TopGunner, Inc. (“TopGunner,” “we,” “us,” or “our”) respects your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard information when you use our website (topgunner.io), mobile applications, and related services (collectively, the “Platform”).
This Policy is designed to address both U.S. state privacy laws (such as the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA/CPRA”), and similar state laws) and, where applicable, the EU/UK General Data Protection Regulation (“GDPR”). Terms like “personal data” and “personal information” are used interchangeably in this Policy.
1. Information We Collect
a. Information You Provide
- Account information: name, email address, password (hashed), institution/affiliation, professional role (e.g., student, resident, attending, allied health), profile photo (optional).
- Payment information: billing name, billing address, and payment method details, processed by our third-party payment processor (e.g., Stripe) — TopGunner does not store full payment card numbers.
- Content you submit: quiz answers, question submissions, comments, support requests, survey responses.
- Communications: emails or messages you send to us.
b. Information Collected Automatically
- Usage data: pages viewed, quizzes attempted, questions answered, time spent, click patterns, device type, browser type, operating system, IP address, and approximate location derived from IP address.
- Cookies and similar tracking technologies, as described in our Cookie Policy, incorporated herein by reference.
- Analytics data collected via tools such as Google Analytics.
c. Information from Third Parties
- If you sign in via a single sign-on provider (e.g., Google), we receive basic profile information as authorized by you and that provider.
- Institutional partners (e.g., medical schools, residency programs) may provide limited enrollment or cohort information for institutional accounts.
2. How We Use Information
We use personal information to:
- Create and maintain your account and authenticate logins;
- Operate, personalize, and improve the Platform, including adaptive question selection and AI-assisted content generation or feedback;
- Calculate and display leaderboards, rankings, and contest results per our Leaderboard & Contest Rules;
- Process payments and manage subscriptions per our Subscription & Billing Policy;
- Send transactional communications (account, billing, security notices) and, where you have opted in, marketing communications;
- Monitor for fraud, abuse, cheating, and violations of our Acceptable Use Policy and Community Guidelines;
- Analyze aggregate and de-identified usage trends to improve educational content and product features;
- Comply with legal obligations and enforce our Policies.
3. AI Tools and Your Data
Certain features (e.g., AI-generated quiz questions, AI-assisted grading or feedback) may process your quiz responses or submitted content using third-party AI service providers. We take reasonable steps to require such providers to protect your data and not use it to train their general-purpose models beyond what is necessary to provide the service, but you should review our AI Content Disclaimer for more information about the limitations of AI-generated content.
4. How We Share Information
We do not sell your personal information for money. We may share information with:
- Service providers who perform functions on our behalf (e.g., cloud hosting, payment processing, analytics, customer support, AI content providers), under confidentiality and data protection obligations;
- Institutional administrators, if you are enrolled through an institutional account, limited to information necessary for cohort management and reporting (e.g., aggregate performance, not individual quiz answers, unless otherwise disclosed to you at enrollment);
- Other users, limited to your display name/username, rank, and score, if you participate in leaderboards or public contests;
- Legal and safety purposes, including to comply with law, respond to legal process, protect the rights and safety of TopGunner and its users, or investigate fraud or violations of our Policies;
- Business transfers, in connection with a merger, acquisition, financing, or sale of assets, subject to standard confidentiality protections.
For CCPA/CPRA purposes, disclosures to service providers and analytics/advertising partners for cookies (see Cookie Policy) may be considered a “sale” or “share” under California law’s broad definitions; see Section 8 below for your opt-out rights.
5. Data Retention
We retain personal information for as long as your account is active and as necessary to provide the Platform, comply with legal obligations, resolve disputes, and enforce our agreements, consistent with our Security & Data Retention Policy, incorporated herein by reference.
6. Data Security
We implement reasonable administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, disclosure, alteration, or destruction, as described further in our Security & Data Retention Policy. No method of transmission or storage is 100% secure, and we cannot guarantee absolute security.
7. International Users and Data Transfers
If you access the Platform from outside the United States, you understand that your information will be transferred to, stored, and processed in the United States, where data protection laws may differ from those in your jurisdiction. Where required by GDPR, we rely on appropriate safeguards (such as Standard Contractual Clauses) for transfers of personal data originating in the EU/UK/EEA.
8. Your Privacy Rights
a. U.S. State Privacy Rights (e.g., California).
Depending on your state of residence, you may have the right to: know/access the categories and specific pieces of personal information we hold about you; request deletion; request correction; opt out of the “sale” or “sharing” of personal information (including certain cookie-based advertising); and not be discriminated against for exercising these rights. To exercise these rights, contact us at contact@topgunner.io. We will verify your request using information associated with your account.
b. GDPR Rights (EU/UK/EEA users).
You may have the right to access, rectify, erase, restrict or object to processing, receive a portable copy of your data, and withdraw consent at any time (without affecting prior lawful processing). Our legal bases for processing include performance of a contract (providing the Platform), legitimate interests (improving and securing the Platform), consent (marketing, certain cookies), and legal obligation. You may also lodge a complaint with your local data protection authority.
c. Marketing Opt-Out.
You may opt out of marketing emails at any time via the unsubscribe link or by contacting contact@topgunner.io. Transactional and account-related emails are not subject to opt-out while your account remains active.
9. Children’s Privacy
The Platform is not directed to children under 13, and we do not knowingly collect personal information from children under 13. If we learn we have collected personal information from a child under 13 without parental consent, we will delete it promptly. Parents who believe their child has provided us information may contact contact@topgunner.io.
10. Cookies and Tracking Technologies
See our Cookie Policy for details on the types of cookies and tracking technologies we use and how to manage your preferences.
11. Third-Party Links
The Platform may contain links to third-party websites or services not operated by TopGunner. We are not responsible for the privacy practices of such third parties, and we encourage you to review their privacy policies.
12. Changes to This Policy
We may update this Privacy Policy from time to time. Material changes will be communicated via the Platform or email, and the “Last Updated” date above will reflect the most recent revision. Continued use of the Platform after changes take effect constitutes acceptance.
13. Contact Us
Questions about this Privacy Policy or our data practices may be directed to: contact@topgunner.io