1. Introduction

Toptoptime SAS ("Toptoptime", "we", "us", "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal data when you use our platform (website and mobile application).

2. Data Controller

The data controller responsible for your personal data is:

Toptoptime SAS
25 rue de Ponthieu, 75008 Paris, France
RCS 930 179 544
Email: privacy@toptoptime.com

3. Personal Data We Collect

We collect the following categories of personal data:

• •Account Information: name, email address, phone number, profile picture, password.
• •Identity Verification (Mentors): government-issued ID, professional certifications.
• •Transaction Data: booking history, payment information (processed by our PSP), invoices.
• •Location Data: address for service delivery, approximate location for search functionality.
• •Usage Data: device information, IP address, browser type, pages visited, interaction data.
• •Communications: messages between Mentors and Learners, customer support inquiries.

4. Legal Basis for Processing

We process your personal data based on:

• •Contract performance: to provide our services and fulfill bookings.
• •Legitimate interests: to improve our platform, prevent fraud, and ensure security.
• •Legal obligations: to comply with tax, accounting, and regulatory requirements.
• •Consent: for marketing communications (which you can withdraw at any time).

5. How We Use Your Data

• •Create and manage your account
• •Facilitate bookings and payments between Mentors and Learners
• •Verify Mentor identities and qualifications
• •Send booking confirmations, reminders, and service notifications
• •Provide customer support
• •Improve and personalize our services
• •Detect and prevent fraud or abuse

6. Data Sharing

We may share your data with:

• •Other Users: Mentors and Learners can see relevant profile information for booking purposes.
• •Payment Service Providers: to process transactions (e.g., Stripe).
• •Service Providers: hosting, analytics, customer support tools.
• •Legal Authorities: when required by law or to protect our rights.

7. Data Retention

We retain your personal data for as long as your account is active or as needed to provide services. After account deletion, we may retain certain data for up to 5 years to comply with legal obligations, resolve disputes, and enforce our agreements.

8. Your Rights (GDPR)

Under the GDPR, you have the right to:

• •Access your personal data
• •Rectify inaccurate data
• •Eraseyour data ("right to be forgotten")
• •Restrict processing of your data
• •Data portability – receive your data in a structured format
• •Object to processing based on legitimate interests
• •Withdraw consent for marketing at any time

To exercise these rights, contact us at privacy@toptoptime.com.

9. Cookies

We use cookies and similar technologies to enhance your experience, analyze usage, and provide personalized content. You can manage your cookie preferences through your browser settings or our cookie consent banner.

10. Data Security

We implement appropriate technical and organizational measures to protect your personal data, including encryption, secure servers, and access controls. However, no method of transmission over the Internet is 100% secure.

11. International Transfers

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

12. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of significant changes via email or through the Platform. The "Last updated" date at the top indicates when revisions were made.

13. Contact & Complaints

For questions or complaints about this Privacy Policy or our data practices, contact us at:

Email: privacy@toptoptime.com
Address: Toptoptime SAS, 25 rue de Ponthieu, 75008 Paris, France

You also have the right to lodge a complaint with the French data protection authority (CNIL): www.cnil.fr