Promotions
We may collect the following information provided by you:

• First name, last name, email address, postal address, phone number, or other similar data

Purchase Products
We may ask you for payment information you provide which may include:

• Payment card number, security code, expiration date and similar information

If you ask a question or report an issue
Our contact forms we may collect information you submit, such as:

• First Name, Last Name, postal address, email address, phone number and similar information

Suppliers to Itoya Topdrawer Corp
As a supplier to us, we may collect the following information that you would have chosen to give us:

• Contact details, location and products or services offered by your company and information related to pricing, sourcing and other business practices, if you apply to become an approved supplier

Employees, and applying for Employment
We may ask for the following information and collect information relevant for your application or employment:

• Education and academic degrees
• Applicable licenses or certifications
• Prior employment history
• National ID
• References
• Any other data you choose to provide

By accepting an interview or employment with Itoya Topdrawer Corp you agree that we will collect other relevant information from you in addition to the information provided during the recruitment process and it will become part of your personnel record with topdrawer.

We collect information about how you interact with our website and other Services through the use of cookies, pixel tags and similar technologies. This also includes usage information, browsing history and information about how you navigate within our Services. We may also collect your device information which includes IP address, location, internet provider, device ID and operating system.

We may also collect demographic information such as your country and preferred language as our privacy policy may be slightly different depending on which country you live.

We may obtain information through partners, vendors, suppliers and other third parties which are typically corporate entities (although some may be educational and public enterprises) and may be located in any of the locations in which we do business. We collect this data in order to make your experiences better on our websites, for example. These third parties fall into the following categories:/p>

• Advertising & marketing companies
• Social media platforms & partners
• Promotional partners

Our agents and contractors do or might have access to personally identifiable information to help carry out the services that they are performing for us in connection with our business and providing the Service. We make reasonable efforts to assure that such third parties will honor this Privacy Policy, including by obligating them to do so in our agreements with them.

We do or might share personally identifiable information with business partners and third parties (for example, other marketers, websites, advertisers, and commercial and not for profit organizations) that want to market products or services to you. We provide you the opportunity to opt out of (stop) use of your personally identifiable information for such marketing purposes.

Our Service does or might contain links to third party websites and services whose information practices are or might be different from our own. We are not responsible for, do not vouch for, and have no control over the third parties who might be receiving or collecting information from or about you. Please refer to those third parties privacy policies and statements before submitting any information.

If you are in the European Economic Area, our legal basis for collecting and using personal information described above will depend on the personal information concerned and the specific context in which we collect it.

However, we will collect personal information from you only where we have your consent to do so, where we need the personal information to perform a contract with you, where we have a legal obligation to do so or where the processing is in our legitimate interests( such as processing for administrative purposes, preventing fraud or criminals acts and in support of information security) and not overridden by your data protection interests or fundamental rights and freedoms.

If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the time of collection. We will also tell you whether the requirement for that information is mandatory and explain any consequences to you if you do not provide the information.

Similarly, if we collect and use your personal information based on our legitimate interests (or those of any third party), we will take reasonable steps to provide clear notice and describe our legitimate interests.

Itoya Topdrawer Corp excepts that it is the Data Controller of all personal information collected in the EEA by our websites, except where a supplemental policy says otherwise.

If you have questions about or need further information concerning the legal basis for any specific processing activity or wish to contact the Data Controller, please contact at PRIVACY@TOPDRAWERSHOP.COM

We do or might offer content or services that are sponsored by or co-branded with identified third parties. As a result, such third parties might obtain personally identifiable information that you provide in connection with such content or services. We are not responsible for, and we do not monitor or control, information provided to or collected by such third parties.

Third parties (for example, Google) do or might present or serve advertisements, provide us with data collection, reporting, ad response measurement, and Site analytics, and assist with delivery of marketing messages and advertisements. The use of these technologies by these third parties is subject to their own privacy policies and is not covered by this Privacy Policy. They may also obtain information about other applications that you have downloaded to your device, the websites you visit, and other information about you or your device in order to help analyze and serve anonymous targeted advertising on the Site and elsewhere. These third parties also may view, edit, or set their own cookies (we explain cookies below). For more information about third party ad servers at our Site and your ability to opt out of targeted advertising from such third parties, please visit the Network Advertising Initiative and/or the Self-Regulatory Program for Online Behavioural Advertising.

Your opting out of targeted advertising via these programs is intended to stop certain targeted advertising, but still will allow the collection of usage data for some purposes, including research, analytics and internal operations. We are not responsible for the operation of these opt out mechanisms and does not assure that they will work.

We may disclose personally identifiable information in response to legal process, for example in response to a court order or a subpoena, or in response to requests from law enforcement or other government agencies. We also may disclose such information to third parties in connection with fraud detection and prevention activities, or when we believe it is necessary or appropriate to investigate, prevent, or take action regarding known, suspected or anticipated (i) illegal activities or fraud, (ii) harm or threats to the safety and well-being of any person or property, (iii) violations of our Terms of Service, or (iv) violations of our rights, or the rights of others, or violations of law.

We may transfer all information about you in connection with a transaction for the sale or transfer of our company, business, or assets. Such a transaction might be (but is not limited to) a merger, acquisition, asset sale, dissolution, bankruptcy, reorganization, or reincorporation.

We intend our Service for use solely by users located within the United States. We rely on third parties to provide services and otherwise enable us to provide the Service to you. We cannot control how or where such third parties route, process or store information and data. If you use the Service, you consent to the collection, processing and storage in the United States and elsewhere of your information.

We have not certified with the U.S. Department of Commerces Safe Harbor Program to address data transfers from the European Union and Switzerland. U.S. data protection and privacy regulations may not offer the same level of protection as in other parts of the world. We do not assure that your information will be stored, shared or used only within the U.S.

If you would like more information about our data transfer practices or obtain a copy of any relevant safeguarding measure or the countries in which we process personal data, please contact PRIVACY@TOPDRAWERSHOP.COM

If you would like to correct or update your personal information, or request access to or deletion of your personal information, you may contact us at privacy@topdrawershop.com Please note that we are obligated to verify your identify before we provide personal information. If you request a change to or deletion of your personal information, please note that we may still need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting such change or deletion. Some of your information may also remain in our systems and other records where necessary for compliance with applicable law.

You can opt out of receiving marketing communications.

You can opt out of receiving (that is, stop) marketing communications from us and from our third party marketers. You can update your preferences for receiving or not receiving marketing communications from us and from third parties by (i) clicking the unsubscribe link provided in marketing emails you may receive and following those instructions; or (ii) sending to privacy@topdrawershop.com an email stating UNSUBSCRIBE from your email account to be unsubscribed.

Please allow a reasonable time for our Service to receive and give effect to your updates.

Even if you opt out of receiving marketing communications, we still may use your information to contact you for non-marketing purposes if and as they relate to your use of the Service (for example, for matters concerning your use of the Service, your merchandise orders, exchanges and refunds, updates to our topdrawershop.com Terms of Service and this Privacy Policy, and other administrative matters).

We do or might share non-personally identifiable information with third parties from time to time as we choose, with or without notice to you, and with no opportunity to opt out.

You may have additional rights under the EU GDPR and certain other countries laws. For example, if you are in the EEA, you may request:

• The purpose of processing
• The categories of personal data concerned
• Who else outside of Itoya Topdrawer Corp might have received the data from us
• What the source of the information was if you didnt provide it directly to us
• How long it will be stored

In many countries including the USA you have a right to lodge a complaint with the appropriate data privacy authority if you have concerns about how we process your personal information.

The California Consumer Privacy Act of 2018 (CCPA) gives consumers more control over the personal information that businesses collect about them and the CCPA regulations provide guidance on how to implement the law. This landmark law secures new privacy rights for California consumers, including:

• The right to know about the personal information a business collects about them and how it is used and shared;
• The right to delete personal information collected from them (with some exceptions);
• The right to opt-out of the sale of their personal information
• The right to non-discrimination for exercising their CCPA rights.

Businesses are required to give consumers certain notices explaining their privacy practices. The CCPA applies to many businesses, including data brokers.

The security of your information is important to us. When we process your data, we utilize reasonable and appropriate administrative, technical and organizational security measures to protect your personal information against risks such as temporary or permanent loss, destruction or unauthorized or unlawful access, alteration, use or disclosure.

We require our suppliers and partners to apply similar protections when they access or use personal information we share with them. Of course, no technology, data transmission or system is 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us at privacy@topdrawershop.com

We try to follow reasonable physical, electronic, and managerial procedures designed to safeguard the information that we collect online at the Service. However, we cannot and do not guarantee or assure you that personally identifiable information that we collect will never be stored, transmitted, disclosed or otherwise used in a manner inconsistent with this Privacy Policy.

We comply with the Childrens Online Privacy Protection Act in the United States and similar laws around the world, where applicable to Itoya Topdrawer Corp Services. We do not knowingly collect personal information from minors. If you believe we may have collected personal information from a minor without the requisite consent, please let us know at PRIVACY@TOPDRAWERSHOP.COM

We retain your personal information for the period necessary to: provide you with the services you have requested of us, as needed to comply with legal obligations (e.g., to comply with mandatory record retention or legal hold requirements), as agreed to in a consent form, to resolve disputes, and to otherwise fulfill the purposes, rights and obligations outlined in this Privacy Notice.

Retention periods can vary significantly based on the type of information and how it is used. Our retention periods are based on criteria that include legally mandated retention periods, pending or potential litigation, our intellectual property rights or ownership rights, contract requirements, operational directives or needs, and historical archiving.

We dont permit use of spam, spyware, malware, or anything else that we do not intend our Service to provide. We dont send emails to anyone without their permission. If you believe that you have received an unsolicited email from us or encountered spyware or malware on our Service, please write us at privacy@topdrawershop.com so that we can investigate.

This Privacy Notice does not address, and we are not responsible for, the policies and practices of third parties or other organizations that are not operating on our behalf, including policies and practices related to privacy and security, data collection, processing use, storage and disclosure. This includes:

• Any third party operating any site or service to which this site is linked
• Any app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer including any personal information you disclose to such organizations through or in connection with Itoya Topdrawer Corps Services, apps or social media pages.

We may change this Privacy Notice from time to time so it accurately reflects our practices, Services and compiles with legal requirements. The Last Revised date below this notice states when this notice was last amended and we update this date each time a revision is posted.

Any changes to this Privacy Notice will become effective when we post it on our website. We encourage you to check back regularly to stay informed of any updates to our Notice.