Privacy Policy

1. Introduction

GlobeTopper LLC (“GlobeTopper,” “we,” “us,” or “our”) is committed to protecting the privacy and security of the information we collect from our business partners, customers, and website visitors. This Privacy Policy explains how we collect, use, disclose, and protect information in connection with our B2B digital gift card marketplace platform and related services.

GlobeTopper operates as a business-to-business (B2B) platform serving financial institutions, fintech companies, program managers, retailers, and corporate partners.

By accessing our website, using our services, or engaging in a business relationship with GlobeTopper, you acknowledge that you have read and understood this Privacy Policy.

2. Information We Collect

2.1 Business Customer Information

We collect information necessary to provide services and comply with legal obligations, including:

• Business Identification Information: Legal business name, trade names, business address, tax identification numbers, jurisdiction of formation, and registration documents
• Contact Information: Names, job titles, email addresses, phone numbers, and mailing addresses
• Beneficial Ownership Information: Names, dates of birth, addresses, and identification details of individuals owning 25% or more of the business or exercising significant control
• Financial Information: Bank account details, billing information, credit references, and transaction data
• Compliance Information: KYC documentation, sanctions screening results, and due-diligence records

2.2 API and Technical Information

• API keys, authentication tokens, and access credentials
• API usage logs, transaction records, and integration activity
• IP addresses, browser type, device identifiers, operating systems, and access timestamps
• Server logs, error reports, and performance data

2.3 Website Visitor Information

• Information submitted through contact or inquiry forms
• Website analytics such as pages visited, session duration, and referral sources
• Cookie and tracking data (see Section 7)

2.4 Information from Third Parties

We may receive information from business data providers, sanctions screening services, public databases, credit agencies, and business partners.

3. How We Use Your Information

3.1 Service Delivery

• Processing gift card orders and transactions
• Providing platform and API access
• Managing accounts, billing, and customer support
• Fulfilling contractual obligations

3.2 Compliance and Risk Management

• KYC and KYB verification
• Sanctions and watchlist screening
• Fraud prevention and financial crime detection
• Legal and regulatory compliance

3.3 Business Operations

• Improving and developing services
• Platform security and monitoring
• Business communications and service updates

3.4 Legal Purposes

• Enforcing agreements and policies
• Protecting rights, property, and safety
• Legal claims and dispute resolution

4. How We Share Your Information

GlobeTopper does not sell personal information.

4.1 Service Providers

We share data with trusted vendors (payment processors, cloud hosting providers, compliance services, legal and accounting advisors) under strict confidentiality obligations.

4.2 Business Partners

Information may be shared with suppliers and partners to fulfill transactions and services.

4.3 Financial Institutions

We share required information with banking partners for payment processing and regulatory compliance.

4.4 Legal and Regulatory Disclosure

We may disclose information when required by law, regulation, court order, or to prevent fraud or illegal activity.

4.5 Corporate Transactions

Information may be transferred in the event of a merger, acquisition, or asset sale, with appropriate notice.

4.6 Affiliates

Information may be shared with affiliated entities for operational and compliance purposes.

5. Data Retention

We retain information only as long as necessary:

• KYC and customer identification records: 5 years after relationship ends
• Transaction records: 7 years
• Beneficial ownership data: 5 years after relationship ends
• Sanctions screening records: 5 years
• API logs and technical data: 2 years
• Marketing data: Until opt-out or 3 years of inactivity
• Website analytics: 26 months

6. Data Security

We use industry-standard safeguards including:

• Encryption in transit (TLS/SSL) and at rest
• Role-based access controls
• Strong authentication requirements
• Continuous security monitoring
• Vendor security due diligence

No system is completely secure, and absolute security cannot be guaranteed.

7. Cookies and Tracking Technologies

Types of Cookies

• Essential: Required for security and functionality
• Analytics: Improve website performance and usability
• Functional: Store preferences and settings

You can manage cookies via browser settings. Disabling essential cookies may impact functionality.

8. International Data Transfers

GlobeTopper is based in the United States. Data may be processed in the U.S. or other countries.

For EEA, UK, and Swiss data transfers, we use appropriate safeguards such as Standard Contractual Clauses or legally approved mechanisms.

9. Your Rights and Choices

General Rights

• Access, correction, and deletion requests
• Marketing opt-out

GDPR Rights (EEA/UK/Switzerland)

• Data portability
• Processing restriction
• Objection to processing
• Withdrawal of consent
• Right to lodge a complaint

California Privacy Rights (CCPA/CPRA)

• Right to know, delete, and correct
• Opt-out of sale or sharing (we do not sell data)
• Non-discrimination

To exercise rights, email privacy@globetopper.com. Identity verification may be required.

10. Data Breach Notification

If a data breach occurs, we will notify affected parties and authorities as required by law.

11. Children's Privacy

GlobeTopper services are intended for businesses only and not for children.

12. Third-Party Links

We are not responsible for the privacy practices of third-party websites or services.

13. Changes to This Privacy Policy

We may update this policy and will notify customers of material changes. Continued use constitutes acceptance.

14. Contact Us

GlobeTopper LLC

Email: privacy@globetopper.com

Website: www.globetopper.com