Data controller: Shanghai Boren Information Technology Co., Ltd. (trading as "Top Couple"). Contact: support@couple.top.
1. Who is responsible for your data
Shanghai Boren Information Technology Co., Ltd. (trading as "Top Couple") is the controller of personal data processed through couple.top. Contact: support@couple.top.
For orders sold by Sailor & Oasis Co., Limited ("S&O") through its Merchant of Record checkout, S&O is the controller of the payment and billing data it collects for that order. Shanghai Boren Information Technology Co., Ltd. remains the controller of the account, profile, report and technical data described below.
2. What we collect
Account data: your phone number, login credentials, and your region and language settings.
Profile data that you enter: name, gender, date of birth, time of birth, place of birth, and the relationships you record between profiles.
Report data: the questions you ask, the reports generated for you, and your feedback on them.
Transaction data: order references, amounts, credit balance and credit history. Full card details never reach us: for purchases outside mainland China they are collected and stored by PayPal, or by S&O and its payment providers for orders sold by S&O; for purchases in mainland China payment is handled by WeChat Pay or Alipay. None of them pass your payment password or full card number to us.
Technical data: IP address, device and browser type, and usage logs.
3. Why we process it, and on what legal basis
To provide the Service and generate the reports you ask for. Legal basis: performance of our contract with you.
To run your account and process payments. Legal basis: performance of our contract with you.
To keep the Service secure and prevent abuse. Legal basis: our legitimate interests.
To send service messages such as payment receipts and security notices. Legal basis: performance of our contract with you.
To meet tax, accounting and other legal obligations. Legal basis: compliance with a legal obligation.
To send marketing messages. Legal basis: your consent, which you can withdraw at any time.
4. Birth data
Date, time and place of birth are collected because our report templates use them as input variables. They are used only to generate your reports. We do not use them to identify you, we do not sell them, and we do not use them for advertising.
5. Who we share it with
PayPal, our payment service provider for purchases made outside mainland China, to process those payments and to process refunds for them.
Sailor & Oasis Co., Limited ("S&O"), as Merchant of Record and reseller for orders it sells, to process those orders, collect payment through its payment providers, handle refunds, chargebacks and payment-related inquiries, and meet its tax and accounting obligations.
WeChat Pay and Alipay, to collect payments made in mainland China and to process refunds for them. They return the payment order reference and result to us.
AI model providers, to generate report text. Data is sent under contract and is not used by them to train their public models.
Cloud hosting and database providers, to store and serve the Service.
Professional advisers and authorities, where the law requires it.
We do not sell your personal data.
6. International transfers
Our servers and our service providers may be located outside the country where you live, including in China, the European Union and the United States. Where personal data from the European Economic Area or the United Kingdom is transferred outside that area, we rely on appropriate safeguards such as the European Commission's Standard Contractual Clauses. Payments made in mainland China are processed by WeChat Pay and Alipay within mainland China. For orders sold by S&O, payment and billing data may be processed by S&O and its payment providers outside your country of residence.
7. How long we keep it
Account and profile data: while your account is open, and for 30 days after you delete it.
Reports and questions: while your account is open.
Transaction and tax records: for as long as tax and accounting law requires.
Server logs: for a limited period, after which they are deleted or anonymised.
We may keep records for longer where the law requires it, or to establish or defend legal claims.
8. Your rights
Subject to the law where you live, you may:
access the personal data we hold about you;
correct data that is inaccurate;
delete your account and the data in it;
export your data in a portable format;
restrict or object to certain processing;
withdraw a consent you have given.
You can exercise these rights from your profile settings or by writing to support@couple.top. We respond within 30 days.
9. Complaints
If you live in the European Economic Area or the United Kingdom, you have the right to complain to your local data protection authority. We would appreciate the chance to resolve your concern first.
10. Children
The Service is not intended for anyone under 18, and we do not knowingly collect personal data from children.
11. Cookies
We use strictly necessary cookies to keep you signed in and to remember your language and region. We do not use advertising cookies.
12. Security
We encrypt data in transit and at rest, restrict access on a need-to-know basis, and review our practices. No system is perfectly secure, so please use a strong, unique password.
13. Changes to this Notice
We may update this Notice and will post the new version here with a new "last updated" date. If a change is material, we will notify you in the app or by email.
Shanghai Boren Information Technology Co., Ltd. (trading as "Top Couple") · support@couple.top