This notice sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your sensitive information and how we will deal with it.
Who We Are
We are TOPBOX Marketing. We are a company registered in Canada and our registered office is at 53B Tycos Dr, North York, ON, Canada.
If you have any concerns about the way we use your information or any questions about this Privacy Notice, please let us know. We can be contacted via email at email@example.com, or you can write to us at the address above.
What we do with your information
We will use your information to:
- deliver emails to you and to send you information about the services that we offer and other related topics;
- allow you to request a sample from one of our brand partners and to share our offers with your friends;
- deliver our brand partners' sample(s) to your nominated address;
- allow you to participate in interactive features of the TOPBOX Marketing system and TOPBOX Marketing services, when you choose to do so;
- collect feedback from you on behalf of TOPBOX Marketing and our brand partners related to the sample that you have claimed and the service that we have delivered;
- keep a record of your request for a sample (a record we will never disclose to anyone) for analysis purposes in order to better understand what works well and what works not so well in the distribution of samples for our brand partners; and
- contact you with information about the services we provide by other means.
Information we collect from you
We will collect and process the following information about you:
Information you give us – this is information about you that you give us by filling in forms on our Website or by corresponding with us by phone, email or otherwise. It includes information you provide when you request a sample. We only ask from you the minimum data required for you to use our service.
TOPBOX Marketing does not collect or store any of your financial information. Where access to your financial information such as credit or debit card is required, this information will be processed through secure payment pages of our chosen third party service providers (e.g. PayPal, Stripe).
Information we collect about you – Whenever you visit our Website we will automatically collect the following information:
technical information - including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
information about your visit - this includes the full Uniform Resource Locators (URL), clickstream to, through and from our Website (including date and time), pages you have visited, page response times, download errors, length of visits to certain page and page interaction information (such as scrolling, clicks, and mouse-overs).
Information we receive from other sources – This is information we receive about you if you use any of the other websites we operate or the other services we provide. In this case we will have informed you when we collected that data if we intend to share those data internally and combine it with data collected on this Website. We will also have told you for what purpose we will share and combine your data. We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies). We will notify you when we receive information about you from them and the purposes for which we intend to use that information.
Where we hold and what we do with your information
The information and content held on our Website is deployed geographically to maximise user experience. All information that could identify individuals within North America is stored exclusively within North America. We will never share your user information with third parties for promotional purposes without your consent.
Our production databases are stored in Google Cloud which is contracted by use for the provision of technical services. We remain responsible at all times for the security of your information, but if you want to know more about how we interact with Google Cloud you can view their Privacy Notice, amongst their other policies at https://cloud.google.com/security/privacy/.
We use Campaign Monitor to send email from our platform. In order to do this, we have to supply Campaign Monitor with your email address and a body for the email. If you want to know more about how we interact with Campaign Monitor you can view their Privacy notice, amongst other policies at https://www.campaignmonitor.com/policies/#privacy-policy.
We will often share your information with our trusted brand partners that you have claimed a sample from through TOPBOX Marketing, but only where you have expressly consented for us to do so.
We may also disclose your information to third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Notice.
What we do to ensure the security of your personal information
We take the security of your personal data very seriously. Our approach to information security is constantly evolving and continually reviewed.
We have adopted industry best practices from both technological and business process perspectives in order to make the security of your data a key part of the way we do business.
Your rights regarding your personal information
We may contact you via email with updates about the services that we offer or any changes that we have made to our Website.
You can opt in or out at any time by clicking the 'Unsubscribe' link in our emails.
Our Website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates (including, but not limited to, websites on which our service may be advertised). If you follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy notices and that we are not responsible or liable for these policies or for any personal data that may be collected through these websites or services, such as contact and location data. Please check these policies before you submit any personal data to these websites or use these services.
Access to Information
You have the right to find out what information we hold about you. You can exercise that right by contacting us and we will send you any request for information in a suitable electronic form within 20 working days. To make a request for information please contact firstname.lastname@example.org and a member of our team will be in touch.
If your personal data is incorrect then you have the right to rectify this information and ensure that it is accurate and up to date. If your data is incorrect then please contact us at the email address above and a member of the TOPBOX Marketing team will rectify this on your behalf.
You have the right 'to be forgotten' and to have your personal identifiable information permanently deleted from our systems. Again, if you would like to exercise this right then please contact us at email@example.com.
There will be no charge made for reasonable electronic access to your information, your right to rectification or for your right to be forgotten from our systems.
How long we hold your information for
At TOPBOX Marketing, we have procedures in place to regularly review what personal data we hold. We keep your personal data in a plain text format only for as long is required in order to carry out the processing activities you have permitted us to do. Once the sampling campaign that you engaged with has concluded (on average about 90 days) and we have completed all of the processing activities required to the get the sample into your hands and gather feedback from you, our data lifecycle management comes into effect. All personal data we hold on you in our production databases that was collected as part of your engagement with one of our sampling campaigns is encrypted using your email address and a secret hash as the encryption key. Once your personal information has been encrypted, we then create an irreversible hash of your email address. We then replace the email address we hold on record with this hash.
At this point we will only be able to personally identify you as a user of TOPBOX Marketing again if you attempt to claim another sample in the future, using the same email address as you did previously.
So that we can continue to improve how TOPBOX Marketing works, there are five bits of personal data which you share with us that we exclude from our data lifecycle management process – your postcode, country, opt-in preference, any HTTP referrer value present when you visited our sampling page and any "utm_source" query string parameter present when you visited our sampling page.
We keep your postcode and country in plain text so that we can report on what parts of the world we are delivering samples to. We cannot identify you as the owner of this postcode once your other personal data has been encrypted.
We keep your opt-in preference in plain text so that we can report on average opt-in rates on our platform so that we can keep our brand partners informed about benchmarks on our platform. We cannot identify you as the owner of an opt-in preference once your other personal data has been encrypted.
We keep your utm_source and HTTP referrer value in plain text for two reasons. Firstly, so that we can report back to our brand partners about the performance of their sampling campaigns. Secondly, to help combat abuse of our platform by entities who act against our terms and conditions. We cannot identify you as the owner of a utm_source value or HTTP referrer once your other data has been encrypted.
Of course, you also have the right to be forgotten at any point and can find out more about this in the 'Access to Information' section above.
Changes to this Privacy Notice
Any changes we may make to our Privacy Notice in the future will be posted on this page. The new terms may be displayed on-screen and you will be required to read and accept them to continue your use of our services.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.
As part of our overall approach to privacy and transparency, this section describes what cookies are in the context of our web and mobile interfaces, and what their use means to you. At the end, we've included some links to help you research cookies and their impact, and how you can use your web browser to control the way it manages cookies.
We use the following types of cookies:
- Strictly necessary cookies - these are cookies that are required for the operation of our Website. They include, for example, cookies that enable you to log into secure areas of our Website, use a shopping cart or make use of e-payment system.
- Analytical/performance cookies - these allow us to recognise and count the number of visitors and to see how visitors move around our Website when they are using it. This helps us to improve the way our Website works, for example, by ensuring that users are finding what they are looking for easily.
- Functionality cookies - these are used to recognise you when you return to our Website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
- Targeting cookies - these cookies record your visit to our Website, the pages you have visited and the links you have followed. We will use this information to make our Website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose but these cookies will contain no information capable of identifying you personally.
You can find more information about the individual cookies we use and the purposes for which we use below:
We use Google Analytics to understand general trends about our content and traffic sources; for example, where users come from, which pages are most popular, which sites provide most traffic, how our marketing efforts impact the amount of visits we receive. We have our Google Analytics account set to retain data for twenty-six months from the point at which you last visited our website.
Google's statement about privacy can be found here.
The Twitter button allows our users to share our platform and services with their followers more easily.
We use Facebook button to allow you to share out platform with your friends and other Facebook users. We also use the Facebook Connect feature in certain campaigns to verify your identity and that of any friends you wish to share a sample with.
More information about cookies
Still don't know what cookies are? Then why not follow the link conveniently located here which provides more information about what they are and how they work.
Last Updated: February 2018