THE TOPPS COMPANY, INC. PRIVACY AND COOKIES POLICY
Last Updated: January 1, 2020
Topps Company, Inc. (“Topps,” “we,” “our,” or “us”) respects the
privacy rights of our users and recognizes the importance of protecting the information
understand what information we collect about you when you use any of our
(collectively, the “Services”), how we use that information and what choices
that we may post.
changes by posting the revised policy here. We encourage you to periodically
specific areas set out below.
- How to Contact Us
- What Information We Collect
- How We Collect Information
- How We Use Your Information
- Interest-Based Advertising
- Customized Ad Campaigns
- Sharing and Disclosure of Information
- Your Choices Regarding Direct Marketing
- Your Privacy Rights
- Links and Third Parties
- International Data Transfers
HOW TO CONTACT US
may contact us in the following ways:
Address: The Topps Company, Inc.
One Whitehall Street
New York, New York
WHAT INFORMATION WE COLLECT
collects personal information and other information from and about you to
provide the Services. Personal information is data that identifies an
individual either directly or indirectly.
information we collect depends on the Services involved, and includes:
- Login Information that identifies and validates you as a user. Login information typically includes a password plus personal contact information, such as an e-mail address. You may be able to access some of the Services using Social Sign-On information.
- Personal Contact Information that allows Topps to contact you directly, such as your first and last name, e-mail address, mailing address, telephone number, and mobile number.
- Interest and Demographic Information, such as your age, gender, interests and preferences.
- Technical Information collected when you use the Services, such as your IP address, device information, information about the network you are using to access the Services, browser type and version, your activities while using the Services, sites or services previously visited, and content you see or click on.
- Order Information collected when you purchase a product or service, such as products ordered, payment information, and Personal Contact Information for the sender and recipient.
- Customer Service Information collected when you contact our internal or external customer service agents.
- Location Information including information that allows you to be precisely located.
- Social Sign-On Information such as login information, profile information, and friend lists from a social network that you choose to share when accessing the Services.
- User-Generated Content that you post or upload, such as comments, videos, photos, or social media interactions.
Duty to Inform Us of Changes. It is important that the personal
information we hold about you is accurate and current. Please keep us
informed of any changes to your personal information during your relationship
You Fail to Provide Personal Information. Where we need to
collect personal information by law, or under the terms of a contract we have
or are seeking to enter into with you and you fail to provide such data when
requested, we may not be able to perform the contract (for example, to provide
you with goods).
HOW WE COLLECT INFORMATION
you use the Services, Topps collects information from and about you in the
We collect information voluntarily provided by you, including Login
Information, Personal Contact Information, Interest and Demographic
Information, Order Information, Customer Service information, and User-Generated
Content when you:
- Create an account and/or register for the Services;
- Participate in one of our online games, activities or applications;
- Participate in contests, sweepstakes, or other promotions;
- Post user-generated content;
- Participate in a survey or questionnaire;
- Apply for a job online;
- Subscribe to updates, newsletters or other marketing communications;
- Place an order or engage in other transactions; or
- Contact us with a comment, question, or for further information.
If you choose to access the Services or register using an external third party
application, such as a social network, Topps will receive information from such
application. Certain Services, including eTopps, may provide the option
to sell any of your eTopps cards on the special eTopps trading floor on eBay,
in which case we will ask you for your eBay user name and password. That
information will allow us to list your items for sale on eBay, and to track the
auction for you. By providing us this information you consent to allow us to
link your eBay account with your eTopps account.
Topps or its third-party technology partners may also collect Location
Information, including Location Information provided by a mobile device
interacting with one of our apps or associated with your IP address or Wi-Fi
network. You can generally limit or prohibit the collection of Location
Information using the built-in settings on your mobile device. Check the device
instructions for information on how to do so. We do not permit the collection
of precise location information (actual address) in mobile apps without your
HOW WE USE YOUR INFORMATION
collects information from and about you to serve your needs, manage our content
and advertising, operate efficiently, and improve our Services and products.
collect information and use it, either alone or combined with other information,
- Provide you with products and services,
including the Services;
- Respond to inquiries and requests;
- Enable you to participate in online games,
contests, sweepstakes, and other promotions;
- Enable you to communicate with other users of
the Services and share information about our products and Services with others;
- Provide you with personalized content;
- Understand our visitors and improve our
products and services;
- Maintain the security, integrity, and quality
of our products and services;
- Comply with laws and protect our legal rights
and the legal rights of others;
- Send you or other individuals you identify
marketing communications on behalf of Topps and other companies within the
Topps family, and on behalf of select non-affiliated companies;
- Offer interest-based advertising and measure
the effectiveness of our advertising; and
- Complete and fulfill a transaction,
redemption, confirm an order, track delivery and payment, and provide updates
about the status of an order.
applicable laws require that we obtain your consent to collect information for
a particular purpose, we will do so at the time we collect the information.
may combine information we collect through your use of the Services with
information that we collect from other sources (e.g., offline records or
publicly available information).
we may take personal information and de-identify it and share it in a
de-identified or aggregated form with third parties, advertisers and/or
business partners in order to analyze site usage, improve our service or
service offerings, and improve our user experience, or for similar purposes.
and its service providers, including advertising and analytics partners, use
small text files called “cookies” and similar technology that are saved on your
computer or mobile device to automatically collect information about use of the
Services. Different types of cookies, such as session or persistent cookies,
may be used for different functions. Persistent cookies remain on a user’s
device for a set period of time, and are activated each time a user visits the
Services where cookies were set. Session cookies are temporary and allow
us to link a user’s actions during a browser session. The information collected
may include an IP address, geolocation information, device information,
information about the network you are using to access the Services, sites or
services that you previously visited, and content you see or click on.
and our third party analytics and advertising providers generally use the
following types of cookies and other technologies, such as GIF files or web
beacons, for the following purposes:
Necessary. These are essential to navigate the Services
and use the features, and they enable us to provide services such as
registration and shopping carts.
These are used to recognize you when you use the Services. They enable us
to personalize content for you and remember your preferences.
These are used to understand and improve the Services and understand how
you use the Services.
These are used to deliver relevant ads and track ad campaign performance
- Social. These
allow you to share content and experiences and to sign in with your
social network ID and stay logged in across the Internet.
Click here for
more information about the types of cookies being used and their purposes. Please note
that third party relationships may change, so the list may not always be
comprehensive or up to date. In addition, not all of the technologies listed may
be used for all of the Services or in all jurisdictions.
many browsers are initially set to accept cookies, you may be able to adjust
your settings to reject cookies. Choices are browser and device specific, and
if you clear cookies from the browser on any of your devices, your opt-out
choices will need to be reset. Consult the “Help” section of your
browser or built-in mobile device settings for more information. In addition,
please note that certain areas of the Services only can be accessed when
cookies are enabled. Thus, disabling cookies may prevent you from accessing
some of our content.
technology to collect information automatically about your use of the Services
through social media plug-ins. You may be able to provide social sign-on
information to access the Services, in which case the social network may be
able to link your activities in the Services to your social media registration
use of their platforms. Your browser or device may allow you to block these
technologies, but you should visit the third-party website and review their
technology to collect certain information regarding use of the Services and
other websites and apps automatically and may use the information to serve
targeted ads for products and services that may be of interest based on your
activity. To learn more about interest-based advertising and how you can opt-out
of having your web browsing information used for interest based advertising by
companies that participate in the Network Advertising (“NAI”) or Digital
Advertising Alliance (“DAA”), visit the NAI website (US) and the DAA Ad
Choices websites (US, EU, Canada, and AU/NZ). Note, however, that not all service
providers participate in the NAI and DAA. In addition, if you opt-out, you may
still see online advertising from Topps and third parties, but the ads may be
less relevant to you. If you delete or block cookies, buy or use a different
device, access the Services from a different device, login under a different
name, or change web browsers, you will need to opt-out again. Some web browsers
may transmit “do not track” signals. At this time, Topps does not take steps to
respond to such signals.
CUSTOMIZED AD CAMPAIGNS
some of the Services, we work with Facebook to display interest-based
advertisements on Facebook through a tool known as the “Custom Audiences”.
We share hashed/encrypted email addresses collected from users of the
Services with Facebook, which permits Facebook to target advertisements on our
behalf through its platform.
SHARING AND DISCLOSURE OF
- Topps Family of Companies: We may share information we collect within the Topps Family of companies, which may use the information for the purposes described above.
- Service Providers: We may share information we collect with third parties that process information on our behalf. We may use such service providers to:
- host the Services and provide database and server maintenance and security,
- help us conduct contests, sweepstakes or other promotions,
- send e-mails on our behalf,
- help us analyze our offerings, and
- process and fulfill online transactions.
- Payment Processors: When you make a purchase using the Services, payment processing companies collect and store payment information. We have engaged Braintree, a division of PayPal, Inc., Stripe, Inc. for these purposes. More information about Braintree and Stripe, Inc. privacy and security practices is set forth in the Security section below.
- Business Partners: With your consent, we may share information with non-affiliated third parties to enable them to provide you with information about their products or services that may be of interest. Please see the section below titled, “Your Choices Regarding Direct Marketing” for more information on how to changes your preferences or opt out of such information sharing.
- Legal Compliance & Protecting Security and Safety: Topps may access, preserve and disclose your information if required to do so by law or in a good faith belief that such access, preservation or disclosure is reasonably necessary to: (i) comply with legal process or respond to a legal request or subpoena; (ii) enforce the Topps Terms & Conditions; (iii) respond to claims that your conduct has violated the rights of third parties; (iv) respond to your requests for customer service; (v) protect the rights, property or personal safety of Topps, its users and the public; (vi) or as otherwise required to comply with, or permitted by, applicable laws and regulations.
- Business Transactions: We may transfer information collected if we or one of our affiliates are acquired by, sold to, or merged with another entity.
YOUR CHOICES REGARDING
your consent, Topps may use personal information collected pursuant to this
policy to market our own sports entertainment, collectible, and candy products
and services and on behalf of other companies within the Topps family, and to
market products and services offered by select non-affiliated sports,
collectible, games, and candy companies.
marketing communications from Topps is voluntary. If at any time you wish to
change your marketing preferences or opt out entirely from receiving further
marketing information from us, you can log into your account if you have
registered through the Services, follow the unsubscribe instructions in an
e-mail communication, or contact us at the address in the How to Contact Us
YOUR PRIVACY RIGHTS
have the right to access, update and correct factual inaccuracies in personal
information that we collect through the Services, subject to certain exceptions.
If you have created an online account, you can access, update, and delete your
personal information or request to delete your account by logging in to your
account through the Services. Any requests you submit will be reviewed
and, if approved, processed by our staff. We may retain certain
information as necessary to pursue legitimate business interests or resolve
disputes or as required by applicable laws. To protect your privacy and the
security of your personal information, we will take reasonable steps to verify
your identity before granting access to your personal information or deleting
If you are a citizen of an EEA member
state, the General Data Protection Regulation (EU) 2016/679 (“GDPR”) provides you
certain rights with respect to your personal information. You may, with certain
access to your personal information
correction of the personal information we have about you
erasure of your personal information
to our processing of your personal information
to restrict the processing of your personal information
a copy of the personal information we have about you
to not be subjected to automated decision-making or profiling
will always endeavor to fulfill your request to exercise these rights, but
sometimes, we may have legal grounds or obligations to reject your request. You will not have to pay a
fee to exercise any of the aforementioned rights, but we may charge a
reasonable fee if your request is unfounded, repetitive or excessive.
Alternatively, we could refuse to comply with your request in these
you are a citizen of an EEA member state, you also have the right to contact
supervisory authorities within the EEA about any concerns you have related to
Topps’ privacy practices.
you have any concerns, we request that you contact us first so we can
investigate, and hopefully resolve, your concerns.
GDPR requires that we inform you of the legal bases we rely on to process your
personal information. The legal bases for processing are set forth below.
- Our legitimate
For example, to maintain system security, communicate with you and fulfill your
requests, conduct surveys, improve our products and services, and protect our
rights and the rights of others.
- Performance of a
contract with you.
For example, when you purchase goods or services.
- Compliance with
For example, to comply with legal and regulatory requirements or respond to a
court order or legal request.
- Consent. Where we
rely on consent to process your personal information, you can withdraw your
consent at any time.
California Consumer Privacy Act of 2018 (CCPA) provides California residents
with certain rights with respect to their personal information:
to request that we disclose, no more than twice in a 12-month period:
categories and specific pieces of personal information we have collected about
categories and sources from which personal information is collected.
business or commercial purposes for collecting or selling personal information.
categories of third parties with whom we share personal information.
We will provide this information upon
receipt of a verifiable consumer request.
How we will verify your identity depends on how you have interacted with
us in the past.
- The categories and sources of personal information we collect and the business or commercial purposes for collecting personal information are described in the What Information We Collect, How We Collect Information, and How We Use Your Information sections above.
to request that we delete any personal information about you that we have
collected from you, subject to certain exceptions. If we are required to delete your personal
information, then upon receipt of a verifiable request, we will delete your
personal information from our records and direct any service providers to
delete your personal information from their records.
to opt-out of the “sale” of your personal information to third parties, as that
term is defined in the CCPA. We share certain personal information with third
parties under circumstances that might be deemed a “sale” under the CCPA. This
includes when we share information collected from cookies and similar tracking
technologies with advertising technology partners in order to create user
profiles and present advertising messages based on your preferences, and to
help us identify other users likely to be interested in our products and
California residents can exercise their rights by submitting an online request. You can designate an authorized agent to make a request on your behalf. We may require proof of your identity and that the agent is duly authorized by you. We will not discriminate against you for exercising your rights.
Civil Code § 1798.83, the “Shine the Light” law, California residents are
entitled to request, once per year, information about third parties with whom
Topps has shared personal information about them for such parties’ direct
marketing purposes during the previous calendar year, and the categories of
personal information shared. To make such a request, submit a written request
to the address listed in the How to Contact Us section above, or send an e-mail
to firstname.lastname@example.org, specifying that you seek your “California
Shine the Light Notice.” Please allow thirty days for a response.
residents have a right to submit a verified request directing a website
operator to not make any “sale” of covered information collected about the
consumer for monetary consideration to a person for such person to license or
sell the information to additional persons, subject to certain exceptions. If
you are a Nevada resident and you would like to opt-out of a future sale of
your covered information, you can contact us at email@example.com.
strives to use commercially reasonable physical and electronic security
measures to protect against the loss, unauthorized access, misuse, or
alteration of your personal information. We use encryption and/or other
security measures to protect payment information during transmission and adopt
internal procedures to safeguard such information in our systems. We limit
access to personal information to those employees, agents, contractors, and
other third parties who have a business need to know. Please be aware
though that, despite our best efforts, no security measures are perfect or
impenetrable, and we cannot guarantee the security measures of third parties.
If you make a purchase
using the Services, your payment information is collected by a third-party
payment processor and transmitted to it directly via an encrypted connection.
Our payment processors use, process, and store your information in accordance
with their own privacy policies, and they maintain that they are PCI compliant.
LINKS AND THIRD PARTIES
may provide links to other sites owned by third parties. When you place an
order or register on the Services where transactions are handled by a third
party vendor, those transactions are conducted through the vendor’s website and
responsible for those other sites, their privacy policies, or how they treat
the information of their users. We advise you to review their privacy policies
for information on how those sites collect, use, and protect your information.
may be required to register with and log onto a third party mobile app store
before you can download or purchase a Topps app or make in-app purchases using
a Topps app. When downloading a Topps app or using a Topps app with online
features through your mobile platform, the app provider will typically collect
certain device and app-related information. Topps does not control the
requirements or processes of the app stores; you should review the privacy
any app and check your device settings for control options. On occasion, we may
offer content, promotions or other activities that are sponsored or
co-sponsored by or presented with identified third parties. By using this
content or participating in such promotions or activities, the personal
information that you voluntarily submit may be provided to both Topps and the
third parties. Topps has no control over such third parties’ use of this
As the Topps family of companies operates globally, we may transfer to and process personal information about you on our servers in the United States and/or countries other than your home country, and we may use cloud services whose servers may be anywhere in the world. Please note that the data protection laws of some countries, such as the United States, may not offer a level of privacy protection equivalent to that within the European Economic Area (EEA) or your home country. If your use of the Services results in the transfer of personal information from the EEA to non-EEA countries that have not been deemed to offer an adequate level of privacy protection, we may rely on (i) standard contractual clauses approved by the European Commission in our contracts with parties that receive information in such countries, and /or (ii) third party service providers in the United States that are certified to receive such information under the Privacy Shield program. By using the Services, you expressly consent to such transfers.
information we collect will not be stored for longer than is necessary for the
regulatory, tax, accounting, or reporting requirements. In some cases we
may anonymize your personal information (so that it can no longer be associated
with you) for research or statistical purposes, in which case we may use the
information indefinitely without further notice to you.