Privacy policy

topFundr LTD Privacy Notice

topFundr (“topFundr”, “we”, or “us”) is dedicated to protecting the privacy of our customers, and we take our data protection responsibilities with the utmost importance.

Privacy Policy

This Privacy Notice (the “Notice”) describes how topFundr collects and processes your personal information through the topFundr websites and applications that reference this Privacy Notice. topFundr refers to an ecosystem comprising the topFundr website [https://topfundr.com/], mobile applications, clients, applets, and other applications that are developed to offer topFundr Services, and include independently operated platforms, websites, and clients within the ecosystem.

By using topFundr, you consent to the data practices described in this Notice and all extensions and addendums to this Notice.

1. The Controller of Your Personal Data and our Relationship

topFundr, bearing company registration number C106279 and having its registered office at 30/1 KENILWORTH COURT, SIR AUGUSTUS BARTOLO STREET, TA ‘XBIEX, MALTA is the data controller for personal information collected in connection with the provision of topFundr Services.

Please, feel free to contact us via e-mail at support@topfundr.com regarding any questions and regarding your rights relating to the processing of your personal data.

2. The Cookies and Other Identifiers

topFundr uses cookies and similar tools to improve your user experience, deliver our services, enhance our marketing efforts, and understand how customers use our services so we can make improvements. Depending on applicable laws in the region you are located in, the cookie banner on your browser will tell you how to accept or refuse cookies. Our cookie policy is available here

3. The Storage and Data Safety

We developed our systems with your security and privacy as a premise. We have proper security measures in place to prevent your information from being accidentally lost, altered or disclosed, used, or accessed in an unapproved way. We work to protect the security of your personal information during transmission and while stored by using encryption protocols and software. We keep physical, electronic, and procedural safeguards in connection with the collection, storage, and disclosure of your personal information. In addition, we limit access to your personal information to those employees, agents, contractors, and other third parties on a need-to-know basis.

4. How Long Does topFundr Keep/Process Your Data?

We keep your personal information to allow your constant use of topFundr Services, for as long as it is required in order to fulfill the relevant purposes described here, and as may be required by law such as for tax and accounting purposes, compliance with laws, or as otherwise communicated to you.

Please, look at the retention period specified in the section below.

5. The Personal Information That We Collect and Process, the Reason Why we Collect and Process, and the Legal Basis:

The data and the collection	The purpose of the process	The legal basis for our use of the data	The period of retention of the data
The data that was given to us by you as identification and contact data, specifically the name, surname, telephone number, e-mail, address, postal address, date of birth, user name and password, and business identification number or tax registration number, if you are an entrepreneur; payment data, such as bank details; and other data, such as records of communication between you and our company or details of any warranty claims. The data that was given to us by third parties, such as providers of trading platforms that you choose for use of our services, and social network operators if you decide to link your social networking accounts to an account on the website. As data about the simulated transactions, you have completed (such as the type of financial instrument, time of opening and closing the position, amount of investment, profit and loss) and data from social networks (user name, profile picture, e-mail address associated with the account on the social network).	To use the services, you must register on the website and create your account, and for this purpose, we process your personal data. We also process your data related to the settings of your user account. We use your personal information to communicate with you in relation to our services. We use your personal information to provide functionality, troubleshoot, analyse performance, fix errors, and the usability and effectiveness of topFundr Services.	Processing is necessary for the performance of the contract, and the provision of these personal data is required, as we cannot register your user account without them. Also, the processing is necessary for the legitimate interest, after we stop providing you with services, we process personal information for a limited period. Such processing is necessary for the purposes of exercising and protecting our rights based on our legitimate interests. Your consent when we ask for your consent to process your personal information for a specific purpose that we communicate to you. You may withdraw your consent at any time and we will stop processing your personal information for that purpose. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.	To the performance of the contract and to the exercise of rights and obligations in connection with the contract, with any complaints, settlement of damage claims or related litigation, personal data are processed for the necessary period of time, but not more than 10 years from the termination of the last contract; To achieve our legal obligations, we process personal data for the period set out by the relevant legal regulations (e.g. in accordance with tax regulations for a period of 10 years from the issuance of the relevant documents for your order); To improve our services, we usually process personal data for a maximum period of 6 months; For the period specified in the consent.
As our current or past customers, we can from time to time send you marketing communications that relate to our services. We can also send you commercial communications to the extent to which you give us your consent. Each of the e-mails sent will be marked as a business communication and each of them will contain a link with the help of which you can easily unsubscribe from the business communications.	Marketing communication about our services and products or about events in which we take part	Marketing communication about our services and products or about events in which we take part	For the purpose of sending business communications without your given consent, personal data are processed for a maximum of 5 years from the expiry of the last contract between us or until you raise an objection or unsubscribe from the business communications;

For knowledge on how your personal data are processed by trading platform providers and social network operators for their own purposes, please refer to the privacy policies of those parties.

6. The Data Sharing and Transfers To Third Countries

To assist our operations, topFundr may transfer your personal data to our Affiliates, service providers, and third-party partners. These parties include other companies in our group, hosting, and cloud service providers, payment system operators and financial institutions, providers of customer support tools and services, IT companies and system administrators, marketing and communication agencies, consultants, postal service providers, and others similar.

Also, we could transfer your data to persons regarding your consent to it, as well as in the cases where it is our responsibility under the law or under a judicial or any other legally binding decision. These entities are contractually obliged to protect your personal data in harmony with legal provisions and to process the data exclusively in accordance with our instructions.

7. The Rights That You Have

You have several rights in relation to your privacy and the protection of your personal information. You have the right to request access to, correct, or delete your personal information, to ask for data portability, to object to our processing of your personal information, or ask that we restrict the processing of your personal information in certain instances.

In case when you consent to our processing of your personal information for a specified purpose, you can withdraw your consent at any time. If you want to exercise any of your rights please contact us at support@topfundr.com In some situations, this right is limited as detailed in Section 5.

The Rights described here are written in Chapter 3 of the GDPR. Please, look at the list below with a brief explanation to assist you in understanding what each one means and how you may exercise it:

Your right to be informed	A controller is obliged to inform you about all topics posted here, such as which data we collect, how we process them, how long we keep them and other topics.
Your right of access to your personal data undergoing processing	You have the right to obtain confirmation that your personal information is processed and to obtain a copy of it as well as certain information related to its processing. If you request it, we will also provide you with a copy of the personal data processed. Just note that the first copy is free of charge, but the next copies will be required for a small fee. We shall provide a response within one month from receipt of a communication, according to Article 12 GDPR, but we could extend the time to respond if the request is complex or when receiving several requests from the individual.
Your right to get your personal data rectified	You can request the rectification of your personal information, which is inaccurate and add to it. You can also change your personal information in your account at any time.
Your right to get our personal data deleted “right to be forgotten”	In some cases you can have your personal information deleted: If the data are no longer necessary in relation to the purposes for which we have collected or otherwise processed them; If you withdraw your consent to their processing and, at the same time, there will be no other legal ground for their processing (this only applies in the cases where we process personal data on the basis of your consent); If you object and there are no overriding legitimate grounds for the processing, or if you object to the processing for direct marketing purposes; or If your personal data are processed unlawfully. topFundr will not be able to act on the request for the erasure of personal data if their processing is necessary for exercising the right of freedom of expression and information, for compliance with any of our legal obligations, for the performance of a task carried out in the public interest, for the establishment, exercise, or defence of our legal claims, or for other reasons provided for by law.
Your right to data portability	When the processing of your personal data is based on your consent or based on a contract, you have a right to receive the personal data in a structured, commonly used and machine-readable format and the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided.
Your right to object to the processing of your personal data	You have the right to object to a controller processing personal data at any time. This means that you can stop the controller from using your personal data. This right applies in specific circumstances and, in particular, where your personal data is processed: For a task in the public interest; For the exercise of official authority; For the controller’s legitimate interests; For scientific, historical or statistical purposes; or For direct marketing purposes.
Your right in relation to the decisions taken solely by automated means	You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. This right does not apply where the decision: Is necessary for entering into, or performance of, a contract between the data subject and the controller; Is approved by Union or Members State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests; or Is based on your explicit consent.
Your right to lodge a complaint with the IDPC	If you consider that the processing of personal data relating to you infringes the GDPR, you have the right to lodge a complaint with the IDPC against the controller involved and the case will be investigated accordingly.

8. The Notices and Revisions

If you have any concerns about privacy at topFundr, please contact us, and we will try to resolve them. You also have the right to contact your local Data Protection Authority.

Our business changes regularly, and we may change this policy unilaterally, but we will do so only when necessary and we will notify you about such change. You can find the latest version of this policy in your Client Section.