Privacy Policy

TOPREGAL US Corporation and its subsidiaries (“TOPREGAL,” “we,” “us,” or “our”) are committed to the protection of our customers’ and partners’ privacy and to keeping any personal information provided to us secure.

The purpose of our privacy policy (this “Privacy Policy”) is to inform you about the types of personal information we gather about you, how we may use that information, whether we disclose it to anyone, and the rights and choices you have regarding that information. The phrase “personal information” means any information from which you can be identified or are identifiable, either directly or indirectly, such as your name, address, telephone number, device and browsing information, etc.

By using our website or using our online service (collectively, our “Services”), you agree with the terms of this Privacy Policy, which is part of TOPREGAL’s Terms of Use. You consent to the collection, use, and disclosure of your information in accordance with this Privacy Policy. If you do not agree or consent to either the terms of our Privacy Policy or the Terms of Service, please do not use our website or submit information to us through our Services.

1. INFORMATION COLLECTION 

TOPREGAL collects the following categories of personal information, including in the preceding twelve months, when you provide it directly to us and when you use the Services. This information includes both personally identifiable information and information which does not directly identify you:

• Analytics Information
• Browsing Information
• Comment and Opinion Information
• Commercial Information
• Contact Information
• Financial Information
• Non-precise Geolocation Information
• Sensory and Electronic Information
• Social Media Data
• User Account Information

Sensitive Information. TOPREGAL does not collect, use, process, sell, or share personal information which is classified as sensitive information.

When do we collect personal information? We collect this information when you take certain actions like interacting with our Services, submitting a form to contact us, and becoming one of our vendors or customers. We collect information automatically when you browse our website.

How long do we keep personal information? TOPREGAL uses several criteria to determine how long we should keep categories of personal information. We keep data until you close or deactivate your account, until we no longer have a business purpose for the data, or until we no longer have an obligation to keep it.

Please understand that residual copies of the personal information can be stored in locations or formats that make complete erasure extremely difficult. The best way to ensure you control your information is to give us only the personal information that you are completely comfortable sharing with us.

2. SOURCES OF INFORMATION 

TOPREGAL collects information from a variety of sources, including:

• Services users. We collect browsing information automatically from those who visit our website. We collect comments and opinions, contact, commercial, social media, and user account information from those who provide it voluntarily via contact forms and social media links.
• Customers, vendors, and service providers. We will collect commercial information, contact information, and financial information when you voluntarily become our customer, vendor, or service provider.
• Cookies and trackers. We use cookies and other embedded tracking technology like web beacons which automatically collect users’ browsing information when they use our Services. You will find other parties’ trackers on our website. Other parties like our analytics and advertising partners place code with cookies or web beacons embedded in them. These are called third-party cookies. Some third-party cookies are used to track a particular user’s activity across the Internet.
  
  

3. HOW WE USE THE INFORMATION WE COLLECT 

TOPREGAL uses personal information for a variety of business purposes. When you share personal information with us, we may use it for several purposes. For example, we may use the information we obtain about you to:

• Process, validate, and deliver your purchases.
• Create content most relevant to you
• Analyze, test, and optimize content on the website
• Conduct marketing research, such as questionnaires and surveys
• Alert you to special offers, updated information, and other new products or services from TOPREGAL
• Secure our website by identifying potential hackers and unauthorized users
• Enforce our Terms of Service
• Comply with applicable legal requirements, court orders, legal proceedings, document requests, industry standards, and our internal policies
  
  

We may modify or update this page from time to time to reflect the changes in our business and practices, and you should review it periodically. We will update the ‘last modified’ date at the bottom, when we post changes to this Policy. If you object to any changes, you may close your user account. Continuing to use our services after we publish changes to this Privacy Policy means that you are consenting to the changes.

4. HOW WE DISCLOSE INFORMATION TO OTHERS 

Selling and Sharing. TOPREGAL does not sell your personal information, nor have we done so in the last twelve months. We do share your anonymized information with analytics service providers such as Google. By “share,” we mean making personal information available to a third party for cross-context or interest-based advertising. Google may combine your browsing information, including information from your use of our website, to generate interest-based advertisements.

We make your personal information available to third parties under a variety of circumstances. We disclose your information:

• When you consent. Out of respect for your privacy, TOPREGAL will not disclose your personal information to others without your consent, except as specified in this Privacy Policy.
• To our affiliates and companies in the same group of companies as us. Our affiliates and subsidiaries (i.e., any organization or brand we own or control) or our ultimate holding company TOPREGAL GmbH (i.e., any organization that owns or controls us) and any subsidiaries it owns. We disclose the information that we collect to other TOPREGAL companies, subsidiaries, and related affiliates. These companies may use your information in the same way as we can under this Privacy Policy.
• To third parties at your request. You may choose to share your activities on our Service with your friends through email, text, or on various social media networks.
• To select third parties. Third parties, so that they can provide you with information and marketing messages about products or services that may interest you. To opt-out of our sharing your personal information with such companies, see "Your Privacy Choices", below.
• To our promotional partners. Third parties with whom we partner to provide contests and sweepstakes, or other promotional activities.
• To service providers and advisors. Third-party vendors and other service providers that perform services for us, on our behalf, which may include identifying and serving targeted advertisements, providing mailing or email services, tax and accounting services, product fulfillment, payments processing, data enhancement services, fraud prevention, web hosting, or providing analytic services. These service providers are required by contract or law to only use or disclose the information as necessary to perform services on our behalf or as otherwise required by law. Although TOPREGAL requires these third parties to meet our privacy and security requirements, TOPREGAL does not control the privacy or security policies of our service providers and advisors.
• To our product suppliers. Third-party product suppliers who may have a legitimate business or legal interest in receiving such information. For example, personal information may be shared with product suppliers to fulfill warranty service obligations, product recalls, or transaction tracking regarding shipments or leases of supplier products.
• To the public. When you provide feedback or post user content on our Service. For example, if you post a product review on our website or a comment on our social media sites, your information, such as your first name, last initial, state of residence, and your comments, may be displayed on our website or on our social media pages.
• To purchasers and third parties in connection with a business transaction. Personal information may be disclosed to third parties in connection with a Grainger-related transaction, such as a merger, sale of Grainger assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business by another Grainger or third party, or in the event of a bankruptcy or related or similar proceedings; and
• When law enforcement, regulators and other parties request information for legal reasons. We may provide your information without your consent to third parties as required by law or subpoena or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) to enforce our Terms of Use or to protect the security or integrity of our Service; and/or (c) to exercise or protect the rights, property, or personal safety of Grainger, our visitors, or others.

5. YOUR PRIVACY RIGHTS

Certain laws like the California Privacy Rights Act, the Virginia Consumer Data Protection Act, and the Colorado Privacy Act, grant you rights to control your personal information. Consistent with these laws, TOPREGAL gives you options to access, edit, or remove certain information, as well as choices about how we contact you. Although some of these rights apply generally, certain rights will only apply to limited individuals or circumstances.

• Right to Know and Access Information. Note that much of the information you are entitled to know or access is disclosed in this Privacy Policy. With this said, you have the right to know about our information practices. You also have the right to access the categories of data we collect, with whom we share or sell that information, and, in some cases, what specific personal information we associate with you or your account.
• Right to Data Portability. If you request a copy of your specific information then we will provide it in an easily accessible format.
• Right to Deletion or Erasure. You may request that we delete the personal information we have collected about you. Depending on the applicable law, in some cases we are required or permitted to retain your information, even if you validly requested we delete or erase it. 
• Right to Correct Information. You may request we correct or rectify inaccurate information we associate with you or your account.
• Right to Limit Use of Information for Advertising. You may opt-out of our use of your personal information for advertising purposes.
• Right to Withdraw Consent. You may withdraw your consent to our data privacy practices.
• Right to Non-Discrimination. You have the right to not experience discrimination from us for exercising the rights listed in this section. What we mean by discrimination is denying you access to our Services or limiting the quality of our services. However, limiting use of, or deleting, your personal information may restrict the purposes or uses that rely on that information. If you need further assistance, you can contact TOPREGAL through one of the channels listed below under “Contact.

6. EXERCISING YOUR RIGHTS 

To exercise any of your privacy rights, either:

• Call TOPREGAL toll-free at 713 474 8161
  OR
• Email TOPREGAL at [email protected]. Please include your email address, full name, and your specific information about your request(s) and, if applicable, specifically what information you do not want to receive. If you would like to update or correct your email address, street address or other personal information with us, please include specific details about the information you wish to have updated or corrected.

TOPREGAL’s process to fulfill a privacy rights request:

• We acknowledge your request. TOPREGAL will first send you a message acknowledging receipt of your request.
• We ensure that you are the person making the request. In general, when you make a request TOPREGAL will take steps to verify your identity. Verification steps may include asking you for personal information, such as your name, address, or other information we maintain about you. If we are unable to verify your identity with the degree of certainty required, we will not be able to respond to the request. In that case, we will notify you to explain the basis of the denial.
• Your agent can submit requests for you. You may also designate an authorized agent to submit requests on your behalf. If you do so, you will be required to verify your identity by providing us with certain personal information as described above. Additionally, we will also require written proof the agent has permission to act on your behalf. We will deny your request if the agent is unable to submit proof to us that you have authorized them to act on your behalf.
• How long will it take? TOPREGAL will either fulfill or reject your request as soon as we can, generally within 45 days from when we receive your request (or less, if required by law). But we may be allowed to take longer to process your request under certain circumstances. We will let you know if we expect your request will take us longer than normal to fulfill.

7. YOUR PRIVACY CHOICES 

Messaging and newsletter communications. You may control how you receive certain types of communications by unsubscribing within the body of the communication. Note that some messages are required, service-related messages like transaction confirmation messages, legal notices, or updates. If you no longer wish to use our Services or the website, or receive optional communications then you may submit requests to delete your account and your personal information.

Cookies and web tracking technologies. You may limit the automatic collection of information by Google, including the collection of personal information about your online activities over time and across third-party websites or online services, by opting-out of such collection. Download any suitable opt-out browser extension, for your browser to opt-out of the automatic collection of browsing and device data.

Opt out of cross-context and interest-based advertising. You can opt out of interest-based advertising as described in this section and in the “Cookies and Similar Technologies” section of this Policy.  When you opt out, your selection is stored on a cookie on your device. If you delete the cookie from that device or sign in from a different device, you will need to opt out again.

Because the data used for interest-based advertising is also used for other necessary purposes (including providing our Service, for authentication, and security purposes), opting out of interest-based advertising does not stop the data from being collected nor reduce the number of advertisements you will see. However, the data will not be used for interest-based advertising, which means the advertisements you do see may be less relevant to you.

When using a mobile application, you may receive interest-based in-application advertisements. Depending on your device, you may be able to reset your mobile device’s advertising identifier at any time by accessing the privacy settings on your device. In addition, each operating system (e.g., iOS for Apple devices, Android for Android devices and Windows for Microsoft devices) provides its own instructions on how to prevent the delivery of interest-based in-application advertisements. You may review the support materials and/or the privacy settings for the respective operating system in order to opt-out of interest-based in-application advertisements. For any other devices and/or operating systems, please visit the privacy settings for the applicable device or contact (or review the applicable privacy web page of) the applicable platform operator.

You can limit the automatic collection of information by any participating third-party advertisers. To submit your request to opt-out of that automatic collection of browsing data, visit the Digital Advertising Alliance page or the Network  Advertising Initiative page.

8. THIRD-PARTY WEBSITES 

This Privacy Policy applies only to our Services, including our website. Our Services may contain links to other websites including those that permit online transactions. We have no control over the privacy practices or the content of any of our business partners, advertisers, sponsors, or other third parties we link to from our website. TOPREGAL does not endorse, approve, or certify these other websites, and we do not guarantee the accuracy, completeness, efficacy, or timeliness of the information contained on those websites. You should check the applicable privacy policy of the website sponsor when linking to other websites.

9. SECURITY AND YOUR ACCOUNT 

TOPREGAL will take steps to protect your personal information that you transmit to us and to protect such information from loss or misuse, and unauthorized access, disclosure, alteration or destruction. However, no internet transmission is ever fully secure, and we cannot guarantee that information transmitted via our website will remain confidential at all times. When we collect information, it is stored in an area to which the general public does not have access. We maintain physical, electronic and procedural safeguards to ensure that personal information is stored and processed responsibly.

In the event that any use of the website involves log-in credentials, please bear in mind that anyone you provide with your log-in information will also have access to your account and personal information. If you use our website, you are responsible for maintaining the confidentiality of any log-in credentials associated with the website.

10. USERS OF THIS WEBSITE UNDER THE AGE OF 18 

You must be 18 to use our Services. TOPREGAL takes children’s privacy seriously. TOPREGAL does not have actual knowledge of any personal information about individuals under the age of 18 whose information has been collected through our Services. If we become aware that a person submitting information to us through any part of our Services is a minor, we delete the information as soon as we discover it and do not use it for any purpose nor disclose it to third parties.

11. CHANGES TO PRIVACY POLICY 

TOPREGAL recognizes that information privacy is an ongoing responsibility, so we reserve the right to change this Privacy Policy from time to time by posting revisions on our website. Updates to our Privacy Policy will occur when we modify or alter any of our data practices, such as using data for other purposes or disclosing data to other categories of parties not mentioned in this version of this Privacy Policy. TOPREGAL will update the effective date of this Privacy Policy when changes are made, so please check this page periodically for changes.

12. CONTACT US 

You may contact us with any inquiries related to our use of your personal information disclosed in this Privacy Policy or to exercise your privacy rights by:

Calling TOPREGAL at: 713 474 8161
Emailing TOPREGAL at: [email protected]

TOPREGAL Headquarters Address:

TOPREGAL US Corp
18211 Chisholm Trail
Houston, TX 77060

Last Modified: Nov. 2022