Last Updated: August 03, 2020
This privacy notice aims to give you information on how Topcashback collects and processes your
personal data through your use of this Site, including any data you may provide through this Site when
you sign up to our Site, browse or make a purchase via our Site, enter a competition or engage with us
on our Site or through emails you may receive from us.
It is important that you read this privacy notice together with any other privacy notice or fair processing
notice we may provide on specific occasions when we are collecting or processing personal data about
you so that you are fully aware of how and why we are using your data. This privacy notice supplements
the other notices and is not intended to override them.
Topcashback Inc is the controller and responsible for your personal data (collectively referred to as
"Topcashback", "we", "us" or "our" in this privacy notice).
We have appointed a data privacy manager who is responsible for overseeing questions in relation to
this privacy notice. If you have any questions about this privacy notice, including any requests to
exercise your legal rights, please contact the data privacy manager using the details set out below.
Full name of legal entity: Topcashback Inc.
Email address: email@example.com
(For queries which do not relate to this privacy notice, please use firstname.lastname@example.org
Postal address: 340 West Passaic St, Floor 1, Rochelle Park, NJ 07662
Subject to the laws in your jurisdiction, you may have the right to make a privacy complaint to your local
supervisory authority for data protection issues. We would, however, appreciate the chance to deal with
your concerns first, so encourage you to contact us with any questions or concerns.
This policy may change and be updated from time to time. In the event we plan to materially change
how we use previously collected personal data, we will provide you with a notice and an opportunity to
opt-out of such differing uses. Please check back regularly.
It is important that the personal data we hold about you is accurate and current. Please keep us
informed if your personal data changes during your relationship with us.
This Site includes links to third-party Sites, plug-ins and applications. Clicking on those links or enabling
those connections may allow third parties to collect or share data about you. We do not control these
third-party Sites and are not responsible for their privacy statements. When you leave our Site, we
encourage you to read the privacy notice of every website you visit.
Personal data, or personal information, means any information about an individual from which that
person can be identified. It does not include data where the identity has been removed (anonymous
We may collect, use, store and transfer different kinds of personal data about you which we have
grouped together follows:
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose.
Aggregated Data may be derived from your personal data but is not considered personal data as this
data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data
to calculate the percentage of users accessing a specific Site feature. However, if we combine or connect
Aggregated Data with your personal data so that it can directly identify you, we treat the combined
data as personal data which will be used in accordance with this privacy notice.
Except in limited circumstances which will be made clear to you, we do not collect any Special
Categories of Personal Data about you (this includes details about your race or ethnicity, religious or
philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership,
information about your health and genetic and biometric data). Nor do we collect any information about
criminal convictions and offences.
Where we need to collect personal data by law, or under the terms of a contract we have with you and
you fail to provide that data when requested, we may not be able to perform the contract we have or
are trying to enter into with you (for example, to provide you with the cashback service). In this case,
you will not be able to join Topcashback.
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact, Transaction or Financial Data by filling in
forms or by corresponding with us by post, email or otherwise. This includes personal data you provide
Automated technologies or interactions. As you interact with our Site, we may automatically collect
Technical Data about your equipment, browsing actions and patterns. We collect this personal data by
using cookies, server logs and other similar technologies. We may also receive Technical Data about you
navigate our Site, we may collect Usage Data, Profile Data and Marketing and Communications Data as
specified by you from time to time.
Essential Third parties. In order to facilitate the cashback service, we need to receive personal data
about you from various third parties as set out below:
Technical, Transactional, Identity and Contact Data from the following parties:
a) Affiliate Networks; and
b) retailers featured on the Site from time to time
To help improve the service we provide and the functionality of our Site we may receive personal data
about you from various third parties as set out below:
a) Technical Data from analytics providers such as Google; and
b) Contact and Technical Data where you join our Site as a result of our marketing activities involving
Our Site is not intended for children under 13 years of age. We do not knowingly collect personal data
from children under 13. If you are under 13, do not use or provide any personal data on this Site. If we
learn we have collected or received personal data from a child under 13 without verification of parental
consent, we will delete that information. If you believe we might have any personal data from or about a
child under 13, please contact us at email@example.com.
We have set out below, in a table format, a description of all the ways we plan to use your personal
data, and which of the legal bases we rely on to do so. We have also identified what our legitimate
interests are where appropriate.
What is a legitimate interest?
Legitimate Interest means the interest of our business in conducting and managing our business to
enable us to give you the best service and the best and most secure experience on our Site. We make
sure we consider and balance any potential impact on you (both positive and negative) and your rights
before we process your personal data for our legitimate interests. We do not use your personal data for
activities where our interests are overridden by the impact on you (unless we have your consent or are
otherwise required or permitted to by law). You can obtain further information about how we assess
our legitimate interests against any potential impact on you in respect of specific activities by contacting
us firstname.lastname@example.org (For queries which do not relate to this privacy notice,
please use email@example.com).
Performance of Contract means processing your data where it is necessary for the performance of a
contract to which you are a party. If you fail to provide personal data that we require for the
performance of a contract with you we cannot enter into a contract with you for the provision of our
We strive to provide you with choices regarding certain personal data uses, particularly around
marketing and advertising. Within your account you can view and make certain decisions about your
personal data use in relation to marketing emails.
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think
you may want or need, or what may be of interest to you. This is how we decide which products,
services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have signed up to our Site and you have not
opted out of receiving marketing emails.
We will never sell your personal data to any company outside the Top Online Partners Group Limited
group of companies for marketing purposes. As referred to above, we may share your Contact or
Identity Data with certain third parties e.g. sub-processors to facilitate the delivery of marketing emails
to you and social media publishers, in order to ensure our marketing is targeted at and relevant to
You can ask us to stop sending you marketing emails at any time by logging into your account on the Site
and checking or unchecking relevant boxes to adjust your marketing preferences or by following the
opt-out links on any marketing email sent to you.
You can update your personal data and certain preferences in the “My Profile” section of your account
on the Site.
You can always contact us at firstname.lastname@example.org with further questions related to privacy and
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or
inaccessible or not function properly resulting in your cashback not tracking.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is
compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose,
please contact us at email@example.com (For queries which do not relate to this privacy notice, please use firstname.lastname@example.org).
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may have to share your personal data with the parties set out below and for the purposes set out in
the table in paragraph 4 above.
We may disclose your personal data in order to comply with applicable law or a legal proceeding.
We require all third parties under our control to respect the security of your personal data and to treat it
in accordance with the law. We do not allow our third-party service providers to use your personal data
for their own purposes and only permit them to process your personal data for specified purposes and
in accordance with our instructions.
Our Site may be maintained in the United States of America. By using the Site, you authorize the export
personal data from the EU to the USA and other countries, some of which have not been determined by
the European Commission to have an adequate level of data protection. Information stored in the USA
may be subject to lawful requests by the courts or law enforcement authorities in the USA.
If you are located in the EU, please contact us at email@example.com if you want further
information on the specific mechanism used by us when transferring your personal data out of the EEA.
(For queries which do not relate to this privacy notice, please use firstname.lastname@example.org).
We have put in place appropriate security measures to prevent your personal data from being
accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit
access to your personal data to those employees, agents, contractors and other third parties who have a
business need to know. They will only process your personal data on our instructions and they are
subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you
and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for,
including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and
sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your
personal data, the purposes for which we process your personal data and whether we can achieve those
purposes through other means, and the applicable legal requirements.
Details of retention periods for different aspects of your personal data are available in our retention
policy which you can request from us by contacting us at email@example.com
(For queries which do not relate to this privacy notice, please use firstname.lastname@example.org).
You have the right to ask us to delete your data. In most cases, we will comply except when certain legal
or fraudulent concerns are involved.
In some circumstances we may anonymize your personal data (so that it can no longer be associated
with you) for research or statistical purposes in which case we may use this information indefinitely
without further notice to you.
You have the right under data protection laws in relation to your personal data to:
Request access to your personal data (commonly known as a "data subject access request"). This
enables you to receive a copy of the personal data we hold about you and to check that we are lawfully
Request correction of the personal data that we hold about you. This enables you to have any
incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy
of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data
where there is no good reason for us continuing to process it. You also have the right to ask us to delete
or remove your personal data where you have successfully exercised your right to object to processing
(see below), where we may have processed your information unlawfully or where we are required to
erase your personal data to comply with local law. Note, however, that we may not always be able to
comply with your request of erasure for specific legal reasons which will be notified to you, if applicable,
at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a
third party) and there is something about your particular situation which makes you want to object to
processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have
the right to object where we are processing your personal data for direct marketing purposes. In some
cases, we may demonstrate that we have compelling legitimate grounds to process your information
which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the
processing of your personal data in the following scenarios: (a) if you want us to establish the data’s
accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you
need us to hold the data even if we no longer require it as you need it to establish, exercise or defend
legal claims; or (d) you have objected to our use of your data but we need to verify whether we have
overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third
party you have chosen, your personal data in a structured, commonly used, machine-readable format.
Note that this right only applies to automated information which you initially provided consent for us to
use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data.
However, this will not affect the lawfulness of any processing carried out before you withdraw your
consent. If you withdraw your consent, we may not be able to provide certain products or services to
you. We will advise you if this is the case at the time you withdraw your consent.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights).
However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.
Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your
right to access your personal data (or to exercise any of your other rights). This is a security measure to
ensure that personal data is not disclosed to any person who has no right to receive it. We may also
contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a
month if your request is particularly complex or you have made a number of requests. In this case, we
will notify you and keep you updated.
Affiliate Networks means a network that acts as an intermediary between our Site which features
products and services and the retailers who create or sell those products and services. The affiliate
network reports the tracking of cashback, any payments and refund processing together with assisting
with any untracked sales which you may tell us about.
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