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PRIVACY POLICY

Last updated on 16th December 2022

 

Topo Solutions is committed to protecting and respecting your privacy. In this
privacy policy, we explain how Topo Solutions’ collects, uses, shares, stores,
and protects the Personal Information we collect about you when you visit our
website, use our products or services, or otherwise interact with us. This
policy also explains how you may access and control the information.

Our Privacy Policy has been drafted to comply with applicable data privacy laws,
in particular, the EU General Data Protection Regulation (“GDPR”). If the GDPR
does not apply to you, not all terms of this Privacy Policy may be relevant to
you.

 

As used in this policy.

·       “Topo Solutions Limited” or “we” refers to Topo Solutions Limited of
Unit 2811-16, Paul Y. Centre, 51 Hung To Road, Kwun Tong, Hong Kong and
“Platform” means our website at https://topo.cc/ and our software, namely Topo
Solutions.

·       “Personal Information” refers to any data, information, or combination
of data and information that is provided by you to us, or through your use of
our products or services, that relates to an identifiable individual.

 


I.        WHAT DATA WE COLLECT OR PROCESS AND WHY:

 

Personal Information

1.     Account and profile information that you provide when you register for an
account or sign up for our products or services, for example, name, email
address, telephone number(s), location while filling out documents, user
behavior logs (collectively, “Account Data”);

2.     Information you provide through support channels, for example when you
report a problem to us or interact with our support team, including any contact
information, documentation, or screenshots (collectively, “Support Data”);

3.     Content you provide through use of our products or services, for example,
documents and photos (collectively, “User Content”);

4.     Communication, marketing, and other preferences that you set when you set
up your account or profile, or when you participate in a survey or a
questionnaire that we send you (collectively, “Preference Data”);

5.     Information about your device or connection, for example, IP address,
log-in data, browser type, and version, time zone setting, operating system and
platform, and other technology on the devices you use to access our products or
services and information we collect through cookies and other data collection
technologies (please read our Cookies Policy for details) (collectively,
“Technical Data”); and

6.     Information about your use of or visit to our Platform, for example,
errors, page response times (collectively, “Usage Data”);

7.     All of the above.

 

Purpose

1.     To perform the contract we have entered into (or are about to enter into)
with you, including to operate our products or services, to provide customer
support and personalized features, to protect the safety and security of our
Platform, and to study the usage of our products or services.

2.     To perform the contract we have entered into (or are about to enter into)
with you, including to operate our products or services, to provide customer
support and personalized features, to protect the safety and security of our
Platform, and to study the usage of our products or services.

3.     To perform the contract we have entered into (or are about to enter into)
with you, including to operate our products or services, to provide customer
support and personalized features, and to protect the safety and security of our
Platform;

4.     To send you direct marketing materials or publish your information as
part of our testimonials or customer stories to promote our products or services
with your permission.

5.     To administer and maintain the safety and security of our Platform and to
study the usage of our products or services.

6.     To study the usage of our products or services

7.     For compliance with legal and regulatory requirements and corporate
governance obligations.

 

Legal Basis

1. The processing is necessary for the performance of a contract to which you
are a party or in order to take steps at your request, prior to entering into a
contract. Your consent (if such consent is required by law).

2. The processing is necessary for the performance of a contract to which you
are a party or in order to take steps at your request, prior to entering into a
contract.

3. The processing is necessary for the performance of a contract to which you
are a party or in order to take steps at your request, prior to entering into a
contract.

4. Your consent (if such consent is required by law).

5. Processing is necessary for the purposes of our legitimate interests, i.e. To
study the usage of our products or services.

6. The processing is necessary for the performance of a contract to which you
are a party or in order to take steps at the request of you prior to entering
into a contract.

7. Processing is necessary for compliance with legal obligations to which we are
subject.

 


II.      HOW WE STORE AND SECURE THE INFORMATION WE COLLECT

 

1.     We use data hosting service providers based in Hong Kong, Singapore,
Germany, and United States to host the information we collect.

2.     We have adopted the following measures to protect the security and
integrity of your personal information:

a.     information is encrypted using TLS/SSL technology;

b.     your account is password-protected, with the requirement(s) that
passwords must be at least 6 characters long;

c.      access to your personal information is restricted to personnel or
service providers on a strictly need-to-know basis, who will only process your
information on our instructions and who are subject to a duty of
confidentiality; and

d.     our information collection, storage, and processing practices are
reviewed regularly.

3.     We have put in place procedures to deal with any suspected privacy breach
and will notify you and any applicable regulator of a breach where we are
legally required to do so.

4.     While we implement safeguards designed to protect your information,
please note that no transmission of information on the Internet is completely
secure. We cannot guarantee that your information, during transmission through
the Internet or while stored on our systems or processed by us, is absolutely
safe and secure.

5.     We only retain personal information for so long as it is reasonably
necessary to fulfill the purposes we collected it for, including for the
purposes of satisfying any legal, accounting, or reporting requirements. Topo
data is business-relevant data and required for regulatory requirements such as
product safety regulations. Therefore data is kept for a minimum of 10 years
after which it may be deleted. We periodically review the basis and
appropriateness of our data retention policy.

 


III.     HOW WE USE THE INFORMATION WE COLLECT

 

1.     We only use your personal information where the law allows us to. We use
your personal information only where:

a.     we need to perform the contract we have entered into (or are about to
enter into) with you, including to operate our products or services, to provide
customer support and personalized features, and to protect the safety and
security of our Platform;

b.     it satisfies a legitimate interest which is not overridden by your
fundamental rights or data protection interests, for example for research and
development, and in order to protect our legal rights and interests;

c.      you’ve given us consent to do so for a specific purpose, for example, we
may send you direct marketing materials or publish your information as part of
our testimonials or customer stories to promote our products or services with
your permission; or

d.     we need to comply with a legal or regulatory obligation.

2.     If you have given us consent to use your personal information for a
specific purpose, you have the right to withdraw your consent any time by
contacting us (please refer to section IX for contact information), but please
note this will not affect any use of your information that has already taken
place.

3.     We do not share your personal information with any company outside our
group for marketing purpose unless with your specific consent to do so.

 


IV.     HOW WE SHARE INFORMATION WE COLLECT

 

1.   We share information with third parties that help us operate, provide,
support, improve, and market our products and services, for example, third-party
service providers who provide data storage and backup, infrastructure, billing,
payment processing, customer support, business analytics, and other services.

2.     We take reasonable steps to confirm that all third-party service
providers that we engage to process personal information in a manner that
provides at least the same level of protection as is provided under this policy.
Where any third-party provider is unable to satisfy our requirements, we will
require them to notify us immediately and we will take reasonable steps to
prevent or stop non-compliant processing.

3.     We may share personal information on an aggregated or de-identified basis
with third parties for research and analysis, profiling, and similar purposes to
help us improve our products and services.

4.     If you use any third-party software in connection with our products or
services, for example, any third-party software that our Platform integrates
with, you might give the third-party software provider access to your account
and information. Policies and procedures of third-party software providers are
not controlled by us, and this policy does not cover how your information is
collected or used by third-party software providers. We encourage you to review
the privacy policies of third-party software providers before you use the
third-party software.

5.     Our Platform may contain links to third-party websites over which we have
no control. If you follow a link to any of these websites or submit information
to them, your information will be governed by their policies. We encourage you
to review the privacy policies of third-party websites before you submit
information to them.

6.     We may share your information with government and law enforcement
officials to comply with applicable laws or regulations, for example when we
respond to claims, legal processes, law enforcement, or national security
requests.

7.     If we are acquired by a third party as a result of a merger, acquisition,
or business transfer, your personal information may be disclosed and/or
transferred to a third party in connection with such a transaction. We will
notify you if such a transaction takes place and inform you of any choices you
may have regarding your information.

 


V.      HOW WE TRANSFER INFORMATION INTERNALLY

 

1.     We collect information globally and primarily store that information in
Hong Kong, Singapore, Germany and United States. We transfer, process, and store
your information outside your country of residence where we or our service
providers operate for the purpose of providing our products and services to you.

2.     Some of the countries in which our service providers are located may not
have the privacy and data protection laws that are equivalent to those in your
country of residence. When we share information with these service providers, we
make use of contractual clauses, corporate rules, and other appropriate
mechanisms to safeguard the transfer of information.

 


VI.     YOUR DATA PROTECTION RIGHTS

 

Topo Solutions would like to make sure you are fully aware of all your data
protection rights. You may have various rights under data privacy laws in your
country or state. These may include (where required by law):

1.     The right to access the Personal Information we hold about you and be
informed of what we do with your personal information;

2.     The right to rectification requiring us to correct inaccurate Personal
Information we hold about you;

3.     The right to request the restriction of processing data concerning you or
to object to the processing of your Personal Information (including for
marketing purposes);

4.     The right to request the erasure of your Personal Information where it is
no longer necessary for us to retain it (note, however, that we may not always
be able to comply with your request of erasure for record-keeping purposes, to
complete transactions, or to comply with our legal obligations);

5.     The right to data portability including to obtain Personal Information in
a structured, commonly used, and machine-readable format and request that we
transfer such information to another party; and

6.     The right to withdraw your consent at any time where we are relying on
consent to process your personal information (although this will not affect the
lawfulness of any processing carried out before you withdraw your consent).

 

Additionally:

 

1.     Our platform enables you to update certain information about yourself,
for example, you may change your business or personal information by updating
your user profile or changing your user settings.

2.     You may opt-out of receiving marketing materials from us by using the
unsubscribe link in our communications, by updating your preferences within your
account on our Platform, or by contacting us. Please note, however, that even if
you opt-out from receiving marketing materials from us, you will continue to
receive notifications or information from us that are necessary for the use of
our products or services.

3.     As a security measure, we may need specific information from you to help
us confirm your identity when processing your privacy requests or when you
exercise your rights.

4.     Any request under Paragraph 1-6 under Section VI. Your Rights will
normally be addressed free of charge. However, we may charge a reasonable
administration fee if your request is clearly unfounded, repetitive, or
excessive.

5.     We will respond to all legitimate requests within a time period of one
(1) month. Occasionally, it may take us longer than a month if your request is
particularly complex or if you have made a number of requests.

 


VII.   CHANGES TO THIS POLICY

 

1.     We may amend this policy from time to time by posting the updated policy
on our Platform. By continuing to use our Platform after the changes come into
effect, you agree to be bound by the revised policy.

 


VIII.   POLICY TOWARDS CHILDREN

 

1.     Our products and services are not directed to individuals under 16. We do
not knowingly collect personal information from individuals under 16. If we
become aware that an individual under 16 has provided us with personal
information, we will take steps to delete such information. Contact us if you
believe that we have mistakenly or unintentionally collected information from an
individual under 16.

 


IX.     CONTACT US

 

1.     Please contact us at support@topo.cc or submit any written request to:

Topo Solutions Limited

Unit 2811-16, Paul Y. Centre, 51 Hung To Road, Kwun Tong, Hong Kong
Attn: Data Protection Officer

2.     Please contact us in the first instance if you have any questions or
concerns. If you have unresolved concerns, you have the right to file a
complaint with a data protection authority in the country where you live or work
or where you feel your rights have been infringed.

 

Additional information we want you to know:

 

1.     We do not collect sensitive data or special category data about you. This
includes details about your race, ethnic origin, politics, religion, trade union
membership, genetics, biometrics, health, or sexual orientation.

2.     Topo Solutions restricts access to your information to our employees who
need it to do their job. Employees with access to your information are required
to strictly maintain the confidentiality of such information.

 


COOKIES POLICY

Cookies are small text files that are placed on your device by a web server when
you access our Platform. We use cookies to identify your access and monitor
usage and web traffic on our Platform to customise and improve our products and
services.

We use both persistent cookies and session cookies. A persistent cookie stays in
your browser and will be read by us when you return to our Site or a partner
site that uses our services. Session cookies only last for as long as the
session lasts (usually the current visit to a website or a browser session).

 


I.        WE USE THE FOLLOWING TYPES OF COOKIES:

 

1.      Strictly necessary cookies – these are cookies that are required for the
operation of our site. They include, for example, cookies that enable you to log
into secure areas of our website.

2.      Analytical/performance cookies – these allow us to recognise and count
the number of visitors and to see how visitors move around our Site when they
are using it. This helps us to improve the way our site works, for example, by
ensuring that users are easily finding what they are looking for.

3.      Functionality cookies – these are used to recognise you when you return
to our site.
Targeting cookies – these cookies record your visit to our site, the pages you
have visited, and the links you have followed.

 

You can block cookies by activating the setting on your browser that allows you
to refuse the use of all or some cookies. However, if you do so, you may not be
able to access all or parts of our site.

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