By ONTOP Privacy Notice

1. Who this notice covers

This notice covers website visitors, people who contact us, prospective and current clients, applicants, collaborators, suppliers, and user-generated content (UGC) creators. It applies to information received online and offline, including through website forms, email, WhatsApp, social media, telephone calls, contracts, and in-person meetings.

Information we handle on behalf of a client is also addressed in Section 9. This notice does not replace applicable service agreements or confidentiality obligations.

2. Information we collect

Depending on your relationship with us and the services involved, we may receive:

• Contact and identifying information, including your name, email address, telephone number, mailing or billing address, and company details.
• Professional information, including social media profiles, portfolios, photographs, and information submitted for an application or collaboration.
• Communications, documents, project instructions, and other materials you provide.
• Billing, payment card, and other financial information provided in connection with services.
• Business information, including strategies, supplier information, and confidential or proprietary materials.
• Information collected through Google Analytics and Meta Pixel, which may include online identifiers, browser or device information, pages visited, and website interactions, depending on the tools’ configuration.

Business information may contain personal information. Confidential business materials that do not identify an individual remain distinct from personal information and may also be covered by confidentiality provisions in our agreements.

3. How we use information

We use information to communicate about, arrange, and provide our consulting and other services; administer client relationships; process payments; and coordinate projects and authorized collaborations. Information provided in applications or creator submissions is used in connection with the relevant opportunity or relationship.

We also use website analytics and advertising technologies as described in Section 5 and send email communications as described in Section 6.

4. How information is disclosed

We do not sell personal information for money or provide client contact lists to other clients for their independent marketing.

Operating our business involves platforms for payments, hosting, email, customer relationship management, and storage. Information may be processed by these providers as part of providing their services. Use of Google Analytics and Meta Pixel also involves information being transmitted to Google and Meta, as described below.

Before introducing a creator or collaborator to a client or sharing their identifying profile, portfolio, or contact details for that purpose, we request that person’s authorization.

Disclosure may also be required by applicable law or a valid legal demand. Nothing in this notice is intended to prevent compliance with such requirements.

For questions about providers or access to your information, contact [email protected].

5. Cookies, analytics, and advertising technologies

Our website uses Google Analytics and Meta Pixel. These tools may use cookies and similar technologies to collect information about visits and interactions. Depending on their configuration, they may support statistics, conversion measurement, advertising audiences, and remarketing.

Google and Meta process information under the terms and privacy policies applicable to their services. These transmissions can constitute disclosures of personal information. Depending on the applicable law and configuration, advertising-related disclosures may be classified as a “sale” or “sharing” even where no payment is received for the information.

When we conduct advertising or audience activities on behalf of a client, including activities involving client-provided contact lists, we obtain the client’s authorization. That authorization does not replace any notice, permission, or individual privacy choice required by applicable law or platform terms.

You can manage cookies through your browser settings. Browser controls may not prevent every form of data collection or advertising-related processing. Contact [email protected] with questions or requests concerning these technologies.

6. Email communications

We may send newsletters, updates, offers, or invitations by email to contacts who have provided an email address to us or have been clients, subject to applicable law.

You can unsubscribe from marketing emails using the unsubscribe option provided in those messages or contact [email protected]. Unsubscribing from marketing does not prevent communications necessary to provide requested services or administer an existing business relationship.

We do not provide your email address to our clients for their independent promotional use.

7. Payment information

Clients may enter payment information directly into a payment platform. We may also receive payment details that a client chooses to provide by telephone or through an image or other communication.

We do not retain card verification codes (CVV/CVC) after payment authorization. Any card images or other records containing those codes that we receive are discarded after authorization. The retention period described below does not apply to these codes or records.

For information about the payment process and the handling of payment details, contact [email protected]. Please contact us before sending payment card images or other sensitive financial information so that we can discuss the appropriate payment method.

8. Use of artificial intelligence

We use company-managed professional AI tools in our work. Our stated practice is to limit information entered into those tools to non-sensitive information.

For more information about the tools used or the handling of information in a particular project, contact [email protected]. This notice does not represent that every paid AI service has identical privacy terms or that all such services exclude every form of data retention or model training.

9. Information handled on behalf of clients

Where a client provides access to databases, leads, customer lists, or other contact information, we handle that information when needed for the requested consulting or other services.

The client’s instructions, relevant service agreement, and applicable law govern that work. If your information was supplied to us by a business you deal with, that business’s privacy notice may also apply. You may contact that business about your information or contact us at [email protected] to help identify the relevant relationship.

10. Security

Our security practices include two-step authentication and a practice of avoiding public networks when handling company information. We use business platforms with security features and monitor the platforms used in our operations.

No method of storage or transmission can guarantee absolute security. For questions about the safeguards relevant to your information or project, contact [email protected].

11. Retention and disposal

We retain client personal information and project materials for no more than one month after the client relationship ends, unless a longer retention period is required by applicable law or an applicable contractual obligation. We may delete or dispose of this information earlier, subject to those obligations; the one-month period is a maximum, not a guaranteed storage period.

Clients should retain their own copies and request any additional copies they need before the relationship ends. Continued storage or later recovery of project materials is not guaranteed unless agreed in writing.

This provision does not limit any individual’s statutory privacy rights or permit destruction of records that must legally be preserved. Card verification codes (CVV/CVC) are not retained after payment authorization and are excluded from this retention period.

12. Privacy requests

You can contact [email protected] to ask about your information or request access, correction, or deletion. Depending on your location and applicable law, you may have additional rights, including rights concerning certain advertising-related processing.

We may need information to verify your identity or understand your request. The availability and scope of a right, and any applicable exceptions, depend on the law governing the request. Requests for personal information are distinct from contractual requests for project deliverables or business files.

13. International relationships and minors

By ONTOP is based in Florida and works with individuals and businesses in the United States and Latin America. Information provided to our Florida business may be handled in the United States. Contact us for details about the processing arrangements relevant to your relationship with us.

Our services, applications, and creator or collaboration registrations are intended for adults aged 18 or older. We do not knowingly accept registrations or collaborations from minors. If you believe a minor has provided personal information to us, contact [email protected].

14. Changes and contact

Updates to this notice will be reflected in the “Last Revised” date. Any additional notice required by applicable law remains applicable.