The purpose of this Privacy Policy is to inform you of how the Company (“Company” or “we” or “our” or “us”) processes, collects, uses and discloses the personal data that we collect from you when you visit topreviews4you.com or any other website that we own or operate (the "Websites" or the “Sites”), how such data will be used by the Company (as defined below), its Advertising Partners, and/or other persons or entities with whom such data may be shared, as well as your choices regarding the processing, collection, use and distribution of such data and the security measures that we have implemented to protect your privacy. Please read this Privacy Policy carefully to understand our policies and procedures regarding your personal data and how it will be processed.
BY CONTINUING TO USE THE WEBSITES, YOU PROMISE US THAT YOU HAVE READ, UNDERSTAND AND AGREE TO BE BOUND BY THIS PRIVACY POLICY, AS AMENDED FROM TIME TO TIME BY THE COMPANY AT ITS SOLE AND ABSOLUTE DISCRETION. You further agree to regularly review this Privacy Policy to ensure that you are familiar with Company's most-current policies and procedures. Your continued use of the Websites after we make changes is deemed to accept those changes. If you do not agree or are unable to make this promise, you must not use the Websites.
If required by law, we will make reasonable efforts to contact you about material changes or updates to this Privacy Policy; if you have provided us with an email address, you agree that we may email you a notice regarding such changes or updates; if you have not provided us with an email address, you agree to view this page periodically and when our site informs you that this Privacy Policy has been updated.
If you voluntarily contact us by sending an email or any other request or notification, you may be required to provide us with specific personal data such as your name and email address.
Usage Data has collected automatically when using the Websites. Usage Data may include information such as your Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Websites that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
We use cookies to track the activity on our Websites and store certain information.
Via our Websites, if you voluntarily contact us by sending an email or any other request or notification regarding questions, queries, comments or complaints. When you do so, we will collect the data you fill out, including your name and email address. Therefore, we use this data for our legitimate interest in conducting business with you or establishing our future contract with you.
When you access the Websites, we may collect certain data automatically, including Usage Data, cookies, and similar tracking technologies. This data is collected for our legitimate interest in improving and administering our Websites, including data analysis, troubleshooting, and statistical and survey purposes.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may be unable to use some parts of our Websites.
If necessary, we may share your personal data with Service providers to monitor and analyze the use of our Websites, store the personal data, show advertisements to you, help support and maintain our Websites, contact you, etc. We have concluded agreements with our Service providers to protect your personal data.
If the Company is involved in a merger, acquisition, reorganization, assignment, transfer, change of control or asset sale, your personal data may be transferred to third parties in connection with such transaction. We will provide notice before your personal data is transferred and becomes subject to a different Privacy Policy.
We may share your personal data with our business partners to offer you certain products, services or promotions.
Under certain circumstances, the Company may be required to disclose your personal data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
The Company may disclose your personal data in the good faith belief that such action is necessary to comply with a legal obligation, to protect and defend the rights or property of the Company, to prevent or investigate possible wrongdoing in connection with the Websites, to protect the personal safety of users of the Websites or the public, to protect against legal liability.
When you access the Websites, we may use “cookies” (or similar tracking technologies). The use of cookies is a standard industry-wide practice. A “cookie” is a small piece of information that a website assigns and stores on your computer while you are viewing a website. Cookies are very helpful and can be used for various different purposes. These purposes include allowing you to navigate between pages efficiently, enabling automatic activation of certain features, remembering your preferences and making the interaction between you and our Websites quicker and easier. Cookies are also used to help customize your experience.
There are several types of cookies, and among others:
Most browsers will allow you to erase cookies from your computer’s hard drive, block the acceptance of cookies, or receive a warning before a cookie is stored. You may remove our cookies by following the instructions of your device preferences. However, if you block or erase cookies, some features of the Websites may not operate properly, and your online experience may be limited.
The Websites are not intended for individuals under the age of eighteen (18); accordingly, we do not use the Websites to knowingly solicit data from or market to children defined under applicable law (e.g. thirteen (13) regarding US individuals and sixteen (16) regarding European Economic Area (“EEA”) individuals). We request that such individuals do not provide personal data through our Websites. We reserve the right to request proof of age at any stage so that we can verify that children under the age of eighteen (18) are not using the Websites. If you become aware or have any reason to believe that a child has shared with us, please contact us, and we will take reasonable steps to ensure that such data is deleted from our files.
We will retain your personal data only for as long as is necessary for the purposes set out in this Privacy Policy. For example, we will retain and use your personal data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Websites, or we are legally obligated to retain this data for longer time periods.
We may store or process your personal data in the EEA or in other countries. If you visit our Websites from locations outside of the EEA, please note that any data you provide to us through your use of our Websites may be transferred to and processed in countries other than the country from which you accessed our Websites. If you are a resident of the EEA, we will take appropriate measures to ensure that your personal data receives adequate data protection upon its transfer outside of the EEA. If you are a resident of a jurisdiction where the transfer of your personal data requires consent, then your consent to this Privacy Policy includes your express consent for such transfer of your data.
We take great care in implementing and maintaining the security measures of the Websites and your personal data. We employ industry standard procedures and policies and implement technical and administrative security measures to ensure the safety of our user’s personal data and prevent unauthorized access or use of any such personal data. However, no data transmission over the internet or any wireless network can be guaranteed to be 100% secure, and we can not be responsible for the acts of those who gain unauthorized access or abuse our Websites, and we make no warranty, express, implied or otherwise, that we will prevent such access.
We may adopt what we believe is appropriate data collection, storage, and processing practices and security measures to protect against unauthorized access to such data and according to applicable law requirements. If you feel that your privacy was treated not in accordance with our Privacy Policy, or if any person attempted to abuse our Websites or acted in an appropriate manner, please contact us directly.
We reserve the right to amend this Privacy Policy at our sole discretion and at any time. If we make changes to this Privacy Policy, we will immediately post the updated Privacy Policy on our Websites and update the relevant, effective date. Any such changes will be effective immediately upon being posted unless otherwise stated in the change. Your continued use of our Websites following the posting of changes constitutes your acceptance of such changes.
If you are an individual in the European Union or European Economic Area (EEA), we collect and process data about you only where we have a legal basis for doing so under applicable EU laws, including the General Data Protection Regulation (GDPR). The legal basis depends on the way in which you use Websites. This means we collect and use your data only where:
In any case, we will gladly help clarify the specific legal basis that applies to the processing, particularly whether the provision of personal data is a statutory or contractual requirement or a requirement necessary to enter into a contract.
We respect the confidentiality of your personal data and guarantee you can exercise your rights. You have the right under this Privacy Policy, and by law, if you are within the EU/EEA, to:
If you wish to exercise any of the rights set out above, please contact us.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
We may disclose aggregated data about our users and information that does not identify any individual without restriction. We may disclose personal data that we collect or you provide as described in this Privacy Policy:
We may also disclose your personal data:
The Websites contain links to websites operated and maintained by third parties over which Company has no control. Any data you provide to third-party websites will be governed under the terms of use or privacy policy of those respective third parties. Accordingly, we strongly encourage you to investigate and ask questions before disclosing any data to the operators of third-party websites and to familiarise yourself with their privacy practices by reviewing their privacy notices and privacy policies.
The inclusion of third-party websites on or through our Websites in no way constitutes an express or implied endorsement of such websites' policies or notices.
We collect data that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device. The following is a list of categories of personal data that we may have collected from California residents within the last twelve (12) months.
Please be aware that the categories and examples provided in the list below are those defined in the California Consumer Privacy Act (“CCPA”) and California Privacy Rights Act (“CPRA”). This does not mean that all examples of that category of personal data were, in fact, collected by us but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been collected. For example, certain categories of personal data would only be collected if you provided such personal data directly to us.
Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver's license number, passport number, or other similar identifiers.
Collected: Yes.
Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.
Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
Collected: No.
Examples: Records and history of products or services purchased or considered.
Examples: Genetic, physiological, behavioral, and biological characteristics or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
Examples: Interaction with our Websites.
Examples: Approximate physical location.
Examples: Audio, electronic, visual, thermal, olfactory, or similar information.
Examples: Current or past job history or performance evaluations.
Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
Examples: Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Examples: social security, driver’s license, state identification card, or passport number; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin, religious or philosophical beliefs, or union membership; the contents of the email, email, and text messages unless the business is the intended recipient of the communication; genetic data; the processing of biometric information for the purpose of uniquely identifying; personal data collected and analyzed concerning health; personal information collected and analyzed concerning sex life or sexual orientation.
Under CCPA and CPRA, personal data does not include:
We may use or disclose personal data we collect for "business purposes" or "commercial purposes" (as defined under the CCPA and CPRA), which may include the following examples:
If we decide to collect additional categories of personal data or use the personal data we collected for materially different, unrelated, or incompatible purposes, we will update this Privacy Policy.
We may disclose your personal data to a third party for business purposes or sell your personal data, subject to your right to opt out of those sales. When we disclose personal data for a business purpose, we enter a contract that describes the purpose and requires the recipient to keep that personal data confidential and not use it for any purpose except the contract. The CCPA, CPRA, and Virginia Consumer Data Protection Act (“VCDPA”) prohibit third parties who purchase the personal data we hold from reselling it unless you have received explicit notice and an opportunity to opt out of further sales.
We share your personal data with the following categories of third parties:
We may use or disclose and may have used or disclosed in the last twelve (12) months the following categories of personal data for business or commercial purposes:
Please note that the categories listed above are those defined in the CCPA and CPRA. This does not mean that all examples of that category of personal information were, in fact disclosed but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been disclosed.
As defined in the CCPA and CPRA, "sell" and "sale" mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's personal data by the business to a third party for monetary or other valuable consideration. This means that we may have received some kind of benefit in return for sharing personal data, but not necessarily a monetary benefit.
Please note that the categories listed below are those defined in the CCPA and CPRA. This does not mean that all examples of that category of personal data were, in fact, sold but it reflects our good faith belief, to the best of our knowledge that some of that data from the applicable category may be and may have been shared for value in return.
We may sell and may have sold in the last twelve (12) months the following categories of personal data:
We do not knowingly collect personal data from minors under the age of 16 through our Websites, although certain third-party websites that we link to may do so. These third-party websites have their own terms of use and privacy policies, and we encourage parents and legal guardians to monitor their children's Internet usage and instruct their children to never provide data on other websites without their permission.
We do not sell the personal data of consumers we actually know less than 16 years of age unless we receive affirmative authorization (the "right to opt-in") from either the consumer who is between 13 and 16 years of age or the parent or guardian of a consumer less than 13 years of age. Consumers who opt in to the sale of personal data may opt out of future sales at any time. To exercise the right to opt out, you (or your authorized representative) may submit a request to us.
If you have reason to believe that a child under the age of 13 (or 16) has provided us with personal data, please contact us with sufficient detail to enable us to delete that data.
The CCPA and CPRA provide California residents, and VCDPA provides Virginia residents with specific rights regarding their personal data. If you are a resident of California and/or Virginia, you have the following rights:
a) The categories of personal data sold;
b) The categories of personal data disclosed.
For California residents
If you are 16 years of age or older, you have the right to direct us not to sell or share your personal data at any time (the "right to opt out"). We do not sell or share the personal data of consumers we actually know less than 16 years of age unless we receive affirmative authorization (the "right to opt in") from either the consumer who is between 13 and 16 years of age or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal data sales or sharing may opt out of future sales at any time.
To exercise the right to opt out, you (or your authorized representative) may submit a request to us.
For Virginia residents
Virginia residents have the right to opt out of the processing of personal data for purposes of (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer.
To exercise the right to opt out, you may submit a request to us.
“Do not track” policy is required by California Online Privacy Protection Act (CalOPPA)
Our Websites do not respond to do not track (“DNT”) signals.
However, some third-party websites do keep track of your browsing activities. If you are visiting such websites, you can set your preferences in your web browser to inform websites that you do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of your web browser.
Children’s Privacy
Our Websites do not address anyone under the age of 13. We do not knowingly collect personally identifiable data from anyone under the age of 13. If you are a parent or guardian and you are aware that your child has provided us with personal data, please contact us. If we become aware that we have collected personal data from anyone under the age of 13 without verification of parental consent, we take the necessary steps to remove that data from our servers.
If we need to rely on consent as a legal basis for processing your data and your country requires consent from a parent, we may require your parent's consent before we collect and use that data.
Other California privacy rights
California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Websites that are California residents to request certain information regarding our disclosure of personal data to third parties for their direct marketing purposes. To make such a request, please contact us.