Privacy Policy

Privacy Policy2020-01-10T11:16:58+00:00

Privacy Policy

Topa Equities, Ltd. (“Topa” or the “Company”) is committed to treating the personal and corporate information of our customers, vendors, and website visitors with respect and sensitivity.

We’ve updated our Privacy Policy and improved our privacy practices so we can better safeguard your data. By using our website, www.topa.com or www.topaequities.com, or by providing us your personal information you accept the terms of this Privacy Policy. This Privacy Policy identifies how we will collect, and process use any personal information you provide us, such as your name, email, address, financial account information, etc.

If you are a California resident, our privacy practices comply with the California Consumer Privacy Act of 2018 (“CCPA”), and any CCPA-specific information is identified in this Policy. Explanation of your rights under the CCPA can be found here.

As our services evolve and we perceive the need or desirability of using your personal data collected in other ways, we may from time to time amend this Privacy Policy. The effective date appears at the end of this Privacy Policy, and we encourage you to check our Site occasionally to review the current Privacy Policy in effect and any changes that may have been made to it.

By providing your Personal Information to us in any format (e.g., via email, telephone, fax, or in person) and/or continuing to use any of our Services or visiting our Site you accept and consent to the practices described in this Privacy Policy.

1. Introduction

This Privacy Policy describes how the Company collects, uses, and shares information about or customers, clients, vendors, or visitors to our website at www.topa.com or www.topaequities.com (“Site”). The Site and our other programs and services are the “Services.”

Region specific provisions. Certain provisions of this Policy, which are clearly labelled, apply only to users who are citizens or residents of particular regions (e.g., California). Otherwise, the Policy applies to all users of our Services, regardless of location.

Children. The Services of the Company are not directed to children. If you become aware that a child (based on the jurisdiction where the child lives, which in the United States means someone under the age of 13) has provided us with personal information without parental consent, contact us at the location identified below in the Contact Us section.

2. What Personal Information does the company collect?

We collect personal information that you enter on our Site or otherwise volunteer to us when you contact us to, among other things, request information, apply for employment, or obtain any other Services.

For purposes of this Policy, “Personal Information” means information (whether stored electronically or in paper-based filing systems) relating to a living individual who can be identified from that data (or from that data and other information in our possession). The Company collects only the following categories of Personal Information as defined by the CCPA:

Identifiers Name, address, email, phone.
Other Data Certain financial information, and for employees and prospective

employees, possibly medical and health information

Professional Data For employees and prospective employees, CV, resume, employment history, etc.
Education Data For employees and prospective employees, educational background, grades, scores, etc.

3. How does the Company use Personal Information?

Topa does not sell your Personal Information to any Third Parties or disclose your personal information to third parties for any business purpose.

Topa uses your Personal Information for a limited number of purposes, as set forth in this Privacy Policy. These purposes include:

  • To provide you with the information or Services that you request from us
  • To carry out our obligations arising from any contracts entered into between you and us, or between you and any of our affiliates
  • To notify you about changes to our Services
  • To comply with applicable laws and regulations
  • To perform data analyses (including anonymization and aggregation of Personal Information)
  • For prospective employees, to respond to and process your job application and CV

Information we receive from other sources.

Topa may occasionally receive information from our subsidiaries and affiliated companies. In those situations, we will use the information for the purposes set forth above and in the privacy policies of the subsidiary or affiliate.

4. Our storage of your Personal Information

Topa uses reasonable and appropriate measures to protect your Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into due account the risks involved in the processing undertaken and the nature of the Personal Information we collect.

We will keep your Personal Information for as long as we need it, or as otherwise prescribed by law, for the purposes set out above. This period will vary depending on your interactions with us. We may also keep a record of correspondence with you for as long as is necessary to protect us from a legal claim.

5. Access to other websites

Our Site may include links to and from other websites of our subsidiaries and affiliated companies. If you follow a link to any of these websites, please note that these websites are not covered by this Privacy Policy, and each has its own privacy policy. We encourage you to read the applicable privacy policies and terms and conditions of such parties or websites. This Privacy Policy only applies to how Topa deals with your Personal Information, and it does not apply to any other company or any other company’s websites even if you access them via our Site. Please check those websites’ policies before you submit any Personal Information to them.

6. Additional Policies in Compliance with the CCPA

The CCPA affords California consumers the rights with respect to their Personal Information set forth in this section.

6.1   Right to Know About Personal Information Collected, Used, Disclosed, or Sold

California consumers have the right to request that the Company disclose what personal information it has collected, used, disclosed, and sold over the 12-month period preceding the Company’s receipt of such a request. To exercise this right, a California consumer must submit to the Company a verifiable request to know such information. This request can be submitted by following the procedures set forth in the Contact Us section.

6.2   Right to Request Deletion of Personal Information

California consumers have the right to request the deletion of their personal information collected or maintained by the Company. To exercise this right, a California consumer must submit to the Company a verifiable request to delete such information. This request can be submitted by following the procedures set forth in the Contact Us section.

6.3   Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

California consumers have the right to not be discriminated against because the consumer exercised any of the consumer’s rights under the CCPA. That means that the company may not deny goods or services to the consumer, charge different rates for goods or services, or provide a different level or quality of goods or services if the consumer chooses to exercise their rights under the CCPA (unless the different rate or different level or quality is reasonably related to the value to the business of the consumer’s data).

6.4   Submitting a CCPA Data Request

To submit a request to know about the Personal Information we collect about you as described in Section 6.1 or a request for deletion of your Personal Information as described in 6.2, please contact us by calling this toll free number 1-855-761-TOPA (8672) or by emailing us at CCPA@topa.com.

We are required to verify the identity of the individual submitting a request to know or delete a request. To verify your identity, you must provide:

  • If Topa has previously received your email address, Topa may verify that you have access to that email address by sending a verification code; or
  • Verification of government issued identification. In the event the person requesting the information is not the individual we have on record Topa may require legal documents to support the requestor’s legal authority to obtain and access those records

Authorized Agent

California consumers may designate an authorized agent to exercise a CCPA right on the consumer’s behalf. If a consumer utilizes an authorized agent to exercise a CCPA right, the following proof that the agent has been authorized to act on the consumer’s behalf will need to be provided:

  • Proof of written permission by the consumer for the authorized agent to act on his or her behalf and separate verification of the consumer; or
  • Proof that the authorized agent holds a power of attorney to act on the consumer’s behalf pursuant to Cal. Probate Code §§ 4000-4465

7. Conditions of use and changes to our privacy policy

If you choose to visit our Site, or share Personal Information with us, your visit and any dispute over privacy is subject to this Notice, including limitations on damages, resolution of disputes, and application of the law of the State of California. If you have any concern about our privacy practices, please contact us with a thorough description, and we will try to resolve it. As our business changes, our Privacy Policy and Terms of Use may change also. We may e-mail periodic reminders of our notices and conditions, but you should check our Site frequently to see recent changes. Unless stated otherwise, our current Privacy Policy applies to all information that we have about you and your account.

8. Contacting us

This Site is owned and operated by Topa. If you have any questions or suggestions with respect to this Privacy Policy or our privacy practices, please e-mail us at contactus@topa.com or you can contact us by mail at:

Topa Equities, Ltd.
Attn: Privacy Manager
1800 Avenue of the Stars
Suite 1400
Los Angeles, CA 90067

1-855-761-TOPA (8672)

CCPA-Specific Requests: Please submit CCPA-specific data requests through the procedures set forth in Section 6.

Updated January 1, 2020