Topperoo Privacy Policy

Updated: 18 May 2018

1.Introduction

This is our privacy policy. It tells you how we collect and process data received from you on our site. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

If you have any comments on this privacy policy, please email them to support@topperoo.com.

2.Who We Are

Here are the details that the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regards to the processing of personal data and on the free movement of such data, known as General Data Protection Regulation (GDPR) says we have to give you as a ‘data controller’:

• Our site address is https://topperoo.com
• Our company name is Photo Occasions Limited
• We can be contacted at support@topperoo.com.

3.What we may collect

We may collect and process the following data about you:

 

• Information you put into forms or surveys on our site at any time
• A record of any correspondence between us
• Details of transactions you carry out through our site
• Details of your visits to our site
• Information about your computer (e.g. your IP address, browser, operating system, etc.) for system administration and to report aggregate information to our advertisers

Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies:

1. a) you have given consent to the processing of your personal data for one or more specific purposes;
2. b) processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
3. c) processing is necessary for compliance with a legal obligation to which we are subject;
4. d) processing is necessary for the purposes of the legitimate interests pursued by us or by a third party such as our credit card payment processing, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data.

 

4.Cookies

The site uses cookies or similar technology to collect information about your access to the site. Cookies are pieces of information that include a unique reference code that a website transfers to your device to store and sometimes track information about you.

A few of the cookies we use last only for the duration of your web session and expire when you close your browser. Other cookies are used to remember you when you return to the site and will last for longer. All cookies used on our site are set by us.

Most computer and some mobile web browsers automatically accept cookies but, if you prefer, you can change your browser to prevent that or to notify you each time a cookie is set. You can prevent the setting of cookies by adjusting the settings on your browser. Please note however, that by blocking or deleting cookies you may not be able to take full advantage of the site.

Our cookies will be used for:

Essential session management

• creating a specific log-in session for a user of the site in order that the site remembers that a user is logged in and that their page requests are delivered in an effective, secure and consistent manner;
• recognising when a user of the site has visited before allowing us to identify the number of unique users we receive to the site and make sure we have enough capacity for the number of users that we get;
• recognising if a visitor to the site is registered with us in any way;
• we may also log information from your computer including the existence of cookies, your IP address and information about your browser program in order to allow us to diagnose problems, administer and track your usage of our site.

Functionality

• customising elements of the promotional layout and/or content of the pages of the site.

Performance and measurement

• collecting statistical information about how our users use the site so that we can improve the site and learn which parts are most popular to users.

 

Google

Google’s advertising requirements can be summed up by Google’s Advertising Principles. They are put in place to provide a positive experience for users. https://support.google.com/adwordspolicy/answer/1316548?hl=en

Google, as a third party vendor, may use cookies to serve ads on our site. Google’s use of the DART cookie enables it to serve ads to our users based on their visit to our site and other sites on the Internet. Users may opt out of the use of the DART cookie by visiting the Google ad and content network privacy policy.

We have implemented the following:

• Demographics and Interests Reporting

We along with third-party vendors, such as Google use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers such as Facebook or Intercom together to compile data regarding user interactions with ad impressions, and other ad service functions as they relate to our website.

Opting out:

Users can set preferences for how Google advertises to you using the Google Ad Settings page. Alternatively, you can opt out by visiting the Network Advertising initiative opt out page or permanently using the Google Analytics Opt Out Browser add on.

5.How we use what we collect

We use information about you to:

• Present site content effectively to you.
• Provide information, products and services that you request, or (with your consent) which we think may interest you.
• Carry out our contracts with you.
• Allow you to use our interactive services if you want to.
• Tell you about other goods and services that might interest you. 

If you are a user of Topperoo, we will only contact you electronically about things similar to this service.

Please note: We don’t identify individuals to our advertisers, but we do give them aggregate information to help them reach their target audience, and we may use information we have collected to display advertisements to that audience.

In addition, if you don’t want us to use your personal data for any of the other reasons set out in this section in 5, you can let us know at any time by contacting us at support@topperoo.com, and we will delete your data from our systems. However, you acknowledge this will limit our ability to provide the best possible products and services to you.

In some cases, the collection of personal data may be a statutory or contractual requirement, and we will be limited in the products and services we can provide you if you don’t provide your personal data in these cases.

6.Where we store your data

We may transfer your collected data to storage outside the European Economic Area (EEA). It may be processed outside the EEA to fulfil your order and deal with payment.

By giving us your personal data, you agree to this arrangement. We will do what we reasonably can to keep your data secure.

Payment will be encrypted. If we give you a password, you must keep it confidential. Please don’t share it. Although we try to provide protection, we cannot guarantee complete security for your data, and you take the risk that any sending of that data turns out to be not secure despite our efforts.

We use Chargebee Inc to process most of our payments. Payment details processed through Chargebee Inc are secured through their system and is encrypted through the Payment Card Industry Data Security Standard (PCI-DSS).  All direct payment gateways adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover.

PCI-DSS requirements help ensure the secure handling of credit card information by our store and its service providers.

For more insight, you may also want to read Chargebee’s Privacy Policy here: https://www.chargebee.com/privacy/

We only keep your personal data for as long as we need to in order to use it as described above in section 5, and/or for as long as we have your permission to keep it.

7. Disclosing your information

We are allowed to disclose your information in the following cases:

• If we want to sell our business, or our company, we can disclose it to the potential buyer.
• We can disclose it to other businesses in our group.
• We can disclose it if we have a legal obligation to do so, or in order to protect other people’s property, safety or rights.
• We can exchange information with others to protect against fraud or credit risks.

We may contract with third parties to supply services to you on our behalf. These may include website hosting payment processing, search engine facilities, advertising and marketing. In some cases, the third parties may require access to some or all of your data. For a list of the third parties we work with email us at support@topperoo.com.

Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under GDPR and the law.

However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.

8.Your rights

You can ask us not to use your data for marketing. You can do this by contacting us at any time at support@topperoo.com.

Under the GDPR, you have the right to:

• request access to, deletion of or correction of, your personal data held by us;
• request that your personal data be transferred to another person (data portability);
• to object to processing of your personal data; and
• complain to a supervisory authority.

To enforce any of the foregoing rights or if you have any other questions about our site or this Privacy Policy, please contact us at support@topperoo.com.

9.Links to other sites

Occasionally, at our discretion, we may include or offer third party products or services on our website. These third party sites have separate and independent privacy policies and our terms and conditions and privacy policies  will not apply to these websites. We have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.

10.Changes

If we change our Privacy Policy, we will post the changes on this page. If we decide to, we may also email you.

11.Dispute Resolution

11.1 The Parties will use their best efforts to negotiate in good faith and settle any dispute that may arise out of or relate to this Privacy Policy or any breach of it.

11.2 If any such dispute cannot be settled amicably through ordinary negotiations between the parties, or either or both is or are unwilling to engage in this process, either party may propose to the other in writing that structured negotiations be entered into with the assistance of a fully accredited mediator before resorting to litigation.

11.3 All negotiations connected with the relevant dispute(s) will be conducted in confidence and without prejudice to the rights of the parties in any further proceedings.

11.4 If the parties agree on a resolution of the dispute at mediation, the agreement shall be reduced to writing and, once signed by the duly authorised representatives of both parties, shall be final and binding on them.

11.5 If the parties fail to resolve the dispute(s) within 60 days (or such longer term as may be agreed between the parties) of the mediator being appointed, or if either party withdraws from the mediation procedure, then either party may exercise any right to seek a remedy through arbitration.

11.6 Any dispute shall not affect the parties’ ongoing obligations under this Privacy Policy.