1. WHO IS RESPONSIBLE FOR MANAGING MY INFORMATION?

This website (https://www.topbrokers.com) is owned and maintained by NIM Business Services LLC

(“we” or “us”). We are responsible for the collection and proper management of any personal information you submit. We will keep your details secure and use the information you provide consistently with applicable privacy and data protection laws and the terms of this Privacy Policy.

2. WHAT INFORMATION DO WE COLLECT?

Visitation to the Topbroker’s websites

When visiting the website we may capture the following data types:

2.1 IP Address: as part of our cookies, we may capture IP Addresses for website performance analytics, for geographical data.

2.2 Email Address: as part of our subscription or newsletter updates, we may ask for your email address to provide correspondence.

2.3 First Name and Last Name: as part of the Topbrokers registration process and subscription to newsletters, we would request these data items from the end user.

2.4 Contact Number: as part of the registration process for a subscribed user to the Topbrokers platform, a contact number is requested for 2nd device 2FA verification.

Use of the Topbrokers Application and associated platforms.

When subscribed to one of our services, our users will have access to the Topbrokers platform and associated systems, in this instance, we process additional data items, which are processed as part of our data processing agreement with our customers.

For further information please contact the Data Protection Officer (DPO) Office at [email protected]

We also collect website usage information; We do this by using cookies (see section 7 below).

3. HOW DO WE USE YOUR INFORMATION?

The information you provide may be used in several ways, for example:

to enable us to deliver a focused product delivery.
to provide you with the information, products, and services you ask for, and honor any contract you have with us;
for statistical purposes when we evaluate our range of services.
to personalize repeat visits to our website.
to tell you about other products and services we think may be of interest to you (see section 5 below); and
to manage customer service queries.

4. WHO DO WE SHARE YOUR INFORMATION WITH?

To provide you with the products and services that we offer we may share your information with:

5. WHEN CAN WE CONTACT YOU IN THE FUTURE?

We would like to send you information about our products and services, as well as those of selected third parties. We may do this by email or social networks unless you have told us that you do not wish to be contacted in this way. We will always ask you to confirm in advance that you are happy for us to allow third parties to contact you by email.

If you would like to change any of your preferences relating to how we may use your information for direct marketing, then please update your user preferences or send an email to [email protected]

6. HOW LONG WILL WE HOLD YOUR INFORMATION?

We have a system of retention periods in place to ensure that your information is only stored whilst it is required for relevant purposes or to meet legal requirements. Where your information is no longer required, we will ensure it is disposed of in a secure and compliant manner.

7. COOKIES

What are Cookies?

Cookies are small data files that are placed on your computer or mobile device when you visit a website. Cookies are widely used by website owners to make their websites work, or to work more efficiently, as well as to provide reporting information.

Cookies set by the website owner (in this case, Topbrokers are called “first party cookies”).

Cookies set by parties other than the website owner are called “third party cookies”. Third-party cookies enable third-party features or functionality to be provided on or through the website (e.g., advertising, interactive content, and analytics). The parties that set these third-party cookies can recognize your computer both when it visits the website in question and when it visits certain other websites.

What Cookies do Topbrokers use?

Our website does not directly use cookies to distinguish you from other users of our website, however, we have third-party cookies that process the following:

Cookie	Tracker	URL
Google Tag Manager	SEO Tagging and Google Analytics	https://securiti.ai/cookie-consent-integrations/google-tag-manager/orhttps://policies.google.com/privacy?hl=en#infocollect
Session Info	Yandex.ru	https://brokers.ru
Web Page Activity Data
Regional Session Data
Video Relevant Content
New User Registration
Attraction and Retention Session Data
Web Visitor Data	AdRoll	https://www.nextroll.com/privacy
Location Data
Device and Operating System Data

8. HOW CAN YOU ACCESS AND UPDATE YOUR INFORMATION?

You have the right to request a copy of the information that we hold about you. If you would like a copy of some or all of your personal information, please email or write to us at the address below:

[email protected]

We want to make sure that your personal information is accurate and up to date. You may ask us to correct or remove information you think is inaccurate.

9. DOES THE POLICY APPLY TO LINKED WEBSITES?

Our website may contain links to other websites. This privacy policy only applies to this website Should there be a link that leaves the pages of Topbrokers to another domain, not specified as https://www.topbrokers.com you should read their privacy policies.

10. HOW DO WE UPDATE THIS PRIVACY POLICY?

We keep our privacy policy under regular review and we will place any updates on our webpage. This privacy policy was last updated on 2nd March 2023. Please take the time to regularly review

11. WHO CAN YOU CONTACT IF YOU HAVE QUERIES ABOUT THIS PRIVACY POLICY?

Please contact us if you have any questions about our privacy policy or the information we hold about you.

By email: [email protected]

12. POLICY VERSION HISTORY – INTERNAL USE ONLY – DO NOT PUBLISH THIS PAGE ONLINE

Version	Date	Description	Updated By
1.0	20/02/2023	Initial Policy Drafted	Mgr. SB Purdie
1.1	02/03/2023	Formatting and legal entity updates to content	Mgr. SB Purdie

TOPBROKERS TERMS AND CONDITIONS (“TERMS”)

Our Terms and Conditions were last updated on 2nd March 2023.

Please read these terms and conditions carefully before using any of Our Services. Should you not agree with any of the following conditions, refrain from using the platform.

1. INTERPRETATIONS AND DEFINITIONS
- 1.1 InterpretationThe words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or plural.
- 1.2 DefinitionsFor these Terms and Conditions:
  1. “Application” means the application platform provided by the Company accessed by You on any electronic device.
  2. “Application Store” means the digital distribution service operated and developed by Apple Inc. (Apple App Store) or Google Inc. (Google Play Store) in which the Application has been downloaded.
  3. “Affiliate” means an entity that controls, is controlled by, or is under common control with a party, whereas “control” means ownership of 50% or more of the shares, equity interest, or other securities entitled to vote for the election of directors or other managing authority.
  4. “Account” means a unique account created for You to access our Service or parts of our Service.
  5. “Company” (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to NIM Business Services LLC
  6. “Country” refers to Texas, United States of America.
  7. “Content” refers to content such as text, images, or other information that can be posted, uploaded, linked to or otherwise made available by You, regardless of the form of that content.
  8. “Device” means any device that can access the Service such as a computer, a cell phone, or a digital tablet.
  9. “Feedback” means feedback, innovations, or suggestions sent by You regarding the attributes, performance, or features of our Service.
  10. “Service” refers to the Website, Professional Services, or any other services delivered by https://www.topbrokers.com
  11. “Terms and Conditions” (also referred to as “Terms”) mean these Terms and Conditions that form the entire agreement between You and the Company regarding the use of the Service(s).
  12. “Third-party Social Media Service” means any services or content (including data, information, products, or services) provided by a third party that may be displayed, included, or made available by the Service.
  13. “Website” refers to the Company website, accessible from https://www.topbrokers.com
  14. “You” means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.
2. ACKNOWLEDGMENTThese are the Terms and Conditions governing the use of this Service and the agreement that operates between You and the Company. These Terms and Conditions set out the rights and obligations of all users regarding the use of the Service.Your access to and use of the Service is conditioned on Your acceptance of and compliance with these Terms and Conditions. These Terms and Conditions apply to all visitors, users, and others who access or use the Service.By accessing or using the Service You agree to be bound by these Terms and Conditions. If You disagree with any part of these Terms and Conditions then You may not access the Service.You represent that you are over the age of 18. The Company does not permit those under 18 to use the Service.Your access to and use of the Service is also conditioned on Your acceptance of and compliance with the Privacy Policy of the Company. Our Privacy Policy describes Our policies and procedures on the collection, use, and disclosure of Your personal information when You use the Application or the Website and tells You about Your privacy rights and how the law protects You. Please read Our Privacy Policy carefully before using Our Service.
3. USER ACCOUNTSWhen You create an account with Us, You must provide information that is accurate, complete, and current at all times. Failure to do so constitutes a breach of the Terms, which may result in immediate termination of Your account on Our Services.You are responsible for safeguarding the password that You use to access the Service and for any activities or actions under Your password, whether Your password is with Our Service or a Third-Party Social Media Service.You agree not to disclose Your password to any third party. You must notify Us immediately upon becoming aware of any breach of security or unauthorized use of Your account.You may not use as a username the name of another person or entity or that is not lawfully available for use, a name or trademark that is subject to any rights of another person or entity other than You without appropriate authorization, or a name that is otherwise offensive, vulgar or obscene.
4. CONTENT
1. 4.1 Your Right to Post ContentOur Service allows You to post Content (Reviews). You are responsible for the Content that You post to the Service, including its legality, reliability, and appropriateness.By posting content to the Service, You grant Us the right and license to use, modify, publicly perform, publicly display, reproduce, and distribute such Content on and through the Service. You retain any of Your rights to any Content You submit, post, or display on or through the Service and You are responsible for protecting those rights. You agree that this license includes the right for Us to make Your Content available to other users of the Service, who may also use Your Content subject to these Terms.You represent and warrant that:
  1. the content is Yours (You own it) or You have the right to use it and grant Us the rights and license as provided in these Terms, and
  2. the posting of Your Content on or through the Service does not violate the privacy rights, publicity rights, copyrights, contract rights, or any other rights of any person.
2. 4.2 Content RestrictionsThe Company is not responsible for the content of the Service’s users. You expressly understand and agree that You are solely responsible for the Content and for all activity that occurs under your account, whether done so by You or any third person using Your account.You may not transmit any Content that is unlawful, offensive, upsetting, intended to disgust, threatening, libelous, defamatory, obscene, or otherwise objectionable. Examples of such objectionable Content include, but are not limited to, the following:
  1. Unlawful or promoting unlawful activity.
  2. Defamatory, discriminatory, or mean-spirited content, including references or commentary about religion, race, sexual orientation, gender, national/ethnic origin, or other targeted groups.
  3. The processing of data associated with Minors (under the age of 18 years old)
  4. Spam, machine – or randomly-generated, constituting unauthorized or unsolicited advertising, chain letters, any other form of unauthorized solicitation, or any form of lottery or gambling.
  5. Containing or installing any viruses, worms, malware, trojan horses, or other content that is designed or intended to disrupt, damage, or limit the functioning of any software, hardware, or telecommunications equipment or to damage or obtain unauthorized access to any data or other information of a third person.
  6. Infringing on any proprietary rights of any party, including patent, trademark, trade secret, copyright, right of publicity, or other rights.
  7. Impersonating any person or entity including the Company and its employees or representatives.
  8. Violating the privacy of any third person.
  9. False information and features.
3. The Company reserves the right, but not the obligation, to, in its sole discretion, determine whether or not any Content is appropriate and complies with these Terms, refuse or remove this Content. The Company further reserves the right to make formatting and edits and change the manner of any Content.The Company can also limit or revoke the use of the Service if You imply objectionable Content or malicious activity towards Us or any other Users of our platforms. As the Company cannot control all content posted by users and/or third parties on the Service, you agree to use the Service at your own risk.You understand that by using the Service You may be exposed to content that You may find offensive, indecent, incorrect, or objectionable, and You agree that under no circumstances will the Company be liable in any way for any content, including any errors or omissions in any content, or any loss or damage of any kind incurred as a result of your use of any content.

5. COPYRIGHT POLICY
1. 5.1 Intellectual Property InfringementWe respect the intellectual property rights of others. It is Our policy to respond to any claim that Content posted on the Service infringes a copyright or other intellectual property infringement of any person.If You are a copyright owner, or authorized on behalf of one, and You believe that the copyrighted work has been copied in a way that constitutes copyright infringement that is taking place through the Service, You must submit Your notice in writing to the attention of our legal team via email ([email protected]) and include in Your notice a detailed description of the alleged infringement.You may be held accountable for damages (including costs and attorneys’ fees) for misrepresenting that any Content is infringing Your copyright.
2. 5.2 Intellectual PropertyThe Service and its original content (excluding Content provided by You or other users), features, and functionality are and will remain the exclusive property of the Company and its licensors.The Service is protected by copyright, trademark, and other laws of both the Country and foreign countries.Our trademarks and trade dress may not be used in connection with any product or service without the prior written consent of the Company.
6. YOUR FEEDBACK TO USYou assign all rights, titles, and interests in any feedback You provide the Company. If for any reason such assignment is ineffective, You agree to grant the Company a non-exclusive, perpetual, irrevocable, royalty-free, worldwide right and license to use, reproduce, disclose, sub-license, distribute, modify, and exploit such Feedback without restriction.
7. LINKS TO OTHER WEBSITESOur Service may contain links to third-party websites or services that are not owned or controlled by the Company.The Company has no control over and assumes no responsibility for, the content, privacy policies, or practices of any third-party websites or services. You further acknowledge and agree that the Company shall not be responsible or liable, directly or indirectly, for any damage or loss caused or alleged to be caused by or in connection with the use of or reliance on any such content, goods, or services available on or through any such web sites or services.We strongly advise You to read the terms and conditions and privacy policies of any third-party websites or services that You visit.
8. TERMINATIONWe may terminate or suspend Your Account immediately, without prior notice or liability, for any reason whatsoever, including without limitation if You breach these Terms and Conditions.Upon termination, Your right to use the Service will cease immediately. If You wish to terminate Your Account, You may simply discontinue using the Service.
9. LIMITATION OF LIABILITYTo the maximum extent permitted by applicable law, in no event shall the Company or its suppliers be liable for any special, incidental, indirect, or consequential damages whatsoever (including, but not limited to, damages for loss of profits, loss of data or other information, for business interruption, for personal injury, loss of privacy arising out of or in any way related to the use of or inability to use the Service, third-party software and/or third-party hardware used with the Service, or otherwise in connection with any provision of this Terms), even if the Company or any supplier has been advised of the possibility of such damages and even if the remedy fails of its essential purpose.
10. “AS IS” AND “AS AVAILABLE” DISCLAIMERThe Service is provided to You “AS IS” and “AS AVAILABLE” and with all faults and defects without warranty of any kind. To the maximum extent permitted under applicable law, the Company, on its behalf and behalf of its Affiliates and their respective licensors and service providers, expressly disclaims all warranties, whether express, implied, statutory, or otherwise, concerning the Service, including all implied warranties of merchantability, fitness for a particular purpose, title and non-infringement, and warranties that may arise out of a course of dealing, course of performance, usage or trade practice.Without limitation to the foregoing, the Company provides no warranty or undertaking, and makes no representation of any kind that the Service will meet Your requirements, achieve any intended results, be compatible or work with any other software, applications, systems, or services, operate without interruption, meet any performance or reliability standards or be error free or that any errors or defects can or will be corrected.Without limiting the foregoing, neither the Company nor any of the Company’s providers makes any representation or warranty of any kind, express or implied:
1. as to the operation or availability of the Service, or the information, content, and materials or products included thereon;
2. that the Service will be uninterrupted or error-free;
3. as to the accuracy, reliability, or currency of any information or content provided through the Service; or
4. that the Service, its servers, the content, or e-mails sent from or on behalf of the Company are free of viruses, scripts, trojan horses, worms, malware, timebombs, or other harmful components.
Some jurisdictions do not allow the exclusion of certain types of warranties or limitations on applicable statutory rights of a consumer, so some or all of the above exclusions and limitations may not apply to You. But in such a case the exclusions and limitations outlined in this section shall be applied to the greatest extent enforceable under applicable law.
11. GOVERNING LAWThe Federal law of the United States of America, excluding its conflicts of law rules, shall govern these Terms and Your use of the Service. Your use of the Application may also be subject to other local, state, national, or international laws.
12. DISPUTES RESOLUTIONIf You have any concern or dispute about the Service, You agree to first try to resolve the dispute informally by contacting the Company, through a support ticket or if you have a data privacy concern, then use partners @topbrokers.com
13. SEVERABILITY AND WAIVER
1. 13.1 SeverabilityIf any provision of these Terms is held to be unenforceable or invalid, such provision will be changed and interpreted to accomplish the objectives of such provision to the greatest extent possible under applicable law and the remaining provisions will continue in full force and effect.
2. 13.2 WaiverExcept as provided herein, the failure to exercise a right or to require the performance of an obligation under these Terms shall not affect a party’s ability to exercise such right or require such performance at any time thereafter nor shall the waiver of a breach constitute a waiver of any subsequent breach.
14. CHANGES TO THESE TERMS AND CONDITIONSWe reserve the right, at Our sole discretion, to modify or replace these Terms at any time. If a revision is material We will make reasonable efforts to provide at least 30 days’ notice before any new terms take effect. What constitutes a material change will be determined at Our sole discretion.By continuing to access or use Our Service after those revisions become effective, You agree to be bound by the revised terms. If You do not agree to the new terms, in whole or in part, please stop using the website and the Service.
15. CONTACT USIf you have any questions about these Terms and Conditions, You can contact us:By visiting this page on our website: https://www.topbrokers.com By sending us an email: partners@topbrokers.com

Privacy Policy