Privacy Policy

1. About Us

Topline Holdings, Inc. (“Company” “us,” “our,” or “we”) provides professional intelligence services (“Services”) through an online interactive website, mobile application, and related software (collectively, the “Platform”). We respect your privacy and are committed to protecting it through our compliance with this Privacy Policy. Capitalized terms used in this Privacy Policy and not otherwise defined have the meanings set out in our Terms of Service (https://company.topline.com/terms-of-service/).

This Privacy Policy describes the types of information we may collect from visitors to our website (“Visitors”), registered subscribers to our Services (“Clients”), and individuals whose data we may process as part of our Services, as well as our practices for collecting, using, maintaining, protecting, and disclosing that information. We may refer to Visitors and Clients together as “Users.”

This Privacy Policy applies to information we collect:

• Through our Platform

• In email, text, and other electronic messages between you and us outside the Platform

• From third-party sources

Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Platform. By accessing or using our Platform, you accept and consent to this Privacy Policy.

2. Data We Collect

2.1 Non-Personal Data

We may collect Users’ non-Personal Data that is un-identified and non-identifiable. As you navigate through and interact with the Platform, we may use automatic data collection technologies to collect certain information about your use of the Platform, including:

• Details of your visits to the Platform, including traffic data, webpages you viewed, time spent on those pages, and access dates and times.

• Information about the resources that you use to access the Platform, such as your device and internet connection, operating system, and browser type.

2.2 Personal Data

“Personal Data” means information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device. We may collect the following types of Personal Data from you as part of providing our Services:

• Registration: Information provided when you request access to our Services or during the registration process, which may include your name, email address, phone number, password, user name, and mailing address.

• Profile: Clients who populate their profile on the Platform have the option to provide additional Personal Data, including work history, educational background, photos, videos, geographic location, and potentially other Personal Data. Some or all of your profile data is available to other Clients, and should not be transmitted if you do not want it to be publicly available.

• User Content: Information you publish or display (“post”) on interactive or community areas of the Platform, or transmitted to other users of the Platform or third parties (collectively, “User Content”), such as reviews of other profiles, comments to Platform content, photos, videos, and images. Although we may limit access to certain portions of the Platform to registered Clients, your User Content is posted on the Platform and transmitted to others at your own risk. Please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other Users of the Platform with whom you may share your User Content. Therefore, we cannot and do not guarantee that your User Content will not be viewed by unauthorized persons.

• Communications: Records and copies of your correspondence (including email addresses) with us, such as through messaging on the Platform or email, when you report a problem with the Platform, respond to surveys or other requests that we might ask you to complete.

2.3 Automatically Collected Data

When you access and use the Platform, we may collect certain data from automatically collection technologies. The information we collect automatically helps us to improve the Platform and to deliver better Services, including by enabling us to estimate our audience size and usage patterns, store information about your preferences, speed up your searches, and recognize you when you return to the Platform.

The technologies we use for automatic data collection includes:

• Cookies (or browser cookies): We use cookies to understand how you use our Platform, to personalize content, and to improve your experience. Where our use of cookies is not strictly necessary for the provision of Services, you can manage your preferences relating to the use of cookies in your browser settings.

• Strictly necessary cookies: These are required for the operation of our Platform. They include cookies that enable you to log into secure areas, use a shopping cart, or make use of payment processing.

• Analytical/performance cookies: These allow us to recognize and count the number of Users and to see how Users move around our Platform. This helps us improve the way our Platform works.

• Functionality cookies: These recognize you when you return to our Platform. This enables us to personalize our content for you, greet you by name, and remember your preferences.

• Targeting cookies: These record your visit to our Platform, the pages you have visited, and the links you have followed. We will use this information to make our Platform and advertising more relevant to your interests. We may also share this information with third parties for this purpose.

• Web Beacons: Pages of our Platform and our emails may contain small electronic files known as web beacons (clear gifs, pixel tags, etc.) that permit the Company to count users who have visited those pages or opened an email and for other related website statistics.

2.4 Public Data

We may collect publicly posted information (“Public Data”) from various third parties, including social media websites, data providers, and professional-related news sources. This information has been made publicly available by such third-party sources.

2.5 Minors

Our Services are not intended for children under 18 years of age. No one under age 18 may provide any Personal Data to or on the Platform. We do not knowingly collect Personal Data from anyone under 18. If you are under 18, do not use or provide any information on the Platform. If we learn we have collected or received Personal Data from a minor under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a minor under 18, please contact us at [email protected].

3. Purpose of Collection/Processing

We collect and process Personal Data for one or more of the following purposes:

• Consent: To fulfill or meet the reason you provided the information. For example, responding to an inquiry.

• Contract Performance: To carry out our obligations and enforce our rights arising from any contracts entered into between you and us (billing, account notices, renewals).

• Protection: To maintain the safety, security, and integrity of our Platform, prevent transactional fraud, and provide customer support.

• Legitimate Interests: To provide, support, and personalize our Platform and Services; deliver relevant content and targeted offers; process transactions; and conduct research and analysis.

• Legal Obligation: To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

• Other Purposes: To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets.

4. Disclosure of Your Information

4.1 Non-Personal Data

We may share, sell, or disclose anonymized and aggregated information about Users, and information that does not identify any individual, without restriction.

4.2 Personal Data

We may share your Personal Data to third parties for a business purpose or sell your Personal Data, subject to your right to opt-out of those sales (see Opt-Out Rights below). Please note: No mobile information or SMS opt-in consent will be shared with or sold to third parties or affiliates for marketing or promotional purposes. When we disclose Personal Data for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Data confidential and not use it for any purpose except performing the contract. We may share your Personal Data with the following categories of third parties:

• Service providers that perform services on our behalf, such as customer support, advertising and marketing, website hosting, and payment processing.

• Other Users who are interested in your public information that you have elected to make public.

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.

• To enforce or apply our Terms of Service (https://company.topline.com/terms-of-service/) and other agreements, including for billing and collection purposes.

• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of our Company, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

4.3 Public Data

We share Public Data with our Users in order to provide our Services.

5. Third-Party Integrations

On occasion we may integrate third-party products or services on our Platform. Please note that these third parties have their own privacy policies and that we do not accept any responsibility or liability for these policies. Where we provide an integration, it does not mean that we endorse or approve that party’s policy towards user privacy. You should review their privacy policy before engaging with the integration or sending them any Personal Data.

6. Your Data Rights and Choices

6.1 Data Rights

Unless we have the right to keep your Personal Data for legitimate business or legal purposes, you have the following rights to:

• Confirm whether we process your Personal Data.

• Access, review, supplement, correct or delete any Personal Data that you have provided to us or where it is not compliant with applicable laws.

• Remove and/or reject cookies from our Platform with your browser settings. Necessary cookies are a condition of using our Platform. If you remove or reject our cookies, it could affect how the Platform performs for you.

• Request to have your Personal Data in a portable format.

• To the extent we have collected and/or processed your Personal Data with your consent, you may withdraw your consent at any time.

• To make a complaint at any time to the data privacy authority in your jurisdiction. We would appreciate the chance to deal with your concerns first, so please contact us.

6.2 Opt-Out Rights

You have the right to direct us to not sell your Personal Data at any time and to refrain from doing so in the future. We do not sell the Personal Data of individuals we actually know are less than 18 years of age. To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by [email protected] or completing the form at https://company.topline.com/opt-out/. You do not need to register an account with us to exercise your opt-out rights.

6.3 How to Make a Request

To exercise your rights above, you can email us at [email protected]. We may ask you to verify your identity before processing your request concerning your Personal Data. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Data or an authorized representative.

• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Data if we cannot verify your identity or authority to make the request. Making a verifiable consumer request does not require you to create an account with us.

7. Data Retention

We will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process your data, and the applicable legal requirements.

8. Warranty Disclaimer

Regardless of anything in this Privacy Policy to the contrary, we are not responsible for the accuracy, correctness, and security of any of the information we gather, store, and disclose to you or to anyone else.

9. Changes to Our Privacy Policy

We reserve the right to modify this Privacy Policy at any time, so please review it frequently. If we make material changes to our Privacy Policy, we will post a notice on this page or our homepage and by email to the address associated with your account. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting the Platform and this Privacy Policy to check for any changes. Your continued use of this Platform after the effective date of change posted in our notice is deemed to be acceptance of those changes.

10. Contact Information

For questions or concerns about our Privacy Policy and practices, please contact us by email at [email protected].