Terms of Service
Updated Date: April 3, 2025
**Introduction**
The website named "Topinx", client applications, and other forms we may provide from time to time (collectively, the "Topinx Platform") are legally owned and operated by **TOPINX, INC.** (hereinafter referred to as "Topinx Company" or "We"), with our registered address at **DOVER, KENT, DE, 8 THE GREEN**. The term "Our" shall be construed accordingly. For clarity, We reserve all rights to adjust the name of the Topinx Platform.
The term "User" or "You" refers to any individual using the Topinx Platform. The term "Your" shall be construed accordingly.
In this Policy, We describe Our practices for collecting, using, and disclosing personal information in accordance with relevant laws, regulations, and technical standards, and further explain Your rights regarding Your personal information.
This Policy is closely related to Your use of Our Topinx Platform services. When You download, install, launch, browse, register, log in to, or use Our Topinx Platform services, We will process and protect Your personal information in accordance with the terms herein. The term "Topinx Platform services" carries the meaning defined in the **Topinx User Service Agreement**.
If You are under the age of 18 or under the minimum age required to use the Topinx Platform in Your jurisdiction, or if You otherwise lack the legal capacity required to engage in user activities, You must (A) refrain from using the Topinx Platform, or (B) read this Policy under the supervision and guidance of a legal guardian ("Guardian") and use the Topinx Platform only after ensuring the Guardian's consent to this Policy, if required by applicable laws.
Before using or continuing to use Our Topinx Platform services, please read this Policy carefully and thoroughly. Where necessary, make appropriate choices in accordance with the guidance herein. If You choose not to provide specific personal information to Us, it may result in Our inability to provide You with the Topinx Platform services, restrict Your use of the services, or prevent Us from achieving the intended service outcomes.
Table of Contents
1. How We Collect and Use Your Personal Information
2. How We Share, Transfer, or Disclose Your Personal Information
3. How We Store and Protect Your Personal Information
4. How You Can Manage Your Personal Information
5. How to Delete Your Account
6. Special Notes on Third-Party Products and/or Services
7. How We Use Cookies and Similar Technologies
8. Protection of Minors
9. How We Update This Privacy Policy
10. How to Contact Us
11. Miscellaneous
12. EEA+ Supplemental Privacy Statement
13. Supplemental Privacy Statements for Virginia, Colorado, Connecticut, Utah, Oregon, Texas, Montana, Delaware, Iowa, Nebraska, New Hampshire, New Jersey, or California
1. How We Collect and Use Your Personal Information
Topinx Platform is a lifestyle platform for young people, dedicated to helping users "discover what’s new around them." Users can record daily moments, share lifestyles through short videos, images, texts, and interact with others based on shared interests. In this Policy, we will explain the scope of personal information that each feature of our products and/or services may collect, the purposes and methods of collection, and the potential consequences of not providing such information. Please note that even if you choose not to provide specific information required for certain features, you may still use other functionalities of the Topinx Platform.
We adhere to the principles of **lawfulness, legitimacy, and necessity** when collecting and using personal information you voluntarily provide or generate through your use of our products and/or services, solely for the purposes outlined in this Policy. If we intend to use your personal information for purposes not stated herein, or to repurpose collected information for new objectives, we will notify you in a reasonable manner and obtain your explicit consent prior to such use.
1. Account Registration and Login
1.1 "Topinx Account"
A "Topinx Account" (or "Account") refers to the account you may need to register to use the Topinx Platform. When registering or logging in:
- If you use the one-tap login feature (based on our partnership with telecom operators), we collect your [mobile number and telecom carrier information]** to provide seamless login services.
- To complete registration, we also collect your **[gender]** and **[age]** to deliver initial platform services. You may click **[Skip]** in the top-right corner of the collection page if you prefer not to provide this information.
1.2 Third-Party Account Login
If you log in via a third-party account (e.g., social media), to comply with **internet real-name verification requirements**, we will collect your mobile number separately when you use features requiring real-name authentication (e.g., posting, commenting). Please carefully consider providing this information. **Refusal may restrict access to certain functionalities.
1.3 Optional Profile Customization
You may voluntarily add or update your profile photo, name, gender, birthday, region, or bio. Failure to provide such details **will not affect your access to core platform services.
1.4 Public Profile Display
Upon successful registration, your name, profile photo, region, and bio will be visible to other users on the Topinx Platform.
2. Providing Products and/or Services
2.1 Content Browsing, Posting, Liking, Saving, and Sharing
2.1.1
To deliver our core content display services and recommend notes or content aligned with your interests, we collect:
- Your **profile information** (e.g., gender, birthday).
- **Usage data**, including browsing history (e.g., follows, views), click interactions (e.g., interests, clicks, searches, likes, saves, shares, comments, posts, and related actions).
2.1.2
When creating or editing content, we request permissions for:
- **Storage(photos, media, files).
- **Camera（to capture images/videos).
- **Microphone** (to record audio).
**Refusing these permissions will disable specific features but will not affect your use of other Topinx Platform functionalities.**
We use your authorized **geolocation data** to tag your posts with your location and recommend your content to nearby users.
2.1.3
Text, photos, videos, audio, comments, likes, saves, and shares you publish are stored on our servers in **encrypted form**, as storage is essential for these features. You may delete this content at any time.
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2.2 Security and Risk Control Verification
To ensure secure operations, prevent unauthorized access, and protect against fraud, we collect:
Device information
- Hardware model, device name, SIM card serial number (ICCID), hardware serial number (SN), unique identifiers (IMEI, IMSI, Android ID, IDFA, MEID, OAID for Harmony OS/Android).
- Running processes, browser type/settings, language, sensors, OS version, app version, installed apps.
- Network details: MAC address, WLAN access points (SSID/BSSID), IP address, Bluetooth address, network type/quality, cellular data (e.g., carrier name).
- Device sensor data (accelerometer, gyroscope).
**Refusal to provide this information may prevent risk control verification.**
To monitor account security, we periodically check if the app runs in the foreground/background.
2.3 Search Functionality
When using the search feature, we analyze:
- Search queries (text or images).
- Viewing history, timestamps, comments, and interactions.
This data improves content relevance and service quality.
2.4 Location-Based Services
With your consent, we collect geolocation data to deliver location-specific content. You may disable location services in your device settings, but this will not affect other functionalities. We may also infer your city via IP address or authorized data.
2.5 Interactive Features
2.5.1
When you follow accounts, browse, comment, like, save, or share content:
- We display content from accounts you follow.
- Your likes/saves may be shown to your followers unless set to **"Private"** under My > Privacy Settings.
2.5.2
Using QR codes to add friends requires **camera permission**. Denying this only restricts QR-based friend additions.
2.6 Push Notifications
To maintain real-time communication and deliver personalized content:
- We request **startup broadcast permissions** to launch the app.
- Use third-party push services to assign a unique **device ID**.
- Check app status (foreground/background) to optimize notification timing.
2.7 Personalized Content
To tailor recommendations, we analyze:
- Search, playback, and content interaction history.
- Profile details (gender, age, birthday).
2.8 Clipboard Access
When sharing or receiving invites/links, we access your clipboard to enable:
- Redirects, shared content, or event coordination.
Data is used solely for these purposes.
2. How We Share, Transfer, or Disclose Your Personal Information**
1. Sharing
We will **not** share your personal information with any third-party companies, organizations, or individuals unless one or more of the following conditions apply:
1. **With Your Prior Authorization**
2. At Your Explicit Request**
3. **Necessary Collaboration with Business Partners**
To enhance our services, we may authorize partners to provide specific functionalities. In such cases, we may share **necessary personal information** with partners strictly for lawful, legitimate, specific, and clear purposes. We conduct security assessments on data formats, transfers, and usage to ensure safety. Partners are rigorously monitored, and any mishandling of data will result in immediate termination of cooperation and legal action.
Our partners include:
- **A. Advertising and Analytics Partners**: We share **de-identified device or statistical data** (e.g., aggregated trends) to improve ad relevance. All partners are bound by strict data confidentiality agreements.
- **B. Content Moderation Providers**: Third-party moderators may review content you post on Topinx to ensure platform safety.
- **C. Marketing Partners**: We may share **indirect user profiles** (non-identifiable) to optimize ad targeting, but never personally identifiable information without your consent.
- **D. Third-Party SDK Providers**:
- **a. Push Notifications**: SDKs may collect device details, location, and network data (including background access) to deliver tailored notifications.
- **b. Geolocation Services**: SDKs collect device and location data for content recommendations or delivery address setup.
- **c. Cloud Storage**: Third-party providers store your uploaded media and collect device/network data.
- **d. Account Security**: SDKs monitor device, network, and log data to prevent fraud.
4. **Marketing Events**: If you participate in third-party campaigns, we may share sensitive data (e.g., name, bank details) **only with your consent**.
5. **Affiliate Sharing**: We may share necessary data with affiliated companies, who must adhere to this Policy.
6. **Legal Compliance**: Required by applicable laws or regulations.
7. **Your Voluntary Sharing**: You may share your data publicly via Topinx, but we are not liable for consequences of such actions.
2. Transfer
We will **not** transfer your personal information to any third party without your explicit consent, except in the following cases:
1. **With Your Consent**
2. **Corporate Restructuring**: In mergers, acquisitions, or bankruptcy, we will notify you of the transferee’s details and ensure they comply with this Policy.
3. **Legal Obligations**: As required by law.
3. Public Disclosure
We will **not** publicly disclose your personal information unless:
1. **Anonymized Data: For scenarios like contest winners or penalty notices (with sensitive details removed).
2. **With Your Explicit Consent.
4. Exceptions to Consent Requirements
Under applicable laws, we may share, transfer, or disclose your data **without consent** in these cases:
1. **Contract Fulfillment**: Necessary to perform a contract you are party to.
2. **Legal Duties**: To comply with statutory obligations.
3. **Public Health or Safety Emergencies**: To protect life, health, or property.
4. **Public Interest**: For news reporting or public oversight within reasonable bounds.
5. **Other Legally Permitted Scenarios**.
4. How You Can Manage Your Personal Information
We highly value and strive to protect your rights regarding your personal information.
1. Control Over Information Receipt
Content displayed in your feed is based on accounts you **actively choose to follow**. You may **follow or unfollow** accounts at any time according to your preferences.
2. Access, Obtain, Correct, or Delete Your Information
Through intuitive interface design, we provide self-service tools for managing your personal information:
1. **Profile Management**
- Navigate to **[Me > Edit Profile]** to access, update, or delete your **profile details**, including:
- Profile photo, nickname, gender, bio.
2. **Account Security Settings**
- Go to **[Me > Settings > Account & Security]** to:
- View, modify, or reset your **mobile number** and **password**.
3. **Privacy Controls**
- Under **[Me > Settings > Privacy Settings]**, adjust:
- Comment permissions, @ mentions, contact recommendations, location sharing, and block lists.
4. **Content Management**
- Access **[Me > Notes/Collections/Likes]** to review, edit, or delete your posts, saved content, or likes.
**Additional Deletion Rights**
We will proactively delete your personal information, or you may request deletion, in the following cases:
1. The purpose of processing has been fulfilled, is no longer achievable, or is unnecessary.
2. Services are discontinued, or the retention period has expired.
3. You explicitly withdraw consent.
4. We violate laws, regulations, or agreements in handling your information.
5. Other scenarios required by law.
3. Modify or Withdraw Permissions
You may adjust or revoke permissions for:
- **Microphone (audio recording)**
- **Notifications**
- **Network access**
- **Camera**
- **Geolocation**
- **Storage (photos, media, files)**
- **Phone status**
4. Contact Us for Assistance
For security and identity verification reasons, some information cannot be directly modified or deleted via the platform interface. To request access, corrections, or deletions of such data:
- Email us at the address provided in **Section 10 ("How to Contact Us")** of this Policy.
- We will review your request promptly and respond after verifying your identity.
5. How to Delete Your Account
You may delete your account by navigating to **[Me > Settings > Account & Security > Delete Account]** and selecting **[Request Account Deletion]**, provided all deletion conditions are met. We will process your request within **seven (7) business days** after verifying your identity. Upon deletion, your personal information will be removed from the Topinx Platform, except where legally required to retain specific data (e.g., transaction records).
6. Special Notes on Third-Party Products and/or Services
The Topinx Platform may integrate or link to third-party products, services, or information. Before using such services:
- You may be redirected to **mini-programs** or third-party pages.
- Your use of third-party services (including any personal information you provide) is governed by **their terms and privacy policies**, not this Policy. Review their policies carefully before proceeding.
- We are not responsible for third-party data practices. Protect your information and share it judiciously.
7. How We Use Cookies and Similar Technologies
Cookies
1. **Purpose**:
- If you accept cookies, Topinx places/accesses cookies on your devices to enable login and personalized services (e.g., targeted promotions).
2. **Control**:
- You may **accept or block cookies** via browser or device settings.
- **Note**: Blocking cookies may restrict access to certain platform features.
3. **Policy Alignment**:
- Data obtained through cookies is handled per this Policy.
8. Protection of Minors
1. If you are below the minimum age required to use the Topinx Platform in your jurisdiction, or lack the legal capacity to engage in user activities, you must:
- **(A)** Refrain from using the Topinx Platform; or
- **(B)** Review this Policy under the guidance of a parent or legal guardian ("Guardian") and use the Platform only after obtaining their explicit consent, where required by applicable laws.
2. We prioritize the protection of minors’ personal information. Minor users are advised to exercise caution when providing personal data and to use the Topinx Platform under parental supervision.
3. We comply with applicable laws to safeguard the confidentiality and security of minors’ information. If we discover that we have collected a minor’s personal data without verifiable parental consent, we will promptly delete it or take legally compliant corrective actions. For details, review the **Topinx Minor Personal Information Protection Guidelines**. Guardians with concerns about a minor’s use of our services may contact us via the methods outlined in **Section 10.
9. How We Update This Privacy Policy
1. To improve our services, we may update this Policy in response to product changes or legal requirements. Updates will become part of this Policy and will not reduce your rights under the current version without your explicit consent.
2. You will be notified of updates through **in-app notifications** or other reasonable means.
10. How to Contact Us
For complaints, suggestions, or questions regarding personal information protection or this Policy, contact us at:
**Email:** [topinxconnect@topinx.com](mailto:topinxconnect@topinx.com)
We will review your inquiry and respond within **15 business days** after verifying your identity.
11. Miscellaneous
1. Any disputes arising from this Policy or our handling of your personal information shall be resolved by the courts in **Dover, Kent, DE, USA** (our registered jurisdiction).
2. If you believe our data practices infringe your rights, you may report to relevant governmental authorities.
12. EEA+ Supplemental Privacy Statement
If you are located in the European Economic Area (EEA), the United Kingdom, or Switzerland (collectively, “EEA+”), this Supplemental Privacy Statement applies to you. This document supplements the **Topinx Privacy Policy** and outlines how we process your personal data when you use or interact with our products and/or services. In case of conflict between the Topinx Privacy Policy and this Statement, this Statement prevails.
**1. Applicable Laws**
- **EEA**: Processing of your personal data complies with the EU **General Data Protection Regulation (GDPR)** and local data protection laws.
- **UK**: Processing complies with the UK GDPR.
- **Switzerland**: Processing complies with the Swiss **Federal Data Protection Act (FDPA)**. References to the GDPR below apply analogously to the FDPA.
**2. Data Controller**
The data controller is TOPINX, INC., with its registered address at **DOVER, KENT, DE, 8 THE GREEN**.
To contact our GDPR representative for the EEA/UK, email [topinxconnect@topinx.com].
**3. Legal Bases for Processing**
We rely on the following legal bases under GDPR Article 6:
- **Contractual Necessity (Art. 6(1)(b))**: To fulfill obligations under a contract with you.
- **Legal Obligations (Art. 6(1)(c))**: To comply with EEA/UK laws.
- **Legitimate Interests (Art. 6(1)(f))**: To provide services securely, improve our business, manage user relationships, and ensure compliance.
- **Consent (Art. 6(1)(a))**: For non-essential cookies or specific data uses. Withdraw consent via in-app settings or email.
**4. Data Recipients & Cross-Border Transfers**
- Personal data may be disclosed to third parties in **Chicago** and other locations.
- Transfers outside the EEA+/UK are safeguarded by adequacy decisions, Standard Contractual Clauses (SCCs), or Binding Corporate Rules (BCRs).
**5. Retention Period**
We retain personal data only as long as necessary for its purpose or to meet legal obligations (e.g., tax, audit). Data is anonymized or deleted afterward.
**6. Your Rights Under GDPR/FDPA**
You have the right to:
- **Object** to processing (including direct marketing).
- **Access**, **rectify**, or **delete** your data.
- **Restrict processing** or request **data portability**.
- **Withdraw consent** (future effect only).
- **Lodge complaints** with supervisory authorities (links provided below).
- **Provide posthumous instructions** (applicable in France/Portugal).
**Supervisory Authorities**:
- EEA: [EDPB Members](https://edpb.europa.eu/about-edpb/about-edpb/members_en)
- UK: [ICO](https://ico.org.uk/global/contact-us/)
-Switzerland:[FDPIC](https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html)
**7. Exercising Your Rights**
Submit requests to **[topinxconnect@topinx.com]**. Include:
- The specific right(s) you wish to exercise.
- Details to verify your identity (security measure).
**8. Provision of Personal Data**
While voluntary, certain data is **required** to access our services. Refusal may limit functionality.
13. Supplemental Privacy Statements for Virginia, Colorado, Connecticut, Utah, Oregon, Texas, Montana, Delaware, Iowa, Nebraska, New Hampshire, New Jersey, or California
If you reside in **Virginia, Colorado, Connecticut, Utah, Oregon, Texas, Montana, Delaware, Iowa, Nebraska, New Hampshire, New Jersey, or California**, this Supplemental Privacy Statement applies to you.
**For Virginia, Colorado, Connecticut, Utah, Oregon, Texas, Montana, Delaware, Iowa, Nebraska, New Hampshire, and New Jersey Residents**
Under applicable laws, you have the right to:
1. **Confirm** whether we process your personal data and request a copy.
2. **Correct** inaccuracies in your data (*not available in Iowa and Utah*).
3. **Delete** personal data you provided or related to you.
4. **Opt out** of processing for:
- (i) Targeted advertising.
- (ii) The "sale" of personal data.
- (iii) Profiling for decisions with legal or significant effects.
**Targeted Advertising**:
We may collect and use your **device information, browsing data, and purchase history** for targeted ads (as described in Section 1.2.16). Certain laws classify this activity as a "sale" of personal data.
**To opt out**:
1. Navigate to **[☰ > Settings > Privacy Settings > Programmatic Ads]**.
2. Toggle off **Programmatic Ad Recommendations**.
### **For California Residents**
**Collection Notice**:
The categories of personal information we collect (as defined by the **California Consumer Privacy Act (CCPA)**) include:
- **(A) Identifiers**: Name, address, phone number, IP address, email, account name.
- **(B) Personal Records**: Information linked or linkable to you.
- **(D) Commercial Data**: Purchase history, product interests.
- **(F) Internet Activity**: Browsing and usage data.
- **(G) Geolocation**: General location data.
- **(H) Sensory Data**: Audio, visual, or similar information.
- **(K) Inferences**: Preferences and characteristics derived from data.
- **(L)(C) Precise Geolocation**: Exact coordinates.
**Use and Disclosure**:
We may "sell" or "share" personal data (e.g., device info, browsing history) with ad networks for cross-context behavioral advertising.
#### **CCPA Privacy Policy**
**A. Right to Know**
Request details about the personal information we collect, use, disclose, or sell. Submit a **"California Knowledge Request"** to [topinxconnect@topinx.com].
**B. Data Practices (Past 12 Months)**
We collected and disclosed the categories above as outlined in Sections 1 and 2.
**C. Right to Delete**
Request deletion of your personal information via email with the subject **"California Deletion Request"**.
**D. Right to Opt Out of Sale/Sharing**
Opt out via **[☰ > Settings > Privacy Settings > Programmatic Ads]** or email [topinxconnect@topinx.com].
**E. Non-Discrimination**
Exercising CCPA rights will not result in discrimination.
**F. Verification and Authorized Agents**
- **Identity Verification**: Required for all requests.
- **Authorized Agents**: Must submit a notarized authorization letter to our address below.
**G. Contact Information**
Email: [topinxconnect@topinx.com]
Mail: **TOPINX, INC., DOVER, KENT, DE, 8 THE GREEN**