Tophy Privacy Policy
Effective: November 27, 2024
Longdistance Tech Inc. a company incorporated under the Laws of Delaware (hereinafter “we”,
“us”, or “our”) respects your legal rights of privacy when collecting, storing, using and transmitting Personal
Information (as defined below) and this Privacy Policy explains our privacy practices. It is our policy and
obligation to comply with the requirements of the laws of Delaware, in particular, the Personal Data Protection
Act 2012 ("the Act"). In doing so, we will ensure compliance by our Associates to the strictest standard of
security and confidentiality.
Please read the following carefully to understand our policy and practices regarding how your
Personal Information will be treated. This Privacy Policy applies to all registered and unregistered Users of
Longdistance and may from time to time be revised, or otherwise changed where necessary.
By being one of our Users or visitors to our software 'Tophy' you agree to be bound by all the
terms
and conditions set out in this Privacy Policy and THAT YOU GIVE US YOUR CONSENT to collect, use and disclose such
Personal Information. If you do not accept the terms of this Privacy Policy or disagree with any subsequent
amendments, changes, or updates we made, you MUST NOT access the software and not use any Service provided by us.
You hereby agree your only recourse in this case is to cease and desist from further use of the Service.
Please note that our Privacy Policy has also been updated to comply with the requirements under
the EU General Data Protection Regulation (the "GDPR"), the California Consumer Privacy Act (the “CCPA”) and other
personal data protection regulations.
Warning: The Longdistance suite of software, including but not limited to computer and
mobile software (collectively, the "App") may contain or be used to transmit sexually explicit material that is
intended for individuals 18 years of age or older. If you are under the age of 18, if such material offends you,
or if it is illegal to view such material in your jurisdiction, do not continue.
THIS DOCUMENT CONTAINS IMPORTANT TERMS AND CONDITIONS WHICH AFFECT YOUR RIGHT TO PRIVACY AND
YOUR EXPECTATIONS AS TO YOUR PRIVACY. USING THE APP CONSTITUTES ACCEPTANCE BY YOU OF THIS PRIVACY POLICY.
The terms "you", "your", and "yours" refer to all users, and/or any user of the App. The terms
"its", "we", "us", "our" and "Longdistance" refer wholly or in part to Longdistance Tech Inc. (collectively, the
"Company" or "Longdistance"). Your privacy is an important factor that we considered in the development of our
Services. As such, we are committed to being transparent and open. This Privacy Policy explains generally how we
collect, store and process the information, which may include personally identifiable data ("Personal Data"). The
Privacy Policy applies to all Personal Data processed by us, including Personal Data collected or submitted
through our products, services, and software applications (collectively, the "Services").
BY DOWNLOADING OUR APPLICATIONS, YOU ARE CONSENTING TO THE TERMS AND CONDITIONS OF THIS PRIVACY
POLICY AND OUR COLLECTION AND USE OF PERSONAL INFORMATION AS OUTLINED BELOW. IF YOU DO NOT AGREE TO THE TERMS AND
CONDITIONS OF THIS PRIVACY POLICY, PLEASE DO NOT USE THE SERVICES.
1. INFORMATION THAT WE MAY COLLECT
We may collect different types of personal and other identifiable information based on your use
of the Services. Wherever the Company collects Personal Data we make an effort to provide a link to this Privacy
Policy. When you create an account, purchase our products, and otherwise use our Services including when you use
some of the functions of our mobile software applications offline. Generally, we may collect the below categories
of Personal Data related to the Services from our users:
Identifiers such as a real name, alias, postal address, internet protocol address, email address,
account name, geographic location information, or other similar identifiers.
Commercial information, including products or services purchased, obtained, or considered, or other
purchasing or consuming histories or tendencies.
Biometric information. Note: While we do not collect biometric information, if you choose to
authenticate yourself through certain service providers we use, they may collect biometric information subject to
their privacy policies, but we are never provided with access to that information. You explicitly agree that we
collect your gender information, which will be used to categorize your account and the content that you share so
it is easier for site users to find.
Internet or other electronic network activity information, including, but not limited to, user
content, browsing history, search history, and information regarding a consumer’s interaction with an internet
website, application, or advertisement.
Audio, electronic, video, visual, thermal, olfactory, or similar information.
Data collected by Longdistance related software and shared with this App with the data subject’s
license.
By voluntarily providing us with Personal Data, you are consenting to our use of it in
accordance with this Privacy Policy. If you provide Personal Data to the Company, you acknowledge and agree that
such Personal Data may be transferred from your current location to the offices and servers of the Company and the
authorized third parties referred to herein.
We may also collect:
(i) Non-Identifiable Data. When you interact with the Company through
the Services, we receive and store certain personally non-identifiable information. Such information, which is
collected passively using various technologies, cannot presently be used to specifically identify you. The Company
may store such information itself or such information may be included in databases owned and maintained by the
Company, affiliates, agents or service providers. The Services may use such information and pool it with other
information to track, for example, the total number of visitors to our Services, the number of visitors to each
page of our Services, and the domain names of our visitors' Internet service providers. It is important to note
that no Personal Data is available or used in this process.
(ii) Aggregated Personal Data. In an ongoing effort to better understand and serve the users of
the Services, the Company may conduct research on its customer demographics, interests, and behavior based on the
Personal Data and other information provided to us. This research may be compiled and analyzed on an aggregate
basis, and the Company may share this aggregate data with its affiliates, agents, and business partners. This
aggregate information does not identify you personally. The Company may also disclose aggregated user statistics
in order to describe our services to current and prospective business partners and to other third parties for
other lawful purposes.
(iii) A cookie is a text file placed on the hard disk of your computer by a Web page server.
Please rest assured that the Cookies cannot be used to run programs or bring viruses to your device. Cookies are
uniquely assigned to your computer, and can only be read by the web server in the domain which issued to you the
cookies. The purposes of a cookie are to enable the Web server to recognize your return to a specific page, and to
provide you convenience to save you time. You are provided with the option to accept or decline cookies. Most Web
browsers will automatically accept cookies, and you can modify your browser setting to decline cookies. When you
choose to decline cookies, your experience of interaction with the Longdistance services can be compromised.
Both the website and Longdistance APPs use cookies to better your interactions with the
Websites and the APPs. Our servers will send to your device a cookie while you visit our website or Longdistance
APPs. The cookies, however, cannot be used to personally identify you, but merely recognize your Web browser. We
will not be able to know your identity unless you choose to identify yourself to us by, for instance, responding
to our marketing questionnaire.
The types of Cookies include session-based and persistent-based Cookies. Session cookies only
exist during a session and disappear while you close your browser or turn off your computer. Persistent cookies
will be kept on your computer after you close your browser or turn off your computer. In case you choose to
identify yourself to us, the website use session cookies containing encrypted information to allow us to uniquely
identify you, which allows us to, for instance, process your online requests or transactions.
Longdistance APPs and the website use persistent cookies that only the Company will be able to
read and use to identify your previous visit. Whenever you access the APPs or the website, a unique identifier is
assigned to you through the server. This unique identifier is associated with a persistent cookie that
Longdistance APPs or our website place on your browser. The security and confidentiality of the information stored
in persistent cookies shall be especially taken care of by the Company. For example, Longdistance APPs do not
store account numbers or passwords in persistent cookies.
(iv) IP Addresses. When you visit our website, the Company collects IP addresses to track and
aggregate non-personally identifiable information. For example, our website uses IP addresses to identify the
regions from which users navigate the website.
(v) User Generated Content and Public Activities (including Comments). We offer you the ability
to post content that other users can read (e.g., comments or product reviews). Anyone can read, collect and use
any personal information that accompanies your posts. Read our Terms and Conditions on publishing comments for
more information. We do not have to publish any of your content. If the law requires us to take down, remove or
edit your personal information, we will comply to the required extent.
2. HOW WE USE YOUR PERSONAL DATA AND OTHER INFORMATION
The Company uses the Personal Data you provide in a manner that is consistent with this Privacy
Policy. Longdistance may use your data (including data concerning your activity with a Longdistance software )
across all other Longdistance products and software to deliver Longdistance products, functionality, or features.
If you provide Personal Data for a certain reason, we may use the Personal Data in connection with the reason for
which it was provided. For instance, if you contact us by email, we will use the Personal Data you provide to
answer your question or resolve your problem. Also, if you provide Personal Data in order to obtain access to the
Services, we will use your Personal Data to provide you with access to such services and to monitor your use of
such services. The Company may also use your Personal Data and other personally non-identifiable information
collected through the Services to help us improve the content and functionality of the Services to better
understand our users and to improve the Services. The Company may use this information to contact you in the
future to tell you about Services we believe will be of interest to you. If we do so, each marketing communication
we send you will contain instructions permitting you to "opt out" of receiving future marketing communications. In
addition, if at any time you wish not to receive any future marketing communications, or you wish to have your
name deleted from our mailing lists, please contact us as indicated below. If the Company intends on using any
Personal Data in any manner that is not consistent with this Privacy Policy, the Company would inform you of such
anticipated use prior to or at the time at which the Personal Data is collected.
For the avoidance of doubt, we do not accept that we are a joint controller of personal data of any third parties (other than you)
available or contained in any Content submitted by you pursuant to the Terms and Conditions, and disclaim any and all liability in
connection with the Third-Party Personal Data.
3. WE MAY SHARE YOUR PERSONAL DATA AND OTHER INFORMATION WITH THIRD PARTIES
Our Company is not in the business of selling your Personal Data. Maintaining the privacy of
your Personal Data is a vital part of our relationship with you and an important aspect of the Services that we
provide. There are, however, certain circumstances in which we may share your Personal Data with certain third
parties without further notice to you, as set forth below:
Business Transfers. As we develop our business, we might sell or buy businesses or assets, including
Personal Data. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal
Data may be part of the transferred assets.
Agents, Consultants, and Third Parties. The Company, like many businesses, sometimes contracts other
companies to perform certain business-related functions. Examples of such functions include mailing information,
maintaining databases, and processing payments. When we employ another entity to perform a function of this
nature, we only provide them with the information that they need to perform their specific function. Additionally,
we reserve the right to use third party analytics service providers and advertising partners to collect personally
identifiable information about your online activities over time and across different websites when you use our
Services, including details as described in this Privacy Policy. Furthermore, we partner with third parties to
provide certain support services to our users. We try to limit how these third parties can use the information
they gather from you or that we provide. The processing and storage of any and all information you may provide to
any of such third parties, including information they may collect from you, is not governed by this Privacy
Policy. You will need to review the Privacy and Cookie Policy of such third party on their websites and accept
separately if necessary.
Legal Requirements. The Company may share your Personal Data, including information about your interaction
with our Services, with government authorities, industry peers, or other third parties (i) if required to do so by law or
in the good faith belief that such action is necessary to comply with a legal obligation, (ii) to protect and defend our
rights or property, (iii) if we determine, in our sole discretion, that there is a violation of our terms, policies, or the law;
(iv) to detect or prevent fraud or other illegal activity; (v) to protect the safety, security, and integrity of our products,
employees, or users, or the public, or (vi) to protect against legal liability.
4. HOW LONG WE KEEP YOUR CONTENT
We will retain your personal information for the period necessary to fulfil the purposes
outlined in this Privacy Policy and in each case in accordance with applicable legal and regulatory requirements
in respect of permitted or required retention periods and limitation periods relevant to legal action. The storage
periods are determined on a case-by-case basis that depends on factors like the nature of the information, why it
is collected and processed, relevant legal or operational retention needs, and legal obligations.
If you wish to close your registered profile or delete your personal information you have
provided to us, please follow relevant instructions in your account or contact us by email at
[email protected].
* Please be noted that any Content that you send to the recipient as aforementioned does not
fall within the scope of personal information which we will collect under Article 1 of the Privacy Policy. The
Company hereby disclaims any obligation or liability for acquisition, storage and use of the Content by any third
party, including the recipient, to whom the Content is sent by the User.
5. CHILDREN SHOULD NOT SUBMIT PERSONAL DATA
The Company does not knowingly collect Personal Data from individuals under the age of 18. If
you are under the age of 18, please do not use the Services and do not submit any Personal Data through the
Services. We encourage parents and legal guardians to monitor their children's internet usage and to help enforce
our Privacy Policy by instructing their children under the age of 18 never to provide Personal Data to the
Services. If you have reason to believe that someone under the age of 18 has provided Personal Data to the Company
through the Services, please contact us at
[email protected], and we will endeavor to delete that
information from our databases.
6. HOW WE SECURE YOUR INFORMATION AND CONTENT
The Company takes commercially reasonable steps to protect the Personal Data provided via the
Services from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. The Company uses
security measures for any personal and account data that we store (emails, phone numbers, etc.).
Account-identifiable or user-identifiable data collected through the Services may be encrypted and stored on our
internal databases. The Company will not sell or transfer account-identifiable data to third parties. Any
accessible data associated with your account or your profile can be retrieved only if you provide us with your
account identifier. Please be reminded, however, that no internet or email transmission or data storage is ever
fully secure or error free and that information on the Services may be accessed, disclosed or altered. In
particular, email sent to or from the Services may not be secure. Therefore, you should take special care in
deciding what information you send to us. Please keep this in mind when disclosing any Personal Data to Company
via the Internet.
Please note that all payments for products and services are processed by third-parties. The
Company makes good-faith efforts to use third-party companies which employ proper protections for private
information. However, we have no control over said companies; therefore, the Company exclusively disclaims any
obligation or liability for said third-parties' processes and security measures.
7. YOUR ABILITY TO MODIFY OUR USE OF YOUR PERSONAL DATA UNDER GDPR
Under the GDPR, you have the following rights related to the Company's use of your Personal
Data:
a. Right to withdraw consent. You have the right to notify the Company that you no longer want
us to process or use your Personal Data. You can do that by contacting the Company at
[email protected].
b. Right to data portability. You have the right to obtain a copy of your Personal Data stored
and processed by the Company and direct the Company to transfer your Personal Data to another controller via a
structured, commonly used and machine-readable format. You can do that by contacting the Company at
[email protected].
c. Right to erasure/Right to be forgotten. You have the right to request that any of your Personal Data being stored
or processed by the Company is deleted from our records. However, while we can delete your Personal Data from our current records, copies of
your data may be stored in the Company's inactive and archived records and will be deleted in accordance with the Company's then-current
document management policy. In some cases, your Personal Data may be continued to be stored in archived records of transactions or activities
where we are required by law to retain such records.
d. Right to restriction of processing. You may request that the Company restrict the processing of your Personal Data.
In such case, this may affect your ability to navigate or use the Services.
e. Right of access. You have the right to obtain from us confirmation as to whether or not personal data concerning you are being processed,
and, where that is the case, access to the personal data, as well as other supplementary information. You can do that by contacting us
using the contact details abovementioned.
f. Right not to be subject to discrimination. We will not deny, provide a different level of quality of goods or services,
or charge different prices for your exercise of these rights.
g. To exercise any of your rights above, please contact the Company at
[email protected]. If you choose to exercise
any of your rights listed above, it may affect your ability to use the Services, as the operation and functionalities provided on
the Services may require the use of your Personal Data.
8. SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS
This supplemental privacy policy shall apply only to residents of California, according to the
regulation of CCPA, and may be subject to change. The general privacy policy shall continue to apply to the extent
that it applies to you as a resident of California. Any term used in this supplemental privacy policy shall have
the same meaning as in the general privacy policy.
The CCPA requires disclosure of the categories of personal information collected over the past
12 months. While this information is provided in greater detail above, the categories of personal information that
we have collected, as described by the CCPA, are:
Identifiers, including name, email address, IP address, and an ID or number assigned to your
account.
Other individual records such as phone number, billing address, or credit or debit card information.
This category includes personal information protected under pre-existing California law and overlaps with other
categories listed here.
Demographics, such as your age or gender, or, where you have provided such information voluntarily.
This category includes data that may qualify as protected classifications under other California or federal laws.
Commercial information, including purchases and engagement with our services.
Internet activity, including your interactions with our services.
Inferences, including information about orders, interests, preferences, and favourites.
We collect and use these categories of personal information for our business and commercial
purposes that are previously described, including providing and improving our services, maintaining the safety and
security of our services, processing purchase and sale transactions, and for advertising and marketing services.
We share personal data as described above under Article 3.
For the purposes of the CCPA, Longdistance does not “sell” personal information, nor do we have
actual knowledge of any “sale” of personal information of minors under 16 years of age. California Civil Code
Section 1798.83 entitles California customers to request information concerning whether a business has disclosed
personal information to any third parties for the third parties' direct marketing purposes. California customers
who wish to request further information about our compliance with this law or have questions or concerns about our
privacy practices and policies may contact us, in writing by email at
[email protected].
To opt-out of receiving interest-based advertising, you can exercise your choice by using your
privacy settings.
9. ABILITY TO REVIEW AND EDIT YOUR INFORMATION
You may review and approve the Information about you that was stored in our database and obtained
through your use of the Services. Upon your written request, we will remove that information from our database or change
or correct Personal Data that you state is erroneous within applicable regulatory or other legal requirements.
You should understand, however, that information about you in our database might come from a number of sources,
so any inaccuracy is not necessarily the fault of the Company.
10. CHANGES TO THE PRIVACY POLICY
The Company hereby reserves the right to modify/ amend or otherwise change this Privacy Policy,
as it deems necessary or appropriate because of legal compliance requirements or changes in Company's business
practices. We will use reasonable efforts to notify you in the event material changes are made to our processing
activities and/or this Privacy Policy, such as by posting a notice on the Services or sending you an email, and
update the “Last modified” date at the top of this Privacy Policy. Your continued use of the Services following
our posting of any revised Privacy Policy will constitute your acknowledgement of the amended Privacy Policy. If
you do not agree with our updated Privacy Policy, please do not use our Services.
11. CONTACT US
If you have any further questions about this Policy, please contact us by email at
[email protected].