A. About Us.
Please read this Policy as it includes important information regarding your Personal Data and other information. Capitalized terms not defined in this Policy will have the meanings given to such terms in the Terms of Service. As described in this privacy statement, we will not process your information without a lawful basis to do so. We will process your user information with your legal consent (when you voluntarily provide information or opt in) or on the basis of contract law (when you enter into a transaction with us), or when we have a legal obligation to do so. As described herein, we may also process certain user information on the basis of the following legitimate interests, provided that such interests are not overridden by your privacy rights and interests: delivering content, and further developments and improvements to the Site, learning from analyzing traffic to better serve all Site users, to analyze the likes and dislikes of our users, and to help us to provide a more stable, consistent, and secure user experience. If you have any questions regarding this, please contact us.
You may contact us to request what personally identifiable information that we have collected from you by sending a request to firstname.lastname@example.org
You have the right to be forgotten, if you would like us to remove your personally identifiable information from our database, you can deactivate your account through the platform dashboard or you may email us at email@example.com
1. Information We Collect.
(a) Personal Data. Personal Data and other information are collected from you when you create a Account with us or when you otherwise disclose Personal Data or other information to us or third parties when using the Services. “Personal Data” means any information that may be used to identify an individual. Personal Data does not include aggregate information. In connection with the Services, you may be asked to provide us the following Personal Data and other information: your name, email address, mailing address, telephone or cellular phone number, company name, Skype name/identification, business information, payment information, and other information in connection with the Services.
(b) Location Data. We and third parties with whom we may partner may collect location information in relation to a User’s Device and use of the Services (“Location Data”) with respect to you. If you use the Services, then you are providing consent to collect Location Data such as the physical location of your Device which will be used to provide you with certain features of the Services. This Location Data is collected anonymously in a form that does not personally identify you. Location Data is aggregated with data from Devices of other Users to enhance the quality of Content Users provide to us and to enhance the quality of the Services we provide to you. We may also share your Location data with third parties. Location Data is shared anonymously in a form that would not personally identify you.
(c) Use Data. When you send or receive Content using our Services, we collect data about that Content.
(d) Log Information. When you browse our Services, you do so anonymously, unless you have previously created a Account with us. However, we may log your IP address to give us an idea of which part of our Services you visit and how long you spend there. However, we do not link your IP address to any Personal Data unless you have logged into our Services. Also, our Services may use a standard technology called a ‘cookie’ to collect information about how you interact with our Services. Please see Section 7 below for more information.
(e) Ad Data. The Website may use ‘Google AdSense’ by Google, Inc. (“Google”) to integrate advertisements on the Services. Google AdSense uses ‘cookies’ and ‘web beacons’. If this Website uses ‘Google AdSense’, then information about the use of this Website (including your IP address) and the delivery of advertising formats generated by cookies and web beacons will be processed to a server of Google in the United States and will be saved there. This information may be processed to contractual partners of Google by Google. Google will not associate your IP address with any other Google data. Through the use of this Website, you express your consent to the processing of data collected by Google about you in the manner and for the purposes described in this Policy and in Google’s partner data policy here: http://www.google.com/policies/privacy/partners/.
(f) Aggregate Data. Certain aspects of our Services are set up to collect and report aggregate information. Aggregate information is data we collect about the use of the Services or about a group or category of products, services or Users, from which individual identities or other Personal Data has been removed. In other words, information about how you use the Services may be collected and combined with information about how others use the Services. Aggregate data helps us understand trends and User’s needs so that we can better consider new features or otherwise tailor our Services. This Policy does not restrict what we can do with aggregate information.
(h) Device Information. We may collect data about the computer or Device you use to access our Services, including the hardware model, operating system and version, MAC address, unique device identifier (‘UDI’), phone number, and mobile carrier information.
(i) Tracking Technologies. We collect information through technology, such as cookies, flash cookies and web beacons, including when you visit our Services or Linked Sites. Please see Section 7 below for further information regarding tracking technologies.
(j) From Third Parties. We acquire information from other trusted sources to update or supplement the information you provided or we collected automatically. Local law may require that you authorize the third-party to share your information with us before we can acquire it.
2. How We Use It. We use, allow access to, or disclose your Personal Data to third parties with whom we partner in order to:
(a) enable us to provide the Services to you;
(b) notify you regarding Services, your Account, or fees;
(c) increase the usability of the Services;
(d) provide information about promotional offers;
(e) deliver advertisements on our Services and on the websites of advertising partners, to improve and monitor advertising, and to provide you with targeted advertisements;
(f) investigate objectionable use of the Services;
(h) analyze trends and use of our Services; and
(i) carry on our business, as determined by us.
3. Who We Share It With.
We will share your Personal Data with third parties:
(a) When you have enabled us to share your Personal Data with another company or our Affiliates, such as: in sending you offers and promotions about their products and services; or allowing us to share your personal data with third parties or Linked Sites, such as Social Media Accounts. Once we share your Personal Data with another company, the information received by the other company becomes subject to the other company’s privacy practices.
(b) When necessary, as determined by us in our sole discretion, to provide Services to you. This includes for the uses listed in Section 2 above.
(c) When required by law or by court order.
(d) To protect our rights and property, to prevent fraudulent activity or other deceptive practices of Users or third parties, or to prevent harm to others.
(e) If we are acquired by or merged with another company, or if our assets are sold to another company. In all of these circumstances, you understand and agree that our Terms of Service and this Policy will be assigned and delegated to the other company.
(f) To perform tasks for us or in connection with our business, as determined by us. We may use third parties to help operate the Services and perform other aspects of the Services. You agree we may share your Personal Data with our Affiliates and other third parties that provide services to us in connection with our business (such as website or database hosting companies, address list hosting companies, email service providers, analytics companies, distribution companies, and other similar service providers that use such information on our behalf). Unless otherwise stated, these third parties do not have any right to use the Personal Data we provide to them beyond what is necessary for them to assist us, as determined by us.
4. Your Choices.
(a) Any Content that you Post may be searchable by other Users and third parties as well as subject to use by others. Once you have Posted Content or made it viewable to others, that Content may be re-shared by others and we have no control or liability regarding how others my use the Content you Post. We make every effort to prevent undesired disclosure of Content or Personal Data. However, we are not responsible for how others may use Content or Personal Data that is disclosed by you to Users or third parties using the Services.
(b) The Services may allow you to share Content on Social Media Accounts. If you use such functionality of the Services, then you should use caution when determining to whom you want to make Content available. If you choose to Post Content on third-party Social Media Accounts, then, depending on the privacy settings of your Social Media Accounts, it is possible that persons in addition to those to whom you intended to view that Content could have access to that information. Accordingly, you should use caution when sharing Content via third-party Social Media Accounts and you should carefully review the privacy practices of such Social Media Accounts.
(c) If you remove information, Personal Data, or Content that you Post to the Services, copies may remain viewable in cached and archived pages of the Services, or if other Users or third parties copied or saved that information.
(d) You may opt out of targeted advertisements from some third-party companies by visiting the Network Advertising Initiative or Digital Advertising Alliance Consumer Choice Page, which provide simple ways to opt out of ad targeting from participating third-party companies. When you opt out, your selection will be stored in a cookie that is specific to your Device or computer and the web browser you are using. The opt out cookie has an expiration date of five years. If you delete the cookies on your computer or Device, you will need to opt out again.
(e) We will contact you from time to time for marketing purposes. Unless you have opted out, this could include contacting you by phone or email. You may opt-out of receiving marketing communications from us by the following means: (i) contacting us at firstname.lastname@example.org; (ii) following the instructions in the communication; or (iii) by mailing the request to us at Top of Insurance, 1330 6th ave suite 23A, New York, NY 10019
5. Security of Your Personal Information.
We exercise care and prudence in protecting the security of Personal Data provided to us. We carefully protect your data from loss, misuse, unauthorized access or disclosure, alteration, or destruction. Specifically, our Payment Processor uses Secured Socket Layer (‘SSL’) encryption when collecting, storing, or transferring sensitive data. Personal Data is stored in password-controlled servers with limited access. However, you have a significant role in Account security. Someone may see or edit your Personal Data if that person gains access to your username and password, so do not share these with others. WE TAKE THESE PRECAUTIONS IN AN EFFORT TO PROTECT YOUR INFORMATION AGAINST SECURITY BREACHES. HOWEVER, THIS IS NOT A GUARANTEE THAT SUCH INFORMATION MAY NOT BE ACCESSED, DISCLOSED, ALTERED, OR DESTROYED BY BREACH OF SUCH FIREWALLS AND SECURE SERVER SOFTWARE. BY USING THE WEBSITE, YOU ACKNOWLEDGE THAT YOU UNDERSTAND AND AGREE TO ASSUME THESE RISKS.
6. Your Account.
Users may review and update Personal Data by logging into their Account. If your Account is terminated by you or us, we will remove your name and other Personal Data from our publicly viewable database. If you close your Account, we have no obligation to retain your information, and may delete any or all of your Account information without liability. However, we may retain Content related to you for any reason we determine. We may also retain and use Content Posted by you if necessary to provide Services to other Users. We disclaim any liability in relation to the deletion or retention (subject to the terms of this Policy) of Content or any obligation not to delete the Content.
7. Cookies, Tracking Technology, and Do Not Track Requests.
(b) ‘Do Not Track’ is a webpage standard that is currently under development. As it is not yet finalized, we adhere to the standards set out in this Policy, and we will do our best to honor a ‘Do Not Track’ but shall have no obligation to do so. Further, you understand and agree that we shall not be liable for and you expressly release, indemnify, hold harmless, and defend us from any claims you may have related to our inability to honor a ‘Do Not Track’ request.
8. Compliance with the Children’s Online Privacy Protection Act.
We recognize the need to provide further privacy protections with respect to Personal Data we may collect from Children who use our Services. For that reason, we make every effort to comply with the regulations of the Children’s Online Privacy Protection Act of 1998 (at 15 USC § 6501–6506). We never collect or maintain Personal Data through the Services from those we actually know are under thirteen (13), and no part of the Services are structured to attract anyone under thirteen (13). We expressly disclaim, and you expressly release us from, any and all liability whatsoever for any controversies, claims, suits, injuries, harm, loss, penalties, damages, arising from and/or in any way related to any misrepresentations regarding the age of any User. We reserve the right to suspend and/or terminate with or without notice the Account of User who we believe has provided false information when registering for and/or using the Services and each User agrees to make no further use of the Services after termination and/or during suspension.
9. Linked Sites.
The Services and/or third parties may provide links to Linked Sites and data provided by third parties. However, we are not responsible for the privacy practices employed by Linked Sites, nor are we responsible for the information or materials that third-party data contains. This Policy applies solely to information collected by us through the Services; thus when you use a link to go from the Services to a Linked Site, this Policy is no longer in effect. We encourage Users to read the privacy policies of Linked Sites before proceeding to use them. When you conduct e-commerce with a Linked Site, certain Personal Data may be collected by the Linked Site and made available to us.
10. Advertisement Revenue.
The Services may display advertisements operated by us, our Affiliates, and/or third parties. Some of the advertisements we display are targeted to you based on your online behavior and your click habits and we may receive compensation based on your clicks.
11. In the Event of Sale or Bankruptcy
The ownership of the site, topofinsurance.com or the company, Top of Insurance, may change at some point in the future. Should that occur, we want this site and the company to be able to maintain a relationship with you. In the event of a sale, merger, public offering, conversion of the company entity into a different business entity, bankruptcy or other change in control of Top of Insurance, your information may be shared with the person or business that owns or controls this site or the company. Opting out of receiving information from third parties will not affect our right to transfer your information to a new owner, but your choices will continue to be respected regarding the use of your information.
12. GDPR and European Individuals
As described in this privacy statement, we will not process your information without a lawful basis to do so. We will process your user information with your legal consent (when you voluntarily provide information or opt in) or on the basis of contract law (when you enter into a transaction with us), or when we have a legal obligation to do so. As described herein, we may also process certain user information on the basis of the following legitimate interests, provided that such interests are not overridden by your privacy rights and interests: delivering content, and further developments and improvements to the Site, learning from analyzing traffic to better serve all Site users, to analyze the likes and dislikes of our users, and to help us to provide a more stable, consistent, and secure user experience. If you have any questions regarding this please contact us.
13. California Consumer Privacy Act (CCPA)
California residents have the right to:
(a) a specific list of exactly what categories of information you are collecting, how you are using it and what the purpose of this information is;
(b) Links on the Website to opt-out of data collection or have their data removed;
(c) Access to a link on your account Account management that selects:
“Do Not Sell My Personal Information” and link to custom page
(d) Information explaining at least two methods of contacting you in order to update, change, remove or transfer personal information;
(f) equal treatment for Californian residents by the owner and operator of this Website, despite the additional protections afforded to California residents under the CCPA; and
(g) this list of your rights as California residents.
14. Changes to our Policy; Miscellaneous; Anti-Spam provision; Payment Processors.
(a) We reserve the right to change this Policy, our Terms of Service, and our other Policies at any time. We will notify you about changes to this Policy by placing the updated Policy on the Services. You agree that your use of the Services after such notification will constitute acceptance by you of such changes to our Policy. This Policy is and any disputes in connection with this Policy are subject to our Terms of Service and our other Policies which are each hereby incorporated herein by reference. In the event of any conflict between the provisions of this Policy and our Tervms of Service, our Terms of Service shall control.
We will only send email and cellular phone messages to you such as SMS or MMS with your explicit content. Please contact us immediately at email@example.com if you receive any of this type of communication without your consent.
This Website collects some Personal Data from its Users.
Personal Data collected for the following purposes and using the following services:
- Facebook Lookalike Audience, Google AdSense, Google Ad Manager, Google Ads Similar audiences and Google DV360
Personal Data: Tracker; Usage Data
- Facebook Audience Network
Personal Data: Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data
- Google Campaign Manager 360
Personal Data: geographic position; Tracker; Usage Data
- Facebook Ads conversion tracking (Facebook pixel), Google Analytics and AdEspresso conversion tracking
Personal Data: Tracker; Usage Data
- Contacting the User
- Mailing list or newsletter
Personal Data: email address; first name; phone number
- Interaction with data collection platforms and other third parties
- ActiveCampaign widget
Personal Data: email address; first name; phone number
- Interaction with external social networks and platforms
- Facebook Like button and social widgets
Personal Data: Tracker; Usage Data
- Managing contacts and sending messages
- ActiveCampaign Text Message and SMS Marketing
Personal Data: email address; first name; phone number
- Managing data collection and online surveys
- Facebook lead ads
Personal Data: email address; first name
- Remarketing and behavioral targeting
- Facebook Custom Audience
Personal Data: email address; Tracker
- Facebook Remarketing, Google Ads Remarketing and Google Ad Manager Audience Extension
Personal Data: Tracker; Usage Data
- SPAM protection
- Tag Management
- Google Tag Manager
Personal Data: Usage Data
- User database management
Further information about Personal Data
- CCPA: Collection of personal information about minors
We do not knowingly collect personal information of consumers who are below the age of 16.
- iubenda CCPA Cookie (usprivacy)
iubenda CCPA Cookie (usprivacy) is set by the iubenda Cookie Solution and stores California consumer opt-out choices in the local domain.
- iubenda Cookie Solution (consent Cookie)
iubenda consent Cookie (_iub_cs-X) is set by the iubenda Cookie Solution and stores User preferences related to Trackers in the local domain.
- Personal Data collected through sources other than the User
The Owner of this Website may have legitimately collected Personal Data relating to Users without their knowledge by reusing or sourcing them from third parties on the grounds mentioned in the section specifying the legal basis of processing.
Where the Owner has collected Personal Data in such a manner, Users may find specific information regarding the source within the relevant sections of this document or by contacting the Owner.
- Preference Cookies
Preference Cookies store the User preferences detected on this Website in the local domain such as, for example, their timezone and region.
- Rights for registered California Users under the age of 18
California’s “Online Eraser” law, part of California’s Business and Professions Code Sections 22580-22582, requires operators of certain websites and online services targeting minors to allow registered Users who are under the age of 18 and residents of California to request removal of content they post.
In response to this request, the Owner may make content posted by the registered User invisible to other registered Users and the public (rather than deleting it entirely), in which case the content may remain on the Owner’s servers. It may also be publicly available elsewhere if a third party copied and reposted this content.
- The Service is intended for adults
Users declare themselves to be adult according to their applicable legislation. Minors may not use this Website.
- The Service is not directed to children under the age of 13
Users declare themselves to be adult according to their applicable legislation. Minors may use this Website only with the assistance of a parent or guardian. Under no circumstance persons under the age of 13 may use this Website.
- Unique device identification
This Website may track Users by storing a unique identifier of their device, for analytics purposes or for storing Users’ preferences.
- User identification via a universally unique identifier (UUID)
This Website may track Users by storing a so-called universally unique identifier (or short UUID) for analytics purposes or for storing Users’ preferences. This identifier is generated upon installation of this Application, it persists between Application launches and updates, but it is lost when the User deletes the Application. A reinstall generates a new UUID.
- Owner and Data Controller
Top of Insurance
1330 6th ave suite 23A, New York, NY 10019
15. Questions or Comments Regarding this Policy. We value your comments and opinions
If you have questions, comments or a complaint about compliance with this Policy, you may send a written notice to us at: firstname.lastname@example.org 1330 6th ave suite 23A, New York, NY 10019