Effective: December 18, 2018.
When you interact with us through the Services, we may collect information from you, as further described below:
Information You Provide: We collect information from you when you voluntarily provide such information, such as when you register for access to the Services or use certain Services. Information we collect may include but not be limited to Instagram username, email address, images or any other content associated to your account.
Top Nine may allow you to connect your Instagram profile to your Top Nine account. To connect your Instagram account, you will be redirected to Instagram.com to login and approve access to your account. The approval process takes place on Instagram.com, hence we do not have access to your Instagram password. You will be redirected to Top Nine after the process, in which case we will access certain information from Instagram regarding your account. In particular, we may collect profile image, display name, username / profile ID, access tokens, and published posts. This includes the content of your post and engagement data (such as likes, comments, as well as general engagement counts), to the extent permitted by the basic Instagram API. We do not have access to your list of followers, friends or contacts of your Instagram account. This data will only be used by Top Nine to provide you with the Service you expect and will not be shared with any third parties.
Data We Collect Automatically: When you interact with us through the Services, we receive and store certain information such as an IP address, device ID, and your activities within the Services. We may store such information or such information may be included in databases owned and maintained by affiliates, agents or service providers. The Services may use such information and pool it with other information to track, for example, the total number of visitors to our Site, as well as the sites which refer visitors to Top Nine.
In an ongoing effort to better understand and serve the users of the Services, we may conduct research on our customer demographics, interests and behavior based on the information collected. This research may be compiled and analyzed on an aggregate basis, and we may share this aggregate data with our affiliates, agents and business partners. We may also disclose aggregated user statistics in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes.
You may give us permission to collect your information in other services. For example, you may connect a social networking service (“SNS”) such as Instagram, Twitter or Facebook to your Top Nine account.
We may use third party web site analytic tools such as Google Analytics on our website that employ cookies to collect certain information concerning your use of our Services. However, you can disable cookies by changing your browser settings. Further information about the procedure to follow in order to disable cookies can be found on your Internet browser provider’s website via your help screen.
You may see our Service advertised in other applications or websites. After clicking on one of these advertisements and installing our Service, you will become a user of the Service. Advertising platforms, which include Twitter and Facebook (and whose SDKs are integrated within our Service), may collect information for optimizing advertising campaigns outside of the Service.
The Company is based in Uruguay. No matter where you are located, you consent to the processing and transferring of your information in and to Uruguay and other countries. The laws of Uruguay and other countries governing data collection and use may not be as comprehensive or protective as the laws of the country where you live.
The laws in some jurisdictions require companies to tell you about the legal ground they rely on to use or disclose your personal data. To the extent those laws apply, our legal grounds are as follows:
To honor our contractual commitments to you: Much of our processing of personal data is to meet our contractual obligations to our users, or to take steps at users’ request in anticipation of entering into a contract with them. For example, we handle personal data on this basis to create your account and provide our Services.
Legitimate interests: In many cases, we handle personal data on the ground that it furthers our legitimate interests in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals: This includes:
Providing a safe and enjoyable user experience;
Marketing, e.g. sending emails or other communications to let you know about new features;
Protecting our users, personnel, and property;
Analyzing and improving our business, e.g. collecting information about how you use our Services to optimize the design and placement of certain features;
Processing job applications;
Managing legal issues.
Legal compliance: We need to use and disclose personal data in certain ways to comply with our legal obligations.
To protect the vital interests of the individual or others: For example, we may collect or share personal data to help resolve an urgent medical situation.
Consent: Where required by law, and in some other cases, we handle personal data on the basis of your implied or express consent.
The Company is not in the business of selling your information. We consider this information to be a vital part of our relationship with you. There are, however, certain circumstances in which we may share your information with certain third parties, as set forth below:
As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, bankruptcy, dissolution or similar event, your information may be part of the transferred assets.
We may transfer your information with your consent.
Like many businesses, we sometimes hire other companies or individuals to perform certain business-related functions. Examples of such functions include mailing information, maintaining databases and processing payments.
We may disclose your information if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of the Company or Related Companies, (iii) protect the personal safety of users of the Services or the public, or (iv) protect against legal liability.
We may also share aggregated or non-personally identifiable information with our partners or others for business purposes.
You may provide us with ideas for new products or modifications to existing products, and other unsolicited submissions (collectively, “Unsolicited Information”). All Unsolicited Information shall be deemed to be non-confidential and we shall be free to reproduce, use, disclose, and distribute such Unsolicited Information to others without limitation or attribution.
Our Services are for users age 13 and over and we do not knowingly collect personal information from children under the age of 13. If you are a parent or guardian of a child under the age of 13 and believe he or she has disclosed personal information to us please contact us at email@example.com. For residents of the EEA, where processing of personal information is based on consent, Top Nine will not knowingly engage in that processing for users under the age of consent established by applicable data protection law. If we learn that we are engaged in that processing with such users, we will halt such processing and will take reasonable measures to promptly remove applicable information from our records.
We generally retain personal data for so long as it may be relevant to the purposes identified herein. To dispose of personal data, we may anonymize it, delete it or take other appropriate steps. Data may persist in copies made for backup and business continuity purposes for additional time.
We take reasonable steps to protect the information provided via the Services from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or email transmission is ever fully secure or error free. In particular, email sent to or from the Services may not be secure. Therefore, you should take special care in deciding what information you send to us via email. Please keep this in mind when disclosing any information via the Internet.
We believe that users should be treated equally no matter where they are, and so we are giving you the option to delete all the data we have associated with your email address.
You can request to delete any data associated with your email at https://topnine.co/forget-me