Last Updated: 28 June 2022
This privacy policy ("Privacy Policy") is designed to describe Your Top 3’s ("YT3”, "we", "our" or "us") data collection practices in connection with the site (together with its subdomains, features, and services available thereon, the "Site") or any website that is part of the Your Top 3 Network of sites' applications for mobile (the “App”), and in connection with your use or engagement with any feature, content, offer, element or service we make available to you via the Site and App (“Our Services”). The section and sub-section headings used below are for convenience of reading only (and are not to be used for interpretive purposes), and we hope they ease navigating this Privacy Policy.
We reserve the right, in our sole and absolute discretion, to change this Privacy Policy at any time. In which case, we will post the modified Privacy Policy on the Site and App, and the “Last Updated” statement at the bottom shall reflect the effective date of the modified version. Any access or use you make of the Site and any download, access, and/or use of the App following such date constitutes your consent and acceptance of the modified Privacy Policy. If we make significant changes, we will make sure to provide more prominent notice to you, such as posting a notification on the Site and App, seven (7) days before the changes become effective. In which case, the changes will be effective seven (7) days after such notification was published.
This Privacy Policy forms an integral part of Our Services’ Terms of Use. (the "Terms"). Any capitalized term in this Privacy Policy that we don't define, will have the meaning given to it in the Terms.
We process and use Personal Information in accordance with data protection laws. Our legal ground for processing your Personal Information will typically be one or more of the following:
2.1. Performance of a Contract. By accessing or using Our Services, you ask us to provide Our Services to you in accordance with our Terms of Use. In order to do that, we need to process some of your Personal Information (such as your IP address).
2.2. Legitimate Interests. We may use some of your Personal Information where we have legitimate business grounds to do so. We use this Personal Information to operate, improve and promote Our Services (for example, when we customize your experience of Our Services or for analytics purposes) and to protect our business (for example, to prevent fraud or ensuring the Our Services’ security).
2.3. Legal Obligations. In some cases, our use of your personal information will be necessary to comply with regulatory obligations or legal requirements (for example, addressing complaints from users or authorities);
2.4. Consent. In certain cases. We will ask for your consent to process and use your Personal Information in order to provide additional services (for example, when you subscribe to our newsletters, create your user profile, provide us Personal Information to get tailored offers or add a review on a service or product). When we rely on consent as our legal basis of processing You may ask to withdraw your consent. Once we have verified your request, we will contact you.
When you visit or use Our Services we may collect certain information about your visit and usage of Our Services, in one or more of the following ways:
3.1. Information You Provide to Us. Some of Our Services will require you to provide or submit certain Personal Information in order to be able to use it. Some of the features and/or services that require you to provide Personal Information are subject to your specific and active consent (e.g. creating user profile, adding your review to one of the services or products that appear on Our Services, newsletters which may become available in certain Sites or Apps from time to time, promotional material and forms) and choice, and some will be collected upon your consent to this Privacy Policy, as described below.
For the purposes of this Privacy Policy, "Personal Information" means information that may be used, either alone or in combination with other information, to personally identify an individual, such as a first and last name, an email address, phone number, a home or other physical address, and other contact information. In some jurisdictions and given the specific use we make with the information, IP address that your Internet service provider allocates for your device may also be considered as Personal Information. In which case, we will be treating the information as personal in all handling and safeguarding aspects, however, we do not make any use of such information for user identification purposes.
3.1.1. Third-Party Forms and Services: Our Services list, rate and compare various 3rd party businesses, brands, and commercial entities (collectively, "Partners") and their respective products and/or services (collectively, "Products"). We may, from time to time, provide you with offers, services, and Products of Partners via an online form to be filled by you, upon your intent choice and consent, and such information will be used to facilitate your connection and/or engagement with the relevant Partner (“Lead”). Additionally, if you want to receive more information about a Partner or a Product, or if you otherwise want to pursue a transaction with a Partner, and you click the relevant Partner icon or tab, you may be directed to a landing page or an online form that is owned and operated by the Partner (the "Landing Page"); similarly, you may also be directed to the Landing Page through other websites and online searches. In either case, however, you may be prompted to submit certain information on the Landing Page, including Personal Information such as your name, email address, and phone number (such information collectively, "Landing Page Info"). The Landing Page Info that you submit is collected directly by the Partner who provided it and will include its own privacy policy and data collection practices information. We advise you to refer to such privacy policies to better understand the purpose of the collection and use of the Personal Information you submit.
3.1.2. Contact Us. If you send us a ‘Contact Us’ (or similar) request, whether by submitting an online form that we make available, by sending an email to an email address that we display, by using a feedback or reporting feature that is available on Our Services, or by other means, you may be required to provide us with certain Personal Information, such as your name and email address. Such information, including the content of your approach, will be used for the purposes of processing and addressing your request and for our legitimate business purposes, as further described in sections 4 and 5 of this Privacy Policy.
3.1.3. Blogs, Newsletters, Surveys, and Promotions. Our Services may contain a blog forum, reviews, and articles displaying information about Our Services, Partners, Products, and the relevant market vertical. Our Services may also offer you the opportunity to subscribe to newsletters and participate in surveys and other promotional activities (some of which may be administered by us, and some of which may be administered by third party services with which we engage). In each of the foregoing cases, your interaction (such as responding on the blog forum, subscribing to a newsletter, or participating in a survey) may require you to provide certain Personal Information such as your name and email address. In which case, your submission of information will also be provided directly to such third party and will be used according to this privacy policy as well as such third party’s own privacy policy, and for the purpose for which you provided the information.
3.1.4. User Profile and User Reviews. We may offer you the option to give a review of one of our Partners or to create a user profile for some of Our Services which entails providing us with additional information about you that will assist us in providing you with a customized experience.
3.2. Information We Collect from You. We collect information about your use of Our Services and your interaction with Our Services, as follows, and in the following ways:
3.2.1. Device Information: For delivering and compatibility purposes, so as for language, geographic location and time zone, we collect device information such as: device type and version, operating system type, language and version, and information that can be extracted out of a user agent, such as browser type and version, screen resolution.
3.2.2. Interactions and Usage: In order to provide Our Services, operate the Site and App, and keep improving them, so as to be able to sync with our Partners and affiliates, we collect information about your interaction and use of Our Services, such as: URLs from which you were directed to the Site or App and to which you are referred from the Site or App, internal URL’s of the Site or App in which you visited and your actions with respect to Our Services (such as view or click), date/time stamp of Site or App use, the timing for clicks and page-views.
3.2.3. Log Files: We collect information through server log files, but also by deploying tracking technologies within Our Services, such as pixel tags. We do this to analyze trends, track user’s engagement, and interaction with Our Services. The type of information collected may include internet protocol (IP) addresses that your Internet service provider allocated to your device. We collect IP for a limited time and for specific purposes. First is to better understand your geographic location (country, region, and language) and therefore be able to provide Our Services in your own language and relevant to your place of origin. Second, we use automated tools to analyze IP addresses and flag those that are fraudulent.
3.2.4. Cookies and Similar Technologies. Our Services may use "cookies" and other anonymous web tracking technologies (such as "web beacons" and "pixel tags") implemented by us or by third-party service providers. A cookie is a small file containing a string of characters that is sent to your computer when you visit a website. When you visit the website again, the cookie allows that website to recognize your browser. Cookies may store your online preferences and other information about the interaction you make on Our Services. You can reset your browser to refuse all cookies or to indicate when a cookie is being sent to your browser. However, some features or services, included in the Site and App, may not function properly without cookies, and some features may become unavailable for you in such a case. A pixel tag is a type of technology placed on a website for the purpose of tracking activity on websites, or when emails are opened or accessed (if applicable), and is often used in combination with cookies.
3.3. Information we receive from Third Parties. Like many Internet-based services, Our Services are operated and provided in collaboration, sync, and interaction with third parties, including Partners, affiliates, and other third parties. In order to enable and facilitate such sync, we may receive information from third parties, such as an internal user identifier that our system generates for each user (not a unique identifier), and the summary of action taken by you (click, purchase, view, form submission or a phone call). In some of Our Services, you will be able – upon your choice – to consume Our Services on a click-by-call basis. In which case, a third-party vendor/s facilitate the call transmission, tracking, and feedback for success. In such cases, the phone number from which you called may be provided to us (with no other information about you attached), for a limited time and for purposes of resolving referrals and successful calls with our Partners. Except for this purpose, we do not make any other use of such information, unless you will give us your explicit consent.
You are not legally obligated to provide us with Personal Information (and you acknowledge that providing us with Personal Information is done freely). Nor are you required to use Our Services in the first place. By using Our Services and engage or interact with the Site or App, you consent to this Privacy Policy and to our information practices described herein. If you do not agree to this Privacy Policy, please do not access or otherwise use Our Services.
Some of Our Services will require you to submit specific Personal Information. In such a case you can choose whether you want to use such Services or not. Be aware that even if you provided us with your Personal Information, you have the full right to withdraw such consent at any time (please refer to section 8 below to get further details about opting out and withdrawing consent).
In addition to the uses of information we collect (including Personal Information, jointly “your Information”) described elsewhere in this Privacy Policy, we also use Personal Information in the following ways:
To generally provide you with Our Services and constantly improve them. We will use your Information to: (a) administer and make available Our Services to you; (b) further develop and generally improve Our Services; (c) counting and tracking purposes of referrals and ads; (d) validation of users as human and anti-fraud monitoring (e) respond to your inquiries and other communications with you; (f) identify or authenticate your access and use of Our Services.
We do not share Personal Information about you with third parties, except for the following circumstances:
6.1. Data Storage and Security Platforms (“Data Platforms); We use third party cloud and storage services to store and retain your Information. It means that we send or otherwise share your Information to/with third party entities that are located anywhere in the world, including in the U.S, for the purpose of storing such information on our behalf, or for other processing needs. Such entities include Amazon Web Services (which privacy policy available at: https://aws.amazon.com/privacy/). These Data Platforms may be located anywhere in the world. We use Data Platforms that maintain strict privacy protection and data security policies, and strict compliance with applicable data protection laws. However, their practices and activities are fully governed by their own privacy policies.
6.2. Social Media Platforms. We may share not identified information with social media platforms (such as Facebook, LinkedIn, etc.) for marketing and operation purposes. Such social media platforms may collect your Personal Information independently and may combine the not identified information provided by us, with your Personal Information which they collect to which you gave your separate and independent consent. Any such action and any personal Information that may derive from it is subject to the social media's own privacy policy and is not governed, controlled, or known by us. To the extent provided by law, you may opt-out of this data sharing according to section 9 below (Privacy Notice for California Residents).
6.3. Other Third Parties. We may send or otherwise share your Information to/with various third parties that help us with our business operations (for example, customer service operators and email or phone administration providers), that help us understand how our users use Our Services, operate them and to improve them. These third parties may have their own privacy policies that they adhere to, and we require them to make it available whenever their services are provided. We recommend you revisit such privacy policies when those third parties render their services directly to you. Also, these third parties may be based (and their servers may be located) anywhere in the world.
We use ActiveProspect’s TrustedForm Script and Jornaya script to independently document users’ consent to be contacted. These tools are embedded on certain pages on our website and collect the following information when you interact with the page(s) where the script is present: page URL, mouse movements and clicks, contact information inputted by the user, a snapshot of the page, including IP address of the user’s computer, time on the page, date and time that the tools script were loaded, as well as the date and time of the various user interactions with the page, and HTTP headers from the user’s browser. For more information about ActiveProspect’s data use and collection policies and practices and Jornaya data use and collection policies, please review:
ActiveProspect Privacy Policy, located at: https://activeprospect.com/privacy-policy/
Jornaya Consumer Privacy Policy, located at: https://www.jornaya.com/consumer-privacy-policy/
6.4. Enforcement. We may share your Personal Information with any third party if we believe that disclosure of such information is helpful or reasonably necessary to (a) comply with any applicable law, regulation, legal process, or governmental request; (b) enforce our Terms of Use, including investigations of potential violations thereof; (c) detect, prevent, or otherwise address fraud or security issues; and/or (d) protect against harm to the rights, property or safety of NI, our affiliated entities, our users, yourself, and/or the public.
6.5. Partners and Products. Our Services may include submission of online forms, in case you will choose and be interested to receive additional information about one service or another (“Online Form”). In which case, we may send your Online Form information or otherwise share it to/with the Partner about whom (or about whose Product) you wanted to receive more information or with which you have expressed interest in pursuing a transaction (the "Corresponding Partner" and "Corresponding Product", respectively), for such Corresponding Partner to contact you back with the information you have requested. In either case, you acknowledge that: (a) the Partners may contact you using the Online Form information which you submitted; (b) we do not control the way in which Partner may contact you, or the subject matter of such contact; and (c) each Partner is required to provide its own privacy policy, and so it would not necessarily adhere to this Privacy Policy, and (d) Partners may be based (and their servers may be located) anywhere in the world.
6.6. Merger, Sale or Bankruptcy. In the event that YT3 or one of our affiliated entities is acquired by or merged with, a third party entity, or otherwise sells all or part of our/its assets, we may (and hereby reserve the right to) transfer or assign the Personal Information and other information we have collected or received. In such a case, we will require the acquiring entity to post its data practices and provide you with any of your rights as per the jurisdiction of your residency.
We may also share some non-Personal Information with the following type of third parties and under the following circumstances:
6.7. Third parties we engage or host or provide us with services and features we can offer to you collect data from Our Services and visitors’ engagement with the content and features on our behalf, or for the provisioning of their services. This happens in cases where we use or deploy third-party technology, service, or feature, or where we otherwise give these third parties access to our Site, App, or technology for specific purposes, as described in the Privacy Policy or in the Site or App. We may use analytics tools, including Google Analytics and Tableau. These tools help us understand users’ behavior on Our Services, including by tracking page content, and click/touch, movements, scrolls, and keystroke activities.
The privacy practices of these tools are subject to their own policies and they may use their own cookies to provide their services. For further information about cookies, please see our Cookie Policy. Click here for further information about Google cookies. Click here to opt-out of Google Analytics.
The Site and App may link to third party websites (such as those of Partners), content, and other online properties (collectively, "Third Party Properties"). Data associated with your clicking through to such Third Party Properties, as well as any Personal Information you provide on such Third-Party Properties, is provided to the third party (although YT3 and its affiliated entities may have arrangements with such third parties pursuant to which such data and Personal Information is sent or shared back to/with us). We are not responsible for the privacy practices of such third parties, or for such Third-Party Properties, Products, and respective data collection practices. We encourage you to read the terms and conditions and privacy policy of each Third-Party Property that you choose to use or interact with.
It is your choice to provide us with your information for the uses described in this Privacy Policy. You can decide at any time to exercise your rights with respect to your Personal Information and the jurisdiction of your residency. For example (where applicable and relevant):
8.1. Cookies and Tracking Technologies. you may set your browser to refuse and/or block any cookies from the Site, App, or third party services (for more details please refer to Section 2.1.1 hereof).
8.2. When applicable, review and update or request to remove your Personal Information from our servers (for more details please refer to Section 2).
9.1. EU Data Subject Rights. Any Personal Information we collect according to this Privacy Policy is handled and treated in compliance with the GDPR.
As an EU based user, you may:
9.2. Canada. If you are a residence of Canada, you are permitted to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes, where applicable.
9.3. Privacy Notice for California Residents. In some instances, the California law may apply to our data sharing. If you are a California resident, this section may apply to you and supplement the main privacy policy. The California Consumer Privacy Act (CCPA) provides specific rights to California residents in relation to their personal information. As a California resident and to the extent provided by law, you may:
Our California Do Not Track Notice. Some web browsers offer a “Do Not Track” (“DNT”) signal. A DNT signal is an HTTP header field indicating your preference for tracking your activities on Our Service or through cross-site user tracking. We do not currently respond to DNT signals. We may allow third parties, such as companies that provide us with analytics tools, to collect Personal Information about an individual consumer’s online activities over time and across different web sites and services when a user uses Our Services.
We and respective third-party services/affiliate entities implement data security systems and procedures to secure the information transmitted, processed, and stored on the Site or App, our computer servers, and systems. For example, the Site and App are encrypted by using SSL and so as with any other information at transport, we periodically review our information and data collection practices to ensure constant monitoring, we use third-party processing and serving services that implement various information security standards and certifications (at rest and transmission), and we monitor and filter access to data when it comes to personnel in our organization. Such systems and procedures reduce the risk of security breaches, but they do not provide absolute security, as there is no such thing when it comes to the world-wide network. Therefore, we cannot guarantee that Our Services and our servers are immune to unauthorized access to the information stored therein and to other information security risks.
Our Services are not designed to attract children under the age of 16. Accordingly, we do not intend to collect Personal Information from anyone we know to be under 16. If we learn that we have collected Personal Information from a child under 16, we will use commercially reasonable efforts to delete that information as quickly as possible.
We may transfer your Information (including Personal Information) outside the country in which it is collected or in which you reside (e.g., to the United States), including to a country that may not offer the same level of protection for Personal Information as the country in which you reside. However, in which case we make sure to place all contractual safeguards to ensure your Information is processed in a way that offers an adequate level of protection when it is shared between or among our third-party vendors.
By providing Personal Information and using Our Services, you expressly consent to the use of such information in accordance with this Privacy Policy and to the transfer of your Information to another country (including e.g., the United States).
Protecting your privacy online is an evolving practice, and we use our best efforts to evolve Our Services in a manner that meets these requirements and best practices as per all jurisdictions in which Our Services are available.
14.1. General Data Protection Regulation (GDPR) - European Representative. Pursuant to Article 27 of the General Data Protection Regulation (GDPR), Your Top 3 Ltd. has appointed European Data Protection Office (EDPO) as its GDPR representative in the EU. You can contact EDPO regarding matters pertaining to the GDPR by:
Copyright © 2024 Top3 Network. All Rights Reserved.