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Privacy Policy

Updated on January 23, 2024

TopOn ("TopOn" or "we") provides this Privacy Policy to describe how we collect, use and share data. This privacy policy ("Policy") describes TopOn's handling of two types of data.

This Policy is subject to any service agreement between TopOn and you. By using the TopOn Service or TopOn Site, you acknowledge that you have read, understood and agreed to this Policy. Please review this Policy before using the TopOn Service or the TopOn Site.

We evaluate this Policy and procedures to implement improvements and refinements from time to time.

Data protection and ensuring our Business Partners’ and your trust is at the core of TopOn’s business principles. Accordingly, being compliance with applicable data protection laws is our top priority and this Policy is updated to be compliance with the applicable data protection laws, including but not limited to the EU General Data Protection Regulation (“GDPR”), the Children’s Online Privacy Protection Act (“COPPA”), the California Customer Privacy Act (“CCPA”), the Brazilian General Data Protection Law (Lei Geral de Proteção de Dados Pessoais) (“LGPD”) and the any personal data protection law announced by Chinese governments.

TopOn Service Privacy Policy

1.Introduction.

This Privacy Policy describes TopOn's data collection and data use practices in the following scenarios: (i) users viewing advertisements served by TopOn Services or using TopOn Services in any way; (ii) users using platforms, applications, websites or other services provided by TopOn's business partners; and (iii) business partners using TopOn Services.

Our technology enables our Partners to show users more ads that are relevant to users' interests and behavior. In order to provide the TopOn Services, we may collect and use data related to users' activities and preferences. We understand that the confidentiality of users' personal data is very important, especially in today's Internet age. For this reason, we have created this policy in an easy to navigate and read manner so that you can clearly understand our privacy protection provisions.

The TopOn Services may link to third-party websites, applications or other third-party content. Please note that we have no control over the processing of user data by third parties and that third parties may have privacy protection provisions that differ from those described in this Privacy Policy.

2.How and Why We Collect Data from Users.

Depending on the nature of the user's use of the TopOn Services or the services provided by any of TopOn's business partners, we may collect data directly from users or through our business partners (e.g., mobile app developers, ad trading platforms, advertisers). For example, when we partner with an ad trading platform that sends advertising requests to our demand-side platform, it may share data about users with us.

As a mobile mediation advertising platform, we collect data about users for the following reasons and purposes: to place ads on users' devices, including building user profiles for interest-based advertising based on the data we collect; to monitor traffic and count the performance and effectiveness of ads, including ad material and ad effectiveness data monitoring, fraud prevention; to understand and analyze user usage trends and preferences; to improve the quality of our TopOn service quality and develop new products; and ensure the security of systems and processes.

When we collect personal data such as names and email addresses of our partners' business representatives, we do so for the purpose of communicating with them commercially, including as necessary for the fulfillment of our contracts with our partners.

3.Data that We may Collect from Users.

We and/or our business partners may collect data about you when you view advertisements that use TopOn's mediation services or use services provided by TopOn's business partners.

In order to provide you with better services, or to jointly provide services to you, or for the purpose of preventing internet fraud, our affiliates, partners may share your personal data with us in accordance with the law or as agreed with you or with your consent.

We or our business partners may collect the following personal data about you: device manufacturer, device model, CPU model, sensor (accelerometer sensor or gyro-sensor of device), resolving power, device operating system (e.g. iOS) and operating system version, device type (e.g. smartphone, tablet, device model, device manufacturer etc.), device screen size, device screen orientation, carrier data, application version and features of the mobile application used by the user to use the TopOn Services, country, MCC(mobile country code), MNC(mobile network code), startup times, time zone and regional settings (country and region). Time zone and regional settings (country and preferred system language), type of network connection, IP address, SDK version, timestamp, network status such as WiFi, mobile advertising identifier (e.g. Apple IDFA or Google Advertising ID), device event data such as system crash, date and time of your request and source URL, user-agent, TopOn partner's application package name, package version, IDFV. we or our business partners may also collect International Mobile Device Identifier (IMEI, MAC address, OAID), Android ID for users.

Developers of applications may choose to share the personal data they collect with us through our SDK. For more data about how your personal data is collected, used, and shared by the developer of the application and whether you consent to the developer's use of your relevant personal data, please review the privacy policy of the relevant application developer.

Please note that we may require, through our partnership agreements with our partners, that they obtain your full prior consent for any personal data about you that may be collected and shared in the course of the service before using our service.

Note on the collection of installed application data.

For users of Android devices, after our SDK has acquired an ad, it will determine whether you have installed the product promoted by the ad before displaying it, and if so, we will not display the ad (we call this display filtering) and will notify the server not to return the corresponding ad the next time your device requests it, thus improving the user experience. The data about the ads that are "Display Filtered" is reported and no data about other installed applications is collected.

When you interact with an advertisement promoted by us, we collect data about your interaction with the advertisement, such as when you view or click on the advertisement.

When you download and use a product (e.g. an application) promoted by an advertisement that we have viewed or clicked on, we collect data from the advertiser or a third party designated by the advertiser about your download, installation, activation of the advertiser's product or your other actions within that product.

In particular, when TopOn serves as an advertising exchange platform (ADX) for the placement of advertisements, our business partners may collect and transmit to us your personal data, including: screen size, screen orientation, device manufacturer, device model, operating system and version, device type, application version and features of the mobile application used by the user to use the TopOn Service, operator data type of network connection, IP address, user agent, country, time zone and regional settings (country and preferred language), mobile advertising identifier (e.g. Apple IDFA or Google AdWords ID). Also, we may collect data about your interaction with the ads we promote, such as data about having viewed or clicked on the ad.

We work with reputable ad trading platforms. After receiving an ad request with your personal data, the ad trading platform transfers the personal data to TopOn for the purpose of building your profile, personalizing your advertising experience and subsequently placing ads on the Internet with you, if permitted by law or with the consent of the user. The privacy policy linked below provides you with data on how our advertising trading platform handles your personal data.

We provide the TopOn service to our mobile application developers. We may collect email addresses, user names and passwords, IP addresses and addresses of individuals who use the TopOn Services on behalf of such mobile application developers.

Please understand that we are not required by law to obtain your authorized consent to process your personal data in the following circumstances.

(1) It is necessary for the conclusion or performance of a contract at your request.

(2) Necessary for the performance of legal duties or legal obligations, such as those directly related to national security, national defense security, criminal investigations, prosecutions, trials and sentence enforcement, etc.

(3) It's necessary to respond to public health emergencies, or to protect the life, health and property of natural persons in emergency situations

(4) To implement news reporting, public opinion monitoring and other acts in the public interest, and to handle personal data within a reasonable range

(5) Handling personal data that you have disclosed on your own within a reasonable range, or other personal data that has been legally disclosed (such as personal data that has been legally disclosed through legitimate news reports, government data disclosure, etc.)

(6) Other cases stipulated by laws and regulations.

Special Note: According to the law, if the data cannot be identified to a specific individual alone or in combination with other data, it is not personal data. When your data can be identified to you alone or in combination with other data, or when we use data that has not been linked to any specific individual in combination with your personal data, we will treat it as your personal data and handle and protect it in accordance with this privacy policy.

For partners who use Google Ad Manager monetization services, in order to improve our service capabilities, with your explicit authorization, we may receive your advertising performance data regarding to your monetization in Google Ad Manager through Google API Services and display the data at the page of your account. The fields and range of data we received for Google API Services will be solely subject to your authorization.

We promise that our use of Google API Services and the collection and use of personal data received from Google API Services will adhere to Google API Services User Data Policy (https://developers.google.com/terms/api-services-user-data-policy#additional_requirements_for_specific_api_scopes), including but not limited to the Limited Use requirements.

You can learn about all data processing activities involved in our services through this policy (https://www.toponad.com/en/privacy-policy).

Sensitive Personal Data.

Sensitive personal data is generally defined as personal data that, if leaked or used illegally, could easily lead to the violation of a natural person's dignity or endanger the safety of his or her person or property, the scope of which may vary according to the provisions of different applicable laws.

We will not collect your sensitive personal data without your consent. Our business partners will only transfer or authorize us to process your sensitive personal data after they have fully informed you of the need to process it and the impact on your personal rights and interests and have obtained your consent in accordance with the law.

4. How We Use Users' Personal Data.

Your device will be identified by us from other devices based on data automatically sent from your device, such as IP address, browser data, or device data. Your device may also be identified based on our scan of that device's unique combination of characteristics as well. Advertiser identifiers or other data may be stored or accessed on your device for the purposes set forth in this Privacy Policy. Your device may receive or send data to enable you to see and interact with advertisements and content. We may use your personal data to place advertisements on your device. The advertisements placed with you may be based on the content you view, the applications you use, your approximate location or the type of device. We may create a profile of you or your interests; and based on that profile, we may deliver personalized or behavioral ads to you that are relevant to you and that match your interests, preferences, geographic location, or other characteristics. If requested, our business partners (e.g. mobile application developers, advertisers, etc. that use TopOn's SDK) will obtain consent from users on our behalf for the processing of data regarding our user profiling behavior and the placement of advertisements (including personalized or behavioral advertisements) on users' devices. Users may withdraw their consent at any time.

We may use your personal data as necessary for our legitimate interests to: (i) count the performance and effectiveness of the advertisements you view and interact with, including traffic quality statistics for the purpose of fulfilling our contractual obligations to our business partners; (ii) understand and analyze your usage trends and preferences in order to improve the quality of our TopOn service and develop our new products; or (iii) to monitor and prevent fraud and to ensure the correct and secure operation of systems and processes.

At the same time, we may collect and use personal data of users who use the TopOn Services on behalf of our Partners (e.g. employees of our mobile application developers or advertisers) and use it for the purpose of making commercial contact with them or for direct marketing to them (e.g. sending marketing emails). If requested, our partners will obtain the consent of the user on our behalf for our data processing activities with respect to the personal data of such user.

To use a user's personal data in order to comply with relevant laws, regulations or codes of conduct, to protect our legitimate interests and to protect our or other third parties' rights and property.

5.Disclosure of Personal Data of Users.

We may share your personal data with third parties other than TopOn’s affiliates, subject to applicable law.

We may disclose personal data about users to our business partners in order to fulfill our contractual obligations to them, including reporting to our business partners on the performance and effectiveness of the advertisements with which users interact, including statistics on traffic quality, and for anti-fraud purposes. The personal data we share is personal data related to the performance and effectiveness of advertisements, such as device data, clicks, displays, installs or activations, and may be used by these business partners to count users' interactions with advertisements/websites, to evaluate the performance and effectiveness of advertisements viewed or interacted with by users, to identify areas of interest to users, to better understand website and application traffic usage or user behavior to improve their services. Our business partners' use of the data we disclose is governed by their privacy policies.

We may also use third-party technology service providers (such as cloud service providers) to process personal data for the proper and appropriate operation of our systems and processes, and for the purpose of storing data.

In accordance with the personal data Protection Law of the People's Republic of China, we do not share users' personal data with third parties other than TopOn’s affiliates unless they have given their authorized consent, except where the processing cannot identify a specific individual and cannot be recovered. For the names, contact details and other data about our business partners and third-party technical service providers,

We may also share mediation or anonymous data with other third parties in accordance with the terms of this Privacy Policy.

For the purposes of this Privacy Policy, our affiliated companies may also obtain personal data about users.

We may disclose your personal data as required by law in order to comply with a court subpoena, other similar legal process, or government request; or we may disclose your personal data when we believe that disclosure is required by law or is necessary to protect our rights, property, the rights, property, and safety of others, including disclosure to consultants, law enforcement, judicial oversight We may also disclose your personal data to other parties. We may also transfer your personal data to third parties that acquire some or all of our property, equity interests, or acquire part or all of our business in a merger, acquisition, reorganization, or otherwise.

6.Data Transfer.

If you are located in the European Economic Area, the data we collect about you will be transferred to or will be remotely accessible from countries located outside the European Economic Area, including China, the United States and others also not recognized by the European Commission as is a country that provides an appropriate level of protection for personal data, but we will provide appropriate protection to such personal data as required by applicable law. If required by law, our business partners (such as mobile application developers, advertisers, etc. using TopOn's SDK) will ask you for data on transferring your personal data outside the European Economic Area, including transferring to TopOn, Consent of TopOn's affiliates or other recipients under this Privacy Policy. You can withdraw your consent at any time.

If you are located in the mainland of the People's Republic of China, the personal data we collect about you in accordance with this policy will be stored in the People's Republic of China. If it is necessary to provide personal data outside the People's Republic of China due to business needs, our company will transmit it in accordance with the requirements of the relevant laws and regulations of the People's Republic of China.

7.Your Data Rights.

If you are located in the European Economic Area, you have the following rights (subject to limited exceptions under the GDPR): (i) to access, correct or delete personal data; (ii) to restrict or object to the processing of your personal data; and (iii) ) to request an electronic copy of personal data to be provided to others or third parties. At the same time, you have the right to lodge a complaint with the local data protection authority in the European Economic Area regarding the processing of your personal data.

If you are a resident of California, USA, effective January 1, 2020, you have the following rights:(i) To exercise relevant consumer rights, such as: by sending an email to privacy@toponad.com, to request knowledge, disclosure, access and deletion of data collected in the last 12 months; and (ii) to request that the sale of your data be prohibited.If you are a citizen of the mainland of the People's Republic of China, unless otherwise provided by laws and administrative regulations, you have the following rights in the processing of personal data:

(1) The right to know, the right to decide, and the right to restrict or refuse the processing of your personal data.

(2) Except for special circumstances stipulated by law, you have the right to access and copy your personal data.

(3) You have the right to request the transfer of your personal data to the personal data processor you designate.

(4) If you find that the personal data about you processed by us is inaccurate or incomplete, you have the right to request correction or supplementation.

(5) You have the right to request deletion of your personal data under the following

circumstances:

You can contact us and make your rights request by sending an email to privacy@toponad.com.

8.Security of User Personal Data.

Keeping your personal data safe is our top priority. In order to prevent your personal data from being obtained, used, disclosed or destroyed without authorization, we will take strict security protection measures. We take physical, technical and administrative measures that comply with relevant laws and industry standards. For example, we use firewalls, encryption technologies, and other automated software designed to prevent fraud and identity theft; we only store data on devices and locations that provide a high degree of protection. We will also strictly monitor data access at the perimeter and building entrance through video and other electronic monitoring methods.

We will try to minimize the storage of sensitive data on our servers to protect your privacy.

We also contractually require our partners to protect user data.

TopOn may store data about you collected from our business partners for the purpose of providing services, conducting internal analysis, complying with legal obligations, resolving disputes, and enforcing contracts (such as billing). We will only retain your personal data for as long as necessary, and we will retain the personal data about you collected in accordance with this Privacy Policy for a period of no more than 2 years. Criteria for determining retention periods include: Criteria for determining retention periods include: (i) how long personal data needs to be retained to provide services and to operate our business; (ii) the type of personal data collected; and (iii) whether we are subject to legal , contractual or other similar obligations to retain data (for example: mandatory data retention laws, government requirements to retain data in connection with investigations, or data that must be retained for litigation or disputes).

9.Minor Protection.

TopOn services are primarily intended for adults. If the user is a minor according to applicable laws, please be sure to carefully work together under the supervision and guidance of parents or other guardians before using the apps of developers that have integrated TopOn products and services or the apps of advertisers who cooperate with TopOn for advertising Read the privacy policy of the developer or advertiser's application and this Privacy Policy, and use the application or provide personal data with the consent of the guardian.

We protect the personal data of minors in accordance with applicable laws and regulations, and will only collect, use, store, share, transfer or otherwise collect, use, store, share, transfer or protect minors' personal data as permitted by law, express consent of parents or other guardians, or necessary to protect minors. Publicly disclose personal data of minors. If we become aware that a minor's personal data has been collected without prior verifiable parental consent, we will take steps to delete the relevant data as soon as possible.

If you are the parent or other guardian of a minor, when you have questions about the personal data of the minor under your guardianship, please contact us through the contact data published in this Privacy Policy.

If you are a user in the United States, we guarantee compliance with the Children's Online Privacy Protection Act (COPPA). If the applications of our business partners (for example, application developers) are aimed at children under the age of 13, they need to perform relevant COPPA settings on the application on the TopOn platform when using TopOn services, so that TopOn can Ensure that the collected persistent identifiers of users of the app are processed in compliance with COPPA, including that they will not be used to serve behavioral advertisements or to track users for this purpose. In addition, we do not knowingly collect other personal data (such as accurate geographic location data) from apps that we know are aimed at children under the age of 13.

If a parent or guardian finds that a child has provided us with their personal data without consent, the parent or guardian should promptly contact us. We will take reasonable steps to ensure that such data is removed from our files.

10.Marketing.

If you are our business partner, we may periodically provide you with data about our products, services and content that may be of interest to you by email. If relevant laws require us to obtain your consent before sending you marketing communications, we will only send you relevant marketing communications with your consent.

If you do not wish to receive such marketing communications, you may unsubscribe at any time by following the guidelines provided in the marketing communications or by sending an email to privacy@toponad.com to opt out of receiving such communications.

Privacy Policy of TopOn Website

1.Introduction.

This Privacy Policy of TopOn website applies to data collection and use including while you are visiting and using the TopOn Site. According to the General Data Protection Regulation (GDPR), TopOn is the data controller of your personal data.

2.What Data We Collect.

As you navigate through this TopOn site, we may collect data include: (1) personal data you voluntarily provide (for example, names, birth dates, personal ID card numbers, addresses, telephone numbers, E-mail addresses, occupations, education, work experience and related data), or (2) some data that are not voluntarily provided such as your browser type, domain name, IP address, pages visited, and the length of your user session using various technologies and means, such as Internet Protocol Address, cookies, Internet Tags and navigational data collection.

TopOn is entitled to take measures to validate the authenticity of personal data you provide.

If you give us personal data of somebody else, you should warrant that you have gained their permission to do so.

3.How We Use Your Data.

Based on your consent or based on our legitimate interests, we may use your personal data for the following purposes: (i) to provide you with TopOn’s products or services or data; (ii) to sign you up for an event or training; (iii) to contact you and respond to your requests and enquiries; (iv) for business administration, including statistical analysis; (v) to personalize your visit to the TopOn Site and to assist you while you use the Site; (vi) to improve the TopOn Site by helping us understand who uses the Site; or (vii) to periodically provide you with data about our products and services and content that may be of interest to you by email.

If you decide at any time that you no longer wish to receive such communications from us, you may follow the unsubscribe instructions provided in any of the emails or request to be opted-out of receiving such communications via email to privacy@toponad.com

4.Disclosure of Your Personal Data.

Subject to compliance with applicable laws and regulations, we may disclose User’s personal data to TopOn’s Affiliates and other third parties.

Except as expressly stated in this Policy, according to the Personal data Protection Law of the People’s Republic of China, we will not disclose User’s personal data to any third party without User’s consent. Chinese User can inquire via privacy@toponad.com to receive the name, contact data and other data of our Business Partner and any third party technical service provider

We may also share aggregate or anonymous data with other third parties in accordance with the terms of this Policy.

We may disclose users’ personal data to our affiliates for the purposes set out in this Policy or to promote the products or services of our affiliates to users.

The servers used in the operation of the TopOn Site automatically identify a computer by its IP address. Although, we will not be able to identify the computer using its IP address once you have left the TopOn Site. If we, in good faith, determine that you have or are attempting to misuse or harm the Site, we may investigate and cooperate with appropriate law enforcement agencies to protect our rights or property.

Similarly, we may share your personal data as required or permitted by law to comply with a subpoena or similar legal process or government request, or when we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property, or the rights, property or safety of others, including to advisers, law enforcement agencies, judicial and regulatory authorities. We may also transfer your personal data to a third party that acquires all or part of our assets or shares, or that succeeds us in carrying on all or a part of our business, whether by merger, acquisition, reorganization or otherwise.

Similarly, we may share your personal data as required or permitted by law to comply with a subpoena or similar legal process or government request, or when we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property, or the rights, property or safety of others, including to advisers, law enforcement agencies, judicial and regulatory authorities. We may also transfer your personal data to a third party that acquires all or part of our assets or shares, or that succeeds us in carrying on all or a part of our business, whether by merger, acquisition, reorganization or otherwise.

5.International Transfers.

When you are located in the European Economic Area (“EEA”), personal data collected about you will be transferred to recipients in countries located outside the EEA or can be remotely accessed in countries located outside the EEA, including in countries which may not be decided by the European Commission that it provides an adequate level of protection to personal data. We have followed requirements as set out in applicable law to provide adequate protection to your personal data. To the extent as required by applicable law, our Business Partner will obtain your valid consent to the extent for us to transfer your personal data to recipients including TopOn’s affiliates and any other recipients as described in this Policy, which are located outside the EEA. You are entitled to withdraw your consent at any time.

If you are located in the mainland areas of China, we store your personal data inside the mainland areas of China. In cases where necessary (necessary for business needs, etc.) we will transfer your personal data to recipient outside mainland areas of China according to the requirement of any applicable Chinese data protection law.

6.Your Data Rights.

You have the right to access, modify, correct or delete any personal data which we may have collected. To exercise this right please contact privacy@toponad.com

If you are in the EEA, you have a right to (subject to a limited number of exceptions): (i) request access to and rectification or erasure of your personal data; (ii) obtain restriction of processing or to object to processing of your personal data; and (iii) ask for a copy of your personal data to be provided to them, or a third party, in a digital format. You also have the right to lodge a complaint about the processing of your personal data with your local data protection authority in the EEA.

If you are residents of the State of California in the United States, effective from January 1, 2020, you can request the following data about how we have collected and used your Personal data during the past 12 months:

You may submit requests to exercise your California privacy rights described above by (i) writing to us at privacy@toponad.com (ii) opt out of selling of your data by clicking on the following link: DO NOT SELL MY DATA.

These rights are not absolute, and in some instances, we may decline your request as permitted by law. We will need to verify your identity to process your data, access, and deletion requests and reserve the right to confirm your California residency.

If you are in the mainland areas of China, you have the following rights related to your personal data except when laws and administrative regulations otherwise provide.

(1)Right to be informed, right to decide and right to restrict or refuse processing of your personal data.

(2)Right to access and copy your personal data except in special circumstance provided by law.

(3)Right to request to transfer your personal data to another data handler.

(4)Right to request to revise and supplement your personal data when you notice that the personal data we process is inaccurate or incomplete.

(5)Right to delete your personal data in the following circumstances:

Where the purpose of processing has been achieved or is unable to be achieved, or the personal data is no longer necessary for achieving the purpose of processing;

Where TopOn ceases the provision of its product or service involved, or the retention period has expired;

Where consent is withdrawn by the User;

Where the processing of personal data by TopOn is in violation of any law, administrative regulations or any agreement; or

Any other circumstance as provided by law or administrative regulations.

If it is technically difficult to delete the personal data, TopOn shall cease the processing of the personal data, except for the storage and any necessary measure taken for security protection.

(6)You have the right to request an explain of this Policy.

You can contact us via privacy@toponad.com and request your data rights.

7.Security of Your Personal Data.

The security of User’s data is our utmost priority, and we take strict measures in order to protect our data from unauthorized access, use, disclosure or destruction of data. We have implemented physical, technical and administrative security measures for the Services that comply with applicable laws and industry standards. For example, we use firewalls, encryption technology and other automated software designed to protect against fraud and identity theft; our data is only stored in centers that provide high-level security for User’s data. Physical access is strictly controlled both at the perimeter and at building ingress points by our staff utilizing video surveillance and other electronic means.

We also protect User’s privacy by seeking to minimize the amount of sensitive data that we store on our servers in the first place. We also seek appropriate contractual protection from our partners regarding their treatment of user data.

We will only keep your personal data for as long as necessary and in any event in relation to personal data collected by us on the Site we will only keep this personal data for one (1) year.

8.The Protection of Minors.

The Site does not knowingly collect any personal data from minors. The personal data of any minor you provide shall be agreed by the minor’s parent or guardian in advance. Minor is defined in accordance with the laws applicable to this Policy of TopOn website.

9.Use of Cookies and Other Tracking Technologies.

TopOn may use cookies or other technology (collectively “Cookies”) to collect certain data about you when you are visiting the Site. Please read our Cookies Policy for more details.

10.Outside Sites and Linking.

The Site may contain links and pointers to other sites on the Internet that are owned or operated by third party vendors and other third parties (the “Outside Sites”). TopOn is not responsible for the availability of, or the content located on or through, any Outside Site, including any webcasting or other form of transmission received from any Outside Sites. You should contact the site administrator or Webmaster for those Outside Sites if you have any concerns regarding such links or the content located on such Outside Sites. TopOn permits certain third party links to the home page of its Site, provided that TopOn is provided with notice of such links and does not thereafter object to such linking. TopOn a reserves the right to revoke unilaterally any consent that it may at any time give to any linkage, including linkages to the home page. The Outside Sites are being provided to you only as a convenience and any link or pointer contained on this Site does not imply endorsement of the Outside Sites.

11.Copyright.

All Site content, design, text, graphics, images, logos, buttons, icons, interfaces, audio and video clips, and the selection and arrangements thereof are the exclusive property of TopOn, or its respective content providers, and are protected by Hong Kong SAR and international copyright laws. All software used on the Site is the property of TopOn or its respective software suppliers, and such software is protected by Hong Kong SAR and international copyright laws and other applicable laws and treaties. Users of this Site shall not transmit/post any data to this Site that infringes the copyright or other intellectual property rights of others.

12.Trademarks.

All trademarks, service marks and trade names used on the Site (collectively the “Marks”) are solely owned by TopOn. The Marks may not be used in connection with any product or service that is not a product or service of TopOn or that is likely to cause confusion among customers, or that in any manner disparages or discredits TopOn.

13.Online Conduct.

Any conduct by a person that in TopOn’s sole discretion restricts or inhibits any other person from using or enjoying the Site, is prohibited. You agree to use the Site only for lawful purposes and in accordance with that prohibition. You agree that you will not post on the Site or transmit any unlawful, harmful, threatening, abusive, harassing, defamatory, vulgar, obscene, sexually explicit, profane, hateful, racially, ethnically, or otherwise objectionable material of any kind, including, but not limited to, any material that encourages conduct that would constitute a criminal offense, give rise to civil liability or otherwise violate any applicable local, state, national, or international law.

14.Termination of Usage.

TopOn may, without incurring any liability to you, terminate access by you or suspend any access to all or part of the Site, without notice, for any conduct that TopOn, in its sole discretion, believes is in violation of any applicable law or this Agreement, or is harmful to the interests of another user, a third-party, a merchant, a sponsor, a licensor, a service provider, or the Site.

Due to the rapidly evolving technologies on the Internet, we may occasionally update this Policy. All revisions will be posted to this website www.toponad.com