1. INTRODUCTION
    1. We are Topia Limited (referred to as "we", "us" and "Topia") and we are committed to protecting and respecting your privacy when you are visiting any website maintained by us including without limitation the website at www.topia.com and our social networking pages (together the "Website") or communicating electronically with us.
    2. This policy, together with the Terms of Service (which can be found at the bottom of our Website at www.topia.com) explains what types of personal and non-personal information we collect when you use the Website and our services and the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By disclosing your personal information to us by using the Website and/or our services or speaking to us over the telephone you consent to the collection, storage and processing of your personal information as stated in this policy.
    3. Topia uses the personal information we collect from you to provide our service to you. We will not rent, sell or share your personal information with any other company for its own marketing purposes without your consent except where mentioned in this policy.
    4. For the purpose of the Data Protection Act 1998 (the Act), the data controller is Topia LIMITED of 6 Ramillies St, London, W1F 7TY which is registered with the ICO with registered number Z3251331.
  2. WHAT PERSONAL INFORMATION DO WE COLLECT?
    1. We may collect, store and use the following kinds of personal information about you:
      1. when you register as a user of the Website and/or make an enquiry about a vendor, you will be asked to complete a form giving your name, address, email address and telephone number. You may also be asked to provide additional information about your family, property, move date, move route, job, company and other matters relevant to the specific services you require; Please note, where this information has already been provided by your employer, you will not be required to re-enter it.
      2. in connection with an account sign-in facility, your log-in and password details;
      3. when you contact us by email or telephone or through any contact form provided on the Website, we may ask you to provide some or all of the information set out in paragraph (a) above;
      4. when you make request a service from a vendor through the Website, details of that transaction;
      5. we may collect, store and use information about your computer, mobile device or other item of hardware through which you access the Website and your visits to and use of the Website (including without limitation your IP address, geographical location, browser/platform type and version, Internet Service Provider, operating system, referral source/exit pages, length of visit, page views, website navigation and search terms that you use);
      6. if you access the Website through a social networking profile, we may collect, store and use the details of that social networking profile and any information contained therein in order to populate any forms you might wish to complete on the Website.
    2. We may also ask you to complete surveys and give feedback that we may use for research purposes, although you do not have to respond to them.
    3. If you choose to provide us with information on other people, you must ensure that they have consented to you providing us with such information and our use of such information in accordance with this policy. By providing us with information on any other person, we are entitled to assume that such other person has consented to you providing us with their information and to us contacting them in accordance with this policy. We reserve the right to identify you as the person who has made the referral in any message that we send them.
    4. You are under no obligation to provide any such information. However, if you should choose to withhold requested information, we may not be able to provide you with certain services.
  3. LOCATION DATA
    1. We may collect information through the Website and/or mobile application as to your real time location to provide location services where requested or agreed to by you in order to deliver content, advertising or other services that are dependent on knowing where you are. This information may also be collected in combination with an identifier associated with your device to enable us to recognise your mobile browser or device when you return to the Website.
    2. Delivery of location services will involve reference to one or more of the following: (a) the coordinates (latitude/longitude) of your location; (b) look-up of your country of location by reference to your IP address against public sources; and/or (b) your Identifier for Advertisers (IFA) code for your Apple device, or the Android ID for your Android device, or a similar device identifier. See Cookies and other technologies for more information on the use of cookies and device identifiers on the Website.
    3. You may opt out at any time from allowing further access by us to your location data by turning off location tracking within the Apple or Android device settings or contacting help@topia.com to opt out for tracking via the Website.
  4. HOW DO WE USE PERSONAL INFORMATION?
    1. Our service is an introduction and information service providing you with information on relocation services and a medium for contacting vendors of such services.
    2. We may use your personal information for the following purposes.  Please note that you will be required to opt-in where required by relevant law.
      1. to provide our services to you;
      2. to manage and administer the Website and your account with us;
      3. audit the downloading of data from the Website;
      4. to provide recommendations to other services based on your usage of the Website and/or our services;
      5. to improve your browsing experience by personalising the Website;
      6. to enable you to use the Website;
      7. to identify visitors to the Website;
      8. allow, with your consent, carefully selected third parties to send you information directly which you may find useful regarding their products and services;
      9. to send you email confirmations as necessary;
      10. verify and carry out financial transactions in relation to any payments you make online;
      11. to deal with enquiries, complaints and feedback from you and our service providers;
      12. to provide vendors with the necessary details in order for them to deliver their relocation services to you;
      13. to provide third parties with statistical anonymised information about our users;
      14. to analyse and improve the services offered on the Website;
      15. to provide your employer with relevant information about the status of your relocation.
    3. WHEN MIGHT WE DISCLOSE PERSONAL INFORMATION?
      1. We will only disclose your personal information to any vendor who may provide services for you in relation to whom you express a desire to be contacted via the Website and/or you complete a contact form in respect of such vendor, except where we are otherwise required to do so by any applicable law or governmental or judicial body or if we believe that such action is necessary to prevent fraud or cyber crime or to protect the Website or the rights, property or personal safety of any person.
      2. We will use all reasonable endeavours to ensure that any vendor to whom we disclose your confidential information is compliant with the Data Protection Act 1998 (or an equivalent standard) as regards its use and storage of your personal information.
      3. We may aggregate non-personal information (for example relating to your usage of the Website) and provide this aggregated information to third parties. We will ensure that you cannot be identified from such aggregated user information.
      4. We may disclose your personal information to any of our affiliates, or to our agents or contractors who assist us in providing the services we offer through the Website, processing transactions, fulfilling requests for information, receiving and sending communications, updating marketing lists, analysing data, providing IT and other support services or in other tasks, from time to time. Our agents and contractors will only use your information to the extent necessary to perform their functions.
      5. We may share details of your user activity, including but not limited to searches and bookings, with your employer in situations where your employer created the account on your behalf.
      6. In the event that we undergo re-organisation or are sold to a third party, you agree that any personal information we hold about you may be transferred to that re-organised entity or third party.
    4. PUBLIC FORUMS
      1. The Website may, from time to time, make chat rooms, message boards, news groups and/or other public forums available to its users. Any information that is disclosed in these areas becomes public information and you should exercise caution when using these and never disclose your personal information.
    5. OUR USE OF COOKIES AND WEB BEACONS
      1. Cookies are text files stored, either on a temporary or persistent basis on the hard drive of your computer. Cookies are used for authenticating, session tracking and maintaining specific information about the use and users of the Website (including user site preferences or the contents of electronic shopping carts). Cookie files may also be placed on your computer by our trusted third-party advertising companies for the purposes as set out in this paragraph.
      2. The data collected by cookies is anonymous. You can delete all cookies that are already on your computer's hard drive by searching for files with "cookie" in it and deleting them. In addition, if you want to stop cookies from being stored on your computer, you can edit your browser settings so that cookies are blocked. Unfortunately, if you block cookies you may not be able to use the full functionality of the Website. For more information about cookies, please visit:allaboutcookies.org. Please note, however, that by blocking or deleting cookies used on the Website, you may not be able to take full advantage of the Website.
      3. Web beacons consist of a small string of software code that represents a graphic image request on a Web page or email. There may or may not be a visible graphic image associated with the web beacon and often the image is designed to blend into the background of a Web page or email. Web beacons can be used for many purposes - including site traffic reporting, unique visitor counts, advertising auditing and reporting, and personalization. Web beacons used by www.topia.com collect only anonymous data.
      4. We use cookies to remember that you have visited us before. This means we can identify the number of unique visitors we receive. This allows us to make sure we have enough capacity for the number of users that we get.
      5. In order to improve our Website and the services we offer you, we use (temporary and persistent) cookies, authorised third party cookies, web beacons and/or other technologies to collect non-personally identifiable data. This non-personally identifiable data helps us to track browsing behaviour, to create specific or tailor-made offers or advertisements, and to monitor and record the visits and use of the Website.
      6. In particular, our cookies gather information about the pages on the Website that you visit, and also other information about other websites that you visit, so as to place you in a “market segment”. This information is collected by reference to the IP address that you are using and/or your unique user ID, and includes information about the county and city you are in, together with the name of your internet service provider. We may use this information to analyse your use of the website and to place interest-based advertisements on the Website which it is believed will be relevant to your market segment.  For more information about this type of interest based advertising, and about how to turn this feature off please visit http://www.youronlinechoices.com/uk/
      7. In order to understand how people use our Website and for marketing analysis and quality improvement purposes, we (and/or third party service providers) may collect, record, process and use on an anonymous basis certain information, including the total number of transactions, viewed web pages, referring/exit pages, platform type, date/time stamp information and details like the number and location of mouse clicks on a given page, mouse movements, scrolling activity and the search words you use while being on and using the Website.
      8. If you register with us or if you continue to use the Website, you agree to our use of cookies.
    6. WHERE WE STORE YOUR PERSONAL DATA
      1. The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for us or for one of our vendors. The countries concerned may not have similar data protection laws to the EEA. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.
      2. All information you provide to us is stored on our secure servers in the European Union.
      3. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted through our Website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
      4. We transmit personal information using Secure Sockets Layer (SSL) software which encrypts information you input. Further, to the extent that we collect any credit card or bank account information from you, we will only reveal the last four digits of your credit card number when confirming an order. We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of personally identifiable customer information. Our security procedures mean that we may occasionally request proof of identity before we disclose personal information to you.
      5. Any payments made by you on the Website to Topia directly, or where Topia acts as agent for a vendor, are made through our payment gateway provider PayPal. You will be providing credit or debit card information directly to PayPal which operates a secure server to process payment details, encrypting your credit/debit card information and authorising payment. Information which you supply to PayPal is not within our control and is subject to PayPal's own privacy policy and terms and conditions.
    7. LINKS TO THIRD PARTY WEBSITES
      1. The Website may include links to third party websites. We are not responsible for the content of third party websites. Please ensure that prior to using any such website, you have read and understood its privacy policy and terms of service. These documents will govern your rights and obligations when using the relevant third party website.
      2. We may allow third party advertisers to advertise on the Website. Third party advertisers, or internet advertising companies working on their behalf, sometimes use technology to send (or "serve") the advertisements that may appear on the Website directly to your browser. They automatically receive your IP address when this happens. They may also use cookies, JavaScript, web beacons and other technologies to measure the effectiveness of their advertising and to personalise advertising content. We do not have access to or control over cookies or other features that they may use, and the information practices of these advertisers and third party websites are not covered by this Privacy Policy. Please contact them directly for more information about their privacy policies. We are not responsible for the collection, use and disclosure of personal information by third party websites to which you provide information or visit.
    8. YOUR RIGHTS
      1. The Act gives you the right to access all personal information held about you by us. Your right of access can be exercised in accordance with the Act. At our discretion, any access request may be subject to a fee of £10 to meet our costs in providing you with a copy of the information we hold about you. You also have a right to correct any errors in that information.  As mentioned above, you have a right to prevent the use of your personal information for direct marketing purposes.
    9. CHANGES TO OUR PRIVACY POLICY
      1. We reserve the right to amend this privacy policy. Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. This policy was last updated on 1 April 2018.
    10. CONTACT
      1. Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to help@topia.com.