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.
Information Collection & Use
In order to facilitate the sending and receiving of samples, gift cards, coupons, or online coupon codes from, and applicable to products and/or services provided by, our partner merchants/brands via the software or relevant Topbox or partner applications, or Web pages, we collect personal data you provide when you sign-up. This may include information directly provided by you. We collect your shipping address to send your samples to you, and maybe your phone number, to provide you with transactional notifications. We collect other brand- or product-related information such as your child’s age, if you provide that information.
For the reasons outlined above, we also track areas of interest, including: the types of offers that interest you; campaigns you participate in; newsletters you subscribe to; information about friends who refer you or whom you refer; information about how you interact with Topbox or the Sites, such as the products or services you view or share; how you interact with us, and our partners.
We also collect information related to contact you may have with us or our partners via telephone, email, text, postal mail, social media interaction, or other methods of communication, for reasons such as customer support.
We may also collect personal data from time to time through other communications with you, survey responses, information downloads, product or service purchases or sharing, and user support, to allow you to provide feedback on our offerings and improve our services to you.
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.
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.
Information Sharing & Disclosure
We will not transfer your Personal Information to third parties without your permission, except for the following.
We share with our partners anonymized statistics pertaining to the types of users using the Software and Sites and their general behaviour.
With your express consent, we may also share your name, shipping address, age and gender, email address, phone number, and information on your participation in any campaigns, offers and newsletter subscriptions with any current Partners at their request.
In addition, we may send your Personal Information to other companies or people under any of the following circumstances: when we have your consent to share the information; or we need to send the information to companies who work on our behalf (who are not Partners) to provide a product or service to you. In such cases we enter into data protection agreements with our service providers to ensure that your personal data is protected to the same level of protection we offer. We will only provide those companies the information they need to deliver the service, and they are prohibited from using that information for any other purpose.
We may also transfer your Personal Information without your permission to the extent required to do so by law or in the good faith belief that such action is necessary to: (i) comply with legal obligations; (ii) protect or defend our rights or property; (iii) act in urgent circumstances to protect the personal safety, property, or privacy of our employees, users, or members of the public; or (iv) affect a transaction, restructuring or proceeding that transfers to a third party the assets or line of business to which the information pertains.
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.
If you have any questions, comments or concerns please contact us electronically at firstname.lastname@example.org.