Introduction

This privacy policy ("Privacy Policy") applies to the personal information that TopTips processes in connection with the TopTips apps, websites, software and related services (the “Platform”), that link to or reference this Privacy Policy.

Data Controller: If you live in the European Economic Area (“EEA”), the United Kingdom (“UK”), or Switzerland, TopTips app Limited, a UK company ("TopTips," "our," "we," or "us") are the joint controllers of your information processed in connection with this Privacy Policy.

Whallect your information in three ways: Informt Information We Collect

We coation you provide, Automatically collected information, and Information From Other Sources. More detail is provided below.

Information You Provide

• Profile Information. We collect information that you provide when you set up an account, such as your date of birth, username, email address and/or telephone number, and password. You can add other information to your profile, such as a bio or a profile photo.

• User Content. We collect the content you create or publish through the Platform, such as photographs, videos, audio recordings, and comments, and the associated metadata (such as when, where, and by whom the content was created). Even if you are not a user, information about you may appear in content created or published by users on the Platform. We collect User Content through pre-loading at the time of creation, import, or upload, regardless of whether you choose to save or upload that User Content, for example, to recommend music based on the video. We also collect content (such as text, images, and video) from your device's clipboard if you choose to copy and paste content to or from the Platform or share content between it and a third party platform. In addition, we collect location information (such as tourist attractions, shops, or other points of interest) if you choose to add the location information to your User content.

• Direct Messages. If you communicate with others using direct messages, we collect the content of the message and the associated metadata (such as the time the message was sent, received and/or read, as well as the participants in the communication). We do this to block spam, detect crime, and to safeguard our users.

• Your Contacts. If you choose to import your contacts, we will collect information from your device’s phone book or your social media contacts. We use this information to help you make connections, including when you are using our “Find Friends” function and to suggest accounts to you.

• Purchase Information. We collect your payment card information or other third-party payment information (such as PayPal) where payment is required. We also collect your transaction and purchase history.

• Surveys, Research, and Promotions. We collect information you provide if you choose to participate in a survey, research, promotion, contest, marketing campaign, or event conducted or sponsored by us.

• Information When You Contact Us. When you contact us, we collect the information you send us, such as proof of identity or age, feedback or inquiries about your use of the Platform or information about possible violations of our Terms of service (our “Terms”),Community Guidelines (our “Guidelines”), or other policies.

Automatically Collected Information

• Technical Information. We collect certain device and network connection information when you access the Platform. This information includes your device model, operating system, keystroke patterns or rhythms, IP address, and system language. We also collect service-related, diagnostic, and performance information, including crash reports and performance logs. We automatically assign you a device ID and user ID. Where you log-in from multiple devices, we use information such as your device ID and user ID to identify your activity across devices to give you a seamless log-in experience and for security purposes.

• Location Information. We automatically collect information about your approximate location (e.g. country, state, or city) based on your Technical Information (such as SIM card and IP address). Also, where you enable Location Services for the TopTips app within your device settings, we collect approximate location information from your device.

• Usage Information. We collect information about how you engage with the Platform, including information about the content you view, the duration and frequency of your use, your engagement with other users, your search history and your settings.

• Content Characteristics and Features. We detect and collect characteristics and features about the videos, images, and audio recordings that are part of your User Content, for example, by identifying objects and scenery, the existence or location within an image of a face or other body parts; and the text of words spoken in your User Content.  We do this, for example, for content moderation and to provide special effects (such as video filters and avatars) and captions.

• Inferred Information. We infer your attributes (such as age-range and gender) and interests based on the information we have about you. We use inferences, for example, to keep the Platform safe, for content moderation and, where permitted, to serve you personalized ads based on your interests.

• Cookies. We use cookies and similar tracking technologies to operate and provide the Platform. For example, we use cookies to remember your language preferences, make sure you don’t see the same video more than once, and for security purposes. We also use these technologies for marketing purposes. To learn more about our use of cookies, please see our Web cookies Policy and Platform Cookies Policy. We will obtain your consent to our use of cookies where required by law.

Information From Other Sources

• Advertising, Measurement and Data Partners. Advertisers, measurement and data partners share information with us such as mobile identifiers for advertising, hashed email addresses, and event information about the actions you’ve taken outside of the Platform. Some of our advertisers and other partners enable us to collect similar information directly from their website or app.

• Third Party Platforms and Partners. Third party platforms provide us with information (such as your email address, user ID, and public profile) when you choose to sign up for or log in to the Platform using sign-in features provided by those third parties. We may also receive contact information that you hold or is held about you when contact information is synced with our Platform by you or another user. When you interact with any third party service (such as third party apps, websites or products) that integrateTopTips Developer Tools, we will receive the information necessary to provide you with features like cross-service authentication or cross-posting. For example, this will happen if you log in to another platform with your TopTips account or if you use TopTips’ “share” button on a third party platform to share content from there to the Platform.

How We Use Your Information

We use your information to operate, provide, develop, and improve the Platform, including for the following purposes. 

• Provide and administer the Platform, such as enabling you to create, share, and consume content and to interact with other users and their content.

• Personalize and customize your experience on the Platform, such as providing your “For You” feed.

• Process, facilitate, or fulfill requests of purchases of products, goods, and services.

• Enforce our Terms, Guidelines, and other policies that apply to you. We review User Content and other information to protect the safety and well-being of our community.

• Provide certain interactive features, such as enabling your content to be used in other users’ videos, and to suggest your account to other users to help connect you with other users.

• Provide and improve our advertising services, including to serve ads (including personalized ads, where permitted) and to measure and understand the effectiveness of the ads and other content.

• Maintain and enhance the safety, security, and stability of the Platform by identifying and addressing technical or security issues or problems (such as technical bugs, spam accounts, and detecting abuse, fraud, and illegal activity).

• Review, improve, and develop the Platform, including by monitoring interactions and usage across your devices, analyzing how people are using it, and by training and improving our technology, such as our machine learning models and algorithms.

• Share your information with third party platforms to provide you with features, like content sharing at your request when you integrate your TopTips account with a third party service.

• Promote the Platform or third party services through marketing communications, contests, or promotions.

• Comply with our legal obligations, or as necessary to perform tasks in the public interest, or to protect the vital interests of our users and other people.

How We Share Your Information

Service Providers

We engage service providers that help us provide, support, and develop the Platform and understand how it is used. They provide services such as cloud hosting, content delivery, customer and technical support, content moderation, marketing, analytics, and online payment. We share information you provide, Automatically Collected Information, and information from other sources with these service providers as necessary to enable them to provide their services.

Partners

Third Party Platforms and Partners. We share limited information which may include information you provide, Technical information and usage information with third party platforms and partners whose platform or services are integrated with the Platform. We do this to give you a seamless experience, allow your content to be shared on other platforms, and/or enable third party platforms and partners to better authenticate users. Some examples include if you:

• log-in to a third party platform using your account, we will share your basic account information and any other information you provide,

• sign-up or log-in to the Platform using your account details from a third party platform (such as Facebook or Google), we will share certain Technical information to facilitate this,

• share User Content you publish on the Platform on other social media platforms, we will share your User Content and related information.

Advertisers. We provide advertisers with aggregate information about the performance of their ads and other content on the Platform in order to help them measure their effectiveness. We create this aggregate information using information you provide, Automatically collected Information and Information from other sources. We share your information directly with advertisers where you give us your permission.

Measurement and Data Partners. We also share Technical and usage information, with third party measurement providers who help us measure advertising served on the Platform and help our advertisers determine how effective their ads have been.

Our Corporate Group

As a global company, the Platform is supported by certain entities within our corporate group (“Corporate Group”). These entities process Information You Provide, Automatically Collected Information, and Information From Other Sources for us as necessary to provide important functions, such as storage, content delivery, security, research and development, analytics, online payments, customer and technical support, and content moderation. 

Others

We share your information in other limited scenarios as follows:

Other Users and the Public. Based on your privacy settings, your Profile Information and User Content may be visible to other users and the public. You can learn about account types and privacy settings. Your profile and content may also be visible to third parties, such as search engines, content aggregators, and news sites. You and other individuals may be able to share your User Content both on and off the Platform, depending on the choices you make in your privacy settings.

Users of Our Analytics Services. We provide aggregated statistics and insights to help people and businesses understand how people are engaging with the Platform. For example, creators and advertisers can receive information about the number of views, likes, comments and shares of their videos, as well as aggregate demographic information about their followers and the viewers of their videos. We create this aggregate information using Information You Provide and Automatically Collected Information.

Corporate Transactions. Your information may be disclosed to third parties in connection with a corporate transaction, such as a merger, sale of assets or shares, reorganization, financing, change of control, or acquisition of all or a portion of our business.

Legal Obligations and Rights. We may access, preserve, and share the information described in "What Information We Collect" with law enforcement agencies, public authorities, copyright holders, or other third parties if we have good faith belief that it is necessary to:

• comply with applicable law, legal process or government requests, as consistent with internationally recognised standards,

• protect the rights, property, and safety of our users, copyright holders, and others, including to protect life or prevent imminent bodily harm. For example, we may provide information (such as your IP address) to law enforcement in the event of an emergency where someone’s life or safety is at risk,

• investigate potential violations of and enforce our Terms, Guidelines, or any other applicable terms, policies, or standards, or

• detect, investigate, prevent, or address misleading activity, copyright infringement, or other illegal activity.

Our Legal Bases and How We Process Your Information

We may only use your information when we have a “legal basis” to do so. We use different legal bases depending on why we use your information (in other words, the “purpose” of our processing). These legal bases are contractual necessity, legitimate interests (ours, yours or those of another party), consent, compliance with a legal obligation, performing a task in the public interest, and protection of vital interests.

Here we explain the legal bases we rely on when we process your information. This section also describes why we use your information, how this information is processed, the categories of information involved, and the associated rights (which always includes the right to access your information).

Contractual Necessity

We use Information You Provide, Automatically Collected Information, and Information From Other Sources where it is necessary to perform the contract you enter into (our Terms) when you register for, access, or use the Platform. This means we use your information to:

• Provide you with the Platform. We use your information to allow you to access and use the Platform, including allowing you to create and consume content, interact with others, utilize social features, and provide you with products and services you purchase. We also personalize your experience on the Platform, such as providing your “For You” feed, which shows you videos that we think you would be interested in and by suggesting accounts to you.

• Enforce our Terms, Guidelines, or policies. We use your information to enforce our Terms, Guidelines, and policies. This may include removing content (including through automated means) or suspending or banning your account if we determine that you are violating our Terms or Guidelines.

• Administer the Platform. We also use the information we have to administer the Platform, such as to communicate with you on service related matters and respond to your queries (including when you tell us about a problem or ask for a copy of your information).

Your Rights: Whenever we use your information on the basis that it is necessary for the contract we have with you, you have the right to port information you have provided to us.

Legitimate Interests

We use your information where this is necessary to achieve legitimate interests - whether belonging to us, you, or a third party - provided these interests are not outweighed by your interests or fundamental rights and freedoms. We use the information we collect to:

Suggest your account to other users.

• We may suggest your account to other users, including when a user chooses to sync their contacts with the Platform.

• Legitimate Interest relied upon: To enable users to quickly and efficiently find and connect with other users.

• Information used: Information You Provide, Automatically Collected Information, and Information From Other Sources.

Provide all users with non-personalised advertising.

• We show all users non-personalized advertising, including those who have chosen not to receive personalized ads.

• Legitimate Interest relied upon: We show non-personalised ads to keep the Platform free of charge. We process limited categories of your information to make sure our advertising service is useful to our advertisers (for example, to serve ads to users in a particular country or to users who speak the same language).

• Information used:Automatically Collected Information and Information From Other Sources.

Provide measurement and analytics services.

• We help creators and advertisers measure the effectiveness and distribution of ads and other content viewed on the Platform.

• Legitimate Interest relied upon: To enable creators and advertisers to view and understand how their ads or content performed and the audience that viewed or interacted with their ads or content. This is so that they can make informed decisions (such as what kinds of ad campaigns they may want to run, the type of audience they want to reach and the types of content that users enjoy the most). This helps keep the advertising and other content we show users relevant and entertaining, and keeps the Platform free for all users.

• Information used: Information You Provide, Automatically Collected Information, and Information From Other Sources.

Ensure the safety and well-being of our community.

• We use your information to ensure the safety and well-being of our community, including by reviewing User Content (and if permitted under applicable law, Direct Messages and associated metadata) for breaches of our Terms, Guidelines, and other policies. We also infer your age range, and under certain circumstances, may ask you to provide additional information to confirm your age.

• Legitimate Interest relied upon: To keep our community safe, review compliance with our Guidelines, and identify misuse of the Platform.

• Information used: Information You Provide, Automatically Collected Information, and Information From Other Sources.

Ensure the security and stability of the Platform.

• We use your information to ensure the stability and security of the Platform, including by identifying and combating technical or security issues (such as technical bugs, spam accounts, and detecting abuse, fraud, and illegal activity).

• Legitimate Interest relied upon: To ensure the ongoing stability and security of the Platform and to ensure it is continuously available and functioning.

• Information used: Information You Provide, Automatically Collected Information, and Information From Other Sources.

Review, improve, promote and develop the Platform.

• We use the information we have to understand how people are using the Platform and to develop and improve the Platform, including to train, develop, and improve our technology such as our machine learning models and algorithms. We also use this information to better understand and promote the Platform, popular topics, and emerging trends.

• Legitimate Interest relied upon: To improve, promote, and develop the Platform in an informed way.

• Information used: Information You Provide, Automatically Collected Information, and Information From Other Sources.

Share your information with third parties.

• We share your information with third parties whose platforms or services are integrated with the Platform.

• Legitimate Interest relied upon: To provide you with a seamless experience, allow your content to be shared on other platforms, enable third parties to authenticate users, and optimize user experience.

• Information used: Information You Provide, Automatically Collected Information, and Information From Other Sources.

Marketing communications.

• We may send you direct marketing messages about features of the Platform and third party services that we think will interest you. We may also send you promotions, contests, or marketing campaigns or event information. We will obtain your consent to send you messages where required by law.

• Legitimate Interest relied upon: To promote the Platform or third party products and services.

• Information used: Information You Provide, Automatically Collected Information, and Information From Other Sources.

Your Rights: Whenever we use your information on the basis that it is necessary for legitimate interests, you can object to, and request restriction of, such usage.

Your Consent

We ask for your consent to access or use your information for specific purposes. If we do, you’ll always be able to revoke your consent through your device permissions or in-app settings.

Personalized advertising.

• With your consent, we will serve you with personalized ads based on your activity on and off the Platform.

• Information used: Information You Provide, Automatically Collected Information, and Information From Other Sources for this purpose.

Your rights: Whenever we use your information based on your consent, you can withdraw your consent at any time. However, your withdrawal of consent will not affect the lawfulness of processing your information based on your consent prior to your withdrawal of consent. You can withdraw your consent for applicable personalized ads.

You also have the right to port information you have provided to us that we use based on your consent.

Compliance with a legal obligation

We may use your information including your Profile Information or User Content where it is necessary to comply with a legal obligation. This includes situations where we have obligations to take measures to ensure the safety of our users or comply with a valid legal request such as an order from law enforcement agencies or courts. We generally use Information You Provide and Automatically Collected Information, although it depends on the specific situation.

To perform a task in the public interest

We may use your information where it is necessary to perform a task in the public interest, including undertaking research, preventing and detecting crime, safeguarding children and promoting public safety, security, and integrity as laid down by applicable law. We generally use Information You Provide and Automatically Collected Information, although it depends on the specific situation.

Your rights: When we use your information on the basis that it is necessary for a task carried out in the public interest, you have the right to object to, and seek restriction of, our usage.

To protect someone's vital interests

We may use your information where it is necessary to protect your or someone else's life, physical integrity, or safety. This could include providing law enforcement agencies or emergency services with information in urgent situations to protect health or life. We generally provide Information You Provide and Automatically Collected Information, although it depends on the specific situation.

Your Rights and Choices

You have rights and choices when it comes to your information. Some of these rights apply generally, while others will only apply in certain circumstances. Depending on the scenario, these rights may be subject to some limitations. TopTips app UK will be responsible for responding to your request within the relevant periods provided by law. If necessary to resolve your request,Access your information. You can ask us, free of charge, to confirm what information we process about you, to provide certain information about the processing, and for a copy of your information. In-app controls enable you to:

• access your information that is available to other users when you navigate to the "me" tab on your account.

Delete your information. You can delete or ask us to delete some or all of your information. In-app controls enable you to:

• delete the content posted on your profile, such as your User Content and your Profile Information.

• delete your full account.

Rectify your information. You can change or ask us to change or correct your information where that information is not accurate. You can change or correct much of your information through the in-app controls and settings (such as your Profile Information and video content).

Port your information. You have the right to data portability in circumstances where we rely on contractual necessity or consent as our legal basis. This means that you have the right to receive your information in a structured, commonly used, and machine-readable format and to share it with a third party. You can exercise your right of portability by choosing to “Download your data” in your settings.

Object to the processing of your information. You also have the right to object to the processing of your information in certain circumstances. This right applies when we are performing a task in the public interest or pursuing our legitimate interests or those of a third party. In submitting an objection request, please provide all relevant information, including the processing activity you are objecting to, why you want to object and how the processing activity affects you, and any additional information that you think will help us review your request. We will stop the particular processing if we don't have compelling legitimate grounds to continue that processing or don’t need it for legal claims.

Restrict the processing of your information. You have the right to request the restriction of the processing of your information where (a) you are challenging the accuracy of the information, (b) the information has been unlawfully processed, but you are opposing the deletion of that information, (c) where you need the information to be retained for the pursuit or defense of a legal claim, or (d) you have objected to processing and you are awaiting the outcome of that objection request.

We encourage you to “Contact us” if you are not satisfied with how we have responded to any of your rights requests. In addition to these rights, you can control privacy settings for your account.

Data Security and Retention

Security of your information is important to us. We maintain appropriate technical, administrative, and physical security measures that are designed to protect your information from unauthorized access, theft, disclosure, modification, or loss. We regularly review our security measures to consider available new technology and methods.

We retain information for as long as necessary to provide the Platform and for the other purposes set out in this Privacy Policy. We also retain information when necessary to comply with contractual and legal obligations, when we have a legitimate business interest to do so (such as improving and developing the Platform, and enhancing its safety, security and stability), and for the exercise or defense of legal claims.

The retention periods will be different depending on the type of information and the purposes for which we use the information. For example, when we process your information to provide you with the Platform, we keep this information for as long as you have an account. This information includes your Profile Information, User Content, and Direct Messages. If you violate our Guidelines or Terms, we may remove your Profile Information and/or User Content from public view immediately but keep your information as is necessary to process the violation.

Our Global Operations and Data Transfers

These entities commit to processing information in compliance with applicable privacy laws and to implementing appropriate security measures to protect your information.

When we transfer your information outside of the EEA, the UK, or Switzerland, we ensure it benefits from an adequate level of data protection by relying on:

• Adequacy decisions. These are decisions from the European Commission under Article 45 GDPR (or equivalent decisions under other laws) where they recognise that a country offers an adequate level of data protection. We transfer your information as described in What Information We Collect to some countries with adequacy decisions, such as the countries listed here; or

• Standard contractual clauses. The European Commission has approved contractual clauses under Article 46 of the GDPR that allows companies in the EEA to transfer data outside the EEA. These (and their approved equivalent for the UK and Switzerland) are called standard contractual clauses. We rely on standard contractual clauses to transfer information as described in What Information We Collect to certain entities in our Corporate Group (as described here) and third parties in countries without an adequacy decision.

For a copy of these adequacy decisions or standard contractual clauses, please contact us via the details provided in the Contact us section below.