1. INFORMATION WE COLLECT
We may collect, transmit, and store information about you in connection with your use of the Service, including any information you send to or through the Service. We use that information to provide the Service’s functionality, fulfill your requests, improve the Service’s quality, engage in research and analysis relating to the Service, personalize your experience, track usage of the Service, provide feedback to third party businesses that are listed on the Service, market the Service, provide customer support, message you, back up our systems, allow for disaster recovery, enhance the security of the Service, and comply with legal obligations. Even when we do not retain such information, it still must be transmitted to our servers initially and stored long enough to process.
A. Request quotes, services, downloads, or information. When you request quotes, services, downloads, or other similar information from us, we will ask you for your name and email address.
B. Place orders for services. When you place orders for Topline services, we require necessary information to identify you, and to permit us to bill you for the requested services.
C. Participate in surveys or interviews from any platform/device. Participants in surveys or interviews may be asked for personal information, opinions and/or quotes. Interviews may be recorded and transcribed (with interviewee consent).
D. Subscribe to emails lists or other materials. When you subscribe to email lists or other similar publications, we will ask you for information necessary to know how to provide you with the requested materials (such as, for example, your email address), and, if applicable, to bill you for them.
E. Apply for a job or submit your resume or CV. Job applicants may be asked to provide information such as educational background, employment experience and job interest.
F. Contact or submit comments to us. Information you submit to us voluntarily is retained by Topline so it can be used for the improvement of our Services.
2. HOW WE USE YOUR INFORMATION
Topline uses your Personal Information to:
A. Deliver services to Business Partners;
B. Contact you to schedule and complete an interview;
C. Send communications to you, such as emails, or gifts (where applicable);
D. Facilitate communications to Business Partners;
E. Customize, analyze and improve our services, communications and relationship with you;
F. Legitimize quotes or testimonials on our website (with consent);
G. Perform HR functions and background checks;
H. Comply with tax and employment eligibility verification laws;
I. Protect the security and integrity of our website, our business, our Business Partners, or our services; or
J. Otherwise, as disclosed to you at the point of collection.
3. LEGAL BASIS FOR PROCESSING (EEA AND SWITZERLAND ONLY)
For European Residents, our legal basis for collecting and using the information described above will depend on the specific information concerned and the context in which we collect it. We, however, will normally collect personal information from you only where we have your consent to do so, where we need the personal information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person (for instance, to prevent, investigate, or identify possible wrongdoing in connection with the Service or to comply with legal obligations). If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information). If we collect and use your personal information in reliance on our legitimate interests (or those of any third party), this interest will typically be to operate our Services, communicate with you in relation to our Services, or for our other legitimate commercial interests, for instance, when responding to your queries, to analyze and improve our platform, engage in marketing, or for the purposes of detecting or preventing fraud. If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us at the address listed below.
The Topline website uses Google Analytics. For information on how Google Analytics collects and processes data, please visit How Google uses data when you use our partners’ sites or apps.
You can set some Cookie preferences through your device or browser settings, but doing so may affect the functionality of the Service. The method for disabling Cookies may vary by device and browser, but can usually be found in your device or browser preferences or security settings.
5. SHARING PERSONAL INFORMATION
Except as described below, we will not share your Personal Information with third parties. We may store and use your Personal Information outside your country and Personal Information collected from you may be transferred to our Business Partners outside your country according to our consulting agreement. You have the right to a copy of your Personal Information collected and to withdraw consent at any time. We retain your Personal Information so long as Topline or its Business Partners require continual use which terminates upon your withdrawn consent in writing.
Third parties may receive information about you as follows:
A. From Clients Under Contract with Topline: When Topline receives your Personal Information from clients under contract with Topline for services and Topline contacts you on their behalf, any subsequent Personal Information we collect and/or share will be limited to the client that provided your Personal Information, will not be combined with any other project or exceed the express purpose granted in our consulting agreement with that client. We will only share your Personal Information so long as our client agrees to protect your Personal Information and use it solely for the purposes set forth by Topline. Any quotes, personal opinions, or personal information disclosed to our client is subject to the terms of our non-disclosure agreement and confidentiality requirements of our consulting agreement.
B. Aggregate or Anonymous Information: We may share user information in the aggregate for use in marketing materials, presentations, etc.
D. Investigations and Legal Disclosures: We may investigate and disclose information from or about you if we have a good faith belief that such investigation or disclosure: (a) is reasonably necessary to comply with legal or law enforcement processes, such as a search warrant, subpoena, statute, judicial proceeding, or other legal process or law enforcement request; (b) is helpful to prevent, investigate, or identify possible wrongdoing in connection with the Service; or (c) protects our rights, reputation, property, or that of our users, affiliates, or the public. If you flag or otherwise complain to us about content through the Service, we may share the substance of your complaint with the contributor of that content in order to provide an opportunity for the contributor to respond.
E. Links: The Service may link to third party-controlled websites, like a business’s URL. Except as set forth herein, we do not share your personal information with them, and are not responsible for their privacy practices.
6. DATA RETENTION
The Service is intended for general audiences and is not directed to minors under 18. We do not knowingly collect personal information from minors under 18. If we become aware that a minor under 18 has provided us with personal information without parental consent, we take steps to remove such information.
We use various safeguards to protect the personal information submitted to us, both during transmission and after we receive it. However, no method of transmission over the Internet or via mobile device, or method of electronic storage, is 100% secure. Therefore, while we cannot guarantee its absolute security, we strive to use commercially acceptable means to protect your personal information, such as:
- limiting physical access to our premises;
- requiring internal compliance with security protocols;
- limiting access to the information we collect about you; and
- maintaining non-disclosure agreements and confidentiality requirements with Business Partners.
9. MANAGING YOU PERSONAL INFORMATION AND HOW TO CONTACT US
If you have any questions about the type of Personal Information we hold about you, to request deletion or correction of Personal Information we hold about you, or to opt out of our email list please, send a written request to email@example.com or
Topline Strategy Group, Inc.
300 Washington Street, Suite #311
Newton, MA 02458
For security purposes, we will take such steps as we deem necessary to confirm your identity before completing your request or sharing any personal data with you.
We will occasionally update this Privacy Statement. If we make changes to this Privacy Statement or make any material changes to how we use your Personal Information, we will revise this Privacy Statement to reflect such changes and revise this Privacy Statement’s effective date, included at the end of this policy. We encourage you to periodically review this Privacy Statement to be informed of how we are using and protecting your Personal Information.
11. CALIFORNIA RESIDENTS: YOUR CALIFORNIA PRIVACY RIGHTS
Under the California Consumer Privacy Act of 2018 (“CCPA“), California residents have certain rights around Topline’s collection, use, and sharing of their personal information.
Topline does not sell your personal information and will not do so in the future without providing you with notice and an opportunity to opt-out of such sale as required by law. Similarly, we do not offer financial incentives associated with our collection, use, or disclosure of your personal information.
Topline collects various categories of personal information when you use the Service, including identifiers, commercial information, internet or other electronic network or device activity information, geolocation data, and professional information.
If you are a resident of California, you have the right to request to know what personal information has been collected about you, and to access that information. You also have the right to request deletion of your personal information, though exceptions under the CCPA may allow Topline to retain and use certain personal information notwithstanding your deletion request. You can send your request by email to firstname.lastname@example.org. We will not discriminate against you for exercising your rights under the CCPA. An agent may submit a request on your behalf, but you must verify that your agent is authorized to do so.
Separate from the CCPA, California’s Shine the Light law gives California residents the right to ask companies what personal information they share with third parties for those third parties’ direct marketing purposes. We do not disclose your personal information to third parties for the purpose of directly marketing their goods or services to you unless you request such disclosure. If you have any questions regarding this policy, you may contact us at the address listed above.
12. EUROPEAN RESIDENTS: YOUR PRIVACY RIGHTS AND INTERNATIONAL DATA TRANSFER
If you are a “European Resident” (that is, a resident of a country in the European Economic Area (“EEA“) or Switzerland), you have the right to access your personal data, and the right to request that we correct, update, or delete your personal data. You can object to the processing of your personal information, ask us to restrict processing of your personal information, and request portability of your personal information. If we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent. The Service generally provides you with a reasonable means to view and change your profile information and you can opt-out of marketing communications at any time by clicking on the “unsubscribe” or “opt-out” link in the marketing emails we send you. If you have any questions or comments about the processing of your personal information, you may contact us as described above.
Effective Date, 3/9/2020