Top Choice Marketers, LLC, along with its subsidiaries and affiliates (jointly referred to as “Top Choice Marketers,””The Company,””We,”or “Us”), warmly welcomes you to its digital platforms. The terms “you”and “your”refer to you, the reader, and all other individuals visiting our online and mobile platforms who are above the age of 13.
Online and mobile resources refer to the websites and other digital features owned by us, which allow you to engage with our websites. It also includes the apps developed and propagated by us, enabling our customers and followers to access our digital platforms and interact with the content we offer.
WHO WE COLLECT PERSONAL INFORMATION FROM
We gather personal data from various groups, such as those who visit and use our digital platforms, our valued customers, our dedicated team, job applicants, and our third-party associates and partners.
Personal data typically refers to information that can identify you or is easily associated with you—like your name, address, phone number, email, social security number, and birth date. In some regions, privacy laws extend the definition of personal data to include unique aspects. If we fall under such jurisdiction, like the California Consumer Privacy Act (CCPA) or European General Data Protection Regulation (GDPR), we include these unique aspects as part of “personal data”.
The type and use of data we collect vary from group to group. Interestingly, one individual could be part of multiple groups. This statement mostly discusses how we handle the personal data collected from digital platform users and our customers.
Furthermore, as you might expect, we collect and keep professional and employment-based personal data about our current and past team members as well as job applicants. We give legally mandated collection notices and further explain how we use and share our team’s personal data in confidential HR manuals and documents, or through our proprietary staff/applicant portals and apps. Sometimes, these portals and apps are managed by third parties who pass the data onto us. In such cases, it’s often the third party’s legal duty to notify, not ours.
Like any corporation, we purchase products and services, rent equipment and office space, and participate in industry-related events. This means we interact with, and collect personal data from, plenty of existing and potential vendors and business partners. Similar to our customers, this data usually only includes basic business contact information. We use and share this data to manage our contracts, fulfill our duties, and share product information. We further explain our use of vendor and business partner data in our confidential contracts or through our internal vendor management portals.
WHAT WE COLLECT
When you’re surfing our digital platforms or deciding to buy our products or services, we gather two sorts of data from you: (i) non-personal data that we automatically collect from everybody, like the operating system of your device, and (ii) personal data that you willingly share with us or that we collect automatically.
Let’s Talk About the Information You Share.
Certain activities on our online and mobile platforms will ask for some information about you. The personal information we gather might include identifiers like your name, email, postal address, and phone number. We may also collect professional details about your line of work and financial information like credit card details. Rest assured, we don’t sell, rent, or share this data with third parties.
If you’d rather we didn’t have this information, simply don’t provide it. That means steering clear of any activities on our platforms that ask for this data. You might want to connect with us via phone or regular mail instead. Not participating is entirely up to you. It might limit your experience on our digital platforms, but you’ll still be able to access public information.
Here are several ways you could end up sharing your personal data with us and what we do with it:
Emails and Online Forms – Sending an email or completing an online form, such as to contact us, means we’ll keep your email address and any other personal details you provide. We use this information to respond to you and handle your request. You might hear back from us via email, phone calls, or text messages. We may also send you information about our products or services that you might find interesting.
Signing Up for an Account – When you or your child sign up for an account, the personal information you provide, like names and email addresses, is stored by us. We use this data to create and manage your account, and sometimes to set up a password and profile. We’ll communicate with you and any sub-accounts via email.
Enrolling for Events – If you sign up for services, webinars, events, conferences, or programs that we host, you’ll need to provide the identifiers mentioned earlier. If there’s a fee for the event, you might need to provide your credit card or other financial details. We use this data to register you for the event and to keep you updated about it.
Subscribing to Our Service – We use customer information to fulfill our contractual obligations and deliver the products and services they’ve bought, manage their accounts, and communicate with them.
Social Media and Community Features – Some of our digital platforms have social media-like features where users can post messages and comments or upload images or files. If you use these features, remember that your posts, including your screen name and any other personal details, become public and are not protected by this policy.
WHEN/WITH WHOM DO WE SHARE PERSONAL INFORMATION
We harness non-personal data to manage and enhance our digital platforms, making informed business decisions about the kind of programs our customers might enjoy.
When you willingly offer us your private details, we utilize them to address your concerns and provide the services you seek, among other things as detailed later on. Rest assured, we do not trade or lease your personal data to third-party data sellers or advertising firms. As expected, we only disclose your information when it’s mandated by law.
Legally Compelled Disclosures.
We might share your details, including personal ones, with governmental bodies and other external parties. This can occur when such authorities compel us, or at times of our choosing, or as the law dictates or allows. This can include responses to court orders and subpoenas.
To Prevent Harm.
We reserve the right to share your details, including personal data, when we suspect that someone is infringing on our rights or property. This also applies when we believe our online and mobile users, or any other party, may be in harm’s way due to such activities.
In the event that we, or any of our partner entities, or a significant majority of our combined assets, are purchased by a third party or parties through a process such as an acquisition, merger, sale, reorganization, consolidation, or even liquidation, it’s possible that personal information could be among the assets transferred.
Vendors and Business Partners.
Your information, which might include personal data, could be passed on to our vendors and other third parties we’re contractually connected with. We may also share your information, including personal details, with vendors providing third-party software services that you’ve chosen to support your marketing efforts. We always aim to only divulge the necessary details to each of these entities.
We enforce specific standards for vendors and business partners who obtain personal information from us. Our goal is to bind these partners and vendors to these standards via written contracts. We also attempt to restrict, through contractual agreements, how our vendors and business partners handle the personal data we share. This ensures that the data is only used as necessary for the business purpose it was provided for; it’s not shared with anyone else without our permission or direction; and it continues to be our property held between us and the relevant vendor or business partner; and it is not relocated outside of the United States without our agreement.
However, bear in mind that we can’t guarantee that all our vendors and business partners will fulfill these contractual commitments. Even if they do agree, we can’t assure that they will remain entirely compliant at all times.
YOUR RIGHTS AND OPTIONS
You can freely enjoy most features of our online and mobile resources without giving away your personal information. Plus, you have the choice to unsubscribe from certain activities, such as newsletters and announcements. If you’re a California resident, or if your personal data was collected in GDPR Jurisdictions, you’re entitled to extra rights.
When we refer to GDPR Jurisdictions, we’re talking about countries that are part of the European Economic Area, which includes Iceland, Lichtenstein, and Norway, as well as Austria, Belgium, Bulgaria, Croatia, Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, the Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, and Sweden.
In addition, countries like Andorra, Argentina, Canada (only commercial organizations), Faroe Islands, Guernsey, Israel, Isle of Man, Jersey, New Zealand, Switzerland, Uruguay, and Japan have been given a “thumbs up”by the European Commission, meaning they comply with the key terms of the GDPR. Switzerland also has its own system of data protection with its Federal Act of Data Protection, or “DPA”.
The United Kingdom, having officially departed from the European Union, no longer falls under the jurisdiction of the GDPR. They now have their own set of data privacy laws, known as the United Kingdom General Data Protection Regulation, or “UK-GDPR”, which governs the handling of personal data within the UK.
If we’re using your personal information to send you updates, like newsletters or product alerts via text or email, and you decide you’ve had enough, you can opt-out. Just follow the instructions in the email or other communication (for example, by replying to the text with “STOP”), or get in touch with us using the contact information provided. We’ll make sure to remove your name from our distribution lists as soon as we can, but please be aware that it might take some time, so you might still receive some materials for a short while after you opt out. Besides opting out, you can also access, amend, and delete your personal information by reaching out to us.
Some web browsers have a “do not track”feature that allows you to tell websites not to keep tabs on your online activities. Currently, we don’t have a specific response to browser “do not track”signals.
Federal laws put specific requirements on commercial web operators who target and collect information from children under 13. We fully understand these age-specific regulations and therefore, we do not plan for our online and mobile platforms to be used by children under 13 without the confirmed approval of their parent or legal guardian. Furthermore, we don’t knowingly gather personal data from children under 13. Only a parent or legal guardian can provide this information after they have followed our verification process to share such data through our online and mobile platforms.
If we discover that anyone under 18 has provided personal data to our online and mobile platforms, we will promptly remove that information and won’t use it for any purpose at all. If you suspect that an individual under 18 has given their personal data to our online and mobile platforms, please get in touch with us at firstname.lastname@example.org. We urge parents and legal guardians to have conversations with their kids about the possible risks of sharing personal information online.
HOW WE PROTECT COLLECTED PERSONAL INFORMATION
We’re fully committed to safeguarding your personal data that you entrust to our online and mobile platforms. Our adopted security program incorporates a variety of measures – technical, administrative, and organizational – all designed to shield your personal information against any anticipated or actual threats. These measures align with industry standards and legal requirements (the “Security Program”). However, we must admit that we cannot provide an absolute guarantee against unauthorized access, loss, misuse, or alteration of your data while it’s being transmitted, stored on our systems, or under our care. Apart from our legal obligation to maintain the Security Program, we cannot accept liability for any data theft, loss, unauthorized access, or damage. We are confident, though, that our Security Program is robust and suited to our business needs and the foreseeable risks to the personal data we handle. We also make it a point to regularly review and improve our Security Program, as required by the law.
Despite this, part of our Security Program includes certain procedures for incident response and management, which are triggered whenever we suspect your personal information may have been compromised. In addition, we mandate our vendors and business partners to alert us promptly if they have any inkling of an incident that could negatively impact the personal information we’ve shared with them.
THE CALIFORNIA CONSUMER PRIVACY ACT
Whenever we gather personal data from those residing in California, we find ourselves under the purview of the California Consumer Privacy Act, or “CCPA”. As such, these residents are entitled to certain rights under this Act. This part of our statement is constructed to help us meet our responsibilities under the CCPA and to clarify your rights as dictated by the Act. For the purpose of this section, the terms “you” and “your” are exclusively referring to the residents of California.
What did we collect from California Residents?
We gather a variety of personal details, which fall under these categories: identifiers like your name, residence, IP address, and other similar details; personal data as mentioned in Section 1798.80 subdivision (e) (pertaining to California customer records) such as your name, address, contact number, and credit card details; business-related information like the services or products you’ve purchased; internet or electronic activities like your browsing and search history; geolocation details including your physical location or geographical coordinates; and electronic data like audio, video, or other similar information. We may share this information for one or more business-related reasons allowed by the CCPA. Rest assured, we don’t sell your personal information to third parties, and we haven’t done so in the last 12 months.
Rights of California Residents
Under California’s Consumer Privacy Act (CCPA), you are granted certain rights, which include disclosure, access, and deletion of your personal data. For a more detailed understanding, you can visit our link. We want to assure you that irrespective of you exercising these rights or not, there will be no differential treatment towards you compared to other Californian users of our websites, mobile platforms, and services.
You have the provision to exercise these rights twice in a year. To action this, simply reach out to us at email@example.com. We might ask you to complete a request form, purely to ensure your identity or authority to make the request. This is a mandate under the CCPA, which allows us to proceed only once your identity has been authenticated.
Upon successful verification of your request, we will acknowledge its receipt and respond within the timeframe stipulated under the CCPA.
THE EU GENERAL DATA PROTECTION REGULATION
We do gather personal details from individuals residing in regions covered by the GDPR. We meet our GDPR responsibilities to our employees/applicants, our clients (and their customers), and our suppliers and business partners by providing them with specific notices, contracts, or terms at the time, and in the way and format, as dictated by the GDPR and local laws within each GDPR jurisdiction.
We will now outline how we adhere to GDPR protocols for the personal information we collect from visitors and users of our online and mobile resources while they are in a GDPR jurisdiction. For the purposes of this section, “you”and “your”refer only to visitors and users based in a GDPR jurisdiction.
So, what information do we collect from you in the GDPR jurisdictions and how do we use it?
We gather from you the types of personal information previously mentioned. Our legal basis for such actions, including collection, subsequent use, and disclosure, is what the GDPR calls ‘legitimate interest.’ As mentioned elsewhere in this statement, we do not sell any of your personal data to third parties, nor do we use it for automated decision making.
Cross-border Data Transfers and Third-Party Processors
In the case that we move personal data out of regions covered by the GDPR to places not recognized by the European Commission for having sufficient privacy safeguards, we stick to the methods allowed by the GDPR.
Rights of Data Subjects in the GDPR Jurisdictions
We’re committed to providing all our online and mobile users with a level of control over their personal data, but under GDPR rules, we have a legal duty to do so expressly for you. In simpler terms, this means if you’re in a region governed by GDPR, you have certain rights concerning the personal data we collect from you. These rights include transparency, access, correction and deletion, portability, and the right to know who, what, why, and where. You also have the right to restriction/objection. To know more about these rights, please click here.
If you’re interested in exercising any of these rights, don’t hesitate to reach out to us at firstname.lastname@example.org. However, be aware that certain conditions and exemptions, outlined in Articles 12 through 23 of the GDPR, may affect your ability to exercise these rights. For instance, we may have to decline part or all of your request if we can’t adequately verify your identity, as we need to ensure that no unauthorized persons gain access to your personal data under the guise of GDPR rights. Rest assured, we’ll promptly respond to all requests, in line with any timelines set by the GDPR. If you’re unhappy with how we handle your personal data or respond to your requests, it’s your right to lodge a complaint with your data protection regulator. You can find the contact details of EU data protection regulators here.
RIGHTS OF DATA SUBJECTS IN OTHER JURISDICTIONS
In other areas that have similar data privacy rules, we may gather the same categories of personal information from you as previously mentioned. We adhere to local laws when handling (including disclosing) this data. It’s important to note that we don’t sell your personal information to third parties, nor do we employ it for automated decision-making processes.
CHANGES TO THIS PRIVACY STATEMENT
We hold the authority to modify or refresh this policy periodically. We encourage you to visit our online and mobile platforms from time to time to stay abreast of any changes, as any data we gather is governed by the policy that’s in effect at that particular time.
If you have questions about our privacy statement or privacy practices, please contact us at:
Top Choice Marketers LLC
Attn: Legal & Compliance Department
When you accept our terms of service, it means that you are giving your consent to receive different forms of communication from Top Choice Marketers LLC. This includes conventional mail, emails, phone calls, and automated voice messages. The communications will be coming from us and our various business sections, partners, affiliates, vendors, list administrators, and clients who buy our lists. In addition, you give us permission to contact you repeatedly as part of our SMS/MMS mobile message marketing program.
We reserve the right to sell your personal information that you share with us. We also collaborate with other businesses to offer our members exclusive retail opportunities. These may be brought to you through direct mail, email, SMS, text, and telemarketing, which can include prerecorded phone messages.
If you disagree with our terms and conditions, we kindly ask you not to digitally sign this agreement or submit any forms on our websites.
In case you wish to unsubscribe from any of our communication mediums, such as emails, phone calls, SMS, or robo-dialing, you can do so by sending an email to email@example.com. Please include the phone number or email address that you want to be removed.