Effective Date: [07-Aug-2023]
- Our website (topupflix.com)
- Our app
- Our email newsletters
- Our pages or ads on social media networks
We gather various types of Personal Data from our users, as explained in more detail below, and we use this Personal Data internally in connection with our Services, including to personalize, provide, and improve our Services, to allow you to set up a user account and profile, to contact you and allow other users to contact you, to fulfill your requests for certain products and services, and to analyze how you use the Services. In certain cases, we may also share some Personal Data with third parties, but only as described below.
What Information Do We Gather About You?
The following describes the information we collect and how we obtain it.
A) Information Collected Through the Services.
i. Information You Voluntarily Give Us:
When you sign up for a Service (e.g., a subscription), we collect your contact information and account credentials. Once you’re registered, we assign you a unique ID number. This ID number helps us recognize you when you’re signed in.
For some Services, you can instead sign up by linking your Google, Apple, or Facebook accounts. See “From Other Sources” below.
To process payments, we collect and use your payment information.
This can include your name, your address, your telephone number, your email address, your credit or debit card information, and any other relevant information.
For User-Generated Content:
We offer you the ability to post content that other users can read (e.g., comments). Anyone can read, collect, and use any personal information that accompanies your posts.
We do not have to publish any of your content. If the law requires us to take down, remove, or edit your personal information, we will comply to the required extent.
For Contests, Sweepstakes, and Special Offers:
When you sign up for these, you give us your name, email, and any other required information.
For Reader Surveys, Research, Panels, and Experience Programs:
We gather information through questionnaires, surveys, and feedback programs, including demographic information like your age or gender. We also conduct similar research for advertisers. We ask you for your consent to use this information when you participate in these programs and events.
ii. Information Collected Automatically:
When you use the Services, we collect some information automatically. The technologies we use to assist with this data collection include cookies, web beacons, tags and scripts, and software development kits (or SDKs). You may be able to change the preferences on your browser or device to prevent or limit your device’s acceptance of cookies, but this may prevent you from taking advantage of some of our features. For more information about tracking methods on the Services, and how to manage them.
The categories of personal information we collect automatically include:
Identifiers and Device Information:
Whenever you interact with our Services, we automatically receive and record on our server logs information about the device you are using, including unique identifiers. If your browser doesn’t accept our cookies, you can’t access certain parts of our website (e.g., your account settings). The items we log include:
- IP address
- Cookies Identifiers
- Device identifiers (such as MAC address)
- Operating system and web browser information (e.g., type, version, and configuration)
- Browser language
- Advertising identifiers
When you use the Services, we may collect location data. For instance, we collect your IP address, which can establish your approximate (non-precise) location.
Other Usage Data:
We collect certain internet and network activity on our website and app, including the URLs of any pages you visit on our website and app, the URL of the website from which you came to our website, how long you spent on a page, access times, search queries, and other details about your use of and actions on our website and app.
We may use the data described herein to customize content for you that we think you might like based on your usage patterns or for other similar purposes. We may also use it to improve the Services — for example, this data can tell us how often users use a particular feature of the Services, and we can use that knowledge to make the Services interesting to as many users as possible. We combine this data with other information we collect about you.
B) Information we create or generate.
We infer new information from other data we collect, including using automated means to generate information about your likely preferences or other characteristics (“inferences”).
C) Information Collected From Other Sources.
i. Privately Owned Databases:
Marketing, data analytic, and social media-owned databases give us access to a range of information — like public data, survey data, and beyond. This data sometimes includes your mailing address, your gender, your age, your household income, and other demographic data.
ii. Social Media Platforms and Other Third-Party Services:
(Social media platforms include Facebook. Third-party services include Google.)
If you provide your social network account credentials to us or otherwise sign in to the Services through a third-party site or service, you understand some content and/or information in those accounts may be transmitted into your account with us.
You can link your social media or other third-party account to a Service. By linking that account, you authorize us to collect, store, and use any information they may give us (e.g., your email address). You can disconnect your topupflix.com registration from third-party accounts at any time.
We also receive information from you when you interact with our pages, groups, accounts or posts on social media platforms. This includes aggregate data on our followers (e.g., age, gender and location), engagement data (e.g., “likes,” comments, shares, reposts and clicks), awareness data (e.g., number of impressions and reach) and individual users’ public profiles.
iii. Workplace and Schools:
When your employer or school buys an organization-wide subscription to The TopupFlix, they sometimes provide us with your name and organization email address to grant you access as a user.
iv. Advertising Partners:
We receive information about you from some of our service providers who assist us with marketing or promotional services related to how you interact with our website, app, products, services, advertisements, or communications.
If you’d like to invite your friends to use the Services, we will store this information for the sole purposes of allowing you to send your friends referral offers, for determining whether your friends use the Services after a referral is sent, and, for United States residents, to remind your friends of the referral sent on your behalf.
A note about sensitive personal information
We generally don’t want to gather any sensitive information about you. This includes:
- Government-issued IDs (such as your driver’s license, passport, or social security number)
- Your racial or ethnic origin
- Your political opinions
- Your religion or other beliefs
- Your health, biometric, or genetic characteristics
- Any trade union membership
- Your sexuality (information about your sex life or sexual orientation)
- Any criminal background
- The content of your private communications (other than messages you may send to us)
Some laws define account access information, such as a username and password, as sensitive personal information, but we collect that information only for the accounts you create directly with us and not for any other account you may have with a third party.
How Do We Use Personal Data?
We process each of the categories of Personal Data described above to operate, improve, understand, and personalize our Services. For example, we use Personal Data for the following business and commercial purposes:
A) To Provide Our Services
We use your information to help you use and navigate our services, such as:
- To meet or fulfill the reason you provided the information to us.
- To make our Services available to you.
- To create and manage user profiles and content.
- To charge you for the Services costs through one or more payment processing partners.
- To communicate with you about the Services, including Service announcements or updates, or other marketing and promotional material, including targeted offers and ads served through the Services.
B) To Personalize Your Experience
We track your interests and reading habits (e.g., the articles you read) to personalize and calibrate your reading experience using technology like algorithmic recommendations and machine learning. This is how we highlight articles you might be interested in and de-emphasize articles you’ve already read. We also show you prices, promotions, products, or services we believe you’ll find interesting, based on demographic and usage data.
C) To Allow You to Share User-Generated Content
Any information you disclose in your content becomes public — along with your username.
D) To Develop Products and Services, and Conduct Analysis
We analyze data on our users’ subscription, purchase, and usage behaviors. This helps us make business and marketing decisions. This allows us to understand how users interact with the Services as a whole and to improve and develop the Services, including testing new features, research, analysis, and product development.
For example, our analysis lets us predict preferences and price points for our products and services. It helps us determine whether our marketing is successful. It also shows us characteristics about our readers, which we sometimes share in aggregate with advertisers.
E) To Carry Out Administrative Tasks
For auditing: We verify that our internal processes work as intended.
For fraud and security monitoring: We use your data to detect and prevent cyberattacks or unauthorized robot activities, protect against or deter fraudulent, illegal, or harmful actions, and maintain the safety, security, and integrity of our Services.
For customer satisfaction: We provide customer support and assistance for the Services, respond to user inquiries and fulfill user requests, and assess users’ satisfaction with the Services and our customer care team.
F) To Allow for Personalized Advertising on the Services and Create Audiences for Third-Party Advertisers
We also identify groups of users to whom to serve personalized ads on behalf of our advertisers. To do this, we combine information we collect through surveys or registration with information we collect automatically using tracking technologies while you browse our website and app. This combined information is used to build models. These data models are then used to measure users’ attributes, like their demographic information or their interests. Working with service providers, we use these measurements to group users by common attributes. Each group is associated with a random ID which is then passed to our ad server for use in targeting ad campaigns on our website and app.
- We try to limit how our third-party advertising technology vendors use the information they gather from you. Many of these providers require us to enter into contracts that allow them to optimize their own services and products, or that help them create their own.
- Essentially, these providers combine any information they gather about you through the Services with information they receive from their other clients. This helps them target ads to you on behalf of their other clients, not just us.
- These third parties sometimes use other services in order to serve ads; check their privacy policies for more details. For further information on tracking technologies and your rights and choices regarding them, California residents have the right to instruct us not to “sell” or “share” their personal information. Residents of Colorado, Connecticut, and Virginia have the right to opt out of “targeted advertising” and “sales” (as defined under applicable law) of their personal information. More information is available below.
G) To Advertise the Services to You
We market our Services to you. Sometimes we use marketing vendors to do this.
We serve ads through websites, locations, platforms, and services operated and owned by third parties. Often these ads are targeted at people who have visited or registered for the Services but have not subscribed or purchased anything. The ads are also targeted at people with similar traits or behaviors to our subscribers or customers.
We target our advertising to these users by uploading an encrypted customer list to a third party, or by incorporating a tracking technology from a third party onto our Service. The third party then matches individuals who appear in both our data and their data. Because of how this matching process works, the third party can’t read our encrypted customer list if they don’t already have it.
To opt out of receiving these matched ads, contact the applicable third parties. For example, when we use “Custom Audience” to serve you our ad through Facebook, you should be able to hover over the box in the right corner of that Facebook ad and opt out. We are not responsible for any third party’s failure to comply with opt-out requests.
We periodically send you targeted email newsletters or promotional emails. For information on opting out of these emails.
H) To Aggregate (or De-Identify) Personal Information Into Larger Findings
Sometimes we aggregate or de-identify information so that it can no longer identify you, under applicable laws. This helps us better understand and represent our users, such as when we measure ad performance, create advertising interest-based segments, or compile survey results. We can use and disclose this aggregated or de-identified information for any purpose, unless an applicable law says otherwise.
I) For Legal and Regulatory Purposes
We may use your Personal Data to comply with legal, regulatory, and contractual obligations and respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
We may also use your information for any other business purpose stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws, such as the California Consumer Privacy Act.
The above activities can involve outside companies, agents, or contractors (“Service Providers”) with whom we share your personal information for these purposes (discussed further below).
To Whom Do We Disclose or Share the Information We Gather?
Disclosures of Personal Data for a Business Purpose
We may disclose your Personal Data to Service Providers and other parties for the following business purposes:
- Auditing related to a current interaction and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
- Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
- Debugging to identify and repair errors that impair existing intended functionality.
- Short-term, transient use of Personal Data that is not used by another party to build a consumer profile or otherwise alter your consumer experience outside the current interaction.
- Performing services on our behalf, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or Service Provider.
- Undertaking internal research for technological development and demonstration.
- Undertaking activities to verify or maintain the quality or safety of a service or device that we own, manufacture, was manufactured for us, or control.
We disclose your Personal Data to the following categories of Service Providers and other parties:
- Service Providers, including hosting and other technology and communications providers, security and fraud prevention consultants, and staff augmentation and contract personnel.
- Payment processors and providers of related financial services.
- Ad networks and analytics providers (which may or may not act as Service Providers). Third-party analytics and advertising on our website and app may collect the user’s IP address, browser type, and approximate location (based on the IP address). They may also use web logs or web beacons and may set and access cookies on your computer or other device. Please be aware that cookies placed by third parties may continue to track your activities online even after you have left our Services. For more details, including information on limiting this type of tracking.
- Parties who acquire your Personal Data through an acquisition or other change of control.
- Personal Data may be transferred to a third party if we undergo a merger, acquisition, bankruptcy, or other transaction in which that third party assumes control of our business (in whole or in part).
- Other parties are at your direction.
- Other users (where you post information publicly or as otherwise necessary to effect a transaction initiated or authorized by you through the Services). Certain user profile information, including your name, location, and any content that you have uploaded to the Services, may be displayed to other users to facilitate user interaction within the Services or address your request for our services. Please remember that any content you upload to your public user profile, along with any Personal Data or content that you voluntarily disclose online in a manner other users can view (on discussion boards, in messages and chat areas, etc.), becomes publicly available, and can be collected and used by anyone. Your username may also be displayed to other users if and when you send messages or comments or upload images or videos through the Services, and other users can contact you through messages and comments.
- Other third-party business partners who you access through the Services.
- There are situations when we share your information with third parties beyond our Service Providers.
- Social media services (if you intentionally interact with them through your use of the Services).
- Other parties authorized by you.
We can preserve or disclose personal information if the law requires us to do so. We can also preserve or share personal information if we believe it would be necessary to:
- Comply with law or legal process
- Protect and defend our rights and property
- Protect against misuse or unauthorized use of the Services
- Protect the safety or property of our users or the general public
- Cooperate with government authorities, which could be outside your country of residence
We may disclose public activities in our RSS feeds, APIs, and other distribution formats. Your public activities could thus appear on other websites, blogs, or feeds.
Non-Personal or Aggregate Information: We may de-identify your Personal Data so that you are not identified as an individual, and provide that information to our partners. We may also provide aggregate usage information to our partners (or allow partners to collect that information from you), who may use such information to understand how often and in what ways people use our Services, so that they, too, can provide you with an optimal online experience. However, we never disclose aggregate usage or de-identified information to a partner (or allow a partner to collect such information) in a manner that would identify you as an individual person.
What Are Your Rights and Choices?
We provide a variety of ways for you to control the personal information we hold about you, including choices about how we use that information. In some jurisdictions, these controls and choices are enforceable as rights under applicable law.
How Do I Opt Out of Email, Phone, and Push Notifications?
You can opt out of receiving promotional communications from us by adjusting your settings on your account page or by using the unsubscribe mechanism included in the message, where applicable.
You can opt out of push notifications at any time by adjusting your device settings, or by uninstalling our app.
You can opt out of text alerts at any time by replying “STOP” or any alternative keyword we’ve shared with you.
We will complete any opt-out request as quickly as we can. Note that this opt-out request won’t prohibit us from sending you transactional or other important nonmarketing notices.
What Personal Data Can I Access, Correct, or Delete?
Through your account settings, you may access, and, in some cases, edit or delete the following information you’ve provided to us:
- Name and password
- Email address
- User profile information
If you have any questions about viewing, receiving (for data portability), correcting, or deleting information we have on file about you, or if you are unable to take such actions through your account settings and the controls described above, please contact us at [email protected]. If making a request via email, please use the email address linked to that personal information — we only complete requests on the information linked to your email address. To verify your identity, we will email the email address you provide us, and which matches our records, and wait for your response. In some instances, we may also ask for additional information. This is how we verify your identity before complying.
How Can I Restrict or Object to Data Processing?
In some jurisdictions you have a right to restrict, or object to, how we process personal information about you. For example, in the European Union, you have the right to object to, or obtain a restriction of, the processing of your personal information under certain circumstances; and where the processing is based on your consent, you have a right to withdraw that consent at any time for future processing.
What Other Rights Do I Have?
You will not receive discriminatory treatment by us for the exercise of your privacy rights.
In some jurisdictions, you may appeal to us if we refuse to take action on your exercise of certain choices described above. In order to appeal such a refusal, please contact us at [email protected] using the subject line “Appeal of Refusal to Take Action on Privacy Request” and provide the relevant information in the email.
If you’d like, you can lodge a complaint with a data protection authority. A list of E.U. data protection authorities is available. But we encourage you to first contact us with any questions or concerns.
Opt Out of Targeted Advertising and “Sales” of Personal Information:
Residents of certain jurisdictions, including Colorado, Connecticut, and Virginia have the right to opt out of targeted advertising and “sales” (as defined under applicable law) of personal information. In order to exercise your right to opt out of targeted advertising or “sales” of your personal information, please click the Your Privacy Choices link in the footer of our website. California residents should review relevant information relating to California law below.
Additional Privacy Information for California Residents
If you are a California resident, you have the rights outlined in this section.
Notice at Collection
Rights to Know (Access), Correction, and Deletion
You also have the rights to request that we correct any inaccurate Personal Data or that we delete the Personal Data that we have collected from you. Under the CCPA, this right is subject to certain exceptions: for example, we may need to retain your Personal Data to provide you with the Services or complete a transaction or other action you have requested. If your deletion request is subject to one of these exceptions, we may deny your deletion request.
Exercising Your Rights
Please see What Personal Data Can I Access, Correct, or Delete? above for details, including on how to exercise these rights. Additionally, to exercise the rights described above, you must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data, and (2) describes your request in sufficient detail to allow us to understand, evaluate, and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify you and complete your request. You do not need an account to submit a Valid Request.
We will work to respond to your Valid Request within 45 days of receipt. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive, or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.
You may submit a Valid Request by selecting “Make a Privacy Request” in the top right-hand corner of this page.
You can designate an authorized agent to make a request to exercise your rights under the CCPA on your behalf. In order to do that, please provide the agent with written permission, signed by you, authorizing the agent to submit the request on your behalf. The agent must submit that written permission along with the request. We will contact you to verify your identity — and the authorized agent’s permission — before a response to the request is sent.
Personal Data Sales and Sharing Opt-Out and Opt-In
You have the right to opt-out of the “sale” or “sharing” (as those terms are defined in the CCPA) of your Personal Data. To do so, click the Your Privacy Choices link in the footer of our website. Also, if your browser supports it, you can turn on the Global Privacy Control to opt-out of the “sale” or “sharing” of your Personal Data.
Once you have submitted an opt-out request, we will not ask you to reauthorize the sale of your Personal Data for at least 12 months.
We do not knowingly “sell” or “share” (as those terms are defined in the CCPA) the personal information of minors under 16 years old who are California residents.
Right to Limit Use and Disclosure of Sensitive Personal Information
If you are a California resident, you have a right to limit our use of sensitive personal information for any purposes other than to provide the services or goods you request or as otherwise permitted by law. Note that we do not use sensitive personal information for any such additional purposes.
Right to Non- Discrimination
We will not discriminate against you for exercising your rights under the CCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CCPA.
Shine the Light Disclosure
Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at [email protected].
California residents are entitled to ask us for a notice identifying the categories of Personal Information which we share with our Affiliates and/or Third Parties for marketing purposes, and providing contact information for such Affiliates and/or Third Parties. If you are a California resident and would like a copy of this notice, please submit a written request to [email protected].
Is Personal Data About You Secure?
Your account is protected by a password for your privacy and security. If you access your account via a third-party site or service, you may have additional or different sign-on protections via that third-party site or service.
We seek to protect Personal Data using appropriate technical and organizational measures based on the type of Personal Data and applicable processing activity. We take various steps to protect your information, including, but not limited to, the following:
- We implement technical measures to prevent unauthorized access, and keep security patches and software up-to-date
- We restrict employee access to your information on a need-to-know basis
Despite the safeguards we implement, we cannot guarantee its absolute security. We recommend that you use complex and unique passwords for your accounts and for third-party accounts linked to them. Do not share your password with anyone. Limit access to your computer or device and browser by signing off after you have finished accessing your account.
If you have reason to believe your interaction with us is no longer secure, notify us immediately.
Are There Guidelines for Children?
Our Services are not intended for children under the age of 13 and we do not knowingly collect or solicit Personal Data from anyone under the age of 13. If you are under 13, please do not attempt to register for the Services or send any Personal Data about yourself to us. If we obtain actual knowledge that we have collected Personal Data from a child under age 13, we will delete that information as quickly as possible. If you believe that a child under 13 may have provided us Personal Data, please contact us at [email protected].
How Is Information Transferred Internationally?
TopupFlix is headquartered in the United States. If you are located outside the United States, your information is collected in your country and then transferred to the United States — or to another country in which we (or our Affiliates or Service Providers) operate.
If we transfer your data out of the European Economic Area (E.E.A.), we implement at least one of the two following safeguards:
- We transfer your information to countries that have been recognized by the European Commission as providing an adequate level of data protection according to E.E.A. standards (see the full list of these countries).
- We take steps to help ensure that the recipient is bound by E.U. Standard Contractual Clauses together with additional safeguards to protect your Personal Data. You can see a copy of these clauses.
In certain situations, the courts, law enforcement agencies, regulatory agencies, or security authorities in those countries might be entitled to access your personal information.
What Is Our Legal Basis?
We will only process your Personal Data if we have a lawful basis for doing so. Depending on your jurisdiction, lawful bases for processing include consent, contractual necessity, and our “legitimate interests” or the legitimate interest of others, as further described below.
- Contractual Necessity: We process the following categories of Personal Data as a matter of “contractual necessity,” meaning that we need to process the data to perform under our Terms of Service with you, which enables us to provide you with the Services. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Services that require such data.
- Personal identifiers.
- Customer records identified by state law.
- Commercial information.
- Legitimate Interest: We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties.
- Internet or other similar network activity information.
- Geolocation data.
- Inferences drawn from other personal information.
- Examples of these legitimate interests include:
- Operation and improvement of our business, products and Services
- Marketing of our products and Services
- Provision of customer support
- Protection from fraud or security threats
- Compliance with legal obligations
- Completion of corporate transactions
- Examples of these legitimate interests include:
- Consent: In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.
- Other Processing Grounds: From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.
What About Third-Party Services?
- As mentioned above, some of the Services are offered on third-party digital properties (such as third-party websites, frameworks, and domains) which can affect our data practices and your data preferences.
- If you set your data preferences while using one of these third-party digital properties, your preferences will only be saved with respect to the Services on that specific third-party digital property. Your preferences will not carry over when you use the Services on our own digital properties.
How Long Do We Retain Your Personal Data?
We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide you with our Services. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule, or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.
What If You Have Questions About This Policy?