed to prevent fraud and identity theft; we will only store information in devices and places that can provide a high degree of protection. We will also strictly monitor data access to the perimeter and building entrances through video and other electronic surveillance methods.
I will minimize the storage of sensitive information on our servers to protect your privacy. We also require our partners to protect user data in contracts.
TopOn may retain information about you collected from our business partners to provide services, conduct internal analysis, comply with legal obligations, resolve disputes, and perform contracts (such as settlement). We will only retain your personal information when necessary, and we will retain your personal information collected in accordance with this Privacy Policy for no more than 2 years. The criteria for determining the retention period include: (i) the length of time personal information needs to be retained to provide services and business operations; (ii) the type of personal information collected; and (iii) whether we are subject to legal, contractual or other similar obligations to retain data (for example: mandatory data retention laws, government requirements to retain data related to investigations, or data that must be retained for litigation or disputes).
9. Protection of Minors
TopOn services are mainly for adults. We do not actively or deliberately collect information about minors, nor do we make user profiles or personalized recommendations for minors. In the personal information collection scenarios we disclosed, we use device information to distinguish specific information subjects rather than age dimensions. In the scenario where the partner transmits and shares data with us, we explicitly require our partners to formulate special policies for the protection of minors' information and adopt stricter data desensitization and encryption technologies to protect minors in accordance with the actual situation of their own products and services.
If the end user is a minor as stipulated by applicable laws, please be sure to read the privacy policy of the developer or advertiser application and this privacy policy carefully under the supervision and guidance of your parents or other guardians before using the developer application that has integrated TopOn products and services or the advertiser application that cooperates with TopOn for advertising, and use the application or provide personal information with the consent of the guardian.
We protect the personal information of minors in accordance with the provisions of applicable laws and regulations, and will only collect, use, store, share, transfer or publicly disclose the personal information of minors when permitted by law, with the explicit consent of parents or other guardians, or when necessary to protect minors. If we find that the personal information of minors has been collected without the prior verifiable consent of parents, we will take measures to delete the relevant information as soon as possible.
If you are the parent or other guardian of a minor, when you have questions about the personal information of the minor you are protecting, please contact us through the contact information disclosed in this privacy policy.
If you are a user in the United States, we guarantee compliance with the Children's Online Privacy Protection Act (COPPA). If the applications of our business partners (for example, application developers) are targeted at children under the age of 13, they need to set the relevant COPPA settings for the application on the TopOn platform when using TopOn services, so that TopOn can ensure that the processing of the persistent identifiers collected from the users of the application complies with the provisions of COPPA, including not being used to deliver behaviorally targeted advertisements or to track users for this purpose. In addition, we will not intentionally collect other personal information (such as accurate geographic location information) from applications that we know are targeted at children under the age of 13.
If parents or guardians find that their children have provided us with their personal information without consent, parents or guardians should contact us in a timely manner. We will take reasonable measures to ensure that such information is deleted from our files.
10. Promotional Marketing
If you are our business partner, we may periodically provide you with information about our products and services and content that may be of interest to you by email. If relevant laws require us to obtain your consent before sending you marketing information, we will only send you relevant marketing information after obtaining your consent.
If you do not wish to receive such marketing information, you may unsubscribe at any time by following the instructions provided in the marketing information or by sending an email to privacy@toponad.com requesting not to receive such information anymore.
TopOn Website Privacy Policy
1. Introduction
This TopOn Website Privacy Policy applies to the collection and use of information on the website, including information collected and used by TopOn when you browse and use the TopOn website. If the provisions of European data protection laws should apply here, TopOn is the data controller of your personal information under European data protection laws. If you have any questions, comments or suggestions, please contact us at the following contact information: Email: privacy@toponad.com
2. Information We Collect
When you visit the TopOn website, the personal information you actively provide (such as: name, date of birth, personal identification number, address, telephone number, email address, occupation, education background, work experience and other relevant information) will be collected, and some information that you do not actively provide, such as browser type, domain name, IP address, web pages visited and the length of time you browse the web using different technologies and methods, including IP addresses, Cookies, Internet tags and browsing data collection. In order to improve the quality of our service, we need your personal information to meet your personal needs and provide better services. TopOn has the right to take measures to verify the accuracy of the information you provide. If the information you provide is the personal information of others, we will assume that you have obtained the permission of others. Information transmitted on the TopOn website may be non-confidential, so the information you transmit may be read or intercepted by others.
3. How we use your personal information
Based on our legitimate interests, you may need to provide us with your personal information for the following purposes: (i) providing you with TopOn products, services or related information; (ii) registering you for related events or training; (iii) contacting and responding to your requests and inquiries; (iv) business management, including data analysis; (v) providing you with personalized access services and assistance when using the website; or (vi) helping us understand our users and improve our website.
We will periodically provide you with information about our products and services and content that may be of interest to you via email. If applicable law requires us to obtain your consent before sending you marketing information, we will only send you relevant marketing information after obtaining your consent.
If you do not want to receive such marketing information, you can unsubscribe at any time by following the instructions provided in the marketing information or send an email to privacy@toponad.com to request not to receive such promotional information.
4. Disclosure of your personal information
We will share your personal information with third parties other than TopOn affiliates in accordance with applicable laws.
We may hire third parties to provide services for us, including companies that assist in the development and operation of the TopOn website at the program and technical level, service providers that provide technical services to assist in analyzing website usage, and email service providers, and such third parties may obtain your personal information. Our affiliates may also obtain your personal information through the TopOn website or in connection with the TopOn website for the purposes set forth in this Privacy Policy.
We may also share aggregated or anonymous information with other third parties in accordance with the terms of this Privacy Policy.
For the purposes of this Privacy Policy, our affiliates may also obtain users' personal information.
The network servers used in the operation of the TopOn website automatically identify (your) computer based on the IP address. However, once you leave the TopOn website, we will not be able to identify (your) computer based on the IP address. If we believe that you are attempting to or have abused or damaged the website, we will investigate and cooperate with relevant law enforcement agencies to safeguard our legitimate rights and interests.
At the same time, we will provide your personal information as required or permitted by law in accordance with court subpoenas, other similar legal proceedings or government requests; or we believe that such disclosure is necessary in accordance with legal requirements or to safeguard the legitimate rights and interests and security of us and/or other third parties (including consultants, law enforcement agencies, and judicial supervision agencies). We may also transfer your personal information to a third party that acquires some or all of our assets, shares, or that succeeds to some or all of our business by merger, acquisition, reorganization or otherwise.
5. International transfers
If you are located in the European Economic Area, personal information collected from you, including information collected from the TopOn website, will be transferred to countries located outside the European Economic Area, including Singapore, where the TopOn website servers are located, and other countries that have not been determined by the European Commission to provide an adequate level of protection for personal information. You hereby expressly consent to the transfer of your personal information to recipients located outside the European Economic Area as described in this Privacy Policy, including to TopOn, TopOn's affiliates and other recipients specified in this Privacy Policy.
6. Your information rights
You have the right to access, modify, amend or delete your personal information that we may have collected. To exercise these rights, please contact privacy@toponad.com.
If you are located in the European Economic Area, you will have the following rights (subject to limited exceptions): (i) request access to, modification or deletion of your personal information; (ii) restrict or object to the processing of your personal information; and (iii) request an electronic copy of your personal information to be provided to another person or third party. You also have the right to lodge a complaint with your local data protection authority in the European Economic Area regarding the processing of your personal information.
If you are a resident of California, United States, as of January 1, 2020, you have the following rights:
(i) exercise relevant consumer rights, such as requesting to know, disclose, access, and delete data collected in the last 12 months by emailing privacy@toponad.com; and (ii) requesting an opt-out from the sale of your data: Do Not Sell My Data.
If you are a resident of Virginia, United States (effective January 1, 2023), or if you are a resident of Colorado or Connecticut, United States (effective July 1, 2023), you may exercise the following personal information rights with us:
Confirmation whether we are processing your personal information and access to it;
Correct inaccuracies in your personal information;
Delete your personal information;
Obtain a copy of the personal information you have provided to us; and
Request that we object to processing your personal information for the following purposes: (i) personalized advertising, (ii) selling your personal information, or (iii) user profiling that has a significant legal or similar impact on you.
As provided by the VCDPA, CPA and CDPA, you have the right to exercise the above rights without discrimination.
You can exercise your personal information rights above by (i) sending a written request to privacy@toponad.com; and (ii) clicking on this link to request to prohibit personalized advertising, prohibit the sale of your personal information, and prohibit user profiling that has a significant legal or similar impact on you. If you fail to provide effective information for us to provide effective feedback when exercising the above rights, we may deny your exercise of your rights. If you disagree, you can further send a written complaint to privacy@toponad.com.
If you are a resident of Utah, starting December 31, 2023, you can exercise the following personal information rights with us:
Confirm whether we are processing your personal information and access that personal information;
Delete your personal information;
Obtain a copy of the personal information you provided to us; and
Request to refuse us to process your personal information for the following purposes: (i) personalized advertising, or (ii) sale of your personal information.
As provided by the UCPA, you have the right to exercise the above rights without discrimination.
7. Security of your personal information
We are committed to protecting the security of your personal information. We use a variety of protection technologies and procedures to protect your personal information and prevent your personal information from being obtained, used or disclosed without authorization. We will only retain your personal information as long as necessary, and we will only retain your personal information collected on the website for one year regardless of the method.
8. Protection of Minors
This website does not intentionally collect personal information from minors. Any personal information of minors you provide must be approved by the minor's parents or guardians in advance. The definition of minors is defined by the law applicable to this Privacy Policy.
9. Use of Cookies and Other Tracking Technologies
When you visit the TopOn website, TopOn may use cookies or other technologies (collectively referred to as "Cookies") to collect your personal information.
10. External Websites and Links
This website may contain links and instructions to websites owned or operated by third-party vendors and other third parties ("External Websites"). TopOn is not responsible for the effectiveness of External Websites and the content of External Websites (including any webcasting or any other form of transmission and reception of content on any External Website). If you have any questions about the relevant links or the content on the External Website, please contact the administrator of the External Website. If a third party has informed TopOn that it will link TopOn's homepage to the third party's website and TopOn has not refused, TopOn allows the third party to link to TopOn's homepage. TopOn reserves the right to unilaterally revoke the above consent at any time, including links to its homepage. Any external website provided on this website is only for your convenience. Any link or indication contained in this website does not mean approval of the external website.
11. Copyright
All website content, design, text, graphics, images, logos, buttons, icons, interfaces, audio and video, and all permutations and combinations of the above are the exclusive property of TopOn or its respective content providers and are protected by Hong Kong Special Administrative Region and international copyright laws. All software used on the website is the property of TopOn or its respective software providers and is protected by Hong Kong Special Administrative Region and international copyright laws and other relevant laws and treaties. Website users shall not send/upload any content that infringes on the copyright or other intellectual property rights of others to this website.
12. Trademarks
All trademarks, service marks and trade names (collectively referred to as "marks") used on the website are exclusive to TopOn. Such logos shall not be used on any non-TopOn product or service, or any other product or service that may cause consumer confusion or in any way discredit or discredit TopOn.
13. Online Behavior
If TopOn believes that any individual restricts or prohibits others from using this website, TopOn has the right to prohibit such behavior. You agree to use this website only for lawful purposes and agree not to carry out the above prohibited behavior. You agree not to upload or forward any illegal, damaging, threatening, insulting, harassing, defamatory, vulgar, obscene, sexually suggestive, blasphemous, hateful, racially discriminatory, regionally discriminatory or any other type of negative information to this website, including but not limited to any information that incites illegal behavior, such as any behavior that constitutes a criminal offense, civil liability or other violation of applicable local, state, domestic or international laws.
14. Termination of Use
Based on any violation of relevant laws, this Privacy Policy, or any violation of the interests of other users, third parties, retailers, sponsors, licensors, service providers or the website, TopOn may, at its sole discretion, terminate or suspend your access to all or part of the website without further notice or liability.
In view of the rapid development of network technology and the update of privacy data-related regulations, we will update this Privacy Policy from time to time. All revisions will be posted on the website www.toponad.com.