Privacy Policy
Privacy Policy of ToppleAI
This document contains sections dedicated to Californian consumers and their privacy rights, as well as Brazilian Users and their privacy rights.
This document can be printed for reference by using the print command in the settings of any browser.
Owner and Data Controller
ToppleAI
Owner contact email: raymondjordanaisolutions@gmail.com
Types of Data Collected
Among the types of Personal Data that ToppleAI collects, by itself or through third parties, there are:
- Personal Identification Data: First name, last name, email address, phone number.
- Usage Data: Tracker; Usage Data; Data communicated while using the service; various types of Data.
- Payment Information: Payment details necessary for handling payments.
Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in the case of Usage Data, collected automatically when using this Application.
Unless specified otherwise, all Data requested by this Application is mandatory, and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or other tracking tools – by this Application or by the owners of third-party services used by this Application serves the purpose of providing the Service required by the User, in addition to any other purposes described in this document and in the Cookie Policy, if available.
Users are responsible for any third-party Personal Data obtained, published, or shared through this Application and confirm that they have the third party's consent to provide the Data to the Owner.
Mode and Place of Processing the Data
Methods of Processing
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT-enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge involved with the operation of this Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner.
The updated list of these parties may be requested from the Owner at any time.
Legal Basis of Processing
The Owner may process Personal Data relating to Users if one of the following applies:
- Users have given their consent for one or more specific purposes.
- Provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof.
- Processing is necessary for compliance with a legal obligation to which the Owner is subject.
- Processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing.
Place
The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.
Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law.
If any such transfer takes place, Users can inquire with the Owner using the information provided in the contact section.
Retention Time
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
Therefore:
- Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
- Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing or when required to do so for compliance with a legal obligation.
Once the retention period expires, Personal Data shall be deleted.
The Purposes of Processing
The Data concerning the User is collected to allow the Owner to provide its Service, comply with legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), and detect any malicious or fraudulent activity.
Specific purposes include:
- Access to Third-Party Accounts
- Analytics
- Contacting the User
- Hosting and Backend Infrastructure
- Handling Payments
- Remarketing and Behavioral Targeting
- Advertising
- Registration and Authentication
- Tag Management
For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed Information on the Processing of Personal Data.”
Google API Services User Data Policy
Our application complies with the Google API Services User Data Policy, including the Limited Use requirements. We understand the importance of protecting user data and have implemented measures to ensure compliance with the policy. We only use user data for the purposes outlined in our privacy policy and do not share or sell user data to third parties.
- Google Sheets: We allow you to get data and update your Spreadsheet.
- Google Calendar: We read the list of events on your calendar to avoid overbooking. Also, we add events to your Calendar when a customer books an appointment.
- Dialogflow: We use Dialogflow to allow you to automate customer services. We only use Dialogflow to detect user intents.
This Application’s use and transfer of information received from Google APIs to any other app will adhere to the Google API Services User Data Policy, including the Limited Use requirements.
Facebook Permissions Asked by this Application
This Application may ask for some Facebook permissions allowing it to perform actions with the User's Facebook account and to retrieve information, including Personal Data, from it.
For more information about the following permissions, refer to the Facebook permissions documentation and to the Facebook privacy policy.
The permissions asked are the following:
- Basic Information
- Manage Pages
- Page Messaging
- Pages Read Engagement
Detailed Information on the Processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
Access to Third-Party Accounts
This type of service allows this Application to access Data from your account on a third-party service and perform actions with it.
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Facebook Account Access (Facebook, Inc.)
This service allows this Application to connect with the User's account on the Facebook social network, provided by Facebook, Inc.
Permissions asked: Basic information; Email; Manage Pages; Page Messaging; Pages Read Engagement.
Place of processing: United States – Privacy Policy.
Advertising
This type of service allows User Data to be utilized for advertising communication purposes.
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Google Ad Manager (Google Ireland Limited)
Google Ad Manager is an advertising service provided by Google Ireland Limited.
Personal Data processed: Tracker; Usage Data.
Place of processing: Ireland – Privacy Policy.
Analytics
The services contained in this section enable the Owner to monitor and analyze web traffic.
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Google Analytics
Google Analytics is a web analysis service provided by Google LLC or by Google Ireland Limited.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Contacting the User
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Mailing List or Newsletter
By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list.
Personal Data processed: Email address; first name; last name; phone number; Usage Data.
Handling Payments
This Application processes payments via external payment service providers.
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Stripe (Stripe Technology Europe Ltd)
Stripe is a payment service provided by Stripe Technology Europe Ltd.
Personal Data processed: Email address; first name; last name; payment info.
Place of processing: Ireland – Privacy Policy.
Hosting and Backend Infrastructure
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Google Cloud Storage (Google LLC)
Google Cloud Storage is a hosting service provided by Google LLC.
Personal Data processed: Various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Registration and Authentication
By registering or authenticating, Users allow this Application to identify them.
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Google OAuth (Google Ireland Limited)
Google OAuth is a registration and authentication service provided by Google Ireland Limited.
Personal Data processed: Various types of Data as specified in the privacy policy of the service.
Place of processing: Ireland – Privacy Policy.
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Facebook Authentication (Facebook Ireland Ltd)
Facebook Authentication is a registration and authentication service provided by Facebook Ireland Ltd.
Personal Data processed: Tracker; various types of Data as specified in the privacy policy of the service.
Place of processing: Ireland – Privacy Policy.
Remarketing and Behavioral Targeting
This type of service allows this Application and its partners to inform, optimize, and serve advertising based on past use of this Application by the User.
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Facebook Custom Audience (Facebook Ireland Ltd)
Facebook Custom Audience is a remarketing and behavioral targeting service provided by Facebook Ireland Ltd.
Personal Data processed: Email address; Tracker.
Place of processing: Ireland – Privacy Policy – Opt Out.
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Google Ads Remarketing (Google Ireland Limited)
Google Ads Remarketing is a remarketing and behavioral targeting service provided by Google Ireland Limited.
Personal Data processed: Tracker; Usage Data.
Place of processing: Ireland – Privacy Policy – Opt Out.
Tag Management
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Google Tag Manager (Google Ireland Limited)
Google Tag Manager is a tag management service provided by Google Ireland Limited.
Personal Data processed: Tracker; Usage Data.
Place of processing: Ireland – Privacy Policy.
The Rights of Users
Users may exercise certain rights regarding their Data processed by the Owner. In particular, Users have the right to:
- Withdraw their consent at any time.
- Object to processing of their Data.
- Access their Data.
- Verify and seek rectification.
- Restrict the processing of their Data.
- Have their Personal Data deleted or otherwise removed.
- Receive their Data and have it transferred to another controller.
- Lodge a complaint before their competent data protection authority.
How to Exercise These Rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests will be addressed by the Owner as early as possible and always within one month.
Cookie Policy
This Application uses Trackers. To learn more, the User may consult the Cookie Policy.
Additional Information about Data Collection and Processing
Legal Action
The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Application or the related Services.
Additional Information
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time.
System Logs and Maintenance
For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application.
Data Shared with Third-Party Tools
Our app does not auto-share user data to third-party tools without the user's consent. The user has full control over their data.
Information Not Contained in This Policy
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time.
Changes to This Privacy Policy
The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page.
Information for Californian Consumers
This part of the document integrates with and supplements the information contained in the rest of the privacy policy.
Your California Privacy Rights and How to Exercise Them
Users residing in California have specific rights regarding their Personal Data. These rights include:
- The right to know and to portability
- The right to request the deletion of your personal information
- The right to opt out of the sale of personal information
To exercise these rights, you can contact us using the contact details provided in this document.
Information for Users Residing in Brazil
This part of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided in compliance with the "Lei Geral de Proteção de Dados" (LGPD).
Your Brazilian Privacy Rights
Users residing in Brazil have specific rights regarding their Personal Data. These rights include:
- Obtaining confirmation of the existence of processing activities
- Access to your personal information
- Rectification of incomplete, inaccurate, or outdated personal information
- Anonymization, blocking, or elimination of unnecessary or excessive data
To exercise these rights, you can contact us using the contact details provided in this document.
Definitions and Legal References
- Personal Data (or Data): Any information that allows for the identification of a natural person.
- Usage Data: Information collected automatically through this Application.
- User: The individual using this Application.
- Data Subject: The natural person to whom the Personal Data refers.
- Data Processor: The natural or legal person who processes Personal Data on behalf of the Controller.
- Data Controller (or Owner): The natural or legal person who determines the purposes and means of the processing of Personal Data.
- Service: The service provided by this Application.
- European Union (or EU): All current member states to the European Union and the European Economic Area.
- Cookie: Small sets of data stored in the User's browser.
- Tracker: Any technology that enables the tracking of Users.
Contact Information:
If you have any questions or concerns about this Privacy Policy, please contact us at:
Email: raymondjordanaisolutions@gmail.com
Website: toppleai.com