Introduction
Welcome to the Top, Inc. (doing business as Downtime Dollars) Privacy Policy. At Downtime Dollars, we prioritize your privacy and are committed to protecting your personal information. This policy outlines how we collect, use, disclose, and safeguard your data when you use our Downtime Dollars application. Please read this policy carefully to understand our practices regarding your personal information.
We will not use, collect, or share your information with anyone except as described in this Privacy Policy. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined, terms used in this Privacy Policy have the same meanings as in our Terms and Conditions.
During app use, you may be asked to provide certain personally identifiable information that can be used to contact or identify you. Personally identifiable information collected by Top, Inc. (doing business as Downtime Dollars) may include, but is not limited to, your phone number, name, or email ("Personal Information"). We collect this information for the purpose of identifying and communicating with you, including delivery of value earned in the app, as well as responding to your requests/inquiries and improving our app services. Any collection or use of your personal information for this purpose will be with your express consent. Some features of the Services enable us to customize your experience or receive offers based on your location. If you decline to provide location information, or if, in our judgment, we cannot verify your location, you will be unable to utilize some features of these services.
We value your privacy. This information will not be sold, shared, or used in any way outside of the standard operation of the application.
Service and Content Providers
Additionally, Top, Inc. (doing business as Downtime Dollars) works with certain third-party companies or services to facilitate our Service to users of the Top, Inc. (doing business as Downtime Dollars) app and/or assist us in analyzing how our Service is used. These partnerships are in two specific areas:
Service partnerships for Tracking: We may use third-party services that collect, monitor, and analyze this type of information in order to increase our Service's functionality. These third-party service providers have their own privacy policies addressing how they use such information.
Ad Delivery: Videos served for purposes of entertainment and/or value accrual in the Top, Inc. (doing business as Downtime Dollars) app may be supplied by unaffiliated third-party networks or companies. In these cases, our Services may be linked to properties operated to deliver ads or other engagements.
Survey Serving Technology: In order to provide survey earnings opportunities, Top, Inc. (doing business as Downtime Dollars) uses third-party survey providers, currently Pollfish, Tap Research, inBrain, and Theorem Reach. These services provide an online survey platform through which surveys from various research partners are conducted and made available to publisher partners like Top, Inc. (doing business as Downtime Dollars). In order to serve our users with these third-party survey opportunities, specific sets of device data (including Advertising ID which may be processed by providers only in strict compliance with App store policies) and response metadata (including information about the apps which the user may have installed) will be automatically sent to survey servers, allowing them to discern whether or not you are eligible for a survey.
For a full list of data received by survey providers through this app, please read third-party respondent terms carefully:
Pollfish: Privacy Policy
Tap Research:Privacy Policy
InBrain:Terms of Service,Privacy Policy
Theorem Reach:Terms of Service,Privacy Policy
Log Data
When you access the Service by or through a mobile device, we may collect certain information automatically, including the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, and other device statistics ("Log Data").
Account Expiration & Data Retention
Top, Inc. (doing business as Downtime Dollars) user account information and provided in-app response data are stored on Top, Inc. (doing business as Downtime Dollars) servers and accessible for as long as the account remains active. Active accounts are defined as accounts that are currently being used or have been inactive for less than 6 months (180 calendar days). For any account not in use for a continuous 180 days, Top, Inc. (doing business as Downtime Dollars) will disable the account and delete the user data and all related personal information. Top, Inc. (doing business as Downtime Dollars) will retain anonymized, aggregated user response data for purposes of analysis. We may share data with or allow third parties to collect data from our application(s) in order for the contracted service to be completed. In the event that data is captured or shared between Top, Inc. (doing business as Downtime Dollars) and an outside organization, we withhold any personally identifiable information unless this information is required in order to perform the services rendered. Third parties may collect data associated with the user's advertiser ID, device opt-out status, and user-reported answers to their survey questions in order to increase the relevance of ads or content provided by third party to each user. Information collected will not be retained in production systems for more than thirty months from the date you last interacted with one of the third-party ads, unless a longer retention period is required by law. We may retain backup information on our servers for up to three years for fraud detection, to enforce our legal rights, or to comply with applicable law or our internal security policies.
Business Transaction
If Top, Inc. is involved in a merger, acquisition, or asset sale, your Personal Information may be transferred as a business asset. In such cases, we will provide notice before your Personal Information is transferred and/or becomes subject to a different Privacy Policy.
Security
The security of your Personal Information is important to us, and we strive to implement and maintain reasonable, commercially acceptable security procedures and practices appropriate to the nature of the information we store, in order to protect it from unauthorized access, destruction, use, modification, or disclosure. However, please be aware that no method of transmission over the Internet or method of electronic storage is 100% secure and we are unable to guarantee the absolute security of the Personal Information we have collected from you.
International Transfer
Your information, including Personal Information, may be transferred to and maintained on computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those from your jurisdiction. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
Children's Privacy
Only persons age 13 or older have permission to access our Service. Our Service does not address anyone under the age of 13 ("Children") and an app age gate has been added to ensure only persons 13 or older can use our Service. We do not knowingly collect personally identifiable information from children under 13. If you are a parent or guardian and you learn that your Children have provided us with Personal Information, please contact us. If we become aware that we have collected Personal Information from children under age 13 without verification of parental consent, we take steps to remove that information from our servers.
For California, Colorado, Connecticut, Oregon, Texas, and Virginia Consumers
Effective date: June 6, 2024 Top, Inc. (doing business as Downtime Dollars) provides this State Privacy Rights and California Notice at Collection (the "State Specific Privacy Notice") to supplement the information contained in the Top, Inc. (doing business as Downtime Dollars) Privacy Policy. This State Specific Privacy Notice sets forth our privacy practices and your privacy rights as required by the California Consumer Privacy Act of 2018 ("CCPA") and privacy laws in Colorado, Connecticut, Oregon, Texas, and Virginia (collectively “State Privacy Laws”). The State Specific Privacy Notice applies only to individuals residing in California, Colorado, Connecticut, Oregon, Texas, and Virginia who are considered "Consumers" and from whom we collect "Personal Information" under applicable State Privacy Laws.
California Notice at Collection
Collection and Use of Personal Information
We may collect Personal Information from you in a variety of different situations, including, but not limited to, on our website, your mobile device, through voluntary surveys, through email, through the mail, and/or over the telephone. More specifically, Top, Inc. (doing business as Downtime Dollars) collects the following categories of Personal Information from its Consumers, which will depend on the particular Business Purpose for which we collect it:
Identifiers: A real name, user name, mobile phone number, mobile device ID, email address.
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)): A name, email address, telephone number, date of birth, gender
Protected classification characteristics under California or federal law:Age, date of birth, gender, and other information described in the sensitive personal information section below.
Commercial Information: Products or services purchased.
Biometric Information: None.
Internet or other similar network activity: None.
Geolocation data: Physical location or movements.
Sensory data: None.
Professional or employment-related information: None.
Education Information as defined by the Family Educational Rights and Privacy Act: None.
Inferences drawn from other personal information: Profile reflecting a person’s preferences, characteristics resulting or relating to points acquired and Rewards redeemed.
Sensitive Information Account log-in; password or credentials allowing access to account; precise geolocation. Racial or ethnic origin, religious or philosophical beliefs; contents of consumer’s mail, email, and text messages unless business is the intended recipient; consumer health information; information collected and analyzed concerning a consumer’s sex life or sexual orientation collected as part of voluntary surveys or as further explained below in the Sensitive Personal Information section. Personal information does not include deidentified or aggregated consumer information.
Sources of Personal Information
Top, Inc. (doing business as Downtime Dollars) obtains the categories of Personal Information listed above from the following categories of sources:
Directly from you. For example, from forms you complete or products and services you purchase.
Indirectly from you. For example, from observing your actions on our website or from information your computer or mobile device transmits when interacting with our website or mobile applications, among other things.
How We Use Personal Information
We may use the Personal Information we collect from you or about you for the following business purposes:
To act in accordance with your direction. For example, where you intentionally interact with our program and direct Top, Inc. (doing business as Downtime Dollars) to share personal information, we use your personal information in accordance with your direction and share your personal information you provide to us by registering and earning rewards with all our participating brands, regardless of your actual interaction with each. In addition, by uploading receipts, participating in Challenges or taking Surveys offered by participating brands, you are using Top, Inc. (doing business as Downtime Dollars) to intentionally interact with all our participating brands who provide points in our Program.
To fulfill or meet the purpose for which you provided the information. For example, if you provide your personal information to become a member, scan receipts, make a payment or redeem a reward, we will use that information to provide you member benefits or process your transaction.
To determine whether you are an eligible age or meet other qualifications to purchase certain products or services.
To contact you and to inform you about products, services, promotions, special offers, and/or events that may interest you.
To inform you about rewards you have redeemed, products and services you have purchased from us.
To create, maintain, customize, and secure your account with us, including to determine the language to use for products, services, and communications.
To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
As part of a voluntary survey to better understand our members, products, and/or services.
If you provide your information in the context of an employment application or your employment, we will use your information to serve those purposes.
To personalize your App or Website experience and to deliver content and product and service offerings relevant to your interests, including customized offers and ads through our website, mobile applications (including informing you about opportunities to purchase products from nearby stores to earn Rewards), third-party sites, and via email or text message (with your consent, where required by law).
To help maintain the safety, security, and integrity of our App or Website, products and services, databases and other technology assets, and business, and to prevent fraud.
For research, analysis, and business development, including to develop and improve our Website, products, and services.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
As described to you when collecting your personal information or subsequently agreed to by you.
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Top, Inc. (doing business as Downtime Dollars) assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Top, Inc. (doing business as Downtime Dollars) about our Consumers is among the assets transferred.
How We Disclose Personal Information
Top, Inc. (doing business as Downtime Dollars) may disclose your Personal Information to a third party for a business purpose, including to our service providers. We disclose your personal information with the following categories of third parties:
Service providers.
Third parties with whom you intentionally interact through our program or direct us to share your personal information, including our participating brands.
Disclosures of Personal Information for a Business Purpose
In the preceding twelve (12) months, Top, Inc. (doing business as Downtime Dollars) has disclosed the following categories of personal information for a business purpose to the following recipients:
Identifiers: Service providers such as web hosting and internet service providers; information technology, customer service, cloud service, data analytics, marketing, and advertising service providers. Contractors that provide us payment processing services and fraud detection. Business such as our participating brands to whom you direct us to share Personal Information or with whom you intentionally interact through our Program.
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)): Service providers such as web hosting and internet service providers; information technology, customer service, cloud service, data analytics, marketing, and advertising service providers. Contractors that provide us payment processing services and fraud detection. Business such as our participating brands to whom you direct us to share Personal Information or with whom you intentionally interact through our Program.
Protected classification characteristics under California or federal law:Service providers such as web hosting and internet service providers; information technology, and cloud service providers. Contractors that provide us payment processing services and fraud detection. Business such as our participating brands to whom you direct us to share Personal Information or with whom you intentionally interact through our Program.
Commercial InformationService providers such as web hosting and internet service providers; information technology, customer service, cloud service, data analytics, marketing, and advertising service providers. Contractors that provide us payment processing services and fraud detection. Business such as our participating brands to whom you direct us to share Personal Information or with whom you intentionally interact through our Program.
Internet or other similar network activity: Service providers such as web hosting and internet service providers; information technology, customer service, cloud service, data analytics, marketing, and advertising service providers.
Geolocation: Service providers such as web hosting and internet service providers; information technology, customer service, cloud service, data analytics, marketing, and advertising service providers.
Sensitive Information:Service providers such as web hosting and internet service providers; information technology, customer service, cloud service, data analytics, marketing, and advertising service providers. Business such as our participating brands to whom you direct us to share Personal Information or with whom you intentionally interact through our Program.
Sales of Personal Information
In the preceding twelve (12) months, Company has not sold personal information.
Sensitive Personal Information
Top, Inc. (doing business as Downtime Dollars) does not use or disclose sensitive personal information for purposes other than to perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services or as directed by a consumer and other purposes allowed by applicable law that do not include creating customer profiles, which include to resist deceptive, fraudulent, and illegal actions directed at Top, Inc. (doing business as Downtime Dollars); for short-term, transient use, including, but not limited to, nonpersonalized advertising shown as part of a consumer’s current interaction with Top, Inc. (doing business as Downtime Dollars), which is not used to build a consumer profile; to maintain or service accounts, provide customer service, process or fulfill orders and transactions, and verify customer information; and to improve, upgrade, or enhance our products or services. To the extent Top, Inc. (doing business as Downtime Dollars) collects sensitive personal information, it does not use that information to infer characteristics about you.
Notice of Financial Incentive
Under the CCPA, because your participation in our Program enables you to earn points, it is considered a financial incentive program. In order to provide you points, you direct us to use and share the personal information you provide when you register along with your activity information with all our participating brands so that you can interact with them and earn points. The value you receive in participating in our Program is calculated by and depends on the amount and nature of your interaction with our participating brands to obtain points. Points do not have monetary value, but each point can generally be redeemed for approximately $0.001 in rewards, but this may vary from time to time. Note that participation in Top, Inc. (doing business as Downtime Dollars) Rewards is completely voluntary and you can withdraw or opt-out at any time. For further details of the Program and its terms, including how to withdraw or terminate your participation, please refer to our Terms of Service.
Your State Consumer Privacy Rights and Choices
Subject to certain limitations, you have the right to (1) request to know more about the categories and specific pieces of Personal Information we collect, use, disclose, and sell, and to access your information, (2) request deletion of your Personal Information, (3) request correction of your Personal Information and (4) not be discriminated against for exercising these rights, (5) limit processing of Sensitive Personal Information.
Access to Specific Information and Data Portability Rights
You have the right to request that Top, Inc. (doing business as Downtime Dollars) disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Your Privacy Rights), we will disclose to you:
The categories of Personal Information we collected about you.
The categories of sources for the Personal Information we collected about you.
Our business or commercial purpose for collecting that Personal Information.
The categories of third parties with whom we disclose that Personal Information.
The specific pieces of Personal Information we collected about you.
If we disclosed your Personal Information for a business purpose, a list disclosing the disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.
If you are a resident of Oregon, the list of third parties to whom we disclosed your personal information.
Deletion Request Rights
You have the right to request that Top, Inc. (doing business as Downtime Dollars) delete any of your Personal Information that we collected from or about you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Your Privacy Rights), we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies. In accordance with applicable law, we may deny your deletion request under certain circumstances, and will inform you of the basis for the denial, which may include, but is not limited to, if retaining the information is necessary for us or our service provider(s) to:
Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation.
Right to Limit Processing of Sensitive Personal Information
In California, you have the right to limit our processing of Sensitive Personal Information to that use which is necessary to perform the services or provide the goods reasonably expected by an average consumer who requests such goods or services. In certain other states, we might require your consent before collecting Sensitive Personal Information. When we collect your Sensitive Personal Information, we collect and use that information in order to perform the services or provide the goods for which that information is necessary and as reasonably expected by you. Moreover, we do not use your Sensitive Personal Information for the purpose of inferring any characteristics about you. We will notify you if we use your Sensitive Personal Information for purposes where you have a right to limit or opt-out of that processing and will provide a method for exercising that right. We will obtain your consent or opt-in to collect or process Sensitive Personal Information where we are required to do so by applicable law.
Right to Correction
You have the right to correct inaccurate Personal Information maintained by us. Once we receive and confirm your verifiable consumer request (see Exercising Your Privacy Rights), we will correct (and direct our service providers to correct) your inaccurate Personal Information we are reasonably able to determine is inaccurate about you from our records, unless an exception applies.
Exercising Your Privacy Rights
To exercise the access, data portability, correction, and deletion rights described above, please visit downtimedollars.com. Only you or a person authorized to act on your behalf may make a verifiable consumer request related to your Personal Information. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.
Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password-protected account sufficiently verified when the request relates to Personal Information associated with that specific account. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. If we deny your request, you may appeal our decision by contacting us at Support@downtimedollars.com. Please clearly denote that it is an appeal.
Response Timing and Format
We try to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to an additional 45 days), we will inform you of the reason and extension period in writing. If you have an account with us, we may deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Other California Privacy Rights
California’s "Shine the Light" law (Civil Code Section § 1798.83) permits users of our website that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to support@downtimedollars.com or use our online privacy opt-out form
Changes to Our State Specific Privacy Notice
This State Specific Privacy Notice was last updated on the date indicated above. We reserve the right to amend this Policy from time-to-time. Any material change to our privacy practices will be reflected in this State Specific Privacy Notice, and we may in some instances notify you in other ways of updates. By continuing to use the Website or App after the date last updated, you agree to the privacy practices contained in the updated State Specific Privacy Notice. We encourage you to review this notice regularly to stay informed about our information practices and the choices available to you. Email support@downtimedollars.com or visit DowntimeDollars.com and find the “Do Not Sell My Personal Information” link at the bottom of the page.
Changes To This Privacy Policy
Changes To This Privacy Policy This Privacy Policy is effective as of June 6, 2024 and will remain in effect except with respect to any changes in its provisions in the future, which will be in effect immediately after being posted on this page. We reserve the right to update or change our Privacy Policy at any time and you should check this Privacy Policy periodically. Your continued use of the Service after we post any modifications to the Privacy Policy on this page will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Privacy Policy. If we make any material changes to this Privacy Policy, we will notify you either through the email address you have provided us, or by placing a prominent notice on our website.
Contact Us
If you have any questions about this Privacy Policy, please contact us at support@downtimedollars.com.