PRIVACY POLICY

Last modified: March 2024

1. INTRODUCTION
   1.1 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://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, allowing us to customize the Platform according to your individual interests.
   • Speed up your searches.
   • 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. For information about managing your privacy and security settings for cookies, see Your Data Rights and Choices.
   o Strictly necessary cookies. These are cookies that are required for the operation of our Platform. They include, for example, cookies that enable you to log into secure areas of our Platform, use a shopping cart or make use of payment processing.
   o Analytical/performance cookies. These allow us to recognize and count the number of Users and to see how Users move around our Platform when they are using it. This helps us to improve the way our Platform works, for example, by ensuring that users are finding what they are looking for easily.
   o Functionality cookies. These are used to 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.
   o Targeting cookies. These cookies 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 the advertising displayed on it 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 (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain Platform content and verifying system and server integrity).
   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. PURPOPSE 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, if you share your name and contact information to request a subscription or ask a question about our Services, we will use that Personal Data to respond to your inquiry.
   • Contract Performance. To carry out our obligations and enforce our rights arising from any contracts entered into between you and us like when you subscribe to our Services, including for billing and collection, to provide you with notices about your account (including expiration and renewal notices), to allow you to participate in interactive features on the Platform, to notify you about changes to the Platform or any Services we offer though it.
   • Protection. To help maintain the safety, security, and integrity of our Platform, Services, databases and other technology assets; to prevent transactional fraud; to provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses; to create, maintain, customize, and secure your account with us.
   • Legitimate Interests. To provide, support, and personalize our Platform and Services for you; to deliver content and offerings relevant to your interests, including targeted offers through our Platform, third-party sites, and via email or text message (with your consent, where required by law); to process your requests, transactions, and payments; for testing, research, analysis, and to develop and improve our Platform and Services.
   • Legal Obligation. To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
   • Other Purposes. As described to you when collecting your Personal Data; to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, in which Personal Data held by us about our Users is among the assets transferred.
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). 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://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. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. If you delete your User Content from the Platform, copies of your User Content may remain viewable in cached and archived pages, or might have been copied or stored by other Platform users.
   • Remove and/or reject cookies from our Platform with your browser settings. Necessary cookies are a condition of using our Platform. If you reject these types of cookies, then we cannot predict how our website will perform when you visit it. You can control the use of functionality cookies, targeting cookies or advertising cookies by adjusting your browser settings. 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, however, appreciate the chance to deal with your concerns before you approach such authority so please contact us in the first instance.

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://topline.com/opt-out/. You do not need to register an account with us to exercise your opt-out rights. We will only use Personal Data provided in an opt-out request to review and comply with the request.
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 related to your Personal Data. 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, which may include:
• 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 and confirm the Personal Data relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Data provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

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 of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, 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. The date the Privacy Policy was last revised is identified at the top of the page. 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].