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Privacy Policy

Last Updated: November 25, 2024

Version: 2.0
 

We take your privacy and the security of your information seriously.

This policy (“Privacy Policy”) describes how Topkey, Inc. (“Topkey,” “we,” or “us,”) collects, aggregates, stores, safeguards and uses the data and information (including non-public, personal information, or “personal information”) provided by users through our Sites, in the process of opening a Topkey Account, or in provision of the Services.

As used in this Privacy Policy, “personal information” is any information that identifies, relates to, describes, is reasonably capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular consumer, device, or household.

As with the Terms of Use, Topkey reserves the right to amend this Privacy Policy or impose additional obligations or restrictions on you at any time with or without notice to you. As much as practicable, we will try to notify you of these changes if the obligations or restrictions they impose on you are material, as determined in our sole and reasonable discretion. However, by continuing to use the Sites or the Services, you agree to be bound by such amendments or additional obligations or restrictions.

Please note that the date on the top of this page shows when the Privacy Policy was last updated.

As a reminder, the Privacy Policy is a part of the Terms of Use and is incorporated by reference in its entirety into the Terms of Use. Please read the Privacy Policy carefully. Your use of the Site or the Services constitutes your agreement of this Privacy Policy.

General

In general, this policy explains:

  • What information we collect, and how we use it;
  • Choices you can make about the way your information is collected and used;
  • How we protect Personal Information electronically and physically.

Types of Personal Information we collect

Information that you provide to us

When you visit the Sites, you may provide Personal Information or business information to us as part of your application process to use the Services, including to set up an account with Topkey.

Examples of personal information that you may provide to us include name, email address, phone number, and address.

Examples of business information include your company name, employment identification number, and financial information, number of employees, number of properties, type of entity, type of properties managed, geographical location.

Information we collect automatically from you

We or our vendors or service providers may also automatically collect information when you use the Sites to, for example, protect against fraud or to improve our products and services and user experience.

This information can include:

  • Your browser type;
  • Your device type or operating system;
  • Your device’s location and other information sent by your device;
  • Your device’s IP address; or
  • Your interaction with the Site or the Services, such number of clicks, landing pages and pages viewed.

Tracking and Cookie Data

Like many online services, we may use cookies or other anonymous identifiers to collect information about you. Cookies are small pieces of data placed on your computer, phone, or similar device when you use that device to visit the Sites or use our Services.

Examples of cookies we may use:

  • Session cookies: Session cookies help us recognize users who visit our Sites.
  • Tracking cookies: Tracking cookies help us remember preferences and other settings.
  • Security cookies: Security cookies help us prevent fraud.
     

You can decide whether to accept cookies through your internet browser’s settings. Most browsers have an option for turning off the cookie feature, which will prevent your browser from accepting new cookies. If you do not accept cookies, however, you may not be able to use some or all portions of our Sites.

Transaction Data Collection

We currently use Astrada and the Payment Card Networks (Visa and Mastercard) to monitor card transactions for your participation in the Topkey program. Your agreement to the various Topkey Terms of Use (Terms) authorize Astrada and the Payment Card Networks to monitor the transactions made with your registered eligible payment cards via the Verge Platform. The data collected from Astrada and the Payment Card Networks includes your registered card identifier, merchant, transaction date/time and amount.

Transaction data means the data supplied by a Payment Card Network(s) relating to a transaction and includes the last 4 digits of PAN (Primary Account Number), MCC (Merchant Category Code), authorization code, merchant location, card token, currency, authorization and settlement date and time, and amount paid.

‍Transaction Data Usage

Notwithstanding anything to the contrary in the Terms or Privacy Policy, Topkey and its Third Party Service Providers (including Astrada) will use transaction information solely as follows:

To create a record of the transaction data and thereafter maintain and use data in connection with operating the Platform;

To provide information in order to respond to a request from government authority or a payment organization involved in a transaction with you or a merchant. You authorize the sharing, exchange and use of transaction data described above and herein by and among Topkey and Topkey’s Third Party Service Providers and applicable Payment Card Networks.

‍Transaction Monitoring

By registering a payment card in connection with transaction monitoring, you authorize Topkey to share your payment card information with the Payment Card Networks so it knows you enrolled in, and participate in, the Topkey Platform. You authorize the Payment Card Networks to monitor transactions on your registered card(s) in order to enable your usage of real time transaction data for all transactions made on an enrolled card linked through the Topkey Platform. You may opt out of transaction monitoring on the payment card(s) you have registered by navigating to your settings menu to remove your linked card(s).

Information that we may collect from third parties

We may also supplement any of the information that you provide to us or that we obtain with information that we receive from third parties, such as credit bureaus, data providers, fraud detection services and data analytics providers. Some of these third parties may obtain your personal information or business information through your use of the Sites or the Services, and other third parties may already have your personal information that they then share with us. As a condition of your use of the Services, you may be asked to provide your consent to certain other third parties for those third parties to obtain, use, or share your information with us.

We may use this information for marketing, identify verification, fraud prevention, to help us provide our Services to you, including determining whether you are eligible for the Services, and for other business purposes.

Use of Your Information

We may use your personal information or business information for everyday business purposes, including to:

  • To help us assess your eligibility to use the Services. Examples include verifying your identity for a Topkey Account with us or preventing fraudulent or unauthorized transactions.
  • To support our internal business operations. Examples include maintaining your Topkey Account with us, providing the Services to you, or improving our Services or products or building new products or services.
  • To contact or communicate with you. Examples include providing customer services to you by phone or email or marketing our products and services.
  • To comply with our own policies and procedures, regulation, or applicable law. Examples include complying with our obligations under applicable law, regulation, or other legal process or complying with our contractual or audit obligations.
     

As described above, we may communicate with you if you’ve provided us the means to do so. For example, if you’ve given us your email address, we may send you promotional email offers or email you about your use of the Services. If you wish to unsubscribe from these emails, simply click the “unsubscribe” button at the bottom of the email. Please note, however, that you may not unsubscribe from emails about your account with us or any other similar transactional emails.

Aggregated or Anonymized Information

We may share aggregated and/or anonymized information with any third parties at any time to the extent such information cannot be linked back to any identifiable person.

Safeguarding Personal Information

We will implement reasonable safeguards to ensure the protection of your personal information and business information from unauthorized access or use. Such safeguards may include physical, technical, or administrative security measures.

That said, you acknowledge and agree that your personal information and business information will be transmitted over the internet and/or shared electronically, and that even with such safeguards, there is no guarantee of security.

As and to the extent permitted by applicable law, you agree that Topkey will not be liable for any loss, third party interception, unauthorized access or disclosure, or unauthorized use of your information by or to a third party.

Please notify us immediately if you believe your information with Topkey has been compromised in any way.

Ongoing Privacy Monitoring and Review

Topkey conducts semi-annual reviews of our privacy practices to ensure compliance with applicable laws and regulations.

Retention of Information

We will retain your personal information and business information as long as permitted by our internal data retention policies and as long as necessary in order to:

  • Provide the Services to you.
  • Use for any of the purposes permitted by this Privacy Policy.
  • To comply with any legal or regulatory requirements.

‍

Removal of Data Upon Request

At your request, we will take reasonable steps to remove your personal and business information from our active databases. Please note that even after such removal, portions of your data may remain in our systems and backups for a period of time due to technical limitations but will adhere to all other terms of this Privacy Policy.

Children’s online privacy

Protecting children on the Internet is very important to Topkey. For that reason, we do not knowingly solicit or collect personal information from anyone under the age of thirteen (13), and no part of the Sites is intended to attract anyone under thirteen (13).

If you believe that a child under thirteen (13) may have provided us personal information to us, please contact us immediately at support@topkey.io.

Do Not Track Signals

At this time, our Sites do not support Do Not Track (“DNT”). DNT is a privacy preference you can set in your web browser to indicate that you do not want certain information about your web page visits tracked and collected across websites. For more details, including how to turn on Do Not Track, visit https://www.donottrack.us/.