Date: October 29, 2020
TopX, Inc. (referred to in this policy as “TopX,” “we,” or “us”) has developed and offers a service (the “Service”) in the form of an online platform that connects users with the businesses of experts that can provide advice and coaching. Using the Service platform, businesses that offer experts (“Experts”) provide users (“Users”) with advice and coaching.
TopX operates various lines of its Service. One of its offerings is the ParentGoodTM online platform that connects parent or guardian users with the businesses of parenting expert coaches. Other expert businesses on the Service include tutoring services and relationship coaching services for couples.
TopX is a U.S.-based business located in Santa Cruz, California. TopX does not specifically target any specific foreign regions or countries for offering goods or services. In addition, TopX does not monitor the behavior of specific individuals.
- Information We Collect to Provide the Service
- Information We Collect from Site Visitors and App Users Before Registering
We collect the following elements of personal information when users visit the Site or use the App before registering an account:
In the case of Site users, search engine search terms that brought the visitor to the Site
For Site usage information, we may collect the following information on an aggregate basis when visitors visit our Site:
Web browser users are using
Operating systems used by visitors
How many visitors view the Site or specific pages on it
Information We Collect from Users Who Register an Account
We collect the following elements of personal information when we enroll new users of the Service:
The User’s name
The User’s email account
The User’s location
The User’s time zone
Optionally, a photo of the User
A log of the chat sessions between User and Expert
A password chosen for the User’s account
For aspects of the Service connecting users to the businesses of experts that can provide advice and coaching regarding personal relationships (such as the ParentGood service or couples relationship coaching), we may also collect:
- Name(s) of relatives of the user
- Gender information on relevant children or adults
- Age of relevant children or adults
- Specific challenges faced by the user regarding the relevant children or adults
Our payment gateway service collects Users’ payment card information, although TopX does not have access to Users’ payment card information.
- Information We Collect from Experts and Their Businesses
We collect the following elements of personal information when we enroll new Expert users and their businesses:
- Expert’s name
- Expert’s email address
- Expert location
- Expert time zone
- Biographical information about the Expert’s background and expertise
- A resume or CV of the Expert
- A photo of the Expert
- Certificates and degrees held by the Expert
- The hourly rate of the Expert charged by the Expert’s business
- Statistics concerning the Expert’s TopX sessions, such as how many sessions the Expert has conducted
- Bank account and routing number of the Expert’s business
- Calendar information (including dates of past sessions, appointments of scheduled future sessions, and availability for future sessions, such as dates and times on which the Expert is available or not available for sessions)
- A password chosen for the Expert account
- Social Media Accounts
We review information that you provide to us by posting content on TopX’s social media pages hosted by social media services. That information may be text, photos, videos, audio recordings, or any other information in or linked via posts on our social media pages. Also, we will be able to view the username of the person posting such information. We use the information posted on our social media pages to understand the needs and interests of our customers better, as well as to improve our Service, Site, and App.
The privacy and security practices of social media services are governed by their respective privacy policies. These services collect and maintain personal information about you. Please review their privacy policies and terms of service in order to understand their privacy and security practices. TopX does not control how social media services use and protect the information you post to social media accounts.
Cookies may be automatically used to collect specific information from a computer or mobile device that accesses and navigates through the Site over time. Information collected by cookies may include information to help improve and customize the content or layout of the Site.
After visiting or using our Site, a cookie on your computer will enable the Site or another website to show you more relevant advertisements (a process called “retargeting”). We use a marketing service to help provide relevant advertisements and collect information about the websites where you see these ads and which ads you click on.
- Information We Collect from Site Visitors and App Users Before Registering
Our Service, Site, and App are intended for users 18 years or older. We do not market or sell products or services to minors or knowingly collect personal information from children under age 13.If you believe that we have inadvertently gathered personal information about a minor, please write to us at privacy@TopX.team in order for us to delete it.
- Notice to California Residents About “Do Not Track Settings”
Under California law, online service providers must say in their privacy policies how they respond to “do not track” settings that users can set in their browser software. At this time, there is no standard governing what, if anything, a website operator should do when receiving a “do not track” signal. As a result, TopX does not currently take action in response to a “do not track” browser setting. TopX will amend this policy if an industry standard regarding such settings emerges in the future.
- How We Use Your Personal Information
In general, TopX uses personal information of registered Users to provide our online platform Service to our community of Experts and Users. Examples including facilitating and scheduling sessions between Experts and Users, receiving payments, and paying Experts’ businesses. Also, we may use information we collect to understand your needs and to administer, manage, enhance, and improve our Service. In particular, we use personal information for:
- Internal record keeping.
- Improving features or the way we deliver our Service.
- Sending special offers or surveys to users.
More specifically, we may periodically send promotional emails about new products, special offers or other information that we think you may find interesting using the email address which you have provided. From time to time. We may also use your information to contact you for market research purposes. We may use the information you provide in response to these communications to improve our Service according to your interests.
If you send us emails or otherwise communicate with us, we may use your communications to communicate with you in return. Our communications could relate to our Service. For instance, we use your personal information for customer or technical support communications.
As stated in Section 1.2, our payment gateway service processes payment information Users provide to us. TopX, however, does not use and does not even have access to Users’ payment information.
- Transfers or Sharing of Personal Information
In specific, we use Amazon Web Services (AWS) to store and process personal information collected and processed by our cloud-based application. AWS has its own privacy notice, which you can access here.
From time to time, we may be required to respond to a subpoena, court order, search warrant, administrative or judicial process, requests by law enforcement agencies, or other requests that we must respond to under applicable law. We may disclose your personal information in response to any of these requirements.
Also, we may disclose your personal information to preserve the security of our Site, App, or social media accounts, resolve disputes, or to assess any possible wrongdoing.
We also may share aggregate or anonymous information collected about Site, App, or social media usage, as long as the information does not identify any specific individuals.
Except as noted above, we will not sell, distribute, transfer, or lease your personal information to any third parties.
- Data Security Practices
We are committed to securing your personal information. To prevent unauthorized access or disclosure of your personal information, we have put in place industry standard administrative, physical, and technical safeguards to secure the personal information we collect using the Site or the App, or personal information posted on our social media accounts that we have stored on our own systems. More specifically, TopX is committed to maintain reasonable and appropriate administrative, physical, and technical safeguards to:
- Provide assurances of the integrity and confidentiality of personal information we collect,
- Protect against any reasonably anticipated threats or hazards to the security or integrity of personal information, and unauthorized uses or disclosures of personal information, and
- Maintain compliance with the legal framework of requirements for the privacy and security of personal information.
As mentioned above, we use Amazon Web Services (AWS) to store and process personal information collected and processed by our cloud-based application. AWS has its own security policies and disclosures. AWS explains the security of its services on this website, with more detail about its administrative, physical, and technical safeguards in its whitepapers here and here. AWS’s policies relate to the platform used for storage and processing of personal information. For more information about the protection provided by AWS versus protections for which customers such as TopX are responsible, see this website.
- Retention of Personal Information
We will maintain your personal information only as long as it is needed for the purposes described above, to complete any applicable investigations, for the duration of any dispute resolution process, or to the extent required to meet preservation requirements under applicable law.
- Links to Other Websites
Our Site and App may contain links to content of interest provided by third parties. Nonetheless, once you have used these links to leave our Site or App, you should note that we do not have any control over other websites or content. Therefore, we cannot be responsible for the privacy and security of any information you provide while visiting third party Sites or other content, and such Sites and content are not governed by this policy. You should exercise caution and look at the privacy statement applicable to the websites or content of these third parties.
- Data Subject Requests
- If you would like access to the personal information about you we may have in our possession, please contact us at privacy@TopX.team. Our privacy team can assist you with accessing the personal information you are seeking.
- You may also contact us at privacy@TopX.team to correct or update personal information about you in our possession. Please keep in mind that we may have a legal right or obligation to preserve personal information as it currently exists.
- If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by emailing us at privacy@TopX.team.
- Any email communications from us contain instructions on opting out of further email communications, although we will still send you emails relating to the support, administration, and security of our Service.
- Contact Information
Please direct all questions or complaints about our privacy practices to our privacy team at privacy@TopX.team.
If you have a complaint, please provide information relevant to your complaint. Our privacy team will evaluate your complaint based on the information you provide and send you a response. We may need to ask you for additional information to evaluate your complaint. We will promptly investigate and respond to your communications about a complaint. You may have other rights under law and the right to contact the privacy regulator in your country about your complaint.
- Amendments to this Policy
TopX may change this policy from time to time. We will make changes by posting a revised copy of this policy to our Site and App or, if TopX deems it necessary, by email notice to you. Your continued use of our Site or App after a revised version of this policy appears on the Site will constitute your approval of the amended version.