Privacy Policy

This website is operated by Toplyne Labs Pte. Ltd. (“we” or “us” or “our” or “Toplyne”).

We recognise that when You choose to provide us with information about Yourself, You trust us to act responsibly and respect Your privacy and we at Toplyne are committed to protecting Your privacy. This privacy policy (hereinafter “Policy”) applies to the information and data collected on our website. This Policy describes how we collect, receive, use, store, share, transfer, and process Your personal information. It also describes Your choices regarding use, as well as Your rights of access and correction of Your personal information.

By accessing this website, You agree and consent to be bound by the Policy. If You do not agree and consent to be bound by the Policy, You should not access or view this website.

‍“You”, “Your”, “Yourself” includes existing and/or new users of this website

Who is Toplyne Pte Ltd.

‍At times we may request that You voluntarily supply us with personal information. Generally, this information is requested when You want us to provide You with information.

Toplyne is a registered company in Singapore with its Headquarter office at: Toplyne Labs Pte Ltd 3 Shenton Way, #07-03 Shenton House, Singapore With offices in the United States of America at: Toplyne Inc.

16192, Coastal Highway, Lewes, Delaware 19958

Pursuant to Article 27 of the EU-GDPR and the UK-GDPR, Toplyne has appointed a representative in Germany to act as their GDPR representative in the EU where required (EU-GDPR Representative) and in the UK (UK-GDPR Representative). You can contact our

Representatives by sending an email or by writing to the responsible GDPR representative as identified below:

Toplyne is a registered company in Singapore with its Headquarter office at: Toplyne Labs Pte Ltd

3 Shenton Way, #07-03 Shenton House, Singapore With offices in the United States of America at:

Toplyne Inc.

16192, Coastal Highway, Lewes, Delaware 19958

Pursuant to Article 27 of the EU-GDPR and the UK-GDPR, Toplyne has appointed a representative in Germany to act as their GDPR representative in the EU where required (EU-GDPR Representative) and in the UK (UK-GDPR Representative). You can contact our

Representatives by sending an email or by writing to the responsible GDPR representative as identified below:

EU-GDPR Representative:

Rickert Rechtsanwaltsgesellschaft mbH

- Toplyne Pte. Ltd. -

Colmantstr. 15

53115 Bonn Germany

art-27-rep-toplyne@rickert.law

UK-GDPR Representative:

Rickert Services Ltd. UK

- Toplyne Pte. Ltd. - PO Box 1487

Peterborough PE1 9XX

United Kingdom

art-27-rep-toplyne@rickert-services.uk

What information do we collect?

We only process personal data where we have a legal basis to do so. You will find the specific legal basis in the sections about data processing, but generally we may process your data if one of the following conditions applies:

Consent of the data subject for processing personal data: We may request that you voluntarily supply us with personal data.

Processing personal data that is necessary for the performance of a contract to which the data subject is a party. The same applies to processing procedures that are necessary to carry out pre-contractual duties.

The processing of personal data is necessary to fulfil legal obligations governing our company.

Legitimate interests as long as they are not overridden by the interests or fundamental rights and freedoms of the data subject.

We may inter alia gather the following information about You when You use our website or our Services:

  • Name
  • Gender
  • Email address
  • Telephone number
  • Age
  • Company name
  • Website name

How do we use Your personal information?

In case we collect Your personal information, we will use it strictly in compliance with the terms of this Policy and only for purposes such as:

  • Improving Your browsing experience by personalising the website.
  • For developing and improving our Services.
  • Register Your account to access and utilize the Services.
  • For sending information which we think may be of interest to You such as marketing or promotional communications related to our Services, by post, email or other means.
  • For sending to You, information regarding material changes, if any, in the Policy.
  • If required by law to do so.
  • With the exception of account information (as mentioned above below) and other information we collect in connection with your registration or authentication into our Services, this Policy does not apply to our security and privacy practices in connection with electronic data, text, messages, communications or other materials submitted to and stored within the Services by You and the same shall be governed by the Master Subscription Agreement.

How We Transfer Personal Data Internationally

a. International Transfers within Toplyne 

To facilitate our global operations, we may transfer information to other Toplyne regions, namely United States of America, where we have operations for the purposes described in this policy. 

This Privacy Policy will apply even if we transfer Personal Data to the United States of America. We have taken appropriate safeguards to require that your Personal Data will remain protected wherever it is transferred. We also implement the Standard Contractual Clauses (approved by the European Commission and Swiss authorities) and UK Addendum to the Standard Contractual Clauses (approved by the UK authorities) where required, as well as additional safeguards where appropriate (such as commercial industry standard secure encryption methods to protect customer data at rest and in transit, TLS for Toplyne hosted sites, web application firewall protection, and other appropriate contractual and organizational measures), as described more in detail in our Data Protection Addendum under Technical and Organizational Measures.

Do we pass Your information to third parties?

‍We do not pass your information to third parties. Your information is strictly used specifically and only for the purpose of processing mentioned under terms of the DPA. We may disclose personal information to third parties when we reasonably believe we are required by law to do so, and in order to investigate, prevent, or take action regarding suspected or actual unlawful or otherwise prohibited activities, including, but not limited to, fraud.

If Toplyne does transfer your personal data to a third party acting as agents on Toplyne’s behalf, Toplyne remains liable under the DPF Principles if the agent processes such personal data in a manner inconsistent with the DPF principles; unless Toplyne can prove that it is not responsible for the event giving rise to the damage.

Where do we send Your information?

We may require/need to transfer Your information outside the country in which it was initially stored, only for the purposes of processing mentioned under terms of the DPA. 

Retention Periods

We delete the data we process or restrict processing in accordance with the statutory provisions. Where not explicitly stated within the scope of this Privacy Policy, we will delete the data stored by us as soon as it is no longer required for its intended purpose. We will only retain the data beyond the point at which it is no longer required for its intended purpose if this is necessary for other legally permissible purposes or if the data must be retained for a longer period due to statutory retention obligations. In this case, processing will be restricted, i.e. blocked, and the data will not be processed for other purposes. A legal obligation to retain data exists, for example, due to documentation obligations under tax and company law.

Cookies

What are cookies?

We may use information obtained from cookies or similar technology to enhance your experience with our website. Cookies are text files containing small amounts of information which we download onto Your device when You visit our website. Therefore, when we refer to “You” in this section we mean Your computer or any other device from which You access the website. Cookies record various aspects of Your visit and assist us in providing You with uninterrupted service. One of the primary purposes of cookies is to store Your preferences and other information on Your computer or any other device that You may use to access the website in order to save Your time by eliminating the need to repeatedly enter the same information and to display Your personalized content. You may change Your browser settings to accept or reject cookies on personal preference.

We process the data collected through cookies either independently or with third party service providers like Google Analytics on the website and PostHog on the Toplyne Dashboard, who analyse the data collected through cookies pursuant to contractual relationships with Us. The processing of such data is done to analyze the pages You visit, websites You visited before coming to the Site, and where You go after leaving the Site. The personal data may be combined for marketing and for market research purposes, including internal demographic studies, so that we can optimize our products and Services and customize the Site for You and for the purpose of providing Our Services.

Please note that our Privacy Policy covers only Your use of our Site and Services and does not cover the use of cookies by third parties, such as our clients. We do not control when or how third parties place cookies on Your device. For example, third party websites to which a link points may set cookies on Your device. We encourage You to take note of other sites’ Privacy Policies.

Also, we use data from targeting cookies placed on Your device by third parties when You have visited other websites.

If you would like to opt-out from having Toplyne collect your cookie-data, we will place an

opt-out cookie on your device. This cookie tells us to not collect Your data to tailor to our online advertising campaigns

Alternatively, if You want to delete any cookies that may already be on Your device yourself, please refer to the instructions for Your file management software to locate the file or directory that stores cookies. If You want to stop cookies being stored on Your device in future, please refer to Your browser manufacturer’s instructions by clicking “Help” in Your browser menu. By deleting our cookies or disabling future cookies You may not be able to access certain areas or features of our website. On android devices, Your settings may allow you to “Opt-out of interest-based ads. On iOS devices, you may enable the “Limit Ad Tracking” setting.

Location Tracking

When using Toplyne, we may infer your non-precise geolocation data based on your IP address to determine which ads to display. We use such data for targeting ads and evaluating their success and may share it with other parties for similar uses. This non-precise location data is maintained in our logs in accordance with our data retention policy.

Third Party Websites

Our website links to other websites. The information practices and the content of such other websites are governed by the privacy statements of such other websites. We encourage You to review the privacy statements of any such other websites to understand their information practices. This Policy does not apply to any third party websites and we are not responsible for third party websites.

How do we protect Your information?

We take appropriate measures to ensure that Your personal information disclosed to us is kept secure, accurate and up to date and kept only for so long as is necessary for the purposes for which it is used.

Your rights

You are entitled to:

  1. ask for a copy of the personal information we hold about You;
  1. have any inaccuracies in Your personal information corrected and updated;
  2. opt-out of communications;
  3. have Your personal information erased, or for our use of it to be restricted (for example, if Your preferences change, or if You don’t want us to send You the information You have requested).

Your rights under the GDPR:

You have the following rights free of charge against any person responsible for the processing of your personal data:

  • Right to withdraw your consent (Article 7 (EU) GDPR);
  • Right of access by the data subject (Article 15 (EU) GDPR);
  • Right to rectification and erasure (Article 16 and Art. 17 (EU) GDPR);

• Right to restriction of processing on the processing of your personal data (Article 18 (EU) GDPR);

  • Right to data portability (Article 20 (EU) GDPR);
  • Right to object to the processing of your personal data at any time for reasons relating to your special situation. (Article 21 (EU) GDPR).

For the assertion of claims, please contact the Data Controller or Should you wish to contact us by e-mail, please use an address used to access our system so that we can identify you.

You also have the right to lodge a complaint about the controller's processing of your personal data with a supervisory authority responsible for data protection.

Please contact us using the details set out below if You would like to exercise any of these rights. Further, if You wish to exercise any other data protection rights that are available to You under Your local data protection laws (such as the right to data portability or to data restriction) then please send Your request to legal@toplyne.io, and we will respond to Your request in accordance with applicable data protection laws.

Children’s Privacy

We do not knowingly collect or solicit personal data from anyone under the age of 16. In the event that we learn that we have collected personal data from a child under the age of 16, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under the age of 16, please contact us at dpo@toplyne.io.

Changes to this Policy

We reserve the right to change this Policy from time to time. If we make any changes, we will revise the date at the top of this Policy. In the event of any material change, we may notify You or Your organisation more directly by email, post or other means. We encourage that You periodically review our Policy to stay informed about practices and the ways in which You can protect Your privacy. Your continued use/access of the website signifies Your acceptance of any revisions and explicit renewal of Your consent to such revisions.

How to contact us

If You have questions or complaints regarding this Policy, please contact us by email at legal@toplyne.io or at:

Toplyne’s Data Protection Officer:

Name- Rohit Khanna

Email Address- dpo@toplyne.io

If You wish to exercise any of Your rights in relation to Your personal information or if You have any queries about how we use Your personal information or have any complaints in relation to the website or use of Your personal information, please let us know by contacting our data protection officer via email at support@toplyne.io. Our EU GDPR Representative is: and/or Our UK-GDPR Representative is: art-27-rep-toplyne@rickert.law /

art-27-rep-toplyne@ricket-services.uk (see above for contact details).

Disclaimer of Warranties

YOUR USE OF THIS WEBSITE IS AT YOUR OWN RISK. THE WEBSITE AND ALL THE MATERIALS, INFORMATION, SOFTWARE, FACILITIES, PROGRAMMES AND OTHER CONTENT ON THE WEBSITE ARE PROVIDED “AS IS” AND “AS AVAILABLE” WITHOUT ANY WARRANTIES OF ANY KIND, EITHER EXPRESS OR IMPLIED. TO THE FULLEST EXTENT PERMISSIBLE PURSUANT TO APPLICABLE LAW, WE DISCLAIM ANY AND ALL WARRANTIES, EXPRESS OR IMPLIED, INCLUDING, BUT NOT LIMITED TO, WARRANTIES OF TITLE OR IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE AND NON-INFRINGEMENT OF THIRD PARTY RIGHTS. WE DO NOT WARRANT THAT THE FUNCTIONS CONTAINED IN THIS WEBSITE WILL BE AVAILABLE CONTINUOUSLY, UNINTERRUPTED OR ERROR-FREE, THAT DEFECTS WILL BE CORRECTED, OR THAT THE WEBSITE OR THE SERVERS THAT MAKE THE WEBSITE AVAILABLE ARE FREE OF VIRUSES OR OTHER HARMFUL COMPONENTS. WE DO NOT WARRANT OR MAKE ANY REPRESENTATIONS REGARDING THE USE OR THE RESULTS OF THE USE OF THE MATERIAL, INFORMATION, SOFTWARE, FACILITIES, SERVICES, PROGRAMMES OR OTHER CONTENT ON OR MADE AVAILABLE ON THE WEBSITE OR ANY WEBSITES LINKED TO THE WEBSITE IN TERMS OF THEIR CORRECTNESS, ACCURACY, RELIABILITY, OR OTHERWISE. WE MAKE NO WARRANTIES THAT YOUR USE OF THE MATERIALS, INFORMATION, SOFTWARE, FACILITIES, PROGRAMMES, SERVICES OR OTHER CONTENT ON THE WEBSITE OR ANY OTHER WEBSITE/ APPLICATION WILL NOT INFRINGE THE RIGHTS OF OTHERS AND WE ASSUME NO LIABILITY OR RESPONSIBILITY FOR ERRORS OR OMISSIONS IN SUCH MATERIALS, INFORMATION, SOFTWARE, FACILITIES, PROGRAMMES, SERVICES OR OTHER CONTENT ON THE WEBSITE OR ANY OTHER WEBSITE/APPLICATION. WE ASSUME NO LIABILITY OR RESPONSIBILITY FOR (I) ANY UNAUTHORIZED ACCESS TO OR USE OF ANY AND ALL PERSONAL INFORMATION AND/OR FINANCIAL INFORMATION STORED THEREIN, (II) ANY INTERRUPTION OR CESSATION OF TRANSMISSION TO OR FROM THE WEBSITE,

(III) ANY BUGS, VIRUSES, TROJAN HORSES, OR THE LIKE WHICH MAY BE TRANSMITTED TO OR THROUGH THE WEBSITE BY ANY THIRD PARTY. IF APPLICABLE LAW DOES NOT ALLOW THE EXCLUSION OF SOME OR ALL OF THE ABOVE WARRANTIES TO APPLY TO YOU, THE ABOVE EXCLUSIONS WILL APPLY TO YOU ONLY TO THE EXTENT PERMITTED BY APPLICABLE LAW.

Limitation of Liability

WE DISCLAIM ANY AND ALL LIABILITY WHETHER BASED IN CONTRACT, TORT (INCLUDING NEGLIGENCE), STRICT LIABILITY OR OTHERWISE. NOTWITHSTANDING ANYTHING TO THE CONTRARY, WE SHALL NOT BE LIABLE, UNDER ANY CIRCUMSTANCES, WHETHER IN CONTRACT OR IN TORT (INCLUDING NEGLIGENCE), STRICT LIABILITY OR OTHERWISE, FOR ANY INDIRECT, SPECIAL, CONSEQUENTIAL OR INCIDENTAL LOSSES OR DAMAGES, INCLUDING ON GROUNDS OF LOSS OF PROFIT, LOSS OF REPUTATION OR LOSS OF BUSINESS OPPORTUNITIES. YOU ALSO SPECIFICALLY ACKNOWLEDGE THAT TOPLYNE OR AFFILIATED COMPANIES ARE NOT LIABLE FOR ANY ACTUAL OR ALLEGED DEFAMATORY, OFFENSIVE, OR ILLEGAL CONDUCT OF OTHER USERS AND VISITORS OF THE WEBSITE OR ANY OTHER THIRD PARTIES. WE SHALL NOT BE HELD LIABLE FOR ANY MEDICAL, HEALTH OR OTHER CONSEQUENCES INCLUDING BUT NOT LIMITED TO DEATH OR INJURY THAT MAY ARISE AS A RESULT OF THE USE OF THE WEBSITE. NOTWITHSTANDING ANYTHING TO THE CONTRARY, YOU ARE SOLELY RESPONSIBLE FOR USE OF THE INFORMATION, MATERIAL, PROGRAMMES, SOFTWARE, FACILITIES OR ANY OTHER CONTENT AVAILABLE ON THE WEBSITE AND ANY EXPENSES OR COSTS THAT MAY ENSUE FOR ANY ACTION ON ACCOUNT OF THE USE THEREOF BY YOU SHALL BE BORNE BY YOU. IF APPLICABLE LAW DOES NOT ALLOW ALL OR ANY PART OF THE ABOVE LIMITATION OF LIABILITY TO APPLY TO YOU, THE LIMITATIONS WILL APPLY TO YOU ONLY TO THE EXTENT PERMITTED BY APPLICABLE LAW.