LAST UPDATED: 29 July 2020
Collectively, we refer to the Websites, the Apps, and our Social Media Pages as the “Services.”
“Personal Information” is information that identifies you as an individual or relates to an identifiable individual
- Postal address
- Telephone number
- Email address
- Bank account details
- Date of birth
- Job titles and roles
- Profile picture
- Social media account ID
Collection of Personal Information
We and our service providers collect Personal Information in a variety of ways, including:
- Through the Services
- We collect Personal Information through the Services, such as when you sign up for a newsletter or an account is created for you.
- We collect Personal Information from you offline, such as when you contact customer service, or when you provide us information at events such as trade shows.
- From Other Sources
- We receive your Personal Information from other sources, such as:
- Publicly available databases (including LinkedIn); and
- Joint marketing partners (such as Sprout), when they share the information with us.
- If you connect your social media account to your Services account, you will share certain Personal Information from your social media account with us, such as your name, email address, photo, list of social media contacts, and any other information accessible to us when you connect your social media account to your Services account.
Use of Personal Information
We and our service providers use Personal Information for legitimate business purposes, including:
- Providing the functionality of the Services and fulfilling your requests.
- To provide the Services’ functionality to you, such as arranging access to your account and providing you with related customer service related to your relocation, assignment, taxes, or payroll.
- To respond to your inquiries and fulfill your requests, when you contact us via one of our online contact forms or otherwise (such as when you send us questions, suggestions, compliments or complaints), or when you request a quote for or other information about our services.
- To complete your transactions and provide you with related customer service.
- To send administrative information to you, such as changes to our terms, conditions, and policies.
- To allow you to send messages to another person if you choose to do so.
We will engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.
- Providing you with our newsletter and/or other marketing materials and facilitating social sharing.
- To send you marketing related emails, with information about our services, new products, and other news about our company.
- To facilitate social sharing functionality that you choose to use.
We will engage in this activity with your consent or where we have a legitimate interest.
- Analysis of Personal Information for business reporting and providing personalized services.
- To analyze or predict our users’ preferences in order to prepare aggregated trend reports on how our digital content is used, so we can improve our Services.
- To better understand you, so that we can personalize our interactions with you and provide you with information and/or offers tailored to your interests.
- To better understand your preferences so that we can deliver content via our Services that we believe will be relevant and interesting to you.
We will provide personalized services either with your consent or because we have a legitimate interest.
- Aggregating and/or anonymizing Personal Information.
- We may aggregate and/or anonymize Personal Information so that it will no longer be considered Personal Information. We do so to generate other data for our use, which we may use and disclose for any purpose.
- Accomplishing our business purposes.
- For data analysis, such as to improve the efficiency of our Services;
- For audits, to verify that our internal processes function as intended and are compliant with legal, regulatory, or contractual requirements;
- For fraud and security monitoring purposes, such as to detect and prevent cyberattacks or attempts to commit identity theft;
- For developing new products and services;
- For enhancing, improving, or modifying our current products and services;
- For identifying usage trends, such as understanding which parts of our Services are of most interest to users;
- For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users; and
- For operating and expanding our business activities, including understanding which parts of our Services are of most interest to our users so we can focus our energies on meeting our users’ interests.
We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or because we have a legitimate interest.
Disclosure of Personal Information
We disclose Personal Information:
- Our affiliates are:
- MOVE Guides India Private Limited (India)
- Topia Limited (Hong Kong)
- Topia Mobility Inc. (California and New York, USA)
- Topia Mobility Inc. (Washington, USA)
- Topia OU (Estonia)
- Teleport Inc. (Deleware, USA)
- Topia Mobility Limited (Ireland)
- MNO Holdings, Inc. (formerly Monaeo, Inc.) (New York, USA)
- We share information between entities based on the services and customers involved.
- Topia Limited is the party responsible for the management of the jointly-used Personal Information.
- Our affiliates are:
- To our third party service providers, to facilitate services they provide to us.
- These can include providers of services such as relocation services, website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, auditing, and other services.
- To third parties, to permit them to send you marketing communications, consistent with your choices.
- By using the Services, you may elect to disclose Personal Information.
- On message boards, chat, profile pages, blogs, and other services to which you are able to post information and content (including, without limitation, our Social Media Pages). Please note that any information you post or disclose through these services will be available to other users and/or the general public.
Other Uses and Disclosures
We also use and disclose your Personal Information as necessary or appropriate, especially when we have a legal obligation or legitimate interest to do so:
- To comply with applicable law and regulations.
- This can include laws outside your country of residence.
- To cooperate with public and government authorities.
- To respond to a request or to provide information we believe is important.
- These can include authorities outside your country of residence.
- To cooperate with law enforcement.
- For example, when we respond to law enforcement requests and orders or provide information we believe is important.
- For other legal reasons.
- To enforce our terms and conditions; and
- To protect our rights, privacy, safety or property, and/or that of our affiliates, you, or others.
- In connection with a sale or business transaction.
- We have a legitimate interest in disclosing or transferring your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings). Such third parties may include, for example, an acquiring entity and its advisers.
“Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual.
- Browser and device information
- App usage data
- Information collected through cookies, pixel tags, and other technologies
- Demographic information and other information provided by you that does not reveal your specific identity
- Information that has been aggregated in a manner such that it no longer reveals your specific identity
Collection of Other Information
We and our service providers may collect Other Information in a variety of ways, including:
- Through your browser or device.
- Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, and Internet browser type and version. We use this information to ensure that the Services function properly.
- Through your use of the App.
- When you download and use the App, we and our service providers may track and collect App usage data, such as the date and time the App on your device accesses our servers and what information and files have been downloaded to the App based on your device number.
- Using cookies.
- Using pixel tags and other similar technologies
- Pixel tags (also known as web beacons and clear GIFs) may be used to, among other things, track the actions of users of the Services (including email recipients), measure the success of our marketing campaigns, and compile statistics about usage of the Services and response rates.
- Using Adobe Flash technology (including Flash Local Shared Objects (“Flash LSOs”)) and other similar technologies
- We may use Flash LSOs and other technologies to, among other things, collect, and store information about your use of the Services. If you do not want Flash LSOs stored on your computer, you can adjust the settings of your Flash player to block Flash LSO storage using the tools contained in the Website Storage Settings Panel. You can also go to the Global Storage Settings Panel and follow the instructions. Please note that setting the Flash Player to restrict or limit acceptance of Flash LSOs may reduce or impede the functionality of some Flash applications.
- IP Address
- Your IP address is automatically assigned to your computer by your Internet Service Provider. An IP address may be identified and logged automatically in our server log files whenever a user accesses the Services, along with the time of the visit and the pages visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications, and other services. We use IP addresses for purposes such as calculating usage levels, diagnosing server problems, and administering the Services. We may also derive your approximate location from your IP address.
- Physical Location
- We may collect the physical location of your device by, for example, using satellite, cell phone tower or WiFi signals. We use your device’s physical location to provide you with personalized location-based services and content via our City Guides product. In some instances, you may be permitted to allow or deny such uses of your device’s location, but, if you do, we may not be able to provide you with the applicable personalized services and content.
Uses and Disclosures of Other Information
We may use and disclose other Information for any purpose, except where we are required to do otherwise under applicable law. In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.
We seek to use reasonable organizational, technical, and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contact Us” section below.
CHOICES AND ACCESS
Your choices regarding our use and disclosure of your Personal Information
We give you choices regarding our use and disclosure of your Personal Information for marketing purposes. You may opt out from:
- Receiving electronic communications from us: If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt-out by following the instructions contained in each such email. Note that users cannot opt out of move-related emails during their move, but may opt out once the move is complete.
- Our sharing of your Personal Information with affiliates for their direct marketing purposes: If you prefer that we discontinue sharing your Personal Information on a going-forward basis with our affiliates for their direct marketing purposes, you may opt out of this sharing by contacting email@example.com.
We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt out of receiving marketing-related emails from us, we may still send you important administrative messages, from which you cannot opt out.
How you can access, change, or delete your Personal Information
If you would like to request to review, correct, update, suppress, restrict, or delete Personal Information that you have previously provided to us, object to the processing of Personal Information, or if you would like to request to receive an electronic copy of your Personal Information for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by applicable law), you may contact us by: emailing firstname.lastname@example.org or send a letter to Privacy, Topia Limited, 5 New Street Square, London, EC4A 3TW, United Kingdom. We will respond to your request consistent with applicable law.
In your request, please make clear what Personal Information you would like to have changed or whether you would like to have your Personal Information suppressed from our database. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.
Please note that we may need to retain certain information for record-keeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion.
We retain Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law.
The criteria used to determine our retention periods include:
- The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you have an account with us or keep using the Services);
- Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
- Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation, or regulatory investigations).
In addition, we are not responsible for the information collection, use, disclosure, or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, Blackberry, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with the Apps or our Social Media Pages.
Use of the Services by MINORS
The Services are not directed to individuals under the age of sixteen (16), and we do not knowingly collect Personal Information from individuals under 16.
Jurisdiction and CROSS-BORDER TRANSFER
Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and, by using the Services, you understand that your information will be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies, or security authorities in those other countries may be entitled to access your Personal Information.
ADDITIONAL INFORMATION REGARDING THE EEA: Some of the non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available here. For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place adequate measures, such as standard contractual clauses adopted by the European Commission to protect your Personal Information. You may obtain a copy of these measures by following this link.
Unless we request it, we ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, or trade union membership) on or through the Services or otherwise to us.
5 New Street Square
London, EC4A 3TW
Because email communications are not always secure, please do not include credit card or other sensitive information in your emails to us.
ADDITIONAL INFORMATION REGARDING THE EEA
You may also:
- Contact our privacy team at email@example.com.
- Lodge a complaint with a data protection authority for your country or region or where an alleged infringement of applicable data protection law occurs.