Privacy 

Policy

TopTechTubers Limited (“TTT“), a company based in New Zealand (NZBN 9429051502966) operates this “website”. TTT works closely with TopTechContent Limited (“TTC“) a company based in England (Company No. 17218379).

This privacy policy gives you information about how TTC and TTT collects and uses your personal data, including when you visit the website or work with TTC or TTT. TTC and TTT may be referred to in this policy as “we”, “us” or “our” (as applicable).

The website is not intended for children and we do not knowingly collect data relating to children.

This policy is split into parts:

• Part 1: General Information – which sets out a general description of the personal data we collect and how we will use it.

• Part 2: UK/EEA Information – which sets out additional information and your rights when the UK and/or EU GDPR applies to our processing of your personal data.

1.The types of personal data we collect about you

Personal data means any information about an individual from which that person can be identified. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, last name, any previous names, username, social media handles or similar identifier title and date of birth.
• Contact Data includes postal address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Creator Data includes any data collected by us in relation to potentially or actually working with you as a content creator, including correspondences, personal data contained in the creator’s content, social media profiles, affiliation and role at any creator company that we may or do contract with.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access the websites.
• Usage Data includes information about how you interact with and use our website, and social media channels, including any communications between you and us. As a social media management company, we operate numerous social media channels including on Instagram, YouTube, X, LinkedIn and Facebook.
• Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.

We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals’ Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.

 

2.How is your personal data collected?

We use different methods to collect data from and about you including through:

• Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
• Work with us as (or on behalf of) a content creator.
• Request marketing to be sent to you.
• Give us feedback or contact or interact with us, including through any social media channels.

• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Further details about the cookies that we use are set out below.

• Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below
  • For Creator Data, we may collect this from social media platforms. Data collected from YouTube and Google is explained in further detail below.
  • Technical Data is collected from the following parties:
    • analytics providers;
    • advertising networks including social media platforms; and
    • search information providers.
  • Identity and Contact Data is collected from publicly available sources such as social media platforms (for example, LinkedIn) or the internet generally.

Creator Analytics:  YouTube & Google User Data
Creator Analytics (the “App“) helps us view YouTube performance analytics for creators who connect their channels.

What we access. When a creator authorizes the App through Google, we request read-only access to their YouTube channel information and YouTube Analytics data, using the youtube.readonly and yt-analytics.readonly scopes. The App uses YouTube API Services and the YouTube Analytics API.

How we use it. We use this data solely to display channel and video analytics, such as views, watch time, subscriber trends, audience demographics, and top-performing videos, inside the Creator Analytics dashboard for our team. Except where you authorise us to do so, we do not use it for advertising, posting, editing, or deleting anything on a creator’s channel.

What we store. We store an encrypted authorization token and the analytics metrics retrieved from YouTube. We do not sell this data or share it with third parties.

Retention and deletion. A creator can disconnect at any time from within the App or by revoking access at myaccount.google.com/permissions. On disconnect, the stored authorization is revoked and deleted. To request deletion of retained analytics, contact us at creatorcollabs@toptechtubers.com.

Limited Use. Creator Analytics’s use and transfer of information received from Google APIs adheres to the Google API Services User Data Policy (https://developers.google.com/terms/api-services-user-data-policy), including the Limited Use requirements.

 

3.How we use your personal data

Purposes for which we will use your personal data

We shall use your personal data for the following purposes:

• To work with you as a content creator, including to manage payments, collect and recover money owed to us.
• To work with our partners, including brands and agencies.
• To manage our relationship with you which will include:
  • Notifying you about changes to our terms or privacy policy.
  • Dealing with your requests, complaints and queries.
  • Any interactions with you on social media channels that we operate.
• To administer and protect our business and the website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).
• To deliver relevant advertisements to you and measure or understand the effectiveness of the advertising we serve to you.
• To use data analytics to improve our website, products/services, relationships and experiences, including through the relevant social media channels, and to measure the effectiveness of our communications and marketing.
• To send you relevant marketing communications.
• To carry out market research.

Direct marketing

You will receive marketing communications from us if you have requested information from us. You can ask us to stop sending you marketing communications at any time by following the opt-out links within any marketing communication sent to you or by contacting us.

 

4.Disclosures of your personal data

We may share your personal data where necessary with the parties set out below for the purposes set out above.

• Contractors, service providers, professional advisers and other third parties we use to support our business and who are bound by contractual obligations to keep personal data confidential and who use it only for the purposes for which we disclose it to them.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
• For any other purpose disclosed by us when you provide the information.
• With your consent.
• To comply with any court order, law or legal process, including to respond to any government or regulatory request.
• To enforce our agreements, including for billing and collection.
• To social media platforms, especially when we work with creators to upload content.
• If disclosure is necessary or appropriate to protect the rights, property, or safety of TTC or TTT, our content creators or others. This includes exchanging information with other companies and organisations for fraud protection and credit risk reduction.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

 

5.Cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive.

 

We may use the following cookies:

Strictly necessary cookies. These are cookies that are required for the operation of our website. These essential cookies are always enabled because our website won’t work properly without them. You can switch off these cookies in your browser settings but you may then not be able to access all or parts of our website. If you decline cookies, we will also place a single cookie in your browser to remember your preference not to be tracked.

 

Performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

 

Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests.

 

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

Cookie Name	Purpose	Duration
_grecaptcha	This is a strictly necessary cookies used to provide spam protection.	6 months
_ga_ZQLX10SDMK	This performance cookie is used by Google Analytics to persist session state.	1 year 1 month
_ga	This performance cookie is associated with Google Universal Analytics – which is a significant update to Google’s more commonly used analytics service. This cookie is used to distinguish unique users by assigning a randomly generated number as a client identifier. It is included in each page request in a site and used to calculate visitor, session and campaign data for the sites analytics reports.	1 year 1 month

You can use your browser settings to block all cookies (including strictly necessary cookies), however, you may not be able to access all or parts of the website if you do so.   

Please note that the following third parties may also use cookies, over which we have no control. These named third parties may include, for example, advertising networks and providers of external services like web traffic analysis services. These third party cookies include those provided by Google.

 

As of 3 September 2026, Google uses the below third party cookies on our website. Please note that this may change and you should seek further information from Google:

Cookie Name	Purpose	Duration
VISITOR_PRIVACY_METADATA	This strictly necessary cookie is used on the domain “.youtube.com” to store the user’s consent and privacy choices for their interaction with the site. It records data on the visitor’s consent regarding various privacy policies and settings, ensuring that their preferences are honoured in future sessions.	5 months 4 weeks
YSC	This targeting cookie is set on the domain “.youtube.com” by YouTube to track views of embedded videos.	Session
VISITOR_INFO1_LIVE	This cookie is set on the domain “.youtube.com” by Youtube to keep track of user preferences for Youtube videos embedded in sites. It can also determine whether the website visitor is using the new or old version of the Youtube interface.	5 months 4 weeks
__Secure-ROLLOUT_TOKEN	This analytics cookie is set on the domain “.youtube.com” by Youtube to launch new features and measure related impact when other existing cookies and identifiers cannot be used for the same purpose.	5 months 4 weeks
__Secure-YNID	This is a cookie set on the domain “.youtube.com” by Youtube. This cookie can be used for analytics, functionality purposes and (depending on your ad settings) for advertising.	5 months 4 weeks

 

To deactivate the use of third party advertising cookies, you may visit the relevant consumer page to manage the use of these types of cookies.

6.Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

7.Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

 

8.Contact details

If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact us in the following ways:

• Email address: creatorcollabs@toptechtubers.com          
• Postal address: 32 Toomer Place, Beachlands, Auckland, New Zealand 2018

 

9.Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.

 

10.Third-party links

The website may include links to third-party website, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party website and are not responsible for their privacy statements. When you leave a website, we encourage you to read the privacy policy of every website you visit.

11.Controller

TTT, to the extent that the EU or UK GDPR applies to its processing, is the controller when it processes your data for its own purposes, including in connection to the website. TTC, as an entity established in the UK, is the controller when it processes your data for its own purposes.

12.Legal basis

Under the EU and UK GDPR, the law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

• Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
• Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
• Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
• Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter or agree to certain cookies.

We have set out below, a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Purpose/Use	Type of data	Legal basis
To work with content creators, including to create and upload social media content	(a) Identity (b) Contact (c) Financial (d) Creator (e) Usage	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to provide services to the entity that we contract with)
Assess potential talent, business or partnership opportunities (including working with brands and agencies).	(a) Identity (b) Contact (c) Financial (d) Creator (e) Usage	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to consider entering into a contract with a content creator or partner, to further our business)
To: (a) Manage payments (b) Collect and recover money owed to us	(a) Identity (b) Contact (c) Financial (d) Creator	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Dealing with your requests, complaints and queries (c) Any interactions with you on social media channels that we operate	(a) Identity (b) Contact (c) Creator (d) Usage	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and manage our relationship with you)
To administer and protect our business and the website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Financial (c) Technical (d) Usage	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To use data analytics to improve our website, products/services, customer relationships and experiences and to measure the effectiveness of our communications and marketing	(a) Creator (b) Technical (c) Usage	Necessary for our legitimate interests (to define types of customers for products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To send you relevant marketing communications	(a) Identity (b) Contact (c) Marketing and Communications	(a) Necessary for our legitimate interests (to carry out direct marketing, develop our products/services and grow our business) (b) Consent
To carry out market research through your voluntary participation in surveys	(a) Identity (b) Contact (c) Usage	(a) Necessary for our legitimate interests (to study how individuals use our products/services and to help us improve and develop our products and services) (b) Consent

 

13.TRANSFERS OUTSIDE OF THE UK AND EEA

We may transfer your personal data to service providers that carry out certain functions on our behalf or to other third parties. This may involve transferring personal data outside the UK and/or European Economic Area (“EEA”) to countries which have laws that do not provide the same level of data protection as the UK or EEA. Whenever we transfer your personal data out of the UK or EEA, we ensure a similar degree of protection is afforded to it by ensuring that the following safeguards are in place:

• We will only transfer your personal data to countries that have been deemed under applicable EEA or UK law to provide an adequate level of protection for personal data.
• We may use specific standard contractual terms approved for use under UK and EEA law which gives the transferred personal data the same protection as it has in the UK and EEA.

14.Your legal rights

You have a number of rights under data protection laws in relation to your personal data.

You have the right to:

• Request access to your personal data (commonly known as a “subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object. You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data (see the table above for details of when we rely on your consent as the legal basis for using your data). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
• If you want us to establish the data’s accuracy;
• Where our use of the data is unlawful but you do not want us to erase it;
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

If you wish to exercise any of the rights set out above, please contact us the above Contact details.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

15.Complaints

You have the right to complain to us if you consider that there is an infringement of your rights in relation to your personal data. You can submit a complaint by email or post.

When we receive a data protection complaint, we will:

• Acknowledge receipt no later than 30 days from receiving it.
• Take appropriate steps to respond without undue delay, which may include making enquiries into the subject matter of the complaint and, where appropriate, keeping you informed about the progress of our handling of the complaint.
• Inform you of the outcome without undue delay.

You have the right to make a complaint to the UK Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). However, before doing so please make sure you have first made your complaint to us or asked us for clarification if there is something you do not understand.

If you are resident in the European Economic Area and believe we are unlawfully processing your personal data, you also have the right to complain to your local data protection supervisory authority.