Privacy Policy


Some Notes on Our Relationship

, doing business as TopicBuddy.com ("Company", "we" or "us") provides a platform and tools to enable users ("Users" or "Clients" or "Customers") to handle lead management and response for the content creation industry ("Service" or "Services").

This Privacy Statement applies to "https://writers.topicbuddy.com" and the customer engagement platform service at "https://writers.topicbuddy.com/login" ("TopicBuddy Outreach Service" or "the Service"), which are owned and operated by STEP BY STEP CO., LTD (SBS). At SBS, we are committed to maintaining the confidentiality and security of any personal information about our users. Your privacy is always at the top of our priorities, and we are focused on protecting it from unauthorized access.

This Privacy Policy supplements our End User License Agreement (EULA)/Terms of Service and spells out how we collect, use, and disclose information from or about you through our website https://writers.topicbuddy.com and the TopicBuddy Outreach Service. Users can access the TopicBuddy Outreach Service via our website https://writers.topicbuddy.com, https://writers.topicbuddy.com/login, applications on Devices, APIs, and third-parties. A "Device" is any device used to access the TopicBuddy Outreach Service, including without limitation a computer, mobile phone, tablet, or other electronic devices. By using our Service, you are consenting to the collection, transfer, processing, storage, disclosure, and other uses described in this Privacy Policy. The use of information collected through our service shall be limited to the purpose of providing the service for which the TopicBuddy client ("Client") has engaged TopicBuddy.

TopicBuddy is responsible for the processing of personal data it receives and subsequently transfers to a third party acting as an agent on its behalf. In certain situations, TopicBuddy may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.



The Information We Collect and Store

TopicBuddy employees will not view the data except where it is necessary to complete tasks for users and clients. In the case that you request our help to resolve your support issues relating to that data, and only after receiving your permission, TopicBuddy employees may access the relevant data.

We may collect and store the following information when running the TopicBuddy Service:
	Information You provide

When you register for an account, we collect some personal information, such as your name, phone number, email address, and location (city, country). You may also ask us to import your contacts and email history by giving us access to your third party services (for example, your email account) or to use your social networking information if you give us access to your account on social network connection services. In fact, in order to use our Service, you must link a third-party email account to your TopicBuddy account. We then import, create, and update versions of your address book and emails for you to access in TopicBuddy. You will also have the option to import and update versions of your calendar, social media contacts, and mobile phone call history, and you can later choose to upload files to, or provide comments through, TopicBuddy. When you invite others to join TopicBuddy by using the Service, we send them an email for that invitation at the email addresses assigned to them in your address book.

When we configure and customize deals, or manage and perform recurring billing, we may also ask you to provide information such as your bank account number; credit card number; national ID number, insurance number, social security number; taxpayer identification number, tax file number, passport number, and driver's license number.



Collection and Use of 3rd Party Personal Information

You may also provide personal information about other people, such as their email address. This information is only used for the sole purpose of completing your request or for whatever reason it may have been provided.

If you believe that one of your contacts has provided us with your personal information and you would like to request that it be removed from our database, please contact us at support@topicbuddy.com.



Your Data and Other Information About You

With your permission (which you grant when you sign up for or begin using our Service), TopicBuddy collects and stores the information you provide or that we collect in order to administer our Services and/or as otherwise described in this Privacy Policy or our Terms of Service. If you or another user uploads a file to TopicBuddy that has been previously uploaded by you or another user, we may associate all or a portion of the previous file with the applicable accounts rather than storing duplicates.

We do not honor "Do Not Track" requests through your web browser because the data we collect is necessary to improve security, to generate reporting statistics, and to improve the user experience with our Services.

SBS is the owner of the information collected through the Service, provided however that you remain the owner of all business information and data uploaded to our Service, see "User Data" below.



User Data Supplementation

We may receive additional demographic information about you from other sources, including publicly available databases or third parties from whom we have purchased data, and combine this data with information we already have about you. This helps us to update, expand, and analyze our records, identify new customers, and provide products and services that may be of interest to you. If you provide us personal information about others, or if others give us your information, we will only use that information for the specific reason for which it was provided to us.

Users granted access to a TopicBuddy account by a user routinely submit user data to us when using the services. For example, leads imported into TopicBuddy by a User or on behalf of a User are User Data.

TopicBuddy obtains this business contact and company information from third party sources, such as business intelligence platforms. The information obtained by these third-party sources is from publicly available sources such as news articles. This information is used to support TopicBuddy's marketing and sales efforts. The TopicBuddy sales team may contact you based on this information to gauge your company's interest in TopicBuddy's services and technology solutions. You may opt-out of these communications at any time by clicking the unsubscribe link provided in the email or by sending a request to the TopicBuddy Technical Support team by emailing support@topicbuddy.com.



Log Data

When you use the Service, we automatically collect certain information from your Device, its software, and your activity using the Services. This may include, for example (but without limitation), the Device's Internet Protocol ("IP") address, browser type, the web page visited before or after you came to our website, the information you search for on our website, locale preferences, identification numbers associated with your Devices, your mobile carrier, date and time stamps associated with transactions, system configuration information, metadata, and interactions with the Service, Internet service provider, referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data to analyze trends in the aggregate and administer the site.
Cookies.

TopicBuddy and its partners use cookies or similar technologies to analyze trends, administer the website, track users' movements around the website, and to gather demographic information about our user base as a whole. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our website or service.

We partner with third parties to either display advertising on our website or to manage our advertising on other sites. Our third-party partners may use technologies such as cookies to gather information about your activities on this website and other sites in order to provide you advertising based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by clicking here (or if located in the European Union click here). Please note this does not opt you out of being served ads. You will continue to receive generic ads.
Cookies Settings.



Social Media Widgets/Buttons

Our website includes social media features, such as the Facebook Like button and widgets, such as the "Share This" button for Twitter and LinkedIn. These features may collect your IP address and the page you are visiting on our site, and they may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our site. Your interactions with these features are governed by the privacy policy of the company providing it.



Purpose and Legal Basis for Using Personal Information

General Use. For Clients, we use personal information to provide the Services and contact Clients regarding account activities, new versions and product offerings, or other communications relevant to the Services. If you contact us by email or by filling out a registration form, we may keep a record of your contact information and correspondence, and may use your email address, and any information that you provide to us in your message, to respond to you. In addition, we may use the personal information described above to send you information regarding the Service. If you decide at any time that you no longer wish to receive such information or communications from us, you can access your account and remove any personal information, but this may result in the closure of your account.

Customer Data is used in accordance with Customer's instructions, including any applicable terms in the Terms of Service and Customer's use of Services functionality, and as required by applicable law. Customers may, for example, use the Services to grant and remove access to a ToppicBuddy account, assign roles and configure settings, access, modify, export, share and remove Customer Data and otherwise apply its policies to the Services. With regards to Customer Data we act as a Service Provider and do not retain, use or disclose the personal information for a commercial purpose other than providing the Services.

In the course of using the Service, we may collect or otherwise obtain information that can be used to contact or identify you ("Personal Information"). Under one or more of the following GDPR lawful bases:

    

  1. Data subject has given consent to the processing of his or her personal data for one or more specific purposes
    2. 

  2. Processing is necessary for the performance of a contract to which the data subject is a party or in order to take steps at the request of the data subject prior to entering into a contract
    3. 

  3. Processing is necessary for compliance with a legal obligation to which the controller is subject
    4. 

  4. Processing is necessary in order to protect the vital interests of the data subject or of another natural person
    5. 

  5. Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller
    6. 

  6. Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child

We use your personal information for the following purposes or as otherwise described to you at the time of collection:

(a) Service delivery
    

  • Provide, operate, maintain, and improve our Service and Websites
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  • Communicate with you regarding the Service, including by sending you Service announcements, technical notices, updates, security alerts, and support and administrative messages or other communication
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  • Process your Service subscription transactions and process your related payments
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  • Understand your needs and interests, and personalize your experience with the Service and our Websites
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  • Provide support for the Service and respond to your requests, questions and feedback

(b) Research and development

We may use your personal information for research and development purposes, including to analyze and improve the Service and our business and develop other products and services. As part of these activities, we may create aggregated, de-identified or other anonymous data from personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.

(c) Marketing

We and our third party advertising partners may collect and use your personal information for marketing and advertising purposes:

    

  • Direct marketing. If you request information from us, use the Service or participate in our surveys, promotions or events, we may send you related marketing communications as permitted by law but will provide you with the ability to opt out.
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  • Interest-based advertising. We may contract with third-party advertising and social media companies to display ads on our Service and other sites. These companies may use cookies and similar technologies to collect information about you (including the device data and online activity data described above) over time across our Service and other sites and services or your interaction with our emails, and use that information to serve ads that they think will interest you.
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  • Other marketing activities to pursue our legitimate business interest to offer you products or services that may be of your interest.


(d) Compliance and protection
    

  • Protect our, your or others' rights, privacy, safety or property (including by making and defending legal claims)
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  • Audit our internal processes for compliance with legal and contractual requirements and internal policies
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  • Enforce our Terms of Service
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  • Protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft
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  • Comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities

(e) Other purposes with your consent

In some cases we will ask for your consent to collect, use or share your personal information for other purposes. For example, we may ask for your consent to post your testimonial or endorsement.



Information Sharing and Disclosure by Us (Do Not Sell My Information)

We do not sell Personal Information to third parties.
Under the CCPA, a business that sells California residents' personal information to others: 1) must give notice to California residents before selling their personal information to others; and 2) must provide the right to opt out of the sale of their personal information.
We do not sell personal information and will not sell it without providing a right to opt out, including personal information of anyone under 16 years old. Thus, these notification and opt-out requirements do not apply to us.
Service Providers, Business Partners and Others
We may use certain trusted third-party companies and individuals to help us provide, analyze, and improve the Service (including but not limited to data storage, maintenance services, database management, web analytics, payment processing, and improvement of the Service's features). These third parties may have access to your information for purposes of performing these tasks on our behalf and under obligations similar to those in this Privacy Policy. As of the date, this policy went into effect, we use Amazon's S3 storage service to store some of your information (for example, your files). You can find more information on Amazon's data security from the S3 site.



Third-Party Applications

Our website includes links to other websites whose privacy practices may differ from those of TopicBuddy. As of the date, this policy went into effect, TopicBuddy has never and will not share your information with a third-party application. If you submit personal information to any of those websites, your information is governed by their privacy policies. In the future, with your consent, we may share your information with a third-party application (for example when you choose to access our Services through such an application). We are not responsible for what those parties do with your information, so you should make sure you trust the application and that it has a privacy policy that is acceptable to you.

Compliance with Laws and Law Enforcement Requests; Protection of TopicBuddy's Rights
We may disclose to third parties data stored in your TopicBuddy account and information about you that we collect only in the ways that are described in this privacy policy and when we have a good faith belief that disclosure is reasonably necessary to (a) comply with a law, regulation, or compulsory legal request, such as to comply with a subpoena; (b) protect the safety of any person from death or serious bodily injury; (c) prevent fraud or abuse of TopicBuddy or its users, or (d) to protect TopicBuddy's rights. If we provide any data stored in your TopicBuddy account to a law enforcement agency, we will remove TopicBuddy's encryption from the information before providing it to law enforcement. However, TopicBuddy will not be able to decrypt anything that you encrypted prior to uploading it to TopicBuddy.


Business Transfers

If we are involved in a merger, acquisition, or sale of all or a portion of our assets, your information may be transferred as part of that transaction, but we will notify you (for example, via email, sign in notification, and/or a prominent notice on our website) if that happens or if your information otherwise becomes subject to a different privacy policy in lieu of this one. We will also notify you of choices you may have regarding the information.



Changing or Deleting Your Information

Upon request, TopicBuddy will provide you with information about whether we hold, or process on behalf of a third party, any of your personal information. If you are a registered user, you may review, update, correct, or delete certain Personal Information provided in your registration or account profile by changing your account settings. If your personal information changes, or if you no longer desire our Service, you may update or delete it by making the change in your account settings, although (in some cases) we may retain copies of your information if required by law, to protect our rights, or if it is not technically reasonably feasible to remove it. You may at any time withdraw any consent that you have provided to us to process your information or exercise any of the following rights by contacting us as provided below. Please note that we may ask you to verify your identity before taking further action on your request, for security purposes.

    

  • Right of Access - the right to be informed of and request access to the personal data we process about you;
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  • Right to Rectification - the right to request that we amend or update your personal data where it is inaccurate or incomplete;
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  • Right to Erasure - the right to request that we delete your personal data;
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  • Right to Restrict - the right to request that we temporarily or permanently stop processing all or some of your personal data;
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  • Right to Object - the right, at any time, to object to us processing your personal data on grounds relating to your particular situation;
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  • the right to object to your personal data being processed for direct marketing purposes;
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  • Right to Data Portability - The right to request a copy of your personal data in electronic format and the right to transmit that personal data for use in another party's service; and
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  • Right not to be subject to Automated Decision-making
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  • Right to Non-Discrimination – You have a right not to receive discriminatory treatment for exercising your privacy rights as identified in this section of the privacy notice as conferred by the CCPA.

For questions about your Personal Information on our Service, please contact support@topicbuddy.com or by contacting us by telephone or postal mail at the contact information listed below. We will respond to your inquiry within 30 days.



Data Retention

TopicBuddy will retain personal data we process on behalf of our Clients and our Clients' customer data for as long as needed to provide services to our Client. Our intention is to retain your information for as long as your account is active or as needed to provide you with the Services. If you wish to cancel your account or request that we no longer use your information to provide you Services, you may delete your account. We may retain and use your information as necessary to comply with our legal obligations, resolve disputes, enforce our agreements and rights, or if it is not technically reasonably feasible to remove it. Consistent with these requirements, we will try to delete your information quickly upon request. Please note, that TopicBuddy may retain your personal data for longer where there is a legal obligation, contractual, or legitimate interest unless these interests are overridden by the individual's fundamental rights; in those cases, data will be removed once it is no longer needed for those purposes. In addition, we do not provide access, transfer, change, or delete information from our servers' files where that right adversely affects the rights of others.



Choice/Opt-Out

If you wish to subscribe to our newsletter(s), we will use your name and email address to send the newsletter to you. You may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails, accessing the email preferences in your account settings page, or you can contact us at support@topicbuddy.com.



Blogs

Our website offers publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog or community forum, contact us at support@topicbuddy.com. In some cases, we may not be able to remove your personal information. If this is the case, we will let you know and indicate why.



Security

TopicBuddy stresses its privacy and security standards. Although no one can guarantee absolute security, we regularly re-evaluate our privacy and security policies in order to adapt to new challenges. We follow generally accepted standards to protect the information submitted to us, both during transmission and once we receive it. We encrypt the most sensitive data that you store on TopicBuddy using the AES-256 standard, which is the same encryption standard used by banks to secure customer data.



Children

Our Services are not directed to persons under 13. We do not knowingly collect personal information from children under 13. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without the parent's consent, he or she should contact us at support@topicbuddy.com. If we become aware that a child under 13 has provided us with Personal Information, we will take steps to delete such information from our files. Because it does not collect such information, we have no such information to use or to disclose to third parties. SBS has designed this policy in order to comply with the Children's Online Privacy Protection Act ("COPPA") and California Consumer Privacy Act ("CCPA").



Foreign Use Of The Service

To the extent that you are accessing our Service in the United States while domiciled outside of the United States, you acknowledge that the Personally Identifiable Information you are providing us may be collected and stored in the United States and elsewhere and therefore consent to the transfer of information to and storage of the information outside of your domiciled country and in the United States and elsewhere.



Contacting Us

If you have any questions about this Privacy Policy, please contact us at support@topicbuddy.com, or at 9 B3.1 Le Quang Dao, Danang, Vietnam. Or by calling at (84) 070 31 258 31.

For European Union data subject, you have the right to lodge a complaint with a supervisory authority concerning TopicBuddy's data processing activities. For questions, or to exercise your rights as an EU data subject, please contact us at (84) 070 31 258 31.



Changes to our Privacy Policy

If we make a change to this privacy policy, we will provide you with notice (for example, by email, a sign-in notification, or some other means) prior to the change becoming effective. By continuing to use the Service after those changes become effective, you are agreeing to be bound by the revised Privacy and Security Policy; if you do not agree to the change, simply don't use the Service after the change is effective, in which case the change will not apply to you.



Information Related to Data Collected through the TopicBuddy Platform

TopicBuddy collects information under the direction of its Clients and has no direct relationship with the individuals whose personal data it processes.



Choice

TopicBuddy acknowledges that you have the right to access your personal information. We collect information for our clients. If you are a customer of one of our Clients and would no longer like to be contacted by one of our Clients that use our service, please contact the client that you interact with directly.



Service Provider, Sub-Processors/Onward Transfer

TopicBuddy may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the provisions in this Policy regarding notice and choice, as well as the service agreements with our Clients. A list of Sub-Processors can be made available upon request.



Access to Data Controlled by our Clients

TopicBuddy has no direct relationship with the individuals whose personal data it processes. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data, should direct his query to the TopicBuddy's Client (the data controller). If the Client requests TopicBuddy to remove the data, we will respond to the request within 30 business days.



Additional Limits on Use of Your Google User Data

Notwithstanding anything else in this Privacy Policy, if you provide the App access to the following types of your Google data, the App's use of that data will be subject to these additional restrictions:

    

  • The App will only use access to read, write, modify or control Gmail message bodies (including attachments), metadata, headers, and settings to provide a web email client that allows users to compose, send, read, and process emails and will not transfer this Gmail data to others unless doing so is necessary to provide and improve these features, comply with applicable law, or as part of a merger, acquisition, or sale of assets.
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  • The App will not use this Gmail data for serving advertisements.
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  • The App will not allow humans to read this data unless we have your affirmative agreement for specific messages, doing so is necessary for security purposes such as investigating abuse, to comply with applicable law, or for the App's internal operations and even then only when the data have been aggregated and anonymized.
    • 



Google API Services Usage Disclosure

TopicBuddy's use of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.
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