TopBlocks Privacy Policy
TopBlocks and its global affiliates (collectively,
            "TOPBLOCKS", "we", "us", and "our")
            respect your privacy. Therefore, we have developed a Privacy Statement
            (hereinafter referred to as "this Policy") that covers how we
            collect, use, disclose, protect, store and transfer your personal data when
            using our websites, products or services. Please take a moment to read and
            understand our Privacy and let us know if you have any questions.
Personal data means any electronic or
            other information which alone or jointly with other information can be used to
            identify a natural person or make him/her identifiable. This Statement explains
            how TopBlocks processes your personal data but does
            not cover all processing scenarios as you will be informed in specific
            processing activity. Therefore, before using a specific product or service, it
            is recommended that you read the privacy notice or supplementary statement
            released by TOPBLOCKS for that product or service to understand how it
            processes your personal data.
This Policy applies only to websites,
            product and services that display or mention this Statement.
This Statement describes:
- How TOPBLOCKS Collects
                 and Uses Your Personal Data
- How TOPBLOCKS Uses
                 Cookies and Similar Technologies
- How TOPBLOCKS Shares Your
                 Personal Data
- How TOPBLOCKS Protects
                 Your Personal Data
- How You Can Manage Your
                 Personal Data
- How TOPBLOCKS Protects
                 Children's Personal Data
- Links to Third-Party
                 Websites, Products, and Services
- International Transfers
                 of Your Personal Data
- Updates to This Statement
- How to Contact Us
I. How TOPBLOCKS
            Collects and Uses Your Personal Data
A. Personal Data Collected by TopBlocks
Personal data means any data that, either
            on its own or jointly with other data, can be used to identify a natural
            person. You directly provide us with such data when you use our websites,
            products, or services, or interact with us by, for example, contacting us for
            support. We may also obtain data by recording how you interact with our
            websites, products, or services. For example, we may use technologies like
            cookies or receive use data from software running on your device. As permitted
            by law, we may also obtain data from public and commercial third-party sources,
            for example, purchasing statistics from other companies to support our
            services. The personal data we collect includes name and email addresses,
            depending on how you interact with TopBlocks, for
            example, the website you visit or the products and services that you use. We
            also collect the information you provide to us and the content of messages you
            send us, such as the query information you provide, or the questions or
            information you provide for customer service support. In addition, we may also
            collect Non-identifiable data, which refers to data that cannot be used to
            identify an individual, for example, the statistics on website visits,
            application downloads, and product sales volume.
Before using our products or services, you
            may need to provide personal data. You do not have to provide your personal
            data to TopBlocks, but in some cases, the
            non-provision of certain personal data will cause the inability to provide you
            with some related products or services.
B. How TOPBLOCKS Uses Your Personal Data
TOPBLOCKS may use your personal data for
            the following purposes:
(1) Provide personalized user experience
            and content.
(2) Send you information about products
            and services you might be interested in, invite you to TopBlocks's
            promotional activities and market surveys, or send marketing information to
            you. If you do not want to receive such information, you can opt out at any
            time.
(3) Collect user feedback. The feedback
            you choose to provide is important to help TOPBLOCKS improve its services. To
            process your feedback, we may use the personal information you provide to
            contact you and keep records.
(4) Carry out internal auditing, data
            analysis, and research; analyze business operation efficiency and measure
            market shares; and improve TopBlocks's products and
            services.
(5) Ensuring the security of our products,
            services and customers or users.
(6) Process pursuant to laws and
            regulations, e.g. tax, authority requests.
(7) Other purposes within specific
            services or with your consent.
 
II.How TOPBLOCKS Uses Cookies and Similar
            Technologies
TopBlocks' websites, online services, interactive
            applications, email messages, and advertisements may use "cookies"
            and other technologies such as pixel tags and web beacons. These technologies
            help us better understand user behavior, tell us which parts of our websites
            people have visited, and facilitate and measure the effectiveness of
            advertisements and web searches. We treat information collected by cookies and
            other technologies as non‑personal information. However, to the extent that
            Internet Protocol (IP) addresses or similar identifiers are considered personal
            information by local law, we also treat these identifiers as personal
            information.
A. Cookie
A cookie is a text file stored by a web
            server on a computer or mobile device, and the content of a cookie can be
            retrieved and read only by the server that created the cookie. Cookies are
            unique to the browser or mobile application you are using. The text in a cookie
            often consists of identifiers, site names, and some numbers and characters.
Sometimes, TOPBLOCKS stores cookies on
            computers or mobile devices for the purpose of improving user experience,
            including the following scenarios:
(1) Personalization cookies: Storage of
            your preferences and settings. A website can use cookies to save settings, such
            as the language setting and font size on your computer or mobile device, and
            other browser preferences.
(2) Advertising cookies. TOPBLOCKS uses
            cookies to collect information about your online activities and interests and
            provide you with advertisements that correlate most highly with you.
(3) Statistical cookies. With cookies, TOPBLOCKS
            can collect information about your use of our websites and other applications,
            either for a single visit (using a session cookie) or for repeated visits
            (using a persistent cookie).
B. Other Local Storage
TOPBLOCKS and some third parties may use
            other local storage technologies, for example, local shared objects (also
            called "Flash cookies") and HTML5 local storage, in certain products
            and services. Similar to cookies, these technologies store information on your
            device and can record some information about your activities and preferences.
            However, these technologies may use different media from cookies. Therefore,
            you may not be able to control them using standard browser tools and settings.
            For details about how to disable or delete information contained in Flash
            cookies, click  here.
D. Do Not Track
Many web browsers provide a Do Not Track
            function that can release Do Not Track requests to websites. Currently, major
            Internet standardization organizations have not established policies to specify
            how websites should handle these requests. If you enable Do Not Track in your
            browser, all TopBlocks' websites will respect your
            selection.
 
III. How TOPBLOCKS
            Shares Your Personal Data
We do not share personal data with other
            companies, organizations and individuals unless one of the following
            circumstances applies:
(1) Sharing with consent: After obtaining
            your consent, TOPBLOCKS will share the information that you have authorized
            with specified third parties or categories of third parties.
(2) Sharing pursuant to laws and
            regulations: TOPBLOCKS may share your information as required by laws and
            regulations, for resolving legal disputes, or as required by administrative or
            judiciary authorities pursuant to law.
(3) Sharing with TopBlocks'
            affiliates: Your information may be shared within TopBlocks'
            affiliates only for explicit, and legitimate purposes, and the sharing is
            limited only to information required by services. For example, we verify the
            global uniqueness of accounts before allowing them to be registered.
(4) Sharing with business partners: Some
            products and/or services are provided to you directly by our partners. TOPBLOCKS
            also may share your information with them, they may use your information to
            provide you with products and/or services you request, make predictions about
            your interests and may provide you with advertisements, promotional materials
            and other materials
(5) Sharing with service providers: TOPBLOCKS
            also may disclose your information to companies that provide services for or on
            behalf of us. 
(6) TOPBLOCKS will share your information
            when there is a reasonable requirement to do so, for example, to meet request
            of applicable law, regulation, legal process or enforceable government.
In scenarios 3 to 6, TOPBLOCKS will ensure
            that the lawfulness of this sharing and sign stringent non-disclosure
            agreements (NDAs) and/or data processing clauses with the companies,
            organizations, and individuals with whom personal data is shared, requiring
            them to comply with this Statement and take appropriate confidentiality and security
            measures when processing personal data.
 
IV. How TOPBLOCKS
            Protects Your Personal Data
TOPBLOCKS attaches great importance to the
            security of your personal data and has adopted standard industry practices to
            protect your personal data and prevent it from unauthorized access, disclosure,
            use, modification, damage, or loss. To this end, TOPBLOCKS takes the following
            measures:
(1) We take reasonable and feasible
            measures to ensure that the personal data collected is minimal and relevant to
            what is necessary in relation to the purposes for which they are processed. We
            retain your personal data for no longer than is necessary for the purposes
            stated in this Statement and privacy notice of specific product or service,
            unless extending the retention period is required or permitted by law.
(2) We deploy access control mechanisms to
            ensure that only authorized personnel can access your personal data. In
            addition, we control the number of authorized personnel and implement
            hierarchical permission management on them based on service requirements and
            personnel levels.
(3) We strictly select business partners
            and service providers and incorporate personal data protection requirements
            into commercial contracts, audits, and appraisal activities.
(4) We hold security and privacy
            protection training courses, tests, and publicity activities to raise
            employees' personal data protection awareness.
TOPBLOCKS is committed to protecting your
            personal data. Nevertheless, no security measure is perfect and no product,
            service, website, data transfer, computing system, or network connection is
            absolutely secure.
To cope with possible risks, such as
            personal data leakage, damage, and loss, TOPBLOCKS has developed several
            mechanisms and control measures, clearly defined the rating standards of
            security incidents and vulnerabilities and corresponding processing procedure. TOPBLOCKS
            has established a dedicated emergency response team to implement security
            planning, loss reduction, analysis, locating, and remediation, and to perform tracking
            operations with related departments based on security incident handling
            regulations and requirements.
If any personal data incident occurs, TOPBLOCKS
            will notify you, pursuant to relevant legal and regulatory requirements, of the
            basic information about the security incident and its possible impact, measures
            that TOPBLOCKS has taken or will take, suggestions about active defense and
            risk mitigation, and remedial measures. The notification may take the form of
            an email, text message, push notification, etc. If it is difficult to notify
            data subjects one by one, we will take appropriate and effective measures to
            release a Security Notice. In addition, we will also report the handling status
            of personal data security incidents as required by supervisory authorities.
 
V. How You Can
            Manage Your Personal Data
Access, rectification, deletion, data
            portability, restriction of processing, objection to processing.
Legislation in some countries and regions
            to which TOPBLOCKS provides products and services or from where TOPBLOCKS processes
            personal data, provides that data subjects the rights request (hereinafter
            referred to as "requests") in regards to the accessing, rectifying,
            deleting or erasure, porting, restricting, and objecting, the processing of
            related personal data by TOPBLOCKS retains.
 
VI. How TOPBLOCKS
            Protects Children's Personal Data
We consider it the responsibility of
            parents to monitor their children's use of our products and services.
            Nevertheless, it is our policy not to require personal information from
            children or offer to send any promotional materials to persons in that
            category.
TOPBLOCKS does not seek or intend to seek
            to receive any personal information from children. Should a parent or guardian
            have reasons to believe that a child has provided TOPBLOCKS with personal
            information without their prior consent, please contact us to ensure that the
            personal information is removed, and the child unsubscribes from any of the
            applicable TopBlocks' services.
 
VII. Links to
            Third-Party Websites, Products, and Services
TopBlocks' websites, application software,
            products, and services may contain links to third-party websites, products, and
            services. TopBlocks' products and services may also
            use or provide products or services from third parties.
All links to third-party websites,
            products, and services are provided for users' convenience only. We are not
            responsible for and cannot control how third-parties use personal information
            which they collect from you. Our privacy policy does not apply to other sites
            linked from our services.
You need to determine your interaction
            with such links on your own. Before submitting your personal data to third
            parties, please read and refer to these third parties' privacy policies.
 
VIII.
            International Transfers of Your Personal Data
Our products and services are delivered
            through resources and servers located in different places, to offer our
            products and services, we may need to transfer your personal data among several
            countries. Authorized TOPBLOCKS personnel and third parties acting on our
            behalf may access, use and process personal data collected from you in a
            country/region that is different from the country/region where you entered the
            personal data, which may have less stringent data protection laws. When we
            transfer your personal data to other countries/regions, we will protect that
            the personal data as described in this Policy or as otherwise disclosed to you
            at the time the data is collected (e.g. via privacy notice or supplementary
            statement of specific product or service).
TOPBLOCKS has implemented global privacy
            practices for processing personal data protected under various data protection
            laws. TOPBLOCKS transfers personal data between the countries in which we operate
            in accordance with the standards and conditions of applicable data protection
            laws, including standards and conditions related to security and processing.
With respect to personal data coming from
            the EU, we comply with applicable legal requirements providing adequate
            safeguards for the transfer of personal data to countries outside of the
            European Economic Area ("EEA"). We use a variety of legal mechanisms,
            such as standard contractual clauses to implement the cross-border transfer of
            your personal data; or implement other safeguards provided for in the GDPR.
 
IX. Updates to
            This Statement
TOPBLOCKS reserves the right to update
            this Policy at any time.
Should this Statement be revised from time
            to time, TOPBLOCKS will release the change notice via various channels, for
            example, posting the latest version on our official website: https://www.topblocks.io.If
            we make any material changes we may notify you by means of a notice on this
            website.
"Material changes" in this
            Statement include but are not limited to:
(1) Material changes in our service modes,
            for example, purposes of personal data processing, types of processed personal
            data, and ways of using personal data
(2) Material changes in our ownership
            structure, organizational structure, etc., for example, ownership changes
            caused by business adjustment, bankruptcy, or acquisition
(3) Changes in the main objects of
            personal data sharing, transfer, or disclosure
(4) Material changes in your rights
            regarding personal data processing and the ways in which you can enjoy those
            rights
(5) Changes of TopBlocks'
            departments, contacts, and complaint channels responsible for the security of
            personal data processing
(6) High risks identified in personal data
            security impact assessment reports
 
X. How to
            Contact Us
If you have any questions or concerns
            about our Sites, Products or Services, our use of your information or this
            Policy, please contact us by visiting https://www.topblocks.io/contact-us or submitting it to contact@topblocks.io.
Note: Due to differences in local laws and
            languages, the local versions of TopBlocks' Privacy Policy
            may be different from this version. In the case of any conflicts, the local
            versions shall prevail.
Copyright ©2022 TopBlocks.
            All rights reserved.