Privacy

Last Updated: 4 Feb, 2024

Introduction

Welcome! You have arrived at a website that is provided by Top Rank, Inc. (“Top Rank” or “we,” “our” or “us”). This “Privacy Policy” governs your use of www.toprank.com (including, without limitation, both mobile and online versions of our website), and also applies to your use of all features, applications, content, downloads and other services that we make available through the website and/or that post a link to this Privacy Policy (collectively, referred to herein as the “Site”), regardless of how you access or use the Site, whether via personal computers, mobile devices or otherwise. This Privacy Policy does not apply to our data collection activities offline or otherwise outside of our Site (unless otherwise stated below).

To the extent we provide you notice on our Site of different or additional privacy policies or practices (e.g., at the point of our collection), those different or additional terms shall govern such data collection and use.

In addition, please review the Site’s Terms of Use  (www.toprank.com/terms-of-use) and any additional terms and conditions that may be provided on or linked to a Site, which govern your use of the Site. By using our Site, you consent to our Privacy Policy and Terms of Use (and any other posted terms and conditions) and our collection, use and sharing of your information and data, and other activities, as described below.

Linkable Table of Contents

It is important that you read and understand the entire Privacy Policy before using the Site. However, this table of contents highlights key issues and points and you can click on the headings and the “More” links to be taken to the full explanation.

1. What Information Does the Site Collect?

 

(a) Information You Provide to Us

You provide us with information when you visit the Site, which may include Personal Information such as when you contact us through the Site or sign up to receive our newsletter or other communications on the Site. More

(b) Information We Collect and Store As You Access and Use the Site

We collect certain information from you automatically when you access and use the Site, some of which may be Personal Information. For example, we and third parties may use Tracking Technologies (defined below) to collect Usage Information (defined below) based on your Device Identifier (defined below) for a variety of purposes, which may include activities over time and across third party locations. More

(c) Information Third Parties Provide About You

We may obtain information about you from third parties. More

(d) Interactions with Third-Party Services; ; Social Networking Features

If you interact with third-party services those services may send us information about you, and you or we may send them information about you. More

(e) Information You Provide About a Third Party

You may provide us information about others, such as when you send a friend a message. More

(f)  Do Not Track Disclosures

We do not look for or respond to do not track signals, but you may have certain other options regarding tracking and/or targeting. More

2. How Do We Use the Information Collected?

We use your information, including Personal Information, Demographic Information and Usage Information, for a variety of purposes detailed in this section. More

3. How and When Do We Disclose Information to Third Parties?

We may provide your information to third parties under various circumstances detailed in this Section. These may include:

(a) When You Request Information From or Provide Information to Third Parties

If you request information from third parties, request that we send information to third parties or interact with third party services, content or tools (including Facebook and other third-party share functionality), we may share your information with such parties and/or they may collect your information directly. More

(b) Third Parties Providing Services on our Behalf

Our vendors may collect your information or we may share it with them. More

(c) Administrative and Legal Reasons

There are a variety of administrative and legal reasons for which we may share your information. More

(d) Affiliates and Business Transfer

We may share your information with our affiliates or in the event of a sale, merger or similar transaction. More

(e) Sweepstakes, Contests and Promotions

Promotions entrants may be required to consent to certain information sharing. More

4. Ads and Information About You

We and third parties may send you targeted ads based on your location, information and/or behavior. If you object, you can exercise choices some third parties may offer. More

5. Do Third-Party Content, Links to Third-Party Sites and/or Third-Party Apps Appear on the Site?

We may allow you to access third-party content on the Site, or to link to third-party applications and locations from the Site, but we are not responsible for your interaction with third-party content, apps, and locations or their uses of your information. More

6. How Do I Change My Information and Communications Preferences?

You may change certain information and preferences. More

7. What About Transfer of Information to the United States?

Data may be transferred to the United States. More

8. What Should Parents Know About Children?

Our Site is intended for general audiences and we do not intentionally collect Personal Information from children. If you think we have, let us know. More

9. What About Security?

No data security is absolute, but we take reasonable steps to secure data appropriately. More

10. What About Changes to the Privacy Policy?

We may change this Privacy Policy as explained here.

11. What are my Rights if I am a Resident of California?

The rights of California consumers are explained here. More

The Full Detailed Privacy Policy

 

1. What Information Does the Site Collect?

Following is a description of information we collect and our sources of collection. Some of the data we collect is “Personal Information” which we consider to be data that is linked to a specific, identifiable individual (such as your full name and email address). We will treat other information, such as Demographic Information, Usage Information, and Device Identifiers as “Personal Information” where required by applicable law.

Note that we may de-identify or pseudonymize your Personal Information so as to make it non-personal, either by combining it with data about other individuals and/or by hashing the data or otherwise removing characteristics that make the information personally identifiable to you. We will treat de-identified or pseudonymized information as non-personal to the fullest extent allowed by applicable law. We maintain and use de-identified information without attempting to re-identify it, except where permitted by applicable law, such as to determine whether our de-identification processes satisfy legal requirements. If we combine non-Personal Information with Personal Information, then we will treat the combined data as Personal Information under this Privacy Policy.

Some Personal Information is defined as “sensitive” Personal Information or a “special category” of Personal Information under various data privacy and protection laws (generally data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, genetic data and biometric data for the purpose of uniquely identifying an individual) (“Sensitive Personal Information”). We do not intentionally collect any Sensitive Personal Information about you for the purposes of the activities described in this Privacy Policy; however, if you volunteer such information to us, such as on any Top Rank community or forum, it may be available to others publicly viewing such community or forum, and we will process such Sensitive Personal Information the same way we process all unstructured user-provided data in Top Rank communities and forums.

(a) Information You Provide to Us

In the course of using the Sites, you may provide us with certain information, including contact information (such as your name and email address) and demographic information, such as information about your gender and age (“Demographic Information”). We may collect this information through various forms and in various places on the Site, including if you sign up for our newsletter or through “contact us” forms, if you request to receive information from us, if you register for a sweepstake, contest, or other promotion, or when you otherwise interact with the Site.

(b) Information We Collect and Store as You Access and Use the Site

We and our third-party service providers may use a variety of technologies that automatically (or passively) collect and store certain information whenever you visit or interact with the Site (“Usage Information”). This Usage Information may be stored or accessed using a variety of technologies that may be downloaded to your personal computer, browser, laptop, tablet, mobile phone or other device (a “Device”) whenever you visit or interact with our Site. This Usage Information may include:

• your IP address, UDID or other unique identifier (“Device Identifier”). A Device Identifier is a number that is automatically assigned to your Device used to access the Site, and our computers identify your Device by its Device Identifier;

• your Device functionality (including browser, operating system, hardware, mobile network information);

• the URL that referred you to our Site;

• the areas within our Site that you visit and your activities there, including remembering you and your preferences;

• your Device location;

• your Device characteristics; and

• certain other Device data, including the time of day, among other information.

We may use various methods and technologies to collect and store Usage Information (“Tracking Technologies”). Tracking Technologies may set, change, alter or modify settings or configurations on your Device. A few of the Tracking Technologies include, without limitation, the following (and subsequent technology and methods later developed):

Cookies and Local Storage. Cookies and local storage are small text files stored locally on your Device that help store user preferences. These technologies are able to store a unique identifier for a Device to us to recognize the Device whenever the Device is used to access our Site. These technologies may be used for many purposes by us and our service providers, such as automatically collecting Usage Information, enabling features, and remembering your preferences. We may use cookies and other technologies to study usage patterns on the Site, to study the effectiveness of our user communications, to manage and measure the performance of our Site, and to personalize your experience of the Site, such as to recognize you when you return to the Site. The information we may store includes Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. If you do not want to accept cookies, you can block them by adjusting the settings on your Internet browser. You can find more information about cookies and how they work at www.allaboutcookies.org.

Web Beacons. Small graphic images or other web programming code called web beacons (also known as “1×1 GIFs” or “clear GIFs”) may be included in our Site’s pages and messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a page or e-mail can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Site, to monitor how users navigate the Site, to count how many e-mails that were sent were actually opened or to count how many particular articles or links were actually viewed. We may use similar tools to collect such information from mobile devices.

Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Site, such as the links you click on. The code is temporarily downloaded onto your Device from our web server or a third party service provider, is active only while you are connected to the Site, and is deactivated or deleted thereafter.

Browser Fingerprinting. Collection and analysis of information from your Device, such as, without limitation, your operating system, plug-ins, system fonts and other data, for purposes of identification.

ETag, or entity tag. A feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL. If the resource content at that URL ever changes, a new and different ETag is assigned. Used in this manner ETags are a form of Device Identifier. ETag tracking may generate unique tracking values even where the consumer blocks HTTP, Flash and/or HTML5 cookies.

Recognition Technologies. Technologies, including application of statistical probability to data sets, which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple Devices is the same user).

Data Collection from Mobile Devices. We use embedded scripts and similar tools to collect data from mobile Devices such as the hardware model, operating system and version, identification numbers assigned to your mobile Device, such as the ID for Advertising (IDFA) on Apple devices, and the Advertising ID on Android devices, mobile network information, location data and website usage behavior. In addition, we may use a variety of other technologies that collect similar Device and Device interaction information for security, fraud detection, and maintenance purposes.

Session Replay Technology. Session replay technology may record your interactions with the Site, such as what pages you visit, how long you visit those pages, and any links you click or information you provide. We use this data for our internal business purposes, such as for website analytics, to improve the Site and other products and services, and to address functionality issues.

We may use Tracking Technologies for a variety of purposes, including:

Strictly Necessary. We may use cookies or other Tracking Technologies that we consider are strictly necessary to allow you to use and access our Site, including cookies required to prevent fraudulent activity, improve security or allow you to make use of Site functionality.

Performance Related. We may use cookies or other Tracking Technologies that are useful in order to assess the performance of the Site, including as part of our analytic practices or otherwise to improve the content, products or services offered through the Site.

Functionality Related. We may use cookies or other Tracking Technologies that are required to offer you enhanced functionality when accessing the Site, including identifying you when you visit our Site or keeping track of our specified preferences, including in terms of the presentation of content on our Site.

Targeting Related. We may use Tracking Technologies to deliver content, including ads, relevant to your interests on our Site and third-party sites based on how you interact with our content and ads. This includes using Tracking Technologies to understand the usefulness to you of the content and ads that have been delivered to you.

There may be other Tracking Technologies now and later devised and used by us in connection with the Site. Further, third parties may use Tracking Technologies in connection with our Site, which may include the collection of information about your online activities over time and across third-party web sites or online services. We may not control those Tracking Technologies and we are not responsible for them. However, you consent to potentially encountering third-party Tracking Technologies in connection with use of our Site and accept that our statements under this Privacy Policy do not apply to the Tracking Technologies or practices of such third parties. If you would like to opt-out of third-party advertising and analytics, there are a variety of tools available to you, some of which are described below in Section 4 (Ads and Information About You). If you are a resident of California, please see our California Privacy Notice below in Section 11.

(c) Information Third Parties Provide About You

We may receive information about you from your friends and others that use the Site, such as when they submit your information to us about you. Additionally, we may, from time to time, supplement the information we collect directly from you on our Site with outside records from third parties for various purposes, including to enhance our ability to serve you, to tailor our content to you and to offer you opportunities that may be of interest to you.

(d) Interactions with Third Party Services; Social Networking Features

Functionality on the Site may permit interactions between the Site and a third-party service such as Facebook, Twitter, YouTube, TikTok or Instagram (“Social Networking Features”). Examples of Social Networking Features include enabling you to “like” or “share” content from the Site or to “like” or “share” our content on a third-party service; to automatically or selectively show your social media posts on the Site; and to otherwise connect the Site to a third-party service. If you choose to share content or to otherwise post information through the Site to a third-party service, or vice versa, that information may be publicly displayed. Similarly, if you post information on a third-party service that references us (for example, by using a hashtag associated with us in your post), your post may be published on the Site or otherwise in accordance with the terms of that third party.

Also, both we and the third party may have access to certain information about you and your use of the Site and the third-party service. In addition, the third-party service may set their own cookies and collect data about your use of the Site, including your IP address or other Device Identifiers, and which pages you visit on the Site. These third-party platforms may be able to collect certain information on your visits to the Site regardless of whether or not you affirmatively interact with the feature and whether or not you are logged into (or have) an account with the third-party platform. If you are logged out or do not have an account and visit a page with a social plug-in, your browser sends a more limited set of information. Like other sites, the third-party platform will receive data about the webpage you are visiting, the date and time of your visit, and other browser-related information. They may use that information to help them improve their products or for other purposes set forth in their privacy policy. We may also receive data about you if other users of social media give us access to their profiles and you are one of their connections or “friends.”

The data we collect in connection with Social Networking Features is subject to this Privacy Policy. The data collected and stored by the third party remains subject to the third party’s privacy practices, including whether the third party continues to share data with us, the types of data shared, and your choices with regard to what is visible to others on that third-party service.

If you submit materials or use Social Networking Features, we may publish that information or content online or offline, including in connection with our advertising, marketing, publicity, and promotional activities, as further described in our Terms of Use or additional terms that you may agree to before submitting materials.

(e) Information You Provide About a Third Party

You may send someone else a communication from the Site, such as sending an invitation to a friend. If so, the information you provide (names, email addresses, mobile number, etc.) is used to facilitate the communication and is not used by us for any other marketing purpose unless we obtain consent from that person or we explicitly say otherwise. Please be aware that when you use any send-to-a-friend functionality on our Site, your email address, mobile number, name or user name and message may be included in the communication sent to your addressee(s). If you disclose any Personal Information relating to other people, you represent that you have the authority to do so and to permit us to use the Personal Information in accordance with this Privacy Policy.

(f) Do Not Track Disclosures

Do Not Track (“DNT”) signals offered by some web browsers are settings that request that a web application disable its tracking of an individual user. When you choose to turn on the DNT setting in your browser, your browser sends a special signal to websites, analytics companies, ad networks, plug in providers, and/or other web services you encounter while browsing to stop tracking your activity. There is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and online services, we may not alter our practices when our systems receive a “Do Not Track” signal from a visitor’s browser, except as specifically required by law. You can learn more about Do Not Track at www.allaboutdnt.com.

2. How Do We Use the Information Collected?

We may use your Personal Information and non-Personal Information for various purposes, including:

• to provide you with information such as to send you electronic newsletters or to provide you with special offers or promotional and marketing materials on behalf of us or third parties, including to let you know about upcoming boxing matches and events;

• to provide the Site to you and enable you to participate in a variety of the Site’s features such as to enable you to participate in online surveys, entry sweepstakes, contests or other promotions;

• to improve the Site, marketing endeavors or our Site offerings;

• to customize your experience on the Site or to serve you specific content or ads that we believe are relevant to you;

• to provide customer support;

• to contact you with regard to your use of the Site and, in our discretion, changes to the Site and/or Site’s policies;

• to improve the overall experience at the Site;

• for internal business purposes, including to prevent fraud or other illegal activity, to prevent imminent bodily harm, or to protect ourselves and you from people violating our Terms of Use, or otherwise to protect our or third-party rights or interests, which may include sharing information with other companies, lawyers, courts, or other government entities;

• to respond to subpoenas, court orders or legal process, or to establish or exercise our legal rights or defend against legal claims; and

• for purposes disclosed at the time you provide your information or with your prior consent, or as otherwise set forth in this Privacy Policy.

3. How and When Do We Disclose Information to Third Parties?

We may share non-Personal Information, such as aggregated user statistics, with third parties at our discretion and as permitted by law, including for advertising, research and marketing purposes. Further, we may share your Device Identifiers with third parties along with data related to you and your activities. Also, we may share your Personal Information with third parties with whom we have marketing or other relationships for the third parties’ direct marketing purposes. If you are a California resident, you have the right to request additional information about this sharing, so please see Section 11(d) below. In addition, we may share the information we have collected about you, including Personal Information, as disclosed at the time you provide your information and as described below or otherwise in this Privacy Policy. We may disclose your information as follows:

(a) When You Request Information from or Provide Information to Third Parties.

You may be presented with an option on our Site to receive certain information and/or marketing offers directly from third parties or to have us send certain information to third parties or give them access to it. If you choose to do so, your Personal Information and other information may be disclosed to such third parties and all information you disclose will be subject to the third-party privacy policies and practices of such third parties. In addition, third parties may store, collect or otherwise have access to your information when you interact with their Tracking Technologies, content, tools apps or ads on our Site or link to them from our Site. This may include using third party tools such as Facebook, Instagram, TikTok, YouTube, Twitter, Pinterest or other third-party posting or content sharing tools and by so interacting you consent to such third-party practices. It may also include ordering or purchasing products from third parties through us where we indicate that the third party rather than us is the seller. We are not responsible for the privacy policies and practices of such third parties and, therefore, you should review such third-party privacy policies and practices of such third parties prior to requesting information from or otherwise interacting with them.

(b) Third Parties Providing Services on our Behalf. 

We may use third-party vendors to perform certain services on behalf of us or the Site, such as: (i) to assist us in Site operations; (ii) to manage a database of customer information; (iii) hosting the Site; (iv) designing and/or operating the Site’s features; (v) tracking the Site’s activities and analytics; (vi) enabling us to send you special offers or perform other administrative services; and (vii) other services designed to assist us in maximizing our business potential. We may provide these vendors with access to user information, including Personal Information, to carry out the services they are performing for you or for us. Third-party analytics and other service providers may set and access their own Tracking Technologies on your Device and they may otherwise collect or have access to information about you, potentially including Personal Information, about you. We are not responsible for those third-party technologies or activities arising out of them. However, some may offer you certain choices regarding their practices, and information we have been informed of regarding such choices is available in Section 4 below. We are not responsible for the effectiveness of or compliance with any third parties’ opt-out options.

(c) Administrative and Legal Reasons.

We may access, use, preserve, transfer and disclose your information (including Personal Information) to third parties: (i) to satisfy any applicable law, regulation, subpoenas, governmental requests or legal process if in our good faith opinion such is required or permitted by law; (ii) to protect and/or defend the Site’s Terms of Use (www.toprank.com/terms-of-use) and our Website Terms and Conditions relating to our payment platform or other policies applicable to the Site, including investigation of potential violations thereof; (iii) to protect the safety, rights, property or security of the Site or any third party; and/or (iv) to detect, prevent or otherwise address fraud, security or technical issues. Further, we may use IP addresses or other Device Identifiers to identify users, and may do so in cooperation with third parties such as copyright owners, internet service providers, wireless service providers and/or law enforcement agencies, including disclosing such information to third parties, all in our discretion, subject to applicable law. Such disclosures may be carried out without notice to you.

(d) Affiliates and Business Transfer.

We may share your information, including Personal Information, with our parent, subsidiaries and affiliates. We also reserve the right to disclose and transfer all such information: (i) to a subsequent owner, co-owner or operator of the Site or applicable database; or (ii) in connection with a merger, consolidation, restructuring, the sale of substantially all of our interests and/or assets or other corporate change, including during the course of any due diligence process.

(e) Sweepstakes, Contests and Promotions.

We may offer sweepstakes, contests, and other promotions (any, a “Promotion”) through the Site that may require registration. By participating in a Promotion, you are agreeing to official rules that govern that Promotion, which may contain specific requirements of you, including, allowing the sponsor of the Promotion to use your name, voice and/or likeness in advertising or marketing associated with the Promotion. If you choose to enter a Promotion, Personal Information may be disclosed to third parties or the public in connection with the administration of such Promotion, including, in connection with winner selection, prize fulfillment, and as required by law or permitted by the Promotion’s official rules, such as on a winners list.

4. Ads and Information About You

Data about your activities online is collected on our Site for use in providing advertising tailored to your individual interests. We may use third parties such as network advertisers and ad exchanges to serve advertisements across the Internet and may use third party analytics service providers to evaluate and provide us and/or third parties with information about the use of these ads on third party websites and viewing of ads and of our content. Third parties may offer you a choice as to whether or not to have your information collected for that purpose. This section of the privacy policy provides details and explains how to exercise that choice.

You may see certain ads on our Site as well as on other third-party websites across the Internet because we participate in advertising networks administered by third parties. These networks track your online activities over time and across third party websites by collecting information through automated means, including through the use of the Tracking Technologies described elsewhere in this Privacy Policy, and they use this information to show you advertisements (including our ads) that are tailored to your individual interests. The information they collect includes information about your visits to our Site, such as the pages you have viewed. These third-party Tracking Technologies may be set to, among other things: (a) help deliver advertisements to you that you might be interested in; (b) prevent you from seeing the same advertisements too many times; and (c) understand the usefulness to you of the content and advertisements that have been delivered to you. You acknowledge and agree that associated technology may access and use your device and may set or change settings on your device in connection with the associated operations. Note that any images (or any other parts of content) served by third parties in association with third-party ads or other content may act as web beacons, which enable third parties to carry out the previously described activities.

This collection and ad targeting takes place both on our Site and on third-party websites that participate in the ad network, such as websites that feature advertisements delivered by the ad network. This process also helps us track the effectiveness of our marketing efforts. We and third-party vendors, including Google, use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as a DoubleClick cookie) together to report how your ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to our Site. To learn more about how to opt out of Google’s use of the Google Analytics cookie, visit the here. To learn more about how to opt out of DoubleClick’s use of cookies, visit the DoubleClick opt-out page, here.

Third-party Tracking Technologies are not controlled by us, even if they use our technology to help store or collect data. Statements regarding our practices do not apply to the methods for collecting information used by these third-party advertisers and others or the use of the information that such third parties collect. We do however work with third parties to make efforts to provide you with information on their practices and any available opportunity to exercise choice. The relevant third party’s terms of service, privacy policy, permissions, notices and choices should be reviewed regarding their collection, storage and sharing practices. We make no representations regarding the policies or practices of third-party advertisers or advertising networks or exchanges or related third parties. Further, while we may use a variety of companies to serve advertisements on the website, you may wish to visit http://www.networkadvertising.org/choices, which provides information regarding this practice by Network Advertising Initiative (“NAI”) members, and your choices regarding having this information used by these companies, including the “opt-out” procedures of NAI members. Opting out of one or more NAI members only means that those NAI members no longer will be allowed under their own rules to deliver targeted content and/or ads to you, which will affect this and other sites, but does not mean you will no longer receive any targeted content and/or ads. Also, if your browsers are configured to reject cookies when you visit this opt-out page, or you subsequently erase your cookies, use a different device or change web browsers, your NAI opt-out may not, or may no longer, be effective. Additional information is available on the NAI’s website accessible by the above link. You may also be able to opt-out of receiving third-party behavioral ads by visiting the Digital Advertising Alliance (“DAA”) website at http://www.aboutads.info/choices . Similar limitations may apply to the DAA opt-out. We are not responsible for effectiveness of or compliance with any third parties’ opt-out options.

5. Do Third-Party Content, Links to Third-Party Sites and/or Third-Party Apps Appear on the Site?

The Site may contain content, links or apps that are supplied by a third party, and those third parties may collect Usage Information and your Device Identifier when pages from the Site are served to you for their own commercial purposes. In addition, when you are on the Site you may be directed to other sites and apps that are operated and controlled by third parties that we do not control. We are not responsible for the data collection and privacy practices employed by any of these third parties or their sites or apps and they may be tracking you across multiple online services and may be sharing the results of that tracking with us and/or others. These third parties may have their own terms of service, privacy policies or other policies and ask you to agree to the same. For example, if you “click” on a link, the “click” may take you off the Site onto a different location. These other online services may associate their Tracking Technologies with you, independently collect information about you, including Personal Information, and may or may not have their own published privacy policies. We are not responsible for these third-party privacy policies or the practices of third parties. Be sure to review any available policies before submitting any personally identifiable information to a third-party application or otherwise interacting with it and exercise caution in connection with these applications. We also encourage you to note when you leave our Site and to review the third-party privacy policies of all third-party sites and exercise caution in connection with them.

6. How Do I Change My Information and Communications Preferences?

You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information provided as part of registration. The Site may allow you to review, delete, correct or update Personal Information you have provided through the Site’s forms, and you may provide updates and changes or request deletion by contacting us via email at [email protected]. If so, subject to verifying your identity we will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable (but we may retain prior information as business records). Please note that it is not always possible to completely remove or delete all of your information from our databases and that residual data may remain on backup media or for other reasons.

You may cancel or modify our email marketing communications you receive from us by following the instructions contained within our promotional emails or in some cases by logging into your Site account and changing your communication preferences. This will not affect subsequent subscriptions and if your opt-out is limited to certain types of emails the opt-out will be so limited. Subsequent or different subscriptions will be unaffected. Please note that we reserve the right to send you certain communications relating to your account or use of our Site, such as administrative and Site announcements and these transactional account messages may be unaffected if you choose to opt-out from receiving our marketing communications. If you have any questions about the Privacy Policy or practices described in it, you should contact us via email at [email protected].

7. What About Transfer of Information to the United States?

Our Site is operated in the United States and intended for users located in the United States. If you are located outside of the United States, please be aware that information we collect, including Personal Information, will be transferred to, and processed, stored and used in the United States. The data protection laws in the United States may differ from those of the country in which you are located, and your Personal Information may be subject to access requests from governments, courts, or law enforcement in the United States according to laws of the United States. By using the Site or providing us with any information, you acknowledge that you fully understand and unambiguously consent to the transfer to, and processing, usage, sharing and storage of your information, including Personal Information, in the United States as set forth in this Privacy Policy.

8. What Should Parents Know About Children?

The Site is a general audience web site and we do not knowingly collect any Personal Information from children younger than the age of thirteen (13) as required by U.S. law. We will delete any Personal Information collected that we later determine to be from a user younger than the age of thirteen (13). If you are a parent or guardian of a child under the age of thirteen (13) and believe he or she has disclosed Personal Information to us, please contact us via email at [email protected].

9. What About Security?

We endeavor to incorporate commercially reasonable safeguards to help protect and secure your Personal Information. However, no data transmission over the Internet, mobile networks, wireless transmission or electronic storage of information can be guaranteed to be 100% secure. Please note that we cannot ensure the security of any information you transmit to us, and you use our Site and provide us with your information at your own risk.

10. What About Changes to the Privacy Policy?

We reserve the right to change this Privacy Policy at any time without notice to you. Any changes will be effective immediately upon the posting of the revised Privacy Policy and your use of our Site indicates your consent to the privacy policy posted at the time of use. However, we will not use your previously collected Personal Information in a manner materially different than indicated at the time it was collected without your consent. To the extent any provision of this Privacy Policy is found by a competent tribunal to be invalid or unenforceable, such provision shall be severed to the extent necessary for the remainder to be valid and enforceable.

11. What are my Rights if I am a Resident of California?

 

California Privacy Notice

We are providing this California Privacy Notice (“Notice”) pursuant to the California Consumer Privacy Act (“CCPA”) and the California Privacy Rights Act (“CPRA”). This California Privacy Notice supplements our Privacy Policy and provides additional information on how Top Rank and its affiliates may collect, use, share, and retain Personal Information for California residents on our Site. In the event of a conflict between this Notice and any other policy, statement, or notice, this Notice will prevail for residents of California.

If you are a California resident, “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly with you or your household. Personal Information does not include information that is publicly available, de-identified, or aggregated.

(a) Categories of Personal Information that We Collect and Sell or Share.

The following chart identifies the categories of consumer Personal Information that we collected and “sold” or “shared” within the past 12 months and presently collect and “sell” or “share.” The specific pieces of Personal Information that we collect vary depending on the nature of your interactions with us and may not include all examples listed below.

Categories of Personal Information collected (see below for more details) Do we disclose for business purposes? Do we “sell’ or “share”?
Name, contact info and other identifiers such as a real name, alias, address, unique personal identifier, online identifier, Internet Protocol address, email address, account name. Yes Yes, for online identifiers and IP addresses, which may be shared only for our advertising technology programs.
Customer records such as paper and electronic customer records containing Personal Information, such as name, signature, telephone number, live chat records, bank account number, credit card number, debit card number, or any other financial or payment information (processed exclusively through a third-party payment processor), household information in the context of surveys. Yes No
Purchase history and tendencies such as commercial information including records of products or services purchased, obtained, or considered, or other purchasing or use histories or tendencies. Yes No
Usage data such as internet or other electronic network activity information, including, but not limited to, browsing history, clickstream data, search history, and information regarding a resident’s interaction with an internet website, application, or advertisement. Yes Yes, shared only for our advertising technology programs.
Geolocation data such as your approximate location as derived from IP address / device ID in the context of serving locally relevant content, promotions and advertising. Yes Yes, shared only for our advertising technology programs.
Audio, video and other electronic data: audio, electronic, visual, thermal, olfactory, or similar information such as, photographs, videos submissions and call recordings. Yes No
Profiles and Inferences: such as inferences drawn from Personal Information to create a profile reflecting preferences, characteristics, predispositions, behavior, attitudes. Yes Yes, shared only for our advertising technology programs.

We collect these categories of Personal Information from the categories of sources as described in Section 1 of our Privacy Policy above, and for the purposes as described in Section 2 of our Privacy Policy above. We may disclose Personal Information to the categories of recipients as described in Section 3 of our Privacy Policy above.

We do not sell your Personal Information for money. However, as described in the chart above sometimes we share your data with sponsors, vendors, and third-party advertising networks to provide you with certain services and/or to more effectively provide you with personalized services (including advertising), and such sharing can be deemed a sale under the CCPA/CPRA.

We do not knowingly collect Personal Information of persons under the age of 13.

Business to Business Personal Information: Please note that if you are an employee or other representative of a business that we have contracted to do business with, either as a customer or vendor, our processing of information, including Personal Information, in the performance of that contract (including information collected on our payments web site of ePayments web site]) is controlled by the provisions of that contract as pertain to processing of information and supplemented by this Privacy Policy and Notice as applicable. We do not “sell” or “share” (as such terms are defined in the CCPA/CPRA) Personal Information processed in connection with our business-to-business relationships.

(b) How Long We Keep Consumer Personal Information.

The retention periods for each category of Personal Information vary depending on the type of business record in which it is maintained. The retention period for our business records is set based on the length of time Top Rank needs the record for: (1) its original purpose; (2) other operational purposes, such as audits and reporting; and/or (3) legal compliance, including maintenance of opt-out/in lists, legal defense, and legal holds.

(c) Your California Privacy Rights

If you are a resident of California, you have the right to submit certain requests relating to your Personal Information, as more fully described below. To exercise any of these rights, please contact us at [email protected] or call us toll-free at (702) 732-2717.[1] When you submit a privacy rights request, we will require that you verify your identity before we can process your request.

We will confirm receipt of your request and respond to your request as soon as we can and no later than legally required. You may designate an authorized agent to make a request on your behalf; however, we may require proof that you gave the agent permission to submit the request, and you will still need to verify your identity directly with us before we can process your request. Regardless of the method used to submit a request to access, delete, or correct your Personal Information, we must deny your request if we are unable to verify your identity.

Right to Know What Personal Information We Collect, and Right to Access Personal Information. The above chart and information included in our Privacy Policy and this Notice provide the following information about our collection of Personal Information: (i) the categories of Personal Information we have collected and sold or shared, (ii) the categories of sources from which the Personal Information was collected, (iii) our business or commercial purposes for collecting, selling, or sharing Personal Information, and (iv) the categories of recipients to whom we disclose Personal Information.

You may also submit a request to access the specific pieces of Personal Information we have collected about you.

Right to Delete Personal Information. You have the right to request that we delete Personal Information we collected from you, subject to certain exceptions.

Right to Correct Inaccurate Personal Information. If you believe that Personal Information we maintain about you is inaccurate, you have the right to request that we correct that information.

 

Right to Opt Out of the Sale and Sharing of Your Personal Information.

You may opt out of the sale or sharing (for targeted advertising) of your Personal Information by clicking on the Do Not Sell My Personal Information button on our site or emailing us at [email protected]. You will be asked to provide certain information to us in order to exercise this option so we can verify your identity and locate your records with us.

Please see the California Privacy Protection Agency’s website at https://oag.ca.gov/privacy/ccpa or https://globalprivacycontrol.org for more information on valid Global Privacy Controls. Please also review Section 4 (Ads and information About You) of our Privacy Policy for information on industry tools and device settings that may be available to you. Note that disabling certain types of Tracking Technologies may result in some features on our Sites to not function. Also note that we do not control these mechanisms and therefore our Sites will adhere to such signals to the extent reasonably technologically possible.

Right to Limit Use and Disclosure of Sensitive Personal Information. We do not use or disclose Sensitive Personal Information for purposes to which the right to limit use and disclosure applies under the CCPA and CPRA.

 

Right to Non-Discrimination for the Exercise of Your Privacy Rights. If you choose to exercise any of the privacy rights described above, we will not discriminate against you. This means that, consistent with applicable state privacy law, we will not deny providing our products or services to you, charge you different prices or provide a different level or quality of products or services to you unless those differences are related to the value of your Personal Information. You also have the right not to receive discriminatory treatment by us, including retaliation against you.

(d) Other California Rights

We may elect to share information about you with third parties for those third parties’ direct marketing purposes. California Civil Code § 1798.83 permits California residents who have supplied Personal Information (as defined in the law) to us to, under certain circumstances, request and obtain certain information regarding our disclosure, if any, of Personal Information to third parties for their direct marketing purposes. If this law applies to you, you may obtain the categories of Personal Information shared by us and the names and addresses of all third parties that received Personal Information for their direct marketing purposes from us during the immediately prior calendar year. To make such a request, please provide sufficient information for us to determine if this applies to you, attest to the fact that you are a California resident and provide a current California address for our response. To make such a request (limit one request per year), please send an email to: [email protected] with “California Privacy Rights” as the subject line or mail us a letter to: Top Rank, Inc., 748 Pilot Road, Las Vegas, Nevada 89119 (Attn: Legal Department). You must include your full name, email address, and postal address in your request. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.

 

(e) How to Contact Us

If you have any questions, comments, or concerns regarding this Notice and/or practices, please contact us at [email protected].

 

(f) Accessibility

To access this California Privacy Notice by an alternative method, please email us at [email protected] and request a copy.