Effective: September 20, 2023
1. What We Mean by Personal Information
2. Information We Collect
Information You Provide To Us
When you use the Services or otherwise communicate with us, we collect information that you provide to us directly. For example, we collect information in the following circumstances: you (i) use our mobile apps or visit the Site, (ii) register for the Services or create an account or profile or accept the creation of an account or profile on your behalf (an “Account”), (iii) access the Services through social networking sites or third party services, (iv) subscribe to newsletters; (v) purchase a product or service on the Site or in our mobile apps; (vi) invite your friends to join the Services, “share” the Services on social networking sites or perform other similar actions; (vii) request technical support; (viii) otherwise use our mobile apps or online Services where Personal Information is required for such use and/or participation, (ix) when you sign up for a newsletter, and (x) when you contact us via the Site or when you otherwise communicate with us. You can choose not to provide information that is requested of you by us; however, this may limit your ability to use or access the Services.
The information you provide to us directly may include, without limitation, the following information that may, alone or in combination with other data, constitute Personal Information:
Moreover, if you contact us, a record of such correspondence may be kept.
Additionally, if another user refers you to us by providing us with your e-mail address, we may send you a message. However, we will use your e-mail address only to send such other user’s message unless you otherwise affirmatively provide your information to us.
Email Account Information
In accordance with Google authentication and sign-in procedures, we employ a sophisticated algorithm to scan and analyze email accounts for the purpose of offering users attractive cash deals.
Our algorithm functions by searching through your inbox for messages received from well-known retailers such as Apple, BestBuy, Walmart, and Costco. Utilizing machine learning models, our algorithm determines whether a message contains a receipt. If a receipt is detected, another model is utilized to extract crucial information from the receipt, including the purchase date, purchase price, items purchased, and prices of the items. This data is then utilized as input for yet another model, which generates offers to purchase one or more of the items listed in the receipt.
In order to enhance your experience on our platform, we collect and store various features associated with the device used to download and navigate our Services. This encompasses details such as IP address, device type, operating system, and geographical location. To validate the authenticity of email accounts, we gather high-level features associated with the accounts such as the date an account was created. Should you opt to connect your contacts, the uploaded contact information is used to determine who among your contacts has signed up for our Services as well. Moreover, if you choose to connect your Amazon accounts, we collect information pertaining to your purchases.
If you delete your account on our mobile application or Services, we are committed to ensuring compliance with the data privacy standards outlined by the California Consumer Privacy Act (CCPA) and the General Data Protection Regulation (GDPR). This means that user data associated with the deleted account, including personal information and usage data, will be securely and permanently erased from our systems, databases, and backups. By adhering to CCPA and GDPR regulations, we prioritize user privacy and data protection, actively working to safeguard their information throughout their entire journey on our mobile application.
We put you in control so that you can decide who can see your TipTop payments and purchases. Other users of the Services may request to follow your account such that, if you accept their request, they can then view your transaction history on TipTop. You may update the social permissions in your account to continually maintain control over which users can follow your activity on the Services.
We may ask for some Google permissions allowing us to register and authenticate you on the Services using Google. By default, we retrieve certain information such as your Google id, email address, and contacts. This information is used to help us easily connect you to the Services and to help us find new connections for you to meet efficiently but we do not store any user’s email data or message content.
Compliance with Google Limited Use Policy
The Services’ use and transfer to any other app or information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements therein.
Automatically Collected Information
Most of the data we collect in and through the Site and the Services is technical in nature and is collected and processed automatically through so-called application programming interfaces, software development kits, cookies and similar software-based technologies. Alone or in combination with other data, such automatically collected data may constitute Personal Information. The data we may collect by automated means may include, without limitation:
We may use, depending on the Services, (i) location based on the IP address presented by you, (ii) network-based geo-location data based on proximity of network towers or the location of Wi-Fi networks, and/or (iii) geo-location data based on coordinates obtained from a mobile device’s GPS radio and location services. Your GPS geo-location is accessed in accordance with your device settings. If location services are enabled on your mobile device and/or a mobile application in connection with the Services, certain of the Services will passively and automatically send location information to Company in order to for us to deliver location-specific information on your device and compile your individualized timeline. Please note that disabling location service will not anonymize data already collected and uploaded to our servers.
Google Analytics is an element of the Site. By using cookies, Google Analytics collects and stores data such as time of visit, pages visited, time spent on each page of the Site, the Internet Protocol address, and the type of operating system used in the devices used to access the Site. By using a browser plugin available at http://www.google.com/ads/preferences/plugin/ provided by Google, you can opt out of Google Analytics.
Information You Share on Third Party Websites or through Social Media Services
The Services may include links to third party websites and social media services where you will be able to post comments, stories, reviews or other information. Your use of these third party websites and social media services may result in the collection or sharing of information about you by these third party websites and social media services. We encourage you to review the privacy policies and settings on the third party websites and social media services with which you interact to make sure you understand the information that may be collected, used, and shared by those third party websites and social media services.
The following sets out how we may use different categories of cookies and your options for managing cookie settings:
|Type of Cookies
|Because required cookies are essential to operate the Site, there is no option to opt out of these cookies.
|These cookies collect information about how you use our Sites, including which pages you go to most often and if they receive error messages from certain pages. These cookies do not collect information that individually identifies you. Information is only used to improve how the Site function and perform. From time-to-time, we may engage third parties to track and analyze usage and volume statistical information relating to individuals who visit the Site. We may also utilize Flash cookies for these purposes.
|To learn how to opt out of performance cookies using your browser settings, click here. To learn how to manage privacy and storage settings for Flash cookies, click here.
|Functionality cookies allow our Sites to remember information you have entered or choices you make (such as your username, language, or your region) and provide enhanced, more personal features. These cookies also enable you to optimize your use of the Site after logging in. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customize. We may use local shared objects, also known as Flash cookies, to store your preferences or display content based upon what you view on the Site to personalize your visit.
|To learn how to opt out of functionality cookies using your browser settings, click here. To learn how to manage privacy and storage settings for Flash cookies, click here.
|Targeting or advertising cookies
|To learn more about these and other advertising networks and their opt out instructions, click here. To learn how to manage privacy and storage settings for Flash cookies, click here.
We and our service providers may also use “pixel tags,” “web beacons,” “clear GIFs,” or similar means in connection with the Services and HTML-formatted email messages to, among other things, track the actions of users, to determine the success of marketing campaigns and to compile aggregate statistics about Site usage and response rates.
3. Use of Collected Information
We use the information you provide to us for the following purposes: (i) to further our legitimate interests in providing the Services, including without limitation to collect and remit payment for paid features, (ii) to administer your use of the Services and any Accounts you may have with us, (iii) to personalize your experience, (iv) to provide to you Service announcements or inform you of new releases and features, (v) to provide you with further information and offers from us or third parties that we believe you may find useful or interesting, such as newsletters, marketing or promotional materials, (vi) to perform tasks on behalf of and according to instructions of a third party, such as payment processors, third party-service providers or our advertising partners, (vii) to enforce our Terms of Service, (viii) to resolve any disputes between users of the Site or between such users and us, (ix) comply with a legal requirement or process, including, but not limited to, civil and criminal subpoenas, court orders or other compulsory disclosures; (x) to further our legitimate interest in protecting our rights, property, or safety and the rights, property and safety of the Services, our users or the public, and (xi) to contact you to obtain feedback from you regarding the Site and the Services.
In addition to the purposes described above, we use the information collected automatically to (i) to further our legitimate interests in monitoring and analyzing the use of the Services and for the technical administration of the Site, (ii) improve the Site and the Services, (iii) generate and derive useful data and information concerning the interests, characteristics and website use behavior of our users, and (iv) verify that users of the Services meet the criteria required to process their requests. We and or our advertising partners may use demographic and geo-location, as well as information logged from your hardware or device, including data such as IP address, device model and ID, MAC address, operating system, application usage data, device time zone, region and language, and click ID, to ensure relevant advertising is presented within the Services.
4. Third Parties We Share Personal Information With
We may disclose Personal Information you provide to us or that we collect automatically on the Site and in and through the Services with the following categories of third parties:
All of the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.
5. Links to Other Websites
We understand the importance of privacy and security of Personal Information to our users and have made them a priority. Company uses a variety of industry-standard security technologies and procedures to help protect Personal Information about you from unauthorized access, use, or disclosure and trains Company employees on privacy and security issues. However, we cannot guarantee that unauthorized third parties will never be able to overcome those measures or use your Personal Information for improper purposes, and we do not promise that Personal Information about you or private communications will be protected from unauthorized disclosure or use.
7. Do Not Track Signals and Similar Mechanisms
Some web browsers transmit “do-not-track” signals to websites. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. We currently do not take action in response to these signals.
8. Managing Your Privacy
9. Your Rights
We take steps to help ensure that you are able to exercise your rights regarding Personal Information about you in accordance with applicable law. If you would like to access, review, erase, withdraw your consent, or object to, or restrict the processing of Personal Data we collect about you, you may submit a request to email@example.com. We will promptly review all such requests in accordance with applicable laws. Depending on where you live, you may also have a right to lodge a complaint with a supervisory authority or other regulatory agency if you believe that we have violated any of the rights concerning Personal Information about you. We encourage you to first reach out to us at firstname.lastname@example.org, so we have an opportunity to address your concerns directly before you do so.
10. California Residents
California Civil Code Section 1798.83 requires certain businesses that share customer Personal Information with third parties for the third parties’ direct marketing purposes to respond to requests from California customers asking about the businesses’ practices related to such information-sharing. We currently do not share or disclose your Personal Information to third parties for the third parties’ direct marketing purposes. If we change our practices in the future, we will implement an opt-out policy as required under California laws.
Furthermore, subject to certain exemptions, California residents have the following rights with respect to Personal Information we may have collected about them:
Requests to Know
You have the right to request that we disclose:
You may submit a request to know via email@example.com. The delivery of our response may take place electronically or by mail. We are not required to respond to requests to know more than twice in a 12-month period.
Requests to Delete
You have the right to request that we delete any Personal Information about you that we have collected. Upon receiving a verified request to delete Personal Information, we will do so unless otherwise required or authorized by law. You may submit a request to delete Personal Information via firstname.lastname@example.org.
You may designate an authorized agent to make requests on your behalf. You must provide an authorized agent written permission to submit a request on your behalf, and we may require that you verify your identity directly with us. Alternatively, an authorized agent that has been provided power of attorney pursuant to Probate Code sections 4000-4465 may submit a request on your behalf.
Methods for Submitting Consumer Requests and Our Response to Requests
You may submit a request for access and requests to delete Personal Information about you via:
Upon receipt of a request, we may ask you for additional information to verify your identity. Any additional information you provide will be used only to verify your identity and not for any other purpose.
We will acknowledge the receipt of your request within 10 days of receipt. Subject to our ability to verify your identity, we will respond to your request within 45 days of receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. In order to protect your privacy and the security of Personal Information about you, we verify your request.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
The Right to Non-Discrimination
You have the right not to be discriminated against for the exercise of your California privacy rights described above. Unless permitted by the CCPA, we will not:
11. International Transfers of Personal Information
Company is based in the United States. As a result, Personal Information that we collect in and through the Services and on the Site may be transferred to our U.S. offices. In addition, we may work with third-party service providers in the U.S. and in other countries to support our business activities. Thus, Personal Information may be transferred to, stored on servers in, and accessed from the United States and countries other than the country in which the Personal Information was initially collected. In all such instances, we use, transfer, and disclose Personal Information solely for the purposes described in this Privacy Notice and in compliance with applicable laws.
12. Data Retention
We keep Personal Information related to your Account for as long as it is needed to fulfill the purposes for which it was collected, to provide our services, to deal with possible legal claims, to comply with our business interests and/or to abide by all applicable laws. Thereafter, we either delete Personal Information about you or de-identify it. Please note that even if you request the deletion of Personal Information about you, we may be required (by law or otherwise) to retain the Personal Information and not delete it. However, once those requirements are removed, we will delete Personal Information about you in accordance with your request.
14. Contacting Us