PRIVACY POLICY

Last Modified: November 16, 2018    

Topspot provides a fun and simple way to connect with your friends, family and anyone else by allowing you to create and participate in digital contests. Using Topspot requires you to share some information with us, and you will also access the information of others. We are grateful for the trust you put in us when you use Topspot, so we will respect your information you provide to us. This Privacy Policy provides further details regarding the information we collect, how we use it, who we share it with, and the choices we give you to control, access, and update your information. Should you have questions about anything in our Privacy Policy, please feel free to contact us.

INFORMATION WE COLLECT
INFORMATION YOU CHOOSE TO PROVIDE TO US

When you interact with our services, we collect the information that you choose to share with us. For example, most of our services require you to set up a basic Topspot account, so we need to collect some important details about you, such as a username, a password and an email address. If you choose to set up an account with us using social sign-on, for example by using your Facebook account, we may collect additional information you have made available to those websites or software applications. We may also ask you to provide us with some additional information that will be publicly visible on our services, such as a profile picture.
When you use Topspot you may also provide us with information through your use of the platform, for example when you create a Comp or submit an Entry. Content you provide to us can potentially be saved or copied by other users of Topspot. You should always take this into consideration when using Topspot.
If you contact Topspot or communicate with us in any other way, we will also collect information you provide to us from those communications.   

INFORMATION FROM YOUR USE OF OUR SERVICES

When you use our services, we collect information about how you use them. The sorts of information we collect are set out in further detail below.           

Usage Information. This relates to your activity from using our services. For example, we may collect information about the Comps you create, the Comps you enter, the Entries you vote for, your comments on Entries, or which search queries you submit.               

Content Information. This may include the features and settings of Comps you create, the types of Entries you submit, and metadata associated with content you provide. Metadata associated with user content makes content more searchable and interactive. Examples of metadata include hashtags and geotags.               

Device Information. Examples of such information include the hardware model, operating system version, advertising identifier, unique application identifiers, unique device identifiers, browser type, wireless network, and mobile network information.               

Device Phonebook. We may collect information from your device phonebook if you allow us to.        

Camera, Photo and Video. Many of our services require us to collect information from your device’s camera, photos and videos. For example, submitting an Entry requires access to your camera roll.               

Location Information. When you use Topspot we may collect information about your location. If you allow us to we may also collect information about your precise location using methods that include GPS, wireless networks, cell towers, Wi-Fi access points, and other sensors, such as gyroscopes, accelerometers, and compasses.               

Information Collected by Cookies and Other Technologies. As is common for most software applications, we may use cookies and other technologies, such as web beacons, web storage, and unique advertising identifiers, to collect information about your activity, browser, and device.               

Log Information. We may collect certain information when you use our website or mobile application. Such information includes how you’ve used our services, device information, access times, pages viewed, IP address, identifiers associated with cookies or other technologies and pages you may have visited before or after navigating to our website.           

INFORMATION FROM THIRD PARTIES

We may collect information other users provide about you when they use our services. For example, if another user allows us to collect information from their device phonebook—and you’re one of that user’s contacts—we may combine the information we collect from that user’s phonebook with other information we have collected about you. We may also obtain information from other third-party sources and combine that with the information we collect through our services.   

HOW WE USE INFORMATION

We are constantly improving Topspot so that our users have the best experience possible when using our services. This is a fundamental reason why we collect information, including any information you provide to us. Some of the ways we use information you provide to us to help optimize your experience on Topspot are set out below.       

We would like to provide you with personalized content and information.       

To make Topspot the best it can be we may use information you provide to us to improve, test, and monitor the effectiveness of our services.       

Some information you provide to us may help when we develop and test new products and features.       

We want to make it easier for you to use Topspot. To do this we want to allow you to efficiently access your information after you sign in.       

Topspot remembers certain information you provide so you will not have to re-enter it during your use or next time you use Topspot.       

Monitoring and analyzing trends and usage ensures we understand our users and how they interact with Topspot.       

We would like to diagnose, repair and protect against technology issues.       

Information you provide to us can help us to promote a safe and secure environment for our services, including the prevention of fraud and other unauthorized or illegal activity.       

Sometimes we may need to enforce our Terms of Service and other usage policies.       

-   We would like to be able to communicate with you.       

Please note that some of the ways in which we use information you provide to us which we mentioned above may require us to store some information on your device.   

HOW WE SHARE INFORMATION

WITH OTHER TOPSPOT USERS   

We may share the following information with other users of Topspot:

Information about you, for example your username and brief biography.       

Information about how you have interacted with Topspot, such as other Topspot users you are following or a fan of.       

Other information about you which you have consented for us to share.       

Your content on Topspot, for example Comps you have created or Entries you have submitted.      

The way in which we share this information is subject to how you choose to share this information on Topspot.   

WITH THIRD PARTIES   

We may share your information with the following third parties:       

Service providers, sellers, and partners who perform services on our behalf and that provide other services, functionality and information through Topspot.       

Third parties who reasonably require access to certain information for legal reasons to comply with any valid legal process, governmental request, law, rule, or regulation; to investigate, remedy, or enforce potential violations of Topspot’s policies and procedures; to protect the rights, property, and safety of Topspot, our users, or others; to detect and resolve any fraud or security concerns.       

With third parties as part of a merger or acquisition. If Topspot is involved in a merger, acquisition, asset sale, financing, liquidation or bankruptcy of all or some portion of our business involving another entity, we may share information you have provided to us with that entity before and after a transaction closes, or during any engagement with an entity considering a potential transaction.       

With third parties that access aggregated or de-identified information that cannot reasonably be used to identify you. 

INFORMATION YOU CHOOSE TO SHARE WITH THIRD PARTIES

Topspot may also contain third-party links and integrations or offer co-branded or third-party-branded services. By following those links and integrations, or using co-branded or third-party-branded services, you may be providing information directly to the third party, Topspot, or both. You acknowledge and agree that we are not responsible for how those third parties collect or use your information. We encourage you to review the privacy policies of every third-party website, mobile application or service that you visit or use, including those of third parties you interact with through our services.   

HOW WE STORE YOUR CONTENT

The information we collect from you through our services may be stored and processed in the United States or any other country in which Topspot or its service providers maintain facilities.
Topspot or its service providers may transfer information that you provide across borders and from your country or jurisdiction to other countries or jurisdictions. It is possible that we may transfer information, including personal information, to a country or jurisdiction that does not have the same data protection laws as your jurisdiction. By registering for and using Topspot you consent to the transfer of information to the United States or to any other country in which Topspot or its service providers maintain facilities.  
We use commercially reasonable safeguards to help keep the information you provide through our services secure and take reasonable steps to verify your identity before granting you access to your account. However, Topspot cannot ensure the security of any information you provide to us or guarantee that information on our services may not be accessed, disclosed, altered, or destroyed.

HOW LONG WE KEEP YOUR CONTENT

If you terminate, deactivate or delete your Topspot account, we may retain your information for a commercially reasonable period for backup, audit, legal, compliance or archiving purposes.   

CONTROL OVER YOUR INFORMATION

We want you to be in control of your information, so we provide you with the following tools.       

Access and Updates. We strive to let you access and update most of the personal information that we have about you. We may however reject certain requests for a range of reasons, including, for example, that the request risks the privacy of other users, requires technical efforts that are disproportionate to the request, is repetitive, or is unlawful. You can access and update most of your basic account information by updating your settings in Topspot. If you need to access, update, or delete other personal information that we may have, please contact us. Because your privacy is important to us, we may ask you to verify your identity or provide additional information before we let you access or update your personal information.               

Revoking Permissions. If you would like to revoke our ongoing ability to collect information from certain sources that you have already consented to, you can do this by changing the settings on your device if your device offers those options, or by updating your settings on Topspot. Should you encounter difficulty revoking permissions you may contact us.               

Account Deletion. If you ever want to delete your Topspot account, please contact us. We will ensure it is deleted within 5 business days unless we are unable to due to extenuating circumstances.               

Communicating with other Topspot users. We have built tools that let you interact and communicate with other Topspot users. This allows you to remain in control of who can view your content. Please contact us if you require our assistance in relation to communicating with other Topspot users.               

ANALYTICS AND ADVERTISING SERVICES PROVIDED BY OTHERS

We may let other companies use cookies, web beacons, and similar tracking technologies on our services. These companies may collect information about how you use our services and other websites and online services over time and across different services. This information may be used to, among other things, analyze and track data, determine the popularity of certain content, and better understand your online activity. Additionally, some companies may use information collected on our services to deliver targeted advertisements on behalf of us or other companies, including on third-party websites and software applications.

USERS IN THE EUROPEAN UNION

Topspot LLC is the controller of your personal information. Here is some additional information we would like to bring to your attention:

BASES FOR USING YOUR INFORMATION

We may use your personal information when certain conditions apply:

Contract. This is when you’ve entered into a legally enforceable agreement with us. 

Legitimate interest. This is where we have a legitimate interest in doing so. For example, we need to use your information to provide and improve our services and for providing customer support. Please note we only rely on legitimate interest when we think the way we are using your data doesn’t significantly impact your privacy or would be expected to, or if there is a compelling reason to do so. 

Consent. This is when you have given us permission to use your information. Not that where practical, we will make sure you can revoke your consent through our services or through your device permissions, and even if we’re not relying on consent to use your information, we may ask you for permission to access certain data.

Legal obligation. This is when we are required to use your personal information to comply with the law, for example when we respond to valid legal process or need to take action to protect our Topspot users. 

RIGHT TO OBJECT

You have the right to object to our use of your information. If there are types of information you don’t agree with us processing, you can contact us.

INTERNATIONAL TRANSFERS

We may collect your personal information from, transfer it to, and store and process it in the United States and other countries outside of where you live. Whenever we share information of EU users outside the EU we make sure an adequate transfer mechanism is in place. 
Please note that if you’re based in the EU, you can always file a complaint with the supervisory authority in your country or jurisdiction.  

CHILDREN

Our services are not intended for anyone under the age of 13. We do not knowingly collect personal information from anyone under the age of 13. We may also limit how we collect, use, and store some of the information of EU users between 13 and 16. If we need your consent for processing your information and your country requires consent from a parent, we may require your parent’s consent before we collect and use that information.   

REVISIONS TO THE PRIVACY POLICY

We may change this Privacy Policy from time to time. We intend to notify you of any changes either through amending the last modified date of the Privacy Policy, or where otherwise required, through alerts or notifications either on our website or through our services. 
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