Last Updated: September 2023

This Privacy Policy describes how TipTop (“we,” “us,” or “TipTop”), process Personal Information that we collect through the TipTop Platform. When used in this Privacy Policy, “TipTop,” “we,” “us,” or “our” refers to TipTop Software LLC, the entity which owns TipTop and with whom you are contracting. The terms, “you” or “your” means either a Service Provider or Partner, or both as Users; or, a Client or Customer, or both as Users, depending on the context of the Section in this Privacy Policy.

Depending on where you live and what you are doing on the TipTop Platform, not all terms of this Privacy Policy may apply to you. We recommend that you consult with a local attorney if you have any questions or concerns.

BY SUBMITTING PERSONAL INFORMATION ON OUR TIPTOP PLATFORM, YOU AGREE TO THE TERMS OF THIS PRIVACY POLICY AND YOU EXPRESSLY CONSENT TO THE COLLECTION, USE AND DISCLOSURE OF YOUR PERSONAL INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY. NOTE: WE DO NOT INTENTIONALLY GATHER PERSONAL INFORMATION FROM USERS WHO ARE UNDER THE AGE OF 13.

1. Definitions

Undefined, capitalized terms in this Privacy Policy have the same definition as in our Terms of Service (Service Providers and Clients) or in our Terms of Service (Partners and Customers) (collectively, “Terms”).

2. Personal Information We Collect

2.1 Information needed to use the TipTop Platform.

We collect Personal Information about you when you use the TipTop Platform. The term “Personal Information” shall mean information or data that allows someone to identify or contact you, including for example, your name, address, telephone number, e-mail address and other similar non-public information. Without it, we may not be able to provide you with all services requested. This information includes:

• Contact Information, Account, Profile Information. Such as your first name, last name, phone number, postal address, email address, date of birth, and profile photo, some of which will depend on the features you use.

• Identity Verification. Such as images of your government issued ID such as a drivers license.

2.2 Information you choose to give us.

You may choose to provide us with additional Personal Information. This information may include:

• Additional Profile Information. Such as gender, preferred language(s), city, and personal description. Some of this information as indicated in your account settings is part of your Profile and will be publicly visible.

• Address Book Contact Information. Address book contacts you import or enter manually.

• Other Information. Such as when you fill in a form, add information to your account, respond to surveys, post to community forums, participate in promotions, communicate with us, other Users, or share your experience with us. This may include health information if you choose to share it with us.

2.3 Information Automatically Collected by Using the TipTop Platform.

When you use the TipTop Platform, we automatically collect Personal Information. This information may include:

• Location Information. Such as your precise or approximate location data to enable and enhance the use of the TipTop Platform, including to enable you to connect with other Users, improve the provision of Services and Merchandise, and provide information that may be of interest to you. Please see Article 3 for detailed information on how we use this data. If you no longer wish for us or other Users to collect and use location information, you may disable the location features on your device. Consult your device manufacturer settings for instructions. Please note that if you disable such features, your ability to access certain features, Services or Merchandise, or content may be limited or disabled.

• Usage Information. Such as the pages or content you view, searches for Service Providers, Services, Merchandise, and other actions on the TipTop Platform.

• Log Data and Device Information. Such as details about how you’ve used the TipTop Platform (including if you clicked on links to third party applications), IP address, access dates and times, hardware and software information, device information, device event information, unique identifiers, crash data, cookie data, and the pages you’ve viewed or engaged with before or after using the TipTop Platform. We may collect this information even if you haven’t created a TipTop account or logged in.

• Cookies and Similar Technologies as described in our Cookie Policy in Article 5.

2.4 Personal Information We Collect from Third Parties.

We collect Personal Information from other sources, such as:

• Third-Party Services. If you link, connect, or login to the TipTop Platform with a third-party service (e.g. Google, Facebook), you direct the service to send us information such as your registration, friends list, and profile information as controlled by that service or as authorized by you via your privacy settings at that service.

• Background Information. To the extent permitted by applicable laws, we may obtain reports from public records of criminal convictions or sex offender registrations. We may use your information, including your full name and date of birth, to obtain such reports.

• Referrals. If you are invited to the TipTop Platform, the person who invited you can submit Personal Information about you such as your email address or other contact information.

• Other Sources. To the extent permitted by applicable law, we may receive additional information about you from third party providers to help detect fraud and safety issues and combine it with information we have about you. We may receive information about you and your activities on and off the TipTop Platform, or about your experiences and interactions from Customers and other Users. We may receive health information, including but not limited to health information related to contagious diseases.

2.5 Third Party Websites.

When you click on a link to any other website or location, you will leave our Platform and go to another site and another entity may collect Personal Information from you. We have no control over, do not review, cannot be responsible for, these outside websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these outside websites or content, or to any collection of data after you click on links to such sites.

3. How We Use Information We Collect

3.1 Provide, Improve, and Develop the TipTop Platform. We use Personal Information to:

• enable you to access the TipTop Platform,

• enable you to communicate with other Users,

• perform analytics, debug and conduct research,

• provide customer service,

• send you messages, updates, security alerts, and account notifications,

• if you provide us with your contacts’ information such as your friends, we may process this information: (i) to facilitate your referral invitations, (ii) to share your Profile details and, (iii) for fraud detection and prevention, and (iv) to facilitate your requests or for any other purpose you authorize, and

• personalize and customize your experience based on your interactions with the TipTop Platform, your search history, your Profile information, and other content you submit.

3.2 Create and Maintain a Trusted and Safer Environment. We use Personal Information to:

• detect and prevent fraud, spam, abuse, security and safety incidents, and other harmful activity,

• study and combat violations of our TipTop Platform Rules,

• conduct security investigations and risk assessments,

• verify or authenticate information provided by you,

• conduct checks against databases and other information sources, including background or police checks,

• resolve disputes with our Users,

• enforce our agreements with third parties,

• comply with law, respond to legal requests, prevent harm and protect our rights,

• enforce our Terms, and

• in connection with the activities above, we may conduct profiling based on your interactions with the TipTop Platform, your Profile information and other content you submit to TipTop, and information obtained from third parties. In limited cases, automated processes could restrict or suspend access to the TipTop Platform if such processes detect activity that we think poses a safety or other risk to TipTop, Users, or third parties.

3.3 Provide, Personalize, Measure, and Improve our Advertising and Marketing. We may use Personal Information to:

• send you promotional messages, marketing, advertising, and other information based on your preferences and social media advertising through social media platforms,

• personalize, measure, and improve our advertising,

• administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by TipTop or its third-party partners,

• analyze characteristics and preferences to send you promotional messages, marketing, advertising and other information that we think might be of interest to you, and

• invite you to events and relevant opportunities.

4. Sharing & Disclosure

4.1 Sharing Your Consent or at Your Direction.

Where you provide consent, we share your information as described at the time of consent, such as when authorizing a third-party application or website to access your TipTop account or participating in promotional activities by TipTop partners or third parties.

Where permissible with applicable law, we may use certain information about you, such as your email address, de-identify it, and share it with social media platforms, to generate leads, drive traffic to TipTop or otherwise promote our products and services.

4.2 Information You Publish in Profiles, Reviews and Content. You can make certain information publicly visible to others, such as:

• Your Profile page, which includes information you upload.

• Reviews, ratings and other public feedback.

• Content in a community or discussion forum, blog or social media post.

Your information that you upload on TipTop is only available to members of the TipTop community who have created their own profile on TipTop. TipTop does not currently intend to make your information publicly available. If we do so in the future, we will update this Policy.

4.3 Our Relationship with Third Party Services.

We may offer you interfaces that allow you to connect with third party services and social networking services such as Facebook, Instagram and Pinterest (as noted above, collectively, “SNS”) through our Services. We will work with the SNS’s application protocol interface (better known as their developer API) in a way that allows you to authorize us to access your account on that SNS on your behalf. In order to provide this authorization, you will not provide us with your user name or password to the SNS, but you will need to log-in to that SNS directly through our Site. Once authorized by you, the SNS will provide us a token that allows the SNS to recognize us when we ask, on your behalf, for access to your account information or to post information. You will be able to revoke our access to any SNS site at any time by amending the appropriate settings from within your account settings on the applicable SNS, though such revocation may limit the Services or Merchandise we are able to provide you.

4.4 Complying with Law, Responding to Legal Requests, Preventing Harm and Protecting our Rights.

We may disclose your information to courts, law enforcement, governmental or public authorities, tax authorities, or authorized third parties, if and to the extent we are required or permitted to do so by law or where disclosure is reasonably necessary: (i) to comply with our legal obligations, (ii) to comply with a valid legal request or to respond to claims asserted against TipTop, (iii) to respond to a valid legal request relating to a criminal investigation to address alleged or suspected illegal activity, or to respond to or address any other activity that may expose us, you, or any other of our Users to legal or regulatory liability, (iv) to enforce and administer our Terms or Software as a Service Agreement (Service Provider or Partner) with Service Providers/Partners, or (v) to protect the rights, property or personal safety of TipTop, its employees, its Users, or members of the public.

Where appropriate, we may notify Users about legal requests unless: (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon or harm to TipTop, our Users, or expose TipTop to a claim of obstruction of justice.

4.5 TipTop Vendors.

We share Personal Information with TipTop vendors to help us run our business, for example companies that help us: (i) verify your identity or authenticate your identification documents, (ii) check information against public databases, (iii) conduct background or police checks, fraud prevention, and risk assessment, (iv) perform product development, maintenance and debugging, (v) allow the provision of the TipTop Platform through third-party platforms and software tools, (vi) provide customer service or advertising, (vii) process, handle or assess insurance claims or similar claims, or (viii) facilitate non-profit and charitable activities consistent with TipTop’s mission. Any such vendors will be contractually bound to protect your Personal Information and have access to your Personal Information to perform these tasks.

4.6 Payment Processors.

(a) Clients. When Clients book a Service Provider for Services, our payment provider, currently, Stripe, collects information necessary to complete the transaction, including your name, credit card information, billing information and shipping information. See www.stripe.com for information about its privacy policy and use of your Personal Information. We do not collect or store any such information on the TipTop Platform – all payment transactions for Services are strictly between Service Providers and Clients via Stripe.

(b) Customers. When Customers purchase Merchandise from Partners, or from TipTop, on TipTop, third-party vendors with which TipTop has contracted, PayPal (www.paypal.com), Google Pay (www.play.google.com), and Shopify (www.shopify.com), collect information necessary to complete the transaction, including your name, credit card information, billing information and shipping information. See their websites for information about their privacy policies and use of your Personal Information. We do not collect or store any such information on the TipTop Platform – all payment transactions for Merchandise are strictly between Partners and Customers via PayPal, Google Pay or Shopify.

4.7 Business Transfers.

If TipTop undertakes or is involved in any merger, acquisition, reorganization, sale of assets, bankruptcy, or insolvency event, then we may sell, transfer or share some or all of our assets, including your information in connection with such transaction or in contemplation of such transaction (e.g., due diligence). In this event, we will notify you before your Personal Information is transferred and becomes subject to a different privacy policy.

5. Cookie Policy

TipTop uses cookies, mobile identifiers, tracking URLs, log data and similar technologies to help provide, protect, and improve the TipTop Platform. This Cookie Policy (“Policy”) explains how and why we use these technologies and the choices you have.

5.1 Why TipTop Uses These Technologies.

We use these technologies for a number of purposes, such as:

• to enable you to use and access the TipTop Platform

• to enable, facilitate and streamline the functioning of and your access to the TipTop Platform

• to better understand how you navigate through and interact with the TipTop Platform and to improve the TipTop Platform

• to serve you tailored advertising (such as on the TipTop Platform, emails and on third-party websites)

• to show you content (e.g., advertisements) that is more relevant to you

• to monitor and analyze the performance, operation, and effectiveness of the TipTop Platform and TipTop advertisements

• to enforce legal agreements that govern use of the TipTop Platform

• for fraud detection and prevention, trust and safety, and investigations

• for purposes of our own customer support, analytics, research, product development, and regulatory compliance.

5.2 Cookies.

When you visit the TipTop Platform we may place cookies on your device. Cookies are small text files that websites send to your computer or other Internet-connected device to uniquely identify your browser or to store information or settings in your browser. Cookies allow us to recognize you when you return. They also help us provide a customized experience and can enable us to detect certain kinds of fraud. In many cases the information we collect using cookies and other tools is only used in a non-identifiable manner without reference to Personal Information. For example, we may use information we collect to better understand TipTop Platform traffic patterns and to optimize our Platform experience. In some cases we associate the information we collect using cookies and other technology with your Personal Information. Our business partners may also use these tracking technologies on the TipTop Platform or engage others to track your behavior on our behalf.

There are two types of cookies used on the TipTop Platform: (1) “session cookies” and (2) “persistent cookies.” Session cookies normally expire when you close your browser, while persistent cookies remain on your device after you close your browser, and can be used again the next time you access the TipTop Platform.

In many cases you can manage cookie preferences and opt-out of having cookies and other data collection technologies used by adjusting the settings on your browser. All browsers and devices are different so visit the “help” section of your browser and/or device to learn about cookie preferences and other privacy settings that may be available. Please note that if you choose to remove or reject cookies or clear local storage this could affect the features, availability, and functionality of the TipTop Platform.

5.3 Flash Cookies.

We may use Flash Cookies, also known as Local Stored Objects, and similar technologies to personalize and enhance your online experience. A Flash cookie is a small data file placed on a computer using Adobe Flash technology. The Adobe Flash Player is an application that allows rapid development of dynamic content, such as video clips and animation.

We use Flash cookies to personalize and enhance your online experience and to deliver content for Flash players. We may also use Flash cookies for security purposes, to gather certain website metrics and to help remember settings and preferences. Flash cookies are managed through a different interface than the one provided by your web browser. To manage Flash cookies, please visit SquareSpace’s website at www.squarespace.com.

If you disable Flash cookies or other similar technologies, please note that you may not have access to certain content and product features such as your device remembering a Profile that you viewed during a previous visit.

5.4 Pixel Tags, Web Beacons, and Trackers.

Pixel tags, web beacons, and tracking urls are tiny graphic images and/or small blocks of code placed on website pages, ads, or in our emails that allow us to determine whether you performed a specific action. When you access these pages, or when you open an email, let us know you have accessed the web page or opened the email. These tools help us measure response to our communications and improve our web pages and promotions.

5.5 Server Logs and Other Technologies.

We collect many different types of information from server logs and other technologies. For example, we collect information about the device you use to access the TipTop Platform, your operating system type, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone where your device is located. Our server logs also record the IP address of the device you use to connect to the Internet. An IP address is a unique identifier that devices require to identify and communicate with each other on the Internet. We may also collect information about the website you were visiting before you came to the TipTop Platform and the website you visit after you leave the TipTop Platform. These tools help us improve user experience and deliver our services.

5.6 Device Information.

We may use device-related information to authenticate users. For example, we may use your IP address, browser information, or other data provided by your browser or device to identify the device being used to access our platform. We may also use these device-related techniques for associating you with different devices that you may use to access our content including for fraud-protection purposes and to better target advertising.

5.7 Third Parties.

Third parties, including Facebook, place technologies such as pixels and SDKs on the TipTop Platform. These technologies (1) help us analyze how you use the TipTop Platform, such as by noting the third party services from which you arrived, (2) market and advertise TipTop services to you on the TipTop Platform and third party websites, (3) help us detect or prevent fraud or conduct risk assessments, and (4) collect information about your activities on the TipTop Platform, other sites, and/or the ads you have clicked on. For example, to help us better understand how people use the TipTop Platform, we work with a number of analytics partners, including Google Analytics. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-Out Browser by clicking on the link, Google Analytics Opt-out Browser Add-on.

Third parties, including Facebook, may also use such tracking technologies to collect or receive information from the TipTop Platform and elsewhere and use that information to serve ads that they believe are most likely to be of interest to you and measure the effectiveness of their ads both on the TipTop Platform and on other websites and online services. You may opt out by visiting such websites. To the extent advertising technology is integrated into the TipTop Platform and you opt-out of tailored advertising, you may still receive advertising content. In that case, the advertising content will just not be tailored to your interests. Also, we do not control any of these opt-out links and are not responsible for the availability or accuracy of these mechanisms. Users can opt-out of the collection and use of information for ad targeting by updating their Facebook account ad settings.

5.8 Third Party Social Plugins.

The TipTop Platform may use social plugins provided and operated by third parties, such as Facebook’s Like Button. As a result of this, you may send to the third party the information that you are viewing on a certain part of the TipTop Platform. If you are not logged into your account with the third party, then the third party may not know your identity. If you are logged in to your account with the third party, then the third party may be able to link information or actions about your interactions with the TipTop Platform to your account with them. Please refer to the third party’s privacy policies to learn more about its data practices.

5.9 Your Choices.

Most browsers automatically accept cookies, but you can modify your browser setting to decline cookies by visiting the Help portion of your browser’s toolbar. While you may disable cookies through your browser settings, the TipTop Platform currently does not respond to a “Do Not Track” signal in the HTTP header from your browser or mobile application due to lack of standardization regarding how that signal should be interpreted.

Flash cookies operate differently than browser cookies, and cookie management tools available in a web browser will not remove flash cookies. To learn more about how to manage flash cookies, you can visit the Adobe website at, www.adobe.com.

Your mobile device may allow you to control cookies through its settings function. Refer to your device manufacturer’s instructions for more information.

If you choose to decline cookies, some parts of the TipTop Platform may not work as intended or may not work at all.

6. Other Important Information

6.1 Analyzing your Communications.

We may review, scan, or analyze your communications on the TipTop Platform for reasons outlined in the “How We Use Information We Collect” section of this Privacy Policy, including fraud prevention, risk assessment, regulatory compliance, investigation, product development, research, analytics, enforcing our Terms, and customer support purposes. For example, as part of our fraud prevention efforts, we scan and analyze messages to mask contact information and references to other sites. In some cases, we may also scan, review, or analyze messages to debug, improve, and expand product offerings. We use automated methods where reasonably possible. Occasionally we may need to manually review communications, such as for fraud investigations and customer support, or to assess and improve the functionality of these automated tools. We will not review, scan, or analyze your messaging communications to send third-party marketing messages to you and we will not sell reviews or analyses of these communications.

6.2 Linking Third-Party Accounts.

You can link your TipTop account with certain third-party services like social networks. Your contacts on these third-party services are referred to as “Friends.” When you direct the data sharing by creating this link:

• some of the information provided to us from linking accounts may be published on your Profile,

• your activities on the TipTop Platform may be displayed to your Friends on the TipTop Platform and/or that third-party service,

• a link to your public profile on that third-party service may be included in your TipTop Profile,

• other TipTop Users may be able to see any Friends that you may have in common with them, or that you are a Friend of their Friend if applicable,

• other TipTop users may be able to see any schools, hometowns or other groups you have in common with them as listed on your linked social networking service,

• information you provide to us from the linking of your accounts may be stored, processed and transmitted for fraud prevention and risk assessment purposes, and

• publication and display of information that you provide to the TipTop Platform through this linkage is subject to your settings and authorizations on the TipTop Platform and the third-party service.

6.3 Third-Party Partners & Integrations.

Parts of TipTop may link to third-party services, not owned or controlled by TipTop, such as Android App Store for Tracking. Use of these services is subject to the privacy policies of those providers, including without limitation, those identified in Section 4.6. TipTop does not own or control these third parties and when you interact with them you are providing your Personal Information to them.

7. Your Rights

You can exercise any of the rights described in this section consistent with applicable law. Please contact us at www.legal@jointiptop.com to submit a request with respect to your Personal Information. Please note that we may ask you to verify your identity and request before taking further action on your request.

7.1 Managing Your Information.

You can access and update some of your Personal Information through your Account settings. If you connected your TipTop Account to a third-party service, like Facebook or Google, you can change your settings and unlink from that service in your Account settings. You are responsible for keeping your Personal Information up to date.

7.2 Data Access and Portability.

In some jurisdictions, applicable law may entitle you to request certain copies of your Personal Information or information about how we handle your Personal Information, request copies of Personal Information that you have provided to us in a structured, commonly used, and machine-readable format, and/or request that we transmit this information to another Service Provider (where technically feasible).

7.3 Data Erasure.

In certain jurisdictions, you can request that your Personal Information be deleted. Please note that if you request the erasure of your Personal Information:

• We may retain your Personal Information as necessary for our legitimate business interests. For example, if we suspend a TipTop Account for fraud or safety reasons, we may retain information from that TipTop Account to prevent that User from opening a new TipTop Account in the future.

• We may retain and use your Personal Information to the extent necessary to comply with our legal obligations. For example, TipTop may keep information for tax, legal reporting and auditing obligations.

• Information you have shared with others (e.g., Reviews) will continue to be publicly visible on the TipTop Platform even after your TipTop Account is cancelled. However, attribution of such information to you will be removed. Some copies of your information (e.g., log records) will remain in our database, but are disassociated from personal identifiers.

• Because we take measures to protect data from accidental or malicious loss and destruction, residual copies of your Personal Information may not be removed from our backup systems for a limited period of time.

8. Security

While no organization can guarantee perfect security, we are continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unauthorized access, loss, destruction, or alteration.

9. Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time in accordance with applicable law. If we do so, we will post the revised Privacy Policy and update the “Last Updated” date at the top. In case of material changes, we will also provide you with notice of the modification by email at least thirty (30) days before the effective date. If you disagree with the revised Privacy Policy, you can cancel your Account. If you do not cancel your Account before the date the revised Privacy Policy becomes effective, your continued access to or use of the TipTop Platform will be subject to the revised Privacy Policy.

10. Contact Information

For questions or complaints about this Privacy Policy or TipTop’s handling of Personal Information, please contact us at www.jointiptop.com.