Privacy Policy

Last updated: October 2024

Cookies and other identifiers are portions of code that are installed in your browser. This Privacy Policy outlines how Top Product Zone, along with its subsidiaries and affiliates (collectively referred to as the “Company,” “we,” “us,” or “our”), collects, stores, discloses, or otherwise processes personal information (“Personal Information”) from individuals who use or access our products, services, websites, tools, features, and functionalities (collectively, the “Services”), as well as those who participate in recruitment processes or engage with us as partners. By using our Services, you agree to the terms of this Privacy Policy and consent to the collection and processing of your Personal Information as described herein.

This Privacy Policy governs how we collect and process your Personal Information. “Personal Information” (as defined by applicable US privacy laws) or “Personal Data” (as defined by the GDPR) refers to any data related to an identified or identifiable individual. An identifiable person is someone who can be identified directly or indirectly, particularly by reference to an identifier such as a name, location data, origin, an online identifier, or by one or more factors specific to their economic, cultural, or social identity. While you are not legally required to provide Personal Information, certain Services may require it. If you choose to withhold or delete requested Personal Information, access to some Services may be limited. If you do not agree to these terms, please refrain from using the Services.

We understand the importance of privacy. This Privacy Policy applies to all services, tools, features, and functionalities provided by the Company or its affiliates, and it explains how we handle personally identifiable information (PII) collected during the use of our Services. For any questions regarding this Privacy Policy, please contact us at privacy@topproduct.zone. Additionally, please review our Terms of Use at https://topproduct.zone/terms, which outline the terms and conditions for using our Services.

A. Types of Personal Information We Collect, Purposes, and Methods of Collection

To provide and operate our Services, we may collect and process the following types of Personal Information:

A1. Contact Information

When you contact us via the „Contact Us“ form on our website, apply for partnership inquiries, or otherwise use our Services, you may voluntarily provide your name, company name, business email address, telephone number, or other details. This information is processed to deliver the Services, ensure their security, and communicate with you, including sending newsletters or promotional offers from us or our partners (as detailed in section A4).

A2. Information from Third Parties

If we promote our Services through third-party platforms such as social networks or search engines, we may receive Personal Information, like IP addresses, online identifiers, and other pseudonymous identifiers, regarding your interactions with our ads or Services. We use this data to provide more relevant ads and improve our Services.

A3. User Communications

When you communicate with the Company via email or other methods, we may retain those communications to process inquiries, respond to requests, and improve our Services. Additionally, this information may be used to send you reminders, updates, newsletters, and promotional communications. You will be required to opt-in to receive communications from us, and you can revoke your consent anytime by contacting us via the Website or by using the “unsubscribe” or “opt-out” links in our emails.

A4. Technical Information

When you use our Services, we automatically collect technical information from your browser, including your online/offline status, IP address, geolocation data (country and city), browser identifiers, internet service provider, connection speed, search history, browser type, and software/hardware attributes. Some of this data may be considered Personal Information. Our systems record and store this data, including through cookies and tracking technologies (see Section G). The Company uses this data to understand user trends, improve the usability of our Services, and detect fraud or abuse.

A5. Legal and Compliance

We may use Personal Information to prevent illegal activities such as fraud, misappropriation, infringement, identity theft, or misuse of the Services. We also use this data to enforce our legal rights, protect the security of our databases, and manage potential legal liabilities.

B. Legal Grounds for Processing Personal Information

Where applicable, we rely on one or more of the following legal grounds to process your Personal Information:

B1. Consent

You have provided consent for the processing of your Personal Information for specific purposes, including accepting our website’s cookie notice and consent mechanism to enable tracking technologies. You may withdraw your consent at any time through the cookie preference settings (further details are available in Section G) or by contacting us at privacy@topproduct.zone.

B2. Contractual Necessity

Processing your Personal Information is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into a contract.

B3. Legitimate Interests

We process Personal Data in line with our legitimate interests. This may include improving and enhancing our Services, understanding how our Services are used, optimizing marketing and advertising, ensuring the security of our Services, providing customer support, and enforcing our terms and conditions. It also covers protecting or defending our rights and the integrity of our Services.

B4. Legal Obligation

Processing is required to comply with legal obligations to which we are subject.

C. Categories of Recipients and Purposes of Disclosure

We may share your Personal Information internally within our organization or externally with third parties that assist in maintaining, enhancing, or delivering our Services (for example, we may share data with AWS Inc., which provides us with cloud storage services). We ensure that these parties process Personal Information in accordance with this Privacy Policy, applicable laws, and appropriate security safeguards, especially concerning cross-border transfers of data.

The categories of third-party recipients include:

C1. Internal Sharing within Our Group

We may share your Personal Information within our company group when necessary for administrative, management, or other business-related reasons, such as operating and offering our Services, communicating with you, and ensuring the proper functionality of the Services.

C2. Service Providers

We may disclose both Personal and non-Personal Data to third-party service providers and affiliated companies that perform services on our behalf, including hosting, storage, analytics, advertising, marketing, database management, user engagement, and cybersecurity. Additionally, we may share this data with legal, business, and financial advisors.

C3. Advertising Partners

We collaborate with third-party advertisers to display ads on our Services or manage our advertising on external platforms. These advertisers use tracking technologies to collect information about your activities on our Services and across other websites or apps to provide you with ads tailored to your interests. For more details on how we and our advertising partners use tracking technologies, please see the ‚Cookies‘ section below.

C4. Legal and Regulatory Bodies

In certain cases, we may disclose your Personal Information if we believe, in good faith, that such disclosure is necessary to enforce our policies, manage liabilities, defend against third-party claims, protect the security of our Services, or safeguard the rights and property of the Company. Additionally, we may release your information in response to verified requests from legal or regulatory authorities related to terrorism, criminal investigations, or similar illegal activities that may involve legal risks.

C5. Mergers, Sales, or Acquisitions

We may disclose Personal Information in connection with mergers, sales, transfers of assets, investments, acquisitions, bankruptcies, or other corporate transactions with any public, private, foreign, or local entity.

D. Safeguarding Personal Information and Retention Practices

D1. Data Retention

We will retain Personal Information for as long as necessary to fulfill the purposes for which it was collected or to comply with any legal, regulatory, or ethical requirements. Additionally, we may retain Personal Information to meet audit, compliance, and best-practice standards for business operations. Once the retention period has passed, Personal Information will either be deleted or anonymized. Non-personal, anonymized metadata and statistical data related to the use of our Services will be retained for as long as deemed necessary by the Company.

D2. Security Measures

We adhere to widely accepted industry practices to protect Personal Information from unauthorized access, alteration, disclosure, or destruction. However, since no method of data transmission over the Internet or electronic storage is entirely secure, we cannot guarantee the absolute security of your Personal Information or any content transmitted through our Services. Therefore, we urge you to exercise caution when sharing Personal Information, as any transmission is done at your own risk.

E. Cross-Border Data Transfers

E1. Hosting and Processing Locations

The servers that host and process our Services may be located outside the country from which you access them, and possibly outside your country of residence. Some instances of data collection and sharing outlined in this Privacy Policy may involve transferring your Personal Information to countries with varying levels of privacy protection. Despite these transfers, Top Product Zone is dedicated to safeguarding your Personal Information in accordance with relevant legal and privacy standards. We employ appropriate legal mechanisms and contractual agreements to ensure your data remains protected in any jurisdiction where it is transferred.

E2. Data Transfers Outside the EEA or UK

When transferring Personal Information outside of the European Economic Area (EEA) or the United Kingdom, and where no European Commission Adequacy Decision exists for the destination country, we will implement appropriate safeguards, such as the use of European Commission-approved Standard Contractual Clauses (see https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj), or other approved mechanisms, such as the EU-US Data Privacy Framework, where applicable.

F. Your Data Rights

Depending on your location, you may exercise certain rights regarding your Personal Information by contacting us at privacy@topproduct.zone. We will handle your requests in compliance with applicable laws, including verifying your identity and applying relevant legal exceptions. Please note that exercising some of these rights may impact your application if you are a candidate. We do not use automated decision-making related to your Personal Data in the context of our Services.

F1. Right to Access and Correction

You have the right to know what Personal Information we collect about you and ensure that it is accurate and relevant for the purposes it was collected. You may request access to and a copy of your Personal Information, as well as request corrections if the data is inaccurate, incomplete, or outdated.

F2. Right to Erasure, Restriction, or Objection to Processing

In certain circumstances, you may have the right to request the deletion of your Personal Information or restrict its processing (except for storage purposes). You can also object to the processing of your data.

F3. Right to Withdraw Consent

If we process your Personal Information based on your consent, you have the right to withdraw that consent at any time. Withdrawing consent will not affect the legality of the processing conducted before you withdrew consent.

F4. Right to Data Portability

Where technically feasible, you have the right to request that your Personal Information be transferred to another service provider in line with your right to data portability.

F5. Right to Opt-Out of Behavioral Advertising

You have the right to opt-out of the „sharing“ of your Personal Information for cross-contextual behavioral advertising, also known as „interest-based advertising“ or „targeted advertising“ (as defined under the CCPA).

F6. Right to Non-Discrimination

You have the right not to face unlawful discrimination for exercising any of the above rights.

Please be aware that some of these rights may only apply in certain situations, and all are subject to legal limitations. For instance, where fulfilling your request would negatively impact other individuals, our trade secrets, intellectual property, or where overriding public interests are involved, or where we are required by law to retain your Personal Data.

For residents of the EU and UK: If you believe we have violated data protection laws, you have the right to file a complaint with the relevant data protection authority in your country of residence or with the UK ICO, as applicable.

Please note that only you or a person legally authorized to act on your behalf may make a request concerning your Personal Information. To designate an authorized agent, the agent must provide sufficient information to verify their authority to act on your behalf.

In some jurisdictions, you may have the right to appeal a decision related to your request. Appeals should be sent to privacy@topproduct.zone.

G. Use of Cookies

G1. Temporary and Persistent Cookies

To collect the data described in this policy, we may use temporary cookies that remain on your browser for a limited period. We may also use persistent cookies that stay on your browser until the Company’s Services are removed. These cookies help us manage and maintain the Services, as well as record your interactions with them. Cookies cannot be used to identify you personally. They are small files transferred to your computer’s hard drive through your browser, allowing our systems to recognize and remember certain information. Cookies do not harm your browser. Most browsers allow you to block cookies, but doing so may prevent you from using some features of the Services. You can also configure most browsers to notify you when a cookie is received, giving you the option to accept or decline it.

Additionally, we may use web beacons (also called „gifs“) in our Services or emails to collect information. Web beacons help deliver cookies, count visits, and determine whether an email has been opened and acted upon. For more information on our use of cookies, please refer to our Cookie Policy: Cookie Policy link. You can change your cookie preferences by clicking here.

H. Minors‘ Data

We do not knowingly engage with or collect Personal Information from individuals under the age of majority („Minors“) without parental or legal guardian consent. By using the Services, you confirm that you are at least the age of majority in your state, province, or country of residence. If you suspect that a Minor’s Personal Information has been provided to us without the necessary consent, please contact us, and we will take steps to delete the information from our databases.

I. Third-Party Websites and Services

Our Services may contain links to third-party websites or services. We are not responsible for the privacy practices of these third parties. We encourage you to be cautious and review the privacy policies of any third-party websites, services, or applications you interact with. This Privacy Policy only applies to our Services.

J. Additional Information for U.S. Users

The following section outlines key information for U.S. residents. These rights apply based on the privacy laws in your state or jurisdiction and are available as determined by applicable law.

A. Collection, Use, and Sharing of Personal Data

Over the past 12 months, we have gathered the following categories of Personal Information:

• Identifiers: This includes details such as IP addresses, names, surnames, email addresses, and phone numbers.
• Categories Listed Under the California Customer Records Statute: This refers to information like names, addresses, telephone numbers, education details, and employment history (collected from business partners and job applicants).
• Internet and Network Activity: This encompasses your interactions with our Services, including IP addresses, unique device identifiers, device and operating system information, browser versions, pages visited, ads viewed or clicked on, your geographic location, log data, and other relevant usage information.
• Geolocation Information: Includes your IP address and related geographic data.
• Professional or Job-Related Information: This may include job titles, employers, and professions from business partners, as well as job history from candidates.
• Inferences from Personal Information: Information reflecting user preferences, profiles, and interactions with our Services (such as age, gender, income level, and interests).

Sources of Personal Data

In the last 12 months, we have collected Personal Information from the following sources:

• Directly from You: Information you provide through our website’s forms.
• Indirectly from You: Data we gather as you browse the internet, interact with our content or ads, or automatically through tools on our websites.
• Third Parties: Data provided by advertisers, service providers assisting with customer services, internet providers, data analytics companies, social networks, recruitment agencies, and data brokers.

We do not „sell“ your Personal Information; however, we may „share“ it, as defined under U.S. Privacy Laws.

Over the past 12 months, we have disclosed or shared your Personal Information as follows:

• Advertisers: We have shared unique identifiers, IP addresses, and user activity data related to advertisements.
• Service Providers: We have disclosed all categories of Personal Information to service providers.
• Business Acquirers: In the event of business transactions, all categories of Personal Information may be disclosed.
• Entities within Our Group: All categories of Personal Information may be disclosed within our internal company group.
• Legal and Regulatory Authorities: Personal Information may be disclosed to law enforcement or other competent authorities if required by law.

We ensure that recipients only access the necessary information required to deliver our Services, and we implement measures to ensure compliance with data protection laws through contractual safeguards.

Purposes for Data Collection, Use, and Sharing

In addition to the practices mentioned in Section A of this Privacy Policy, we collect, use, and disclose your Personal Information for the following purposes:

• Auditing our interactions with you;
• Legal compliance;
• Detecting security incidents and preventing fraud, malicious activity, and other illegal actions;
• Debugging our Services;
• Delivering services on behalf of us or our partners;
• Conducting internal research to improve technology;
• Managing internal operations;
• Enhancing and maintaining our Services;
• Supporting short-term or one-time activities.

If you wish to opt out of the sharing of your Personal Information, please visit our Cookie Policy to manage your preferences.

B. Request Metrics

As required by the California Consumer Privacy Act (CCPA), we provide metrics below to give transparency on the requests we received and how they were processed during the previous year (July 1st to July 1st):

• Requests to delete: No requests received.
• Requests for data access: No requests received.
• Requests to opt-out of data sharing: No requests received.
• Requests to restrict use: No requests received.

For each request type, we have recorded the number of requests received, complied with (in full or part), denied, and the median time taken for our response, all marked as „-„.

C. Do Not Track Requests

Under California Civil Code Section 1798.83, California residents may request information regarding the disclosure of their Personal Information to third parties for direct marketing purposes. To make such a request, please email us at privacy@topproduct.zone. Please note that we are obligated to respond to only one request per customer annually.

Additionally, our Company does not respond to “Do Not Track” signals sent by browsers.

Updates to This Privacy Policy

We may revise this Privacy Policy from time to time. If there are significant changes in how we handle your Personal Information, we will notify you by sending an email to the primary address associated with your account or by posting a prominent notice within the Services. We encourage you to regularly review this Privacy Policy to stay informed about our privacy practices.

How to Contact Us

If you have any questions or concerns regarding this Privacy Policy or how we handle your Personal Information, please reach out to us at privacy@topproduct.zone.