Privacy Policy

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Who is using my data?

What is my data being used for?

Top Around stores and processes data to   help us maintain your account, process and store transaction details, offer   customer support, send system updates and send offer details.

What will happen to my data?

Top Around may use your data to send you   information, updates and offers we think you’ll be interested in.

What data will be kept and stored?

Top Around stores registration details, transaction   details, usage information and any information about your web preferences on   our website.

What data will be shared with others?

We only share your data with regulators   or government bodies if requested.

How long will my data be kept for?

Top Around will store your data for a   period of 10 years after your last attempted login. After this period, your   account will be deleted. You can request your account to be delete at any   time.

Who will be able to access my data?

Top Around will never sell or share your   data to any third-party, unless you grant us your explicit permission to do   so.

How will my data be kept and made secure?

Top Around stores your data on secure   servers that are based in the UK. Data is processed in the UK, and we use   standard industry security protocols.

Date: Jan 1st, 2015

Top Around takes your privacy seriously. That is why we will only use your personal information to provide you with the products and services you have requested, as well as to administer your account. We will not sell or share your information with third-parties you grant us explicit permission to do so, and we will never use your personal data for any reason other than the reasons described within this policy.

About our privacy policy

Our privacy policy outlines your relationship with our company and explains in detail how we use the information that you provide us with.

About Top Around

Top Around is the trading name of Top Around Media Ltd, which is registered in the United Kingdom and registered with the UK’s Information Commissioner’s Office under the Data Protection Act 2018. Our data controller is reachable at management@toparound.com, and we encourage you to get in touch with any questions you may have about Top Around.

You can reach us by:

· Post: 71-75 Shelton Street, Covent Garden, London WC2H 9JQ

· Email: management@toparound.com

· Website: https://www.toparound.com 

Changing your preferences

If you’d like to change your web, contact or marketing preferences, you can do so at any time. Simply contact us at management@toparound.com to request the necessary amendments.

How we do business

Top Around is committed to upholding and maintaining your personal rights. We operate our business in-line with the European Union’s General Data Protection Regulation and observe your rights to change or withdraw your opt-in options at any time. As part of our ongoing commitment to uphold your rights, Top Around will also extend advice on how you can issue formal complaints to relevant authorities, such as the Information Commissioner’s Office.

Sensitive data

Top Around does not collect any sensitive data about you. Sensitive data refers to (but is not limited to) information about your race or ethnic background, religious or political affiliations, trade union affiliations, sexual orientation, criminal background or health background.

Who our privacy policy applies to

This privacy policy has been developed to inform users of Top Around how we use their data. Top Around is a Digital Marketing Agency, and we need to process the data of individuals to offer our products and/or services. Bearing that in mind, our privacy policy applies to any and all individuals registered with us as a user, customer, administrator or in any other capacity.

What information this policy applies to

There is a lawful basis for processing your data, and this section of our privacy policy outlines how this applies to the personal information you provide us with or allow us to collect.

The information this policy applies to includes information that you:

· Provide as part of any registration process 

· Provide as part of any campaign creation activity

· Provide in the form of numerical data, metadata or communications

· Give us as part of our ongoing relationship

This policy also applies to information that we:

· Collect relating to how you interact with our website

· Must process to complete purchases and other transactions

Consent

Please note that when you submit personal data on our website, you are giving Top Around your explicit consent that we can use that data in line with our privacy policy. 

Opting-out 

After giving Top Around your consent, you are free to amend your consent or withdraw your consent at any time. You have the right to object to the processing of your data. To opt-out, change your preferences or revoke your consent, simply contact us by emailing management@toparound.com  

Data processing and storage

Top Around collects and stores data in the UK. We will store your data for a period of 10 years after your last recorded login attempt unless otherwise noted and explicitly stated.

Top Around stores data relating to transactions, payments and orders for a period of up to seven years. This period may be extended under certain circumstances as part of our ongoing commitment to comply with UK and international law.

We use carefully selected and recognised third-parties to help us take payments, provide commerce services and manage company accounts. Some of these third-parties may operate outside the European Union.

Top Around may process your data based on more than one legal ground.

Circumstances under which we may be required to process your data under more than one legal ground may include:

Reason: Customer registration

Data type: Identity and contact information

Legal basis: To carry out a contract we’ve made with   you

Reason: Processing and/or delivering your order

Data type: Identity, contact information, financial   information, financial and transactional data

Legal basis: To carry out a contract we’ve made with   you and to exercise our legitimate interests to recover debts owed

Reason: To manage our customer relationship with   you

Data type: Identity, contact information, marketing   and communications preferences

Legal basis: To carry out a contract we’ve made with   you, to comply with legal obligations and to exercise our legitimate   interests to keep our records updated

Marketing and communications

Top Around may send you marketing communications if you have given us your contact details and opted-in to marketing communications.

You can opt-out of these marketing communications and manage your preferences at any time.

Our company obligations

As a data controller, Top Around is legally responsible for the data you provide us with. In honouring that responsibility, we pledge to uphold our commitments under GDPR and the Data Protection Act 2018.

We will only ever use your data:

· In ways that are both fair and legal

· As described within this policy

· In ways that are necessary for the purposes described

In addition, Top Around processes the personal data you submit to us or we collect as a data processor. As part of this role, Top Around takes all necessary precautions to secure the personal data we collect, process and store.

We may occasionally use the data you provide us with for marketing, relationship management or account management activities. These activities are designed to ensure you have adequate information about other products and/or services we offer, that we have reason to believe you may be interested in. You have the right to opt-out of these activities at any time.

Third-Parties

Top Around never shares your personal data with third-parties unless those parties have been explicitly mentioned within our privacy statement.

Our security

As part of our ongoing commitment to GDPR, Top Around will report any security breaches or attempted breaches to the relevant authorities within 24 hours. We will subsequently contact all those affected by the breach within 72 hours of its occurrence. 

Legitimate interests

As part of the Data Protection Act 2018, Top Around observes the right to share selected information with third-parties that use data for non-marketing purposes. This could include (but is not limited to) organisations that provide credit assessments, identification services and fraud prevention activities.

Contact us

Top Around is committed to upholding your rights. If you have any questions, comments or concerns about this privacy policy or wish to exercise your rights in relation to your personal data, please contact the Data Protection Office at Top Around at management@toparound.com.

We will process any request within 20 days. Subject Access Requests are normally performed free of charge, but we may need to charge individuals for excessive or unreasonable data requests.