Privacy Policy.

Effective Date: 08/08/2025

This Privacy Policy (“Policy”) explains how Topomer OÜ (“Topomer”, “we”, “us”, “our”), a company registered in Estonia, collects, uses, discloses, and protects your personal data when you use our website, mobile applications, and services (collectively, the “Services”). As a social network for personalized fashion shopping, we are committed to safeguarding your information in compliance with applicable data protection laws, including:
– The EU General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679)
– The Estonian Personal Data Protection Act
– The ePrivacy Directive (Directive 2002/58/EC)
– The California Consumer Privacy Act (CCPA), where applicable
– Google Play Store and Apple App Store privacy requirements

1. Information We Collect

We collect different types of information to provide and improve our Services:
– Account Information: Name, email address, username, date of birth, and password.
– Profile Information: Photos, biography, style preferences, connections with other users.
– Payment Information: When you make a payment through Topomer, we collect and store your credit or debit card details (cardholder name, card number, expiration date, and CVV) for the purpose of processing transactions, facilitating recurring payments for services, and resolving payment-related issues. All payment data is stored in encrypted form in compliance with the Payment Card Industry Data Security Standard (PCI DSS) and applicable data protection laws, including the GDPR. Access to this information is strictly limited to authorized personnel and is protected by multi-factor authentication and secure server environments. Also we are using PayPal and Stripe.

– Usage Data: IP address, device type, operating system, browser type, pages visited, actions within the app.
– Communications: Messages sent via our chat or to personal shoppers.
– Social Activity: Posts, likes, comments, shared content, and interactions with other users.
– Location Data: If enabled, we may collect approximate or precise location data to improve recommendations.

2. How We Use Your Information

We process your personal data for the following purposes:
– To create and manage your account.
– To deliver the personal shopping and consultation services you request.
– To process payments and provide receipts.
– To display your social interactions within the Topomer network.
– To improve, personalize, and expand our Services.
– To detect and prevent fraudulent, unauthorized, or illegal activity.
– To communicate updates, offers, and promotional content (with your consent).
– To comply with legal obligations.

3. Legal Basis for Processing

Under the GDPR, we rely on the following legal bases to process your personal data:
– Consent: For optional data collection such as marketing communications.
– Contract Performance: To provide the Services you request.
– Legal Obligation: To comply with applicable laws and regulations.
– Legitimate Interest: To ensure the security and proper functioning of our Services.

4. Data Sharing & Disclosure

We may share your personal data with:
– Personal shoppers to fulfill your service requests.
– Third-party payment processors (Stripe, PayPal).
– Other users, when you choose to share posts, comments, or messages.
– Service providers who assist with hosting, analytics, and customer support.
– Legal authorities, when required by law or court order.

5. Social Network Visibility

As a social network, your profile information, posts, and interactions may be visible to other users according to your privacy settings. You control what information is public or private. We encourage you to review your settings regularly.

6. Data Retention

We retain your personal data for as long as necessary to provide our Services, fulfill our contractual obligations, comply with legal requirements, resolve disputes, and enforce our agreements. When your data is no longer needed, we securely delete or anonymize it.

7. Data Security

We implement technical and organizational measures to protect your personal data, including encryption, secure servers, firewalls, and access controls. While we strive for the highest level of security, no method of data transmission or storage is completely secure, and we cannot guarantee absolute protection.

8. International Data Transfers

Your personal data may be transferred to and processed in countries outside the European Economic Area (EEA). When this occurs, we ensure appropriate safeguards, such as Standard Contractual Clauses approved by the European Commission.

9. Your Rights (GDPR & CCPA)

You have the following rights:
– Access to your personal data.
– Rectification of inaccurate or incomplete data.
– Erasure (‘Right to be Forgotten’).
– Restriction of processing.
– Data portability.
– Objection to processing.
– Withdrawal of consent.
CCPA residents may also request:
– Disclosure of categories and specific pieces of personal data collected.
– Opt-out of the sale of personal data.
– Non-discrimination for exercising privacy rights.

10. Children’s Privacy

Our Services are intended for individuals aged 16 and older. We do not knowingly collect personal data from children under 16. If we become aware that we have collected such data, we will take steps to delete it promptly.

11. Compliance with Google Play & Apple Requirements

Our data handling practices comply with the Google Play Store Data Safety policy and Apple App Store’s App Privacy requirements, including disclosure of:
– Data collected (personal, financial, usage, and location data).
– Purposes of data use.
– Data sharing with third parties.
– User control over data visibility and sharing.
We provide in-app links to this Privacy Policy and settings to manage permissions.

12. Changes to this Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or legal requirements. Updates will be posted in the app and on our website with the effective date clearly indicated.

13. Contact Information

For privacy-related inquiries or to exercise your rights, please contact us at:
Email: privacy@topomer.com
Address: Harju maakond, Tallinn, Kesklinna linnaosa, Viru väljak 2, 10111