privacy policy

Version update date: February 28, 2024 Version effective date: February 28, 2024 Special Note TOPUPlive ("We") take the protection of our users' privacy and personal information very seriously. When you use our products and/or services, we may collect and use information about you. Your trust is very important to us, and we understand the importance of personal information to you, and we will do our best to keep your personal information secure and under control by taking appropriate security measures as required by law and regulation. In view of this, we have developed this Privacy Policy (hereinafter referred to as "this Policy / this Privacy Policy") and would like to remind you that This Privacy Policy is closely related to the TOPUPlive Mall service you use and the various business functions included in the service (collectively referred to hereinafter as "our products and/or services"), and we hope that you will read it carefully and confirm that you have fully understood the contents written in this Privacy Policy before using our products and/or services, and so that you can make the choices you deem appropriate in accordance with the guidelines in this Privacy Policy. This policy applies to all products and services provided by TOPUPlive. Before using TOPUPlive's products or services, please be sure to read and fully understand the terms and conditions, especially the terms of exemption or limitation of liability, legal application and dispute resolution. The terms that exclude or limit liability will be marked in bold and you should focus on reading them to confirm full understanding and agreement before you start using them. If you have any questions during the course of reading the Agreement, you may contact our customer service for advice; if you do not agree with the relevant agreement or any of the terms agreed to in the Agreement, you should immediately stop visiting TOPUPlive. This Privacy Policy will help you understand the following. I. How we collect and use your personal information 1. Your personal information that we need/may need to collect and use in connection with your use of our products and/or services. (1) In order to achieve the basic function of providing our products and/or services to you, you must authorize us to collect and use the necessary information. If you refuse to provide the corresponding information, you will not be able to use our products and/or services properly. (2) For the purpose of providing you with additional functions of our products and/or services, you may choose to authorize the information we collect and use. If you refuse to provide it, you will not be able to use the relevant additional features or achieve the functional effect we intend to achieve, but it will not affect your normal use of the basic functions of our products and/or services. 2. You understand and agree that. (1) We are committed to creating a variety of products and services to meet your needs. Due to the variety of products and services we provide to you, and the differences in the scope of specific products/services that different users choose to use, the corresponding basic/additional features and the type and scope of personal information collected and used may differ, please refer to the specific product/service features. (2) To bring you a better product and service experience. We are continuously working to improve our technology, and with that we may from time to time introduce new or optimized features that may require the collection or use of new personal information or change the purpose or manner of use of personal information. In this regard, we will separately explain to you the purpose, scope and use of the corresponding information by updating this policy, pop-up windows, page prompts, etc., and provide you with the means to choose your own consent, and collect and use it with your express consent. Personal information is data that can be recorded electronically or otherwise to identify a specific natural person or reflect the activities of a specific natural person, either alone or in combination with other information. Any time you contact TOPUPlive or a TOPUPlive affiliate, you may be asked to provide personal information, which may be shared by TOPUPlive and its affiliates and used in accordance with this Privacy Policy for services, content and advertising. You are not obligated to provide the personal information we request, but in many cases, if you choose not to, we will not be able to provide you with our products or services or respond to any problems you encounter. To make shopping more convenient or enjoyable for you and thereby enhance your online shopping experience at TOPUPlive, your personal information may be collected and used in some of our extended features. If you do not provide this personal information, you can still shop online, but you may not be able to use these extended features that can make shopping fun for you or may need to fill in some information repeatedly when purchasing certain items. You are fully aware that we collect and use personal information without your authorized consent in the following cases: (1) Related to national security, national defense security. (2) Related to public safety, public health, and significant public interest. (3) related to crime investigation, prosecution, trial and execution of judgments, etc. (4) for the purpose of safeguarding the life, property and other significant legitimate rights and interests of the subject of personal information or other individuals but it is difficult to obtain their consent. (5) the personal information collected is the subject of personal information or the guardian's own disclosure to the public. (6) Where your personal information is collected from legitimate public disclosure, such as legitimate news reports, government information disclosure and other channels. (7) necessary to enter into a contract at your request. (8) necessary for the maintenance of the safe and stable operation of the products and/or services provided, such as the detection and disposal of product and/or service failures. (9) Necessary for legitimate press coverage. (10) necessary for academic research institutions to conduct statistical or academic research in the public interest and to de-identify the personal information contained in the results when providing the results of academic research or descriptions to the public. (11) Other circumstances as provided for by laws and regulations. 4. Circumstances in which we obtain your personal information from a third party. (1) We may obtain account information from third parties that you are authorized to share and bind your third-party account to your TOPUPlive account after you agree to this Privacy Policy, so that you can log in and use our products and/or services directly through your third-party account. (2) We will use your personal information in accordance with the agreement with the third party and after confirming the legitimacy of the source of the personal information, subject to the relevant laws and regulations. II. What personal information we collect When you create a TOPUPlive account, purchase products, participate in TOPUPlive offers, contact us, or participate in online surveys, we may collect a variety of personal information about you, including your: (1) Basic information (including name, cell phone number, email address, other online contact information). (2) Personal identification information (including ID card, passport, bank cards and statements, driver's license, etc.). (3) network identification information (including system accounts, IP addresses, e-mail addresses and passwords, passwords, password protection answers related to the foregoing). (4) Personal property information (transaction and consumption records, as well as discount codes, game type redemption codes and other digital goods property information). (5) personal Internet access records (including website browsing records, software usage records, click records). (6) Personal common device information (including hardware model, MAC address of the device, operating system type, software list unique device identification code (such as IMEI/android ID/IDFA/OPENUDID/GUID, SIM card IMSI information and other information describing the basic situation of personal common devices). (7) Personal location information (including IP address, precise positioning information, etc.). (8) When you use TOPUPlive products to share content with family and friends, send gift certificates and products, or invite others to use TOPUPlive services, TOPUPlive may collect information you provide related to the above people, such as name, mailing address, email address, and phone number. TOPUPlive will use such information to meet your requests, provide related products or services, or for anti-fraud purposes. You must authorize us to collect and use your personal information in situations where our products and/or services include core features that are necessary to enable online shopping and to secure transactions. We may collect, store and use such information about you in order to perform such functions. If you do not provide the relevant information, you will not be able’t enjoy the products and/or services provided by us. III. How we use your personal information We will use the personal information we collect in accordance with this Privacy Policy and for the purpose of implementing the functions of our products and/or services. After collecting your personal information, we will de-identify the data through technical means, and the de-identified information will not be able to identify the subject. Please understand and agree that we have the right to use the de-identified information in such cases and that we have the right to analyze and commercially exploit the user database without disclosing your personal information. Please note that all personal information provided by you when using our products and/or services will be licensed to us for the duration of your use of our products and/or services, unless you delete it or refuse to allow us to collect it through system settings. In order for you to quickly find the product you are looking for, we may collect information about the device (including device name, device model, device identifier, operating system and application version, language setting, resolution, service provider network ID (PLMN)), and browser type from which you use our products and/or services to provide you with the best way to display product information. We may also use your personal information as described above in order to continuously improve and optimize the features described above. You may also search to find the exact product or service you are looking for. We will retain your search content so that you can repeat it or show you products that are related to your search. Please note that your search keyword information does not identify you alone and is not part of your personal information, and we have the right to use it for any purpose; only if your search keyword information is used in combination with other information that identifies you, we will treat your search keyword information as your personal information, together with your search history, for the duration of the combination. We will treat and protect your search keyword information as your personal information, together with your search history, for the duration of the combined use in accordance with this Privacy Policy. We may compile statistics on the use of our products and/or services and may share these statistics with the public or third parties to demonstrate overall usage trends for our products and/or services. These statistics, however, do not contain any identifying information about you. When we display your personal information, we will desensitize your information using methods that include content substitution and anonymization to protect the security of your information. When we use your personal information for purposes other than those set forth in this Privacy Policy, or when we use information collected for a specific purpose, we will seek your consent in advance by means of a checkbox that you voluntarily select. With the personal information we collect, we can keep you informed of TOPUPlive's latest product releases and special offers. We also use personal information for the following purposes: to help us create, develop, operate, deliver and improve our products, services, content and advertising, and for loss prevention and fraud prevention purposes. We may use your personal information (e.g., date of birth) to verify identity, assist in identifying users, and determine appropriate services. For example, we may use date of birth to determine the age of TOPUPliveID account holders. At times, we may use personal information to send important notices, such as information about purchases and changes to terms, conditions, and policies. Because this information is essential to communication between you and TOPUPlive, you cannot refuse to receive such information. We also use personal information for internal purposes such as auditing, data analysis, and research to improve TOPUPlive's products, services, and communications with our customers. If you participate in sweepstakes, contests or similar promotions, we will use the information you provide to administer such activities. IV. Collection and Use of Non-Personal Information We also collect data that cannot be directly linked to any particular individual using its own. We may collect, use, transfer and disclose non-personal information for any purpose. The following are some examples of the non-personal information we may collect and how we may use it. We may collect information such as occupation, language, zip code, area code, unique device identifier, referral URL, location, and the time zone in which the user is using TOPUPlive products so that we can better understand customer behavior and improve our products, services, and advertising. We may collect information related to our customers' activities on our website, as well as information obtained from our other products and services. We may aggregate such information and use it to help us provide more useful information to our customers about which parts of our websites, products and services are of most interest to them. Aggregated data is considered non-personal information for the purposes of this Privacy Policy. We may collect and store detailed information about how you use our services, including search queries. Such information may be used to improve the results provided by our Services and to make them more relevant. Such information will not relate to your IP address, except in a few cases where we need to ensure the quality of the services provided over the Internet. If we use non-personal信息 in combination with personal information, such information will be treated as personal information for the duration of the combined use. V. Use of Cookies and Similar Technologies I. Introduction to Cookie and Other Technology Usage TOPUPlive's websites, online services, interactive applications, emails, and advertisements may use "cookies" and other technologies such as pixel tags and web beacons. These technologies help us better understand user behavior, tell us which parts of our websites people visit, measure the effectiveness of advertising and web searches, and improve them. We treat the information we collect through cookies and other technologies as non-personal information. However, we also treat Internet Protocol (IP) addresses or similar identifiers as personal information if such identifiers are considered personal information under local law. Similarly, for the purposes of this Privacy Policy, where non-personal information is used in combination with personal information, we treat the combined use as personal information. II. Usage in Mobile Advertising Services TOPUPlive and its partners use cookies and other technologies in mobile advertising services to control the number of times you see a particular ad, to deliver the ads you are interested in, and to measure the effectiveness of advertising campaigns. If you do not wish to receive such ads that are relevant to you on your mobile device, you may opt out of TOPUPlive by visiting the link below on your device. If you opt out, you will continue to receive the same number of mobile ads, but they may be less relevant because they will no longer be delivered based on your interests. You will still see ads that are related to content on the web or in the application or that are placed in accordance with other non-personal information. Rejection applies only to the TOPUPlive ad service and does not affect interest-based ad services from other ad affiliates. However, if you choose to "Restrict Ad Tracking" on your mobile device, third-party apps are contractually prohibited from using "ad identifiers" (a non-personal device identifier) to deliver targeted ads to you. III. Usage for Personalization TOPUPlive and our partners also use cookies and other technologies to record personal information when you use our website, online services, and applications. In these cases, our goal is to make your experience with TOPUPlive products and services more convenient and personalized. For example, if we know your name, we can welcome you the next time you visit the TOPUPlive online store. If we know your country and the language you speak (or your school if you are an educator), it will help us provide a shopping experience that is tailored to you and more useful to you. If we know that someone has used your computer or device to purchase a product or use a service, it will help us to deliver ads and emails to you that better match your interests. If we know your contact information, hardware identifiers, and information about your computer or device, we can better personalize your operating system, set up your services, and provide you with better customer service. IV. Disabling Cookies If you wish to disable cookies and are using a web browser, go to Preferences and then to the Privacy pane and disable cookies. On your mobile device, click on Settings, then select Privacy, then go to the Cookies section. For other browsers, please contact your provider to find out how to disable cookies, but please note that disabling cookies will prevent you from using certain features of the TOPUPlive website. V. Information Collected in Log Files As with most Internet services, we automatically collect certain information that we store in log files. This information includes Internet Protocol (IP) addresses, browser type and language, Internet Service Provider (ISP), referring/exit sites and applications, operating system, date/time stamp, and clickstream data. We use this information to understand and analyze trends, to administer the Site, to understand user behavior on the Site, to improve our products and services, and to gather information about the overall audience characteristics of our user base, which TOPUPlive may use for our marketing and advertising services. VI. Tracking in Emails In some of our emails, we use "click-through URLs" that link to content on the TOPUPlive website. When a customer clicks on one of these click-through URLs, it passes through a separate web server before reaching the target page on our site. We track this click-through data to help us determine our customers' interest in specific topics and to measure the effectiveness of our communications with them. If you do not like this type of tracking, please do not click on text or image links in emails. Pixel tags allow us to send emails in a format our customers can read and tell us if the email was opened. We may use this information to reduce or eliminate emails sent to customers. VII. Sharing, Public Disclosure, and Transfer of Personal Information to Third Parties 1. Sharing - With your express prior consent or authorization. - To the extent necessary to provide it in accordance with applicable laws and regulations, the requirements of legal proceedings, and mandatory administrative or judicial requirements. - Where necessary to protect TOPUPlive, TOPUPlive's affiliates or partners, you or other TOPUPlive users, or the public from harm to property or safety, within the limits permitted by law or regulation. - Only share your personal information to enable the core functionality of our products and/or services or to provide the services you need. - To handle disputes or controversies between you and others for you upon your request. - Provided in accordance with the relevant agreement signed with you (including the electronic agreement signed online and the corresponding platform rules) or other legal documents agreed upon. - Used in the public interest based on compliance with laws and regulations. We may share your personal information with our affiliates. However, we will only share personal information that is necessary and subject to the purposes stated in this Privacy Policy. We may share your order information, account information, device information, and location information with third parties, such as partners, to ensure the successful completion of the services provided to you. However, our partners are not authorized to use the shared personal information for any other purpose. 2. Public Disclosure We will only publicly disclose your personal information when we have taken security measures that meet industry standards and only in the following circumstances: - In accordance with your needs and in a manner that you have expressly agreed to or authorized for the disclosure of the personal information you have specified. - Where we are required to provide your personal information in accordance with applicable laws, regulations, mandatory administrative enforcement or judicial requirements, we may publicly disclose your personal information in accordance with the type of personal information requested and the manner of disclosure. Subject to laws and regulations, when we receive a request for disclosure of information as described above, we will require that the appropriate legal documents, such as a subpoena or letter of inquiry, must be produced in connection with it. We will also take measures to ensure transparency and carefully review requests to ensure legality and limit to proper data. 3. Transfer We will not transfer your personal information to any company, organization or individual, except for the following: - With your prior express consent or authorization. - Is provided in accordance with applicable laws and regulations, as required by legal process, or as necessary for mandatory administrative or judicial requirements. - Provided in accordance with the relevant agreements signed with you (including the electronic agreements signed online and the corresponding platform rules) or other legal documents agreed upon. - In the event of a merger, acquisition, asset transfer or similar transaction involving the transfer of personal information, we will require the new company or organization holding your personal information to continue to be bound by this Privacy Policy, otherwise, we will require the company or organization to seek your authorized consent again. VIII. Protection of Personal Information 1. Data Security Technical Measures We will adopt security measures in line with industry standards, including the establishment of reasonable institutional norms, security technology to prevent unauthorized access to your personal information use, modification, to avoid damage or loss of data. TOPUPlive's network services adopt encryption technologies such as transport layer security protocols and provide browsing services through https and other means to ensure the safety of user data in the transmission process. TOPUPlive adopts encryption technology to encrypt and save users' personal information and isolate it through segregation technology. When personal information is used, we will use a variety of data desensitization technologies including content replacement and SHA256 to enhance the security of personal information in use. TOPUPlive uses strict data access rights control and multiple authentication technologies to protect personal information and avoid data being used in violation. TOPUPlive uses automatic code security checks and data access log analysis technology for personal information security audits. TOPUPlive online services use encryption technologies such as Transport Layer Security (TLS) to protect your personal information during transmission. When TOPUPlive stores your personal data, we use computer systems with limited access rights, which are deployed in facilities that are protected by physical security measures. 2. Security Incident Handling When trading online goods or services with third parties through the TOPUPlive website, you will inevitably have to disclose your personal information, such as contact information or postal address, to the other party or potential counterparties to the transaction. Please protect your personal information properly and provide it to others only under necessary circumstances. TOPUPlive has developed a number of systems to address possible risks such as personal information leakage, destruction and loss, and to clarify the classification and grading standards for security events and security vulnerabilities and the corresponding handling processes. TOPUPlive has also established a dedicated emergency response team for security events, and in accordance with the requirements of the security event disposal specifications, initiates security plans for different security events to stop, analysis, positioning, developing remedial measures, and joint relevant departments to trace and combat. After the unfortunate occurrence of personal information security events, we will, in accordance with the requirements of laws and regulations, promptly inform you of: the basic situation of the security event and the possible impact, the disposal measures we have taken or will take, the suggestions you can independently prevent and reduce the risk, the remedial measures for you, etc. We will also promptly inform you of the event-related situation by email, letter, telephone, push notification, etc. When it is difficult to inform the subject of personal information one by one, we will take a reasonable and effective way to issue an announcement. At the same time, we will also take the initiative to report the disposal of personal information security incidents in accordance with the requirements of the regulatory authorities. If you have any questions about our personal information protection, you can contact us through the contact information agreed in this privacy policy. If you find that your personal information has been compromised, especially your account and password, please contact us immediately through the contact information agreed in this privacy policy so that we can take appropriate measures. VIII. Integrity and Retention of Personal Information VIII. Retention and Storage of Personal Information TOPUPlive provides convenient ways for you to ensure that your personal information is accurate, complete, and up-to-date. We will retain your personal information for as long as necessary to achieve the purposes described in this Privacy Policy, unless required or permitted by law to retain such information for a longer period. Your personal information will be stored within the Singapore. If you use a cross-border transaction service that requires the transfer of your personal information outside of Singapore to complete the transaction, we will separately obtain your authorized consent and require the recipient to handle such personal information in accordance with our instructions, this Privacy Policy, and any other relevant confidentiality and security measures. IX. Management of Personal Information #(1) Access, Correction Except as required by law or regulation, you have the right to access and correct your account personal information at any time to help us ensure that your contact and preference settings are accurate, complete and up to date. For other personal information we retain, we will provide you with access for any purpose, including requiring us to correct data if it is inaccurate, or to delete such data if TOPUPlive is not entitled to retain it under the law or for legitimate business purposes. We reserve the right to refuse to process insubstantial/entangling requests, requests that compromise the privacy of others, requests that are extremely impractical, and requests that do not require access to information under local law. #(2) Deletion You may request us to delete your personal information in the following cases: if we process personal information in violation of laws and regulations; if we collect and use your personal information without your consent; if we process personal information in violation of our agreement with you; or if we terminate our services and operations. If we decide to respond to your request for deletion, we will also notify the entities from which we obtained your personal information and request that they delete it promptly, unless otherwise required by law or regulation, or unless these entities have your independent authorization. If we respond to your request for deletion, we cannot guarantee that we will immediately delete the appropriate information from the backup system, but we will delete it when the backup system is updated. #(3) Change the Scope of Your Authorization Consent or Withdraw Your Authorization You may change the scope of your authorization for us to continue collecting personal information or withdraw your authorization by deleting information, turning off device features, making privacy settings in the TOPUPlive website or software, etc. Please understand that each business function requires some basic personal information in order to be completed, and when you withdraw your consent or authorization, we cannot continue to provide you with the services for which you have withdrawn your consent or authorization, and we will no longer process your corresponding personal information. However, your decision to withdraw your consent or authorization will not affect the processing of personal information previously carried out based on your authorization. #(4) Responding to Your Request If you are unable to access, correct or delete your personal information in the manner described above, or if you need to access, correct or delete other personal information generated by your use of our products and/or services, or if you believe that TOPUPlive has any violations of laws or regulations or agreements with you regarding the collection or use of personal information, you may send an email to TOPUPlive.com or contact us in any of the other ways described in this Privacy Policy. For security purposes, we may require you to provide a written request or provide documentation of your identity, and we will respond to your request within 15 days of receiving your feedback and verifying your identity. In principle, we do not charge a fee for your reasonable requests, but for repeated requests that exceed reasonable limits, we will charge a cost fee as appropriate. We may refuse requests that are unnecessarily repetitive, require excessive technical means (for example, requiring the development of a new system or a fundamental change in current practice), pose a risk to the legal rights of others, or are highly impractical (for example, involving the backup of information stored on tapes). We will not be able to respond to your request if required by law or regulation to do so in the following circumstances: - Related to national security or national defense security; - Related to public safety, public health, or significant public interests; - Related to crime investigation, prosecution and trial; - Where there is sufficient evidence of subjective malice or abuse of your rights; - Where responding to your request would result in serious damage to the legitimate rights and interests of you or other individuals or organizations; - Where commercial secrets are involved. X. Protection of Personal Information of Minors and Children #(1) General Requirement for Minors In e-commerce activities, we presume that you have the appropriate civil capacity. If you are a minor, we ask that you ask your parents or other guardians to read this privacy policy carefully and use our services or provide us with information with the consent of your parents or other guardians. TOPUPlive attaches great importance to the protection of personal information of minors. If you are a minor under the age of 18, you should obtain prior consent from your guardian before using our products and/or services. TOPUPlive protects the personal information of minors in accordance with the provisions of relevant national laws and regulations. #(2) Collection and Use of Minors' Information We do not actively collect personal information directly from minors. In the case of personal information collected from minors with the consent of their guardians, we will only use, share, transfer, or disclose this information when permitted by law, with the consent of the guardian, or as necessary to protect the minor. If there is evidence that a minor has registered to use our products and/or services without the consent of a guardian, we will consult with the relevant guardian and seek to delete the relevant personal information as soon as possible. If we identify you as a child user, we will notify your guardian and ask your guardian to agree to the rules for the collection and use of children's personal information. In cases where we collect personal information from children with the consent of their parents or other guardians to use our products or services, we will only use, share, transfer or disclose this information as permitted by law or regulation, as expressly agreed by the parents or other guardians, or as necessary to protect the child. #(3) Guardians' Responsibilities and Rights If you are a parent or other guardian of a child, please be concerned about whether the child in your custody is using our services with your authorized consent. We further take the following measures to safeguard the personal information of children under the age of 14 that may be involved. For children who use TOPUPlive products and services, we understand the importance of taking extra precautions to protect their privacy and security. Therefore, we do not knowingly collect, use or disclose personal information from children under the age of 14 (or a similar minimum age in the relevant jurisdiction) unless verifiable parental consent is received. If we discover that we have collected personal information from a child under the age of 14 (or similar minimum age in the relevant jurisdiction) without first receiving verifiable parental consent, we will take steps to delete such information as soon as possible. When you, as a guardian, choose to use TOPUPlive related services for your supervised children, we may need to collect personal information from you about your supervised children that is necessary to perform the related services to you. If we need to collect personal information from you for a specific service, we will obtain your prior authorized consent and inform you of the purpose and use of the collection. Children or their guardians have the right to access and correct children's personal information at any time, and may also make requests to us for correction and deletion. If you have any comments, suggestions or complaints or reports on matters related to children's personal information, please contact us. We will always be available to assist you. XI. Company-wide Commitment to Your Privacy To ensure the safety of your personal information, we have communicated our company-wide privacy and security guidelines to all TOPUPlive employees and have strictly enforced privacy safeguards within the company. XII. Privacy Issues If you have any questions or concerns about TOPUPlive's privacy policy or data processing, or would like to file a complaint about a possible violation of local privacy laws, please contact us. You may contact us at any time by calling the relevant TOPUPlive support phone number in your country/region. The content of all such communications is subject to investigation and, where appropriate, we will respond as soon as possible. If you are not satisfied with the response you receive, you may refer your complaint to the relevant regulatory body in your jurisdiction. If you make a request to us, we will endeavor to provide you with information regarding the relevant avenues of complaint that may apply to your situation. TOPUPlive may update its privacy policy at any time. If we make material changes to our privacy policy, we will post a notice on our website with the updated privacy policy. XIII. Service Providers TOPUPlive shares personal information with companies that provide services such as information processing, fulfilling customer orders, delivering products to you, managing and enhancing customer data, providing customer service, assessing your interest in our products and services, and conducting customer surveys or satisfaction surveys. These companies are obligated to protect your information and may be located in any location where TOPUPlive is engaged in business activities. XIV. Notices and Revisions to this Privacy Policy #1. General Update This Privacy Policy will be updated to provide you with better service and as TOPUPlive's business grows. However, we will not reduce your rights under this Privacy Policy without your express consent. We will issue updated versions through the TOPUPlive website, TOPUPlive mobile and remind you of the updates through website announcements or in other appropriate ways before they take effect, and please visit TOPUPlive to keep up to date with the latest privacy policy. #2. Material Changes For material changes, we will also provide more prominent notice (we will explain the specific changes to the Privacy Policy by means including, but not limited to, emails, text messages, or special instructions on browsing pages). Material changes to this Privacy Policy include, but are not limited to: - Significant changes in our service model. Such as the purpose of handling personal information, the type of personal information handled, the way personal information is used, etc. - Significant changes in our ownership structure, organizational structure, etc. Such as change of ownership caused by business restructuring, bankruptcy and merger, etc. - Changes in the primary recipients of personal information sharing, transfer or public disclosure. - Significant changes in your rights to participate in the processing of personal information and the manner in which they are exercised. - When there is a change in the department responsible for handling personal information security, our contact information and complaint channels. - When the personal information security impact assessment report indicates the existence of high risk. XV. Third Party Websites and Services TOPUPlive's websites, products, applications and services may contain links to third-party websites, products and services. Our products and services may also use or provide products or services from third parties. Information collected by third parties that may contain relevant account data or contact information, etc., is subject to the third party's rules regarding privacy. We want you to be aware of these third party privacy rules. XVI. How Your Information is Transferred Globally Personal information collected and generated in our operations in the Singapore is stored in Singapore, except for the following cases: 1. Explicitly provided for by applicable law. 2. Obtained your explicit authorization. 3. Your personal initiative such as cross-border transactions via the Internet. For the above cases, we will ensure that your personal information is adequately protected in accordance with this privacy policy. XVII. Other It may be necessary for TOPUPlive to disclose your personal information in accordance with the laws, legal proceedings, litigation and/or requirements of public agencies and government departments within or outside your country of residence. We may also disclose information about you if we determine that disclosure is necessary or appropriate in connection with national security, law enforcement, or other matters of public importance. To protect your personal information, we take reasonable precautions and follow industry best practices to ensure that it is not improperly lost, misused, accessed, disclosed, altered or destroyed. Communications with our website are conducted using Secure Sockets Layer (SSL) encryption technology. Through our use of SSL encryption, all information exchanged between you and our website is secure. We do not collect personal information about our users for the primary purpose of collecting it. We do not rent or sell this information to any third party. We will not use your personal information or images for advertising purposes without your consent.