Privacy Data Policy

This Privacy Notice describes how Topper collects, uses, and shares the Personal Data that it receives from you. It applies to all platforms, websites, and services operated by Topper.

Introduction and Scope

This Privacy Notice applies to all users of Topper services and covers the collection, processing, and sharing of personal information across our platforms, including our website, mobile applications, and any affiliated services. It is important that you read this Privacy Notice together with any other privacy notices or fair processing notices we provide on specific occasions when we are collecting or processing Personal Data about you.

Changes to This Privacy Notice

We may update this Privacy Notice from time to time to reflect changes in our business operations or legal obligations. If we make material changes, we will notify you via email, through our website, or within the Topper widget. The latest version will always be available on our website, and the "Last Updated" date will indicate when it was revised.

It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during your relationship with us.

Our Relationship to You

Topper services are offered by the following entities:
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U.S. Users: Uphold HQ Inc.
U.K. Users: Uphold Europe Limited
EEA Users: Uphold Lithuania UAB
Other Regions: Uphold Worldwide Ltd.

Depending on your location and the services you use, one of these entities will be responsible for processing your Personal Data.

How do we collect Personal Data about you?

We collect Personal Data about you both directly and indirectly when you register, open, and use a Topper account. We also collect the information that is sent to us by your device to improve your experience. If you are using Topper on a location-enabled device we may also collect geographical location data or use various means to determine your location (such as sensor data from your device that may, for instance, provide data on nearby cell towers and Wi-Fi access spots). We may also automatically collect technical data about your equipment, browsing actions, and patterns by using cookies, server logs, and other similar technologies. Please see the section on Cookies and Similar Tracking Technologies for additional information.

We also receive data about you indirectly from third parties, for instance, technical data from analytics and advertising partners like Google; from identity verification providers and other screening services; and affiliated and non-affiliated third parties, such as credit bureaus and other financial institutions.
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What Personal Data do we collect?

We collect only the Personal Data necessary to provide and support our Topper services while meeting our legal and regulatory obligations. This data may be collected directly from you or indirectly from other sources, as outlined below. Additionally, when you use Topper, our systems automatically collect certain information.
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Identity verification data: To verify your identity, we collect your name, address, phone, email, and facial image (selfie). We may also require you to provide additional Personal Data for verification purposes, including your date of birth, taxpayer or government identification number, or a copy of your government-issued identification. We may obtain information from affiliated and non-affiliated third parties, such as credit bureaus, identity verification services, and other screening services to verify that you are eligible to use Topper.

Financial data: We may collect various information regarding your finances from third parties and this may include accounts and credit and debit cards you hold, balances, transactions, and a risk score.

Account activity data: We collect information about your transactions using Topper, as well as other details of products and services you have purchased from us.

Application use data: We may collect data on your interaction and use of Topper. This includes visits to our website or app, sign-up activity, your debit or credit card, and other payment details to enable you to use Topper, along with any additional information you may disclose to our user support team to resolve problems you report.

Your device data: We collect and process your internet protocol (IP) addresses, your login data, browser type, and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access Topper.

Marketing data: We collect and process your preferences in receiving marketing from us, and your email address.
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Cookies and Similar Tracking Technologies

We and third parties on our behalf may employ various tracking technologies, such as cookies and other similar technologies (collectively, “Tracking Technologies”), to collect additional Personal Data automatically as you interact with our Services. These Tracking Technologies help us personalize your experience, streamline your interactions, and optimize our content and services.

Cookies

Cookies are small data files stored on your device that enable us to recognize your browser and remember certain information. We may use cookies for various purposes, including to:
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Analyze our web traffic using an analytics package
Identify whether you have previously visited our Sites
Test content on our Sites
Store information about your preferences
Recognize when you return to our Sites
Track advertising attribution statistics
Remember user details to streamline transactions, including pre-filling email, past transactions, and asset details

Preference Cookies & User Control

Some cookies store user preferences to enhance your experience. These cookies allow us to pre-fill forms with your email and transaction details when you return to our platform.
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Consent & Control: When you first visit our Site, you can manage your cookie preferences via our cookie consent banner, where you may opt in or out of preference storage separately from analytics and advertising cookies.
Updating Your Preferences: You can modify your cookie settings at any time through our widget, where you can enable or disable preference cookies.
Opting Out via Browser Settings: If you prefer not to have this information stored, you can disable cookies via your browser settings. Disabling cookies may affect certain features. For guidance on modifying your browser settings, please refer to your browser’s Help menu (e.g., Chrome, Firefox, Safari). Please note that disabling preference cookies may require you to manually re-enter details during future visits.

Third-Party Cookies
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Our Site uses third-party cookies for various purposes, including:
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Cloudflare – Ensures a stable connection and helps identify spammers.
Google Analytics & Ad Tags – Tracks website traffic and user interactions to improve services and ad targeting.
LinkedIn Ads & Twitter Ads – Tracks ad performance and enables targeted advertising.

If you want to exercise your rights regarding personal data collected via cookies and similar tracking technologies, please see the What are your legal data privacy rights section below.

The information generated by the cookies will be transferred to Google and Cloudflare in the above-mentioned scope. Therefore, we would like to inform you that detailed information on the use of cookies by these entities can be found at:

Google Link

Cloudflare Link

Analytics

Our Site and our third-party technology providers use third-party analytics services (such as Google Analytics) to evaluate your use of the Site, compile reports on activity, collect demographic data, analyze performance metrics, and collect and evaluate other information relating to the Site and Internet usage. These third parties use cookies and other technologies to help analyze and provide us with the data. For more information on how to opt-out of Google Analytics tracking, click here.

You can opt-out of targeted advertising by using the links below:

Google
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Twitter
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LinkedIn

‍Additionally, you can opt-out of some of these services by visiting the Digital Advertising Alliance's opt-out portal at: http://optout.aboutads.info/. Or by visiting any of the links below: http://optout.networkadvertising.org/ http://youronlinechoices.eu/, or https://youradchoices.com/appchoices for mobile application opt-out offering. To opt-out of LinkedIn Pixel tracking, you can adjust your ad preferences in your LinkedIn account settings or use the Digital Advertising Alliance's opt-out portal at http://optout.aboutads.info/

How do we use your Personal Data, and on what legal basis do we collect your Personal Data?

We process your Personal Data for the following purposes:
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To provide you with a service: It may sound obvious, but we need to make Topper work in the first place. Without your name, credit/debit card information, and other details; and information about your interaction and use of Topper and the technology you use to access Topper, we simply could not offer you our products and services.
To verify your identity: As a financial institution, we must be able to confirm the true identity of our users. There are rules and regulations across the globe that require us to identify our customers, including laws concerning anti-corruption, anti-bribery, anti-terrorism, and anti-money laundering. We use Veriff to verify your identity by determining whether a selfie you take matches the photo in your government-issued identification. Veriff’s facial recognition technology collects information from your photos that may include biometric data, and when you provide your selfie, you will be asked to agree that Veriff may process biometric data and other data (including special categories of data) from the photos you submit and share it with us. Automated processes may be used to make a verification decision. Veriff’s privacy policy describes its collection, processing, storage, and use of your personal data in more detail.
To verify your address: We use Ekata to validate your physical address. Automated processes may be used to make a verification decision. Ekata’s privacy policy describes its collection, processing, storage, and use of your personal data in more detail. In lieu of Ekata, we may use Trulioo to validate your physical address. Automated processes may be used to make a verification decision. Trulioo’s privacy policy describes the collection, processing, storage, and use of your personal data in more detail. We additionally may require further address verification and validation through our partner, SumSub by requesting that you provide us with documentation verifying your physical address such as bank statements, utility bills, Internet/cable TV/house phone line bills, tax returns, council tax bill, and or government-issued certifications of residence. SumSub’s privacy notice describes its collection, processing, storage, and use of your personal data in more detail.
To perform your transactions: To verify that you are eligible to use Topper and perform the transactions you request, and also to ensure compliance with regulatory requirements (e.g., anti-money laundering laws) and our own internal policies, we must receive and share various information regarding your finances with third parties including accounts you hold, balances, transactions, and a risk score. Please review our sub-processor list for more information on these third parties.
To prevent fraud: We use the personal information we collect in connection with providing you our services to detect and prevent fraudulent activity. We share this information with Unit 21 and Sift, both third-party service providers, to assist us with this effort. Unit 21 and Sift use various technologies to capture various device identifiers, such as canvas fingerprinting and may use automated decision-making to detect and prevent fraudulent activity. For more information on the privacy practices of Unit 21 please review their Privacy Policy. For more information on the privacy practices of Sift, please review their Service Privacy Notice.
To comply with legal obligations: We retain and process data as required by anti-money laundering and other financial regulations.
To keep your account secure: We use your phone number to verify the number you provide at signup. This includes sending SMS or text messages (including by an automatic telephone dialing system) to any of the phone numbers provided by you or on your behalf in connection with your Topper account. We additionally use your email address to conduct a verification round trip at each session.
To keep you informed: It is important for security and financial transparency that we keep you aware of your transactions and related activity at Topper. We will send you emails with confirmations, invoices, technical notices, updates, security alerts, legal and support, and administrative messages.
For investigations: Occasionally, we need to look at your account activity to check and protect against fraudulent, unauthorized, or illegal behavior.
For customer care: We strive to make sure you can easily use Topper with no headaches, but sometimes you need help. Our customer care team will occasionally need access to your account data to fix any issues or answer your questions.
To manage and improve our service: We like to understand how you use and engage with Topper to make sure it is the best it can be. This process includes combining different accounts, transactional, marketing, and other data to analyze the effectiveness and performance of our offering.
Marketing and advertising analytics: We want you to be aware of product updates, news, events, promotions, and much more. If you consent, we will (i) send you information, including regular personalized emails, to keep you up to date with all things Topper; (ii) keep you informed of industry updates and much more; (iii) from time to time we may also invite you to take part in our polls, surveys, focus groups and other types of market research; and (iv) if you have consented/opted in by accepting our cookies we collect hashed identifiers derived from email addresses for cross-device tracking for targeted advertising, and where you may have seen Topper advertisements.
Business operations: We may need to use your Personal Data for our business operations, including internal training and administration, legal compliance, enforcing our legal rights, protecting third-party rights, and in connection with a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets.
Website and software applications: We use data analytics to improve our website and software applications, activities and operations, products/services, events, etc.
Third parties: If you (i) use Topper by (a) using an application (whether directly or by authorizing an application to use Topper, (b) using a link provided by a third-party, or (c) any third party integrations or (ii) if you partner with us in a program or other business arrangement where a third-party intermediary is involved, all such third parties may receive detailed information about your account, your use of Topper, transaction history or even the ability to take actions on your behalf. When you authorize an application or third-party integration via Topper, you will be notified of what Personal Data will be shared with these third parties. Information collected by these applications or third-party integrations is subject to their terms and policies and is required by contract by Uphold to maintain the confidentiality and security of your Personal Data.

We process your Personal Data based on the following primary legal grounds.
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Consent: We get your clear permission before using your data.
Contractual Necessity: We process data needed to provide our services.
Legal Obligations: We must collect some of your information to follow laws and regulations, like those that prevent money laundering and require financial reports.
Legitimate Interests: We process data for legitimate business needs while protecting your rights.

It is important to note that a single processing activity may rely on multiple legal bases. We carefully assess and document the most appropriate legal ground for each specific purpose of data processing, ensuring transparency and compliance with data protection regulations.

How do we keep your Personal Data safe?

We have implemented security measures to prevent your Personal Data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed.

We protect your Personal Data by maintaining physical, electronic, and procedural safeguards, incorporating tested security technologies, in compliance with applicable laws. We may use network safeguards such as firewalls and data encryption, enforce physical access controls, and authorize access to Personal Data only for those people who require access to fulfill their job responsibilities.

In addition, we limit access to your Personal Data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality. Those with access to your Personal Data are carefully screened, periodically reevaluated and are required to keep all your Personal Data confidential.

How do we share your Personal Data?

To verify your identity and comply with legal requirements, we collect name, address, phone, email, date of birth, taxpayer/government ID numbers, government-issued identification documents, and additional verification data as needed. We share necessary personal data with identity verification partners for KYC verification, and you can review our partners' privacy policies to understand how they handle your data. We may also obtain information from credit bureaus, identity verification services, and screening services to verify your eligibility for our Services. For virtual IBAN services, we share necessary personal data with LHV Bank who processes your data according to their privacy policy here.

‍Based on our legitimate interest in fraud prevention and risk assessment, we may in some instances require full KYC verification. To facilitate KYC verification and ensure compliance with applicable laws, we may share your KYC data with:
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Regulatory Authorities and Law Enforcement: Where required by law or under lawful requests, subpoenas, or legal processes
Identity Verification and Compliance Partners: Trusted third-party service providers that assist in identity verification, fraud prevention, and compliance checks
Financial Institutions and Payment Service Providers: Banks, payment processors, and financial institutions involved in transaction processing and settlement
Affiliates and Business Partners: Where necessary for providing our services, ensuring platform security or enabling regulatory compliance

All third parties receiving your KYC data must adhere to strict confidentiality and security measures in accordance with applicable data protection laws. Data shared with external parties is limited to what is necessary for the specified purposes.

We sometimes share your information internally between employees and contractors of our parent company the Uphold Group (including those based outside the European Economic Area (“EEA”)), in particular in connection with activities undertaken jointly or in common with such group members and/or provide IT and system administration services and undertake management reporting.

We do not sell, trade or otherwise transfer your Personal Data to third parties other than third parties who assist us in operating Topper, third parties who assist us in facilitating certain programs and other business arrangements for which you have expressly agreed to participate, management and reporting, maintaining compliance with relevant laws (including compliance with relevant anti-corruption, anti-bribery, anti-terrorism, and anti-money laundering laws), conducting our business or supporting our users, or providing you with applications or services integrated via our API. We require that those third parties agree to keep this information confidential and secure on the same conditions and protection levels we provide to you as a user, per relevant privacy laws, including the GDPR. A complete list of our sub-processors can be viewed here.

Depending on our contractual obligations, we may share the following information with contracted affiliates in the United States for transactional reporting purposes:
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Transaction ID
Timestamp
$ Amount
Crypto purchased
Fees
Transaction status (e.g., completed, on hold)
Crypto address where crypto was sent

We may also release your information to certified and authorized law enforcement officials when we believe release is appropriate to comply with the law, enforce our terms or policies, or protect the rights, property, or safety of Topper, our users, or others. We have a set of guidelines for how we engage with law enforcement officials that are available to the public here.

Finally, in the event of the sale or transfer of ownership, your data would be shared with the new owners.

International Data Transfers

We process and store your data in the U.S. and other countries. Where required, we use Standard Contractual Clauses (SCCs) or other safeguards to ensure compliance with data protection laws.

By voluntarily providing your Personal Data on or via this website or app, you consent to its transfer, processing, and storage in the United States or other countries outside the EEA, some of which have not been deemed by the EEA to have “adequate” privacy safeguards.

Please contact us at data.privacy@uphold.com if you are located in the EU and want further information on the specific mechanism used by us when transferring Personal Data outside of the EEA.

Your Privacy Rights

Depending on your location, you have the right to:
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Access and obtain a copy of your data.
Correct inaccurate information.
Request deletion of your data (subject to legal retention requirements).
Object to or restrict processing.
Withdraw consent for marketing communications.
File a complaint with a data protection authority.

Your marketing preferences can be updated within Topper under your user settings or through any Newsletter via the “Unsubscribe” link. For all other Data Privacy inquiries, please submit your request through our standard customer support process, by contacting our Support Team.

Also, under the relevant privacy laws of the EEA (including the European Union’s General Data Protection Regulation) in respect of your EEA Personal Data, you may have a number of important rights. For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the European Commissioner’s Office (ECO) on individual’s rights under the European Union’s General Data Protection Regulation here.

How long do we retain your Personal Data?

Topper’s parent company Uphold maintains reasonable procedures to help ensure that your Personal Data is reliable for its intended use, accurate, complete, and current.
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We will only retain your Personal Data for as long as necessary to fulfill the purposes we collected it for, including to satisfy any legal, accounting, or reporting requirements, as well as other factors required by General Data Protection Regulation or other laws to which we are subject, including those relating to anti-money laundering and counter-terrorist financing. Our legal and regulatory compliance obligations require that we retain customer data for 7 years after the end of the customer relationship.
When it is no longer necessary to retain your Personal Data, we will securely delete it, subject to applicable laws and regulations.
In some circumstances, we may anonymize your Personal Data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
If you request that we stop sending you marketing materials, we will continue to keep a record of your contact details and appropriate information to enable us to comply with your request not to be contacted by us.
Should you make a Data Subject request through our standard customer support channel, we will retain the minimum required amount of data to keep a record of your request and the action we took to resolve it.

Notice to California Residents

This section applies to California residents. The purpose of this section is to inform California residents (“consumers” or “you”), at or before the time of collection of “personal information” (as that term is defined in the California Consumer Privacy Act (“CCPA”) amended by the California Privacy Rights Act 2020 (CPRA), effective January 1, 2023), about our data collection practices and your privacy-related rights under California law). Your “right to know” about personal information collected, used, and disclosed by Topper includes what categories of personal information we collect from you and the purpose for its collection; how we use those categories of personal information; and how we share the personal information you entrust to us.

Categories of Personal Data Collected

The chart below describes the categories of personal information that Uphold has collected in the preceding 12 months, the sources and purpose of such collection, and the parties to whom the information was shared for business purposes.
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Category	Examples	Collected
A. Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.	YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	YES
C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth, and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	YES
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	NO
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	YES
F. Internet or other similar network activity.	Browsing history, search history,and information on a consumer’s interaction with a website, application, or advertisement.	YES
G. Geolocation data.	Physical location or movements.	YES
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	YES
I. Professional or employment-related information.	Current or past job history or performance evaluations.	NO
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	NO
K. Inferences drawn from other personal information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	NO

Topper obtains the categories of personal information (including sensitive personal information) listed above from the following categories of sources:
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Directly from you. For example, from forms you complete or products and services you purchase, or from applications for employment with us.
Indirectly from you. For example, from observing your actions on our Website.
From third parties. For example, from our third-party service providers to verify your identity or to facilitate our provision of services to you.

All references to personal information below may include sensitive personal information as explained above.
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Rights Under the CCPA

Access to specific Information and data portability rights – Subject to certain exceptions, if you are a California resident you have the right to request a copy of the personal information that we collected about you during the 12 months before your request. Once we receive your request and verify your identity, we will disclose to you:
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The categories of personal information we have collected about you;
The categories of sources for the personal information we have collected about you;
Our business or commercial purpose for the information collection;
The categories of third parties with whom we share that personal information;
The specific pieces of personal information we collected about you.

Sale of Personal Information

You have the right to request that we disclose to you: the categories of your personal information that we sold and the categories of third parties to whom your personal information was sold. Topper does not sell your personal information in its ordinary course of business and will never sell your personal information to third parties without your explicit consent.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request through our standard customer support process, by contacting our Support Team.
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‍Use of an Authorized Agent to Submit a Request

Only you or a person you formally authorize to act on your behalf, may make a verifiable consumer request related to your personal information as a California consumer. If you use an authorized agent to submit such a request, we will require written proof that the authorized agent has been authorized to act on your behalf or a copy of the power-of-attorney document granting that right.

How do we protect children’s privacy?

We do not knowingly solicit or collect information from individuals under 18. If we become aware that a child under the age of 18 has provided us with Personal Data, we will close the account and restrict their information. If you believe that we might have collected Personal Data from a child under 18, please contact us using the information below.

How do we use your personal data for communication and marketing purposes?

In compliance with applicable laws, we may send you personalized marketing information, including by email, and such information may include product and service updates, industry news, our events, activities and offers, information about our business and personnel, and tips. We may combine your Personal Data such as age, transaction history, and account usage to improve the value and specificity of these communications.

You can ask us to stop sending you marketing messages or information at any time by following the “unsubscribe” link on any marketing message sent to you or by updating your contact preferences directly on the Uphold Platform. Please note, it may take up to 10 days for this to take effect. Where you opt out of receiving these marketing messages or publications, this will not apply to Personal Data collected by or provided to us in connection with a specific purpose, request, order, event or activity or any dealings with you, and you may still receive emails from us relating to the operation of Topper, like transaction confirmations.

Where does this Privacy Notice apply?

This Privacy Notice applies to all of the Topper services. This Privacy Notice does not apply to services that have separate privacy notices that do not incorporate this Privacy Notice.

This Privacy Notice doesn’t apply to the information practices of other companies and organizations that advertise our services or to services offered by other companies or individuals, including products or sites that may include Topper or be linked from Topper.

This website and app may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy notices. When you leave our website, we encourage you to read the privacy notice of every website you visit.

Who can you contact if you have further questions or requests about your privacy?

You can direct any questions or complaints about the use or disclosure of your Personal Data to us by contacting us as set out below. We will investigate and attempt to resolve any complaints or disputes regarding the use or disclosure of your Personal Data as soon as possible.

All Data Subject Requests should be submitted to our Customer Support Team. Uphold does not process requests received by a privacy automated service (bot). All requests must come directly from the individual to the email address noted above.

As Uphold is based in the United States it has appointed Uphold, Lda. a company incorporated in Portugal (Co. Number: PT513095136) to be its representative within the EEA. They may be contacted at data.privacy@uphold.com.

If you are a resident of the European Union and are dissatisfied with the resolution of your complaint in respect of your EEA Personal Data, you may contact the EU data protection authority in your jurisdiction using the contact details provided here for further information and assistance.

Topper Subprocessor list

Subprocessor	Purpose	Country
Amazon	Cloud Hosting	United States
Checkout.com	Credit/Debit Card Processing	United States
Customer.io	Customer communications	United States
DLocal	Payment Processor	Brazil
Ekata	Address Verfication Services	United States
SumSub	Address verification Services	Germany
Sift	Fraud Prevention	United States
Trulioo	Address verification Services	Canada
Twilio	Automated SMS Services	United States
Unit 21	Fraud Prevention	United States
Veriff	Identity Verification	Estonia
Zendesk	Customer Support Ticket Management	United States

Privacy

Topper Privacy Notice