PRIVACY POLICY

Last Updated: [21 July 2025]

Introduction:

TopCashback Inc (“we”, “us” or “our”) is committed to respecting and protecting your privacy. In short, this privacy policy (“Privacy Policy”) explains how we collect, use, and disclose your personal information. Additionally, it describes your privacy rights under applicable law. This Privacy Policy is also subject to any other agreement you enter into with us. For purposes of this Privacy Policy, “you” and “your” means you as the user of Site (as defined below).


1.Important Information About RNL and You

TopCashback Inc operates the website (https://giftcards.topcashback.com, the “Site”), which is a platform where you can purchase digital gift cards (each an “E-Gift Card”) for your favorite retailers. By visiting the Site, you accept and consent to this Privacy Policy and the practices outlined in it. The Site is powered by RUNA NETWORK LIMITED (“RNL”) which supports gift card issuance and fulfillment as our service provider.


2.Data We Collect About You 

Generally

Personal Information means any information about an individual from which that person can be identified. It does not include data where the identity of the person has been removed (anonymous data).

We may collect, use, store, and transfer different kinds of Personal Information about you which we have grouped together as follows:

    • Identity Data includes first name, last name
    • Contact Information includes your mailing address and email address.
    • Technical Data includes internet protocol (IP) address, your browser type and version, time zone settings, browser plug-in types and versions, operating system, and other technology on the devices you use to access the Site.
    • Usage Data includes information about how you use the Site.
    • Financial Data includes card details, transaction information and merchant.
    • Marketing Comms Data includes your preferences in receiving marketing from us and our third-parties and your communication preferences.


3.How Is Your Personal Data Collected

When You use the Site, we may collect Personal Information from you directly, or we may collect Personal Information automatically when you interact with the Site.

    • Direct Interactions. You may give us your Identity Data and Financial Data by filing in forms or by corresponding with us through the Site (including when you process a transaction). 
    • Automated Technologies. As you interact with our Site, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Personal Data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. You can manage your cookie preferences when first accessing our Site.


4.How We Use Your Personal Information

We use personal information to: 

    • Provide, operate, and improve the Site and services;
    • Process and fulfill E-Gift Card purchases and deliver confirmations/receipts;
    • Communicate with you about your account, transactions, and updates;
    • Provide customer support and handle claims/complaints;
    • Personalize and measure content and experiences;
    • Perform analytics, debugging, and quality assurance;
    • Detect, prevent, and respond to fraud, abuse, security incidents, and illegal activities;
    • Comply with legal obligations and enforce our terms;

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. 


5.Disclosures of Your Information

Generally

We may share your Personal Information with the parties set out below for the purposes outlined in the table above.

    • Brands to process your purchase transactions.
    • Service providers such as professional advisers (e.g. lawyers, accountants), web and app hosting services, website optimisation services, website usage services, email services, data management platform provision, E-Gift Card distribution services, customer relationship management services, marketing tracking partners, messaging services, online and offline marketing services, to handle, store, or use certain Personal Data on our behalf.
    • Our affiliates.
    • Third parties to whom we may sell, transfer or merge part of our business assets.
    • Regulators or legal authorities (such as law enforcement) to meet our legal obligations, prevent criminal activity or for reasons of substantial public interest.



6.Data Security

We have put in place appropriate security measures to prevent your Personal Information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.


7.Data Retention

We will only retain your Personal Information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for Personal Information , we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.


8.Your Legal Rights

Under certain state laws, you may have the following rights regarding your personal information which are:

    • Right to Know: Request details about the categories and specific pieces of personal information we collect, the sources of that information, and the purposes for which it is used.
    • Right to Delete: Request the deletion of your personal information, subject to certain exceptions.
    • Right to Opt Out: Request that we do not share your personal information for commercial purposes. 
    • Right to Correct: Request corrections to any inaccurate or incomplete personal information.
    • Right to Non-Discrimination: You will not be discriminated against for exercising any of your privacy rights.



To exercise your rights outlined above, you must provide us with sufficient information for us to determine your identity and describe your request with sufficient detail that allows us to properly understand, evaluate and respond to it. Please submit your request to us by email: privacy@topcashback.com. 


9.California Opt-Out of Sale / Sharing Disclosure

You may opt out of the sale/sharing of your Personal Information : 

    • by submitting a request via email to privacy@topcashback.com ; or 
    • by broadcasting an Opt-Out Preference Signal, such as the Global Privacy Control (GPC) (on the browsers and/or browser extensions that support such a signal). To download and use a browser supporting the GPC browser signal, click here: https://globalprivacycontrol.org/orgs. If you choose to use the GPC signal, you will need to turn it on for each supported browser or browser extension you use.


10.Additional Details

Changes to the Privacy Policy

We may make changes to the Privacy Policy from time to time to keep it up to date and accurate based on our privacy practices. If we make material changes, we will notify you by email. 

Third Party Links

This website may include links to third-party websites (“TPW”), plug-ins, and applications. Clicking on those links or enabling those connections may allow third-parties to collect and disclose data about you. We do not control those TPWs, and are not responsible for their privacy practices. 

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