At TOPS.me (Phuket) Co., Ltd, we recognize the importance of personal data to our users and customers and are committed to protecting your privacy and data protection rights.
This Privacy Policy explains how personal information is collected and processed through our websites and applications (the “Platform”) where this Policy is published or referenced. The Policy complies with applicable data protection laws in the jurisdictions in which we operate. In certain cases, additional privacy notices may apply depending on your location.
This document outlines the purposes for which your personal data may be processed through the Platform. We encourage you to review it carefully. By accessing or using the Platform or any related services, you acknowledge that you have been informed about how your personal data is used.
This Privacy Policy applies only to the data subjects described herein and does not cover other categories of individuals.
TOPS.me (Phuket) Co., Ltd operates its services through the TOPS.me platform and related brands and projects. This Privacy Policy is issued on behalf of TOPS.me (Phuket) Co., Ltd. Accordingly, when we use the terms “TOPS.me”, “we”, “us”, or “our” in this Privacy Policy, we refer to TOPS.me (Phuket) Co., Ltd, acting as the entity responsible for processing your personal data.
The role of the Data Controller is performed by TOPS.me (Phuket) Co., Ltd, unless otherwise stated in a specific legal notice, service description, or regional privacy notice applicable to a particular service or jurisdiction.
Information about the Data Controller, including legal and contact details, can be found in the Legal Notice published on our website or within the relevant service pages.
A list of TOPS.me brands, projects, and services is available on the Platform.
If you have any questions regarding this Privacy Policy or the processing of your personal data, you may contact our Data Protection Officer (DPO) using the contact details provided on the Platform.
TOPS.me (Phuket) Co., Ltd may access and process the following categories of personal data:
a) Personal data voluntarily provided by users:
Full name
Telephone number
Email address
Preferences
Types of alerts subscribed to
Favourite properties
Geolocation data, only if the user enables this function on their device
Any other personal data voluntarily submitted directly to TOPS.me
b) Personal data voluntarily provided by agents, developers, or professionals:
Full name
Residential or registered business address
Telephone number
Email address
Billing and payment information
Other contact details (such as WhatsApp ID, Line ID, Skype ID, Messenger ID, WeChat ID and/or website URL)
Geolocation data, only if the agent enables this function on their device
Any other personal data voluntarily submitted directly to TOPS.me
c) Personal data voluntarily provided by property owners:
Name
Telephone number
Email address
Property details provided when publishing an advertisement, including:
Full or partial address
Photos and/or videos
Property description and characteristics
Contact details (WhatsApp ID, Line ID, Skype ID, Messenger ID, WeChat ID) and/or website URL
d) Personal data automatically collected by TOPS.me:
When you interact with our websites or applications, we may automatically collect technical and usage-related data, including through cookies, server logs, and similar technologies.
This data may include:
Device data: operating system, device type, version, unique device identifiers, and mobile network information
Geolocation data: only if you explicitly authorize its use. Location may be determined through IP address, GPS, Wi-Fi access points, or mobile network towers. This data is used solely to enable specific platform features, deliver services, and, where applicable, display location-based advertisements
Navigation data: information about your activity on our Platform, including referring websites, search activity, date and time of visits, interaction with advertisements, alerts created, and visit duration. This information helps us personalize content, suggest relevant properties or services, and display tailored advertising
If you choose to create an account using a social media profile (such as Facebook or Google), this option is entirely voluntary. By doing so, TOPS.me may receive certain personal data from that social network, such as your name, identifier, profile picture, gender, contacts, preferences, or other information, strictly in accordance with your privacy settings on that platform.
We will only access the data that you have explicitly authorized the social network to share and will process it solely for the same purposes as data collected through direct registration. Prior to registration, you will be informed of the data to be shared. We recommend reviewing the terms and privacy policies of the relevant social network before granting authorization. Without the minimum required information, we will not be able to create a user account.
Registration and use of TOPS.me services are entirely voluntary. However, for categories (a), (b), and (c), certain fields are mandatory in order to provide our services. Mandatory fields are typically marked with an asterisk (*) or accompanied by a notice. If such information is not provided, we may be unable to deliver the requested services.
Your personal data will be processed for the purposes described in this Privacy Policy, in accordance with applicable laws and based on the choices and controls available to you.
TOPS.me (Phuket) Co., Ltd may use the personal data collected directly from you or from devices associated with you for the following purposes:
To register you as a user and create and manage your account
To provide our services in accordance with the applicable Legal Notice and Terms & Conditions, including those that may be introduced in the future
To respond to inquiries, consultations, or information requests from users, agents, developers, or property owners
To upload, manage, and publish advertisements submitted by agents or property owners on our websites and applications
To keep you informed about our services, activities, projects, updates, and new features of our websites or applications through email notifications and/or other electronic communication channels
To personalize content and user experience, including creating user profiles in order to offer tailored advertisements, products, or services from TOPS.me or our partners
To operate, analyze, maintain, develop, improve, and optimize our websites, products, services, and internal operations
To detect, investigate, and prevent activities that may violate our policies, terms, or applicable laws
To manage your participation in contests, promotions, or prize draws, where applicable
To publish user-generated content, such as comments or reviews, where applicable and subject to user consent
TOPS.me (Phuket) Co., Ltd may process your personal data on one or more of the following legal grounds:
Performance of a contract: where processing is necessary to manage user accounts and provide our services in accordance with the applicable Terms & Conditions
Compliance with legal obligations: where processing is required to comply with applicable laws and regulatory requirements
Legitimate interests: where processing is necessary to inform you about TOPS.me products, services, updates, or related communications, provided that such interests do not override your fundamental rights and freedoms
Your consent: where you have explicitly given consent for us to:
Inform you about TOPS.me products and services
Send you communications that may be of interest using the contact details you have provided
Process and store information submitted through forms completed by you
You may withdraw your consent at any time, without affecting the lawfulness of processing carried out prior to such withdrawal.
TOPS.me (Phuket) Co., Ltd will only share your personal data in the following circumstances:
With property owners, advertisers, developers, or agents, where such sharing is necessary to provide services or enable communication related to listings or inquiries
With portals, websites, or platforms where advertisements are published or syndicated
When you request a service and/or additional information through contact forms or communication tools made available on the Platform
If you publish an advertisement on our Platform, your contact details (as provided by you), as well as information related to the advertised property or product, will be made publicly available and accessible to other users and visitors of the Platform
Except for the cases described above, your personal data will not be sold, shared, or otherwise disclosed to third parties. However, personal data may be disclosed to regulatory authorities, courts, or other third parties where required or permitted by applicable law.
Additionally, where applicable and upon your request, if you exercise your right to data portability, we will transmit your personal data to the recipient you designate, in accordance with applicable data protection laws.
Depending on the purpose of data collection, access to your personal data may be granted to:
Third-party service providers acting on behalf of TOPS.me, who process personal data strictly in accordance with our instructions and subject to appropriate technical and organizational security measures. These providers may include, by way of example, hosting services, electronic communication providers, analytics services, and technical support or development partners
Affiliated companies or projects of TOPS.me, where such access is necessary for internal administrative, operational, or management purposes and is based on legitimate interests, subject to applicable data protection laws
Google may process certain personal data through cookies or similar technologies, provided that you have given your consent via our websites or applications.
For more information on how Google uses data from partner sites, please refer to:
https://policies.google.com/technologies/partner-sites
In accordance with applicable data protection laws, you may exercise the following rights in relation to your personal data:
Right of access: to request confirmation as to whether TOPS.me is processing your personal data and to obtain access to such data
Right to erasure: to request the deletion of your personal data
Right to rectification: to request correction of inaccurate or incomplete personal data
Right to withdraw consent: where processing is based on your consent. Withdrawal of consent shall not affect the lawfulness of processing carried out prior to such withdrawal
Right to lodge a complaint: with the relevant Data Protection Authority in your country and/or region
Right to data portability: where applicable, to request the transfer of your personal data to another data controller designated by you
Right to restriction of processing: to request limitation of the processing of your personal data in certain circumstances
Right to object: to the processing of your personal data, where permitted by law
Right not to be subject to automated decision-making: including profiling, where such decisions produce legal effects or similarly significant impacts
In the event that you exercise your right to erasure, all personal data linked to your user account, as well as any information and/or content included in your profile, will be deleted.
If the erasure request relates to personal data that is necessary for the provision of services on the Platform, TOPS.me (Phuket) Co., Ltd will be required to terminate its contractual relationship with you. As a result, your account will be deactivated, and you will no longer be entitled to use the services or raise any claims in this regard.
The deletion of personal data will be carried out without prejudice to any legal obligation to retain or block certain data under applicable data protection laws.
You may exercise your rights by sending a written request to the website owner indicated in the applicable Legal Notice or by using the contact details provided at the bottom of each TOPS.me website or application.
Please note that some of the rights listed above may not apply to you depending on the applicable data protection legislation in your country or region. If you request the exercise of a right that is not applicable, we may be unable to comply with such request. We recommend verifying your applicable rights in advance to avoid any inconvenience.
TOPS.me (Phuket) Co., Ltd has implemented appropriate technical and organizational security measures to protect your personal data from accidental loss, unauthorized access, use, alteration, or disclosure.
Access to personal data is strictly limited to employees, contractors, and third parties who need such data for legitimate business purposes only. In all such cases, personal data is processed solely in accordance with our instructions and subject to strict confidentiality obligations.
To further protect your data, we have established procedures to identify, assess, and respond to potential personal data breaches. Where required by applicable law, we will notify affected users and the relevant data protection authorities of any security breach within the legally prescribed timeframes.
However, despite the implementation of robust security measures, users should be aware that no method of data transmission over the Internet or electronic storage is completely secure, and absolute security cannot be guaranteed.
TOPS.me (Phuket) Co., Ltd will process and retain your personal data only for as long as necessary to fulfill the purposes described in this Privacy Policy and in accordance with applicable laws and regulations.
The criteria used to determine the retention period of personal data include:
Purpose of processing: personal data will be retained for as long as it is necessary to achieve the purposes for which it was collected. This generally means that your data will be kept while your account remains active and until you request its deletion or cancel your account
Legal basis for collection: for example, where processing is based on your consent, you may withdraw such consent at any time
Contractual and legal obligations: mandatory data retention periods required by applicable contractual, accounting, tax, or regulatory provisions
Please note that, in certain cases, TOPS.me (Phuket) Co., Ltd may be legally required to retain specific categories of personal data for an additional period of time, even after account termination or deletion, in accordance with applicable data protection, tax, or regulatory laws.
All professionals, employees, contractors, and partners cooperating with TOPS.me (Phuket) Co., Ltd who may be involved in any way in the provision of services to users undertake to maintain strict confidentiality and not to disclose or misuse any information to which they may have access.
Any information provided by the user shall be treated as confidential and shall be used solely for the purposes of managing the user’s account and/or providing the services contracted with TOPS.me, where applicable.
TOPS.me (Phuket) Co., Ltd undertakes not to disclose any information relating to the user, except where such disclosure is required by applicable law, regulatory authorities, or court orders.
TOPS.me (Phuket) Co., Ltd operates internationally. Therefore, in certain cases, it may be necessary to transfer your personal data to third countries for operational, technical, or service-related purposes.
Your personal data may be transferred to:
Affiliated entities, projects, or partners of TOPS.me, as identified in the applicable Legal Notice
Third-party service providers whose services are required for the operation of the Platform and the provision of services
In all cases, only the minimum amount of personal data strictly necessary to fulfill the purposes described in this Privacy Policy will be transferred.
If you are a resident of the European Economic Area (EEA) and your personal data is transferred outside the EEA, TOPS.me (Phuket) Co., Ltd ensures that such transfers are carried out in compliance with applicable data protection laws.
This includes one or more of the following safeguards:
Transferring personal data to countries that the European Commission has recognized as providing an adequate level of data protection; or
Implementing appropriate safeguards, such as:
EU Standard Contractual Clauses (SCCs)
Binding Corporate Rules (BCRs)
Approved codes of conduct or certification mechanisms
Other legally recognized transfer mechanisms that ensure an adequate level of protection
You may request additional information regarding the safeguards applied to international data transfers, including a copy of the relevant contractual clauses, by contacting our Data Protection Officer (DPO) using the contact details provided on the Platform.
TOPS.me (Phuket) Co., Ltd does not intentionally collect or process personal data that is considered especially sensitive or that falls within special categories of personal data, unless such data is explicitly and voluntarily provided by the user.
Special categories of personal data may include, but are not limited to, information relating to race or ethnic origin, political opinions, religious, philosophical, or similar beliefs, membership in trade unions, genetic data, biometric data used for the purpose of uniquely identifying an individual, health-related data, data concerning a person’s sexual life, or sexual orientation.
Where such data is voluntarily provided, it will be processed strictly in accordance with applicable data protection laws and solely for the purposes explicitly stated at the time of collection.
The Platform is not intended for or directed at minors under the age of sixteen (16). Such individuals may not use the Platform without the prior authorization and supervision of their parents or legal guardians.
TOPS.me (Phuket) Co., Ltd does not knowingly collect or process personal data from individuals under the age of sixteen (16).
If a parent or legal guardian believes that a minor has provided personal data to TOPS.me without the required consent, they should notify us immediately using the contact details available at the bottom of our websites. Upon receiving such notice, we will take appropriate steps in accordance with applicable data protection laws.
TOPS.me (Phuket) Co., Ltd undertakes not to use your personal data for direct marketing purposes without your prior explicit consent.
However, where we have an existing business relationship with you, we may send you information about our products or services based on our legitimate interests, in accordance with applicable data protection laws.
If at any time you wish to stop receiving commercial or promotional communications from TOPS.me or third parties, you may unsubscribe free of charge by:
Using the opt-out or unsubscribe link included in any marketing communication
Adjusting your preferences within your user account
Contacting us using the contact details provided on the Platform
Please note that even if you choose not to subscribe to, or decide to unsubscribe from, marketing or promotional communications, TOPS.me (Phuket) Co., Ltd may still need to contact you regarding important non-commercial matters. These may include service-related notifications, technical issues, account inactivity, security alerts, error detection and prevention, or communications necessary to comply with the Legal Notice and operational procedures of the Platform.
TOPS.me (Phuket) Co., Ltd informs you that when you choose to follow us or interact with our profiles or pages on social media platforms, we may process certain personal data in accordance with your privacy settings on the relevant social network and its applicable privacy policy. This processing is carried out solely for the purpose of adding you as a follower and interacting with you through those platforms.
Depending on your privacy settings, our connection may appear on your profile or wall, allowing your contacts to receive notifications about this interaction. By default, we will only have access to publicly available information such as your username and profile picture. We will not have access to additional personal data or your social media activity unless you have explicitly made such information public or accessible to everyone.
Through our social media channels, we may inform you about our activities, events, news, products, or services offered by TOPS.me (Phuket) Co., Ltd or our partners. If you no longer wish to receive such information, you may stop following us at any time using the “unfollow” option provided by the relevant platform.
We inform you that, subject to your prior consent, your comments or interactions on social media may be published outside the original social media platform or using tools other than the official APIs (such as Twitter/X API or Facebook API). In such cases, the content will not be modified, translated, or partially deleted, and your full username will always be referenced. If the original content is deleted or modified on the social media platform, we will make reasonable efforts to remove or update the corresponding content within 24 hours after being notified.
TOPS.me (Phuket) Co., Ltd may use third-party advertising and analytics services (such as Google Ads, Facebook Ads, and similar platforms) to display information or advertising related to our products or services, perform remarketing activities, and/or create similar audiences based on users who interact with us or request additional information via social media. These third parties process data on our behalf and in accordance with their own privacy policies. You may manage or disable cookies and similar technologies through the settings and privacy policies of the relevant platforms.
Please note that TOPS.me (Phuket) Co., Ltd does not have the ability to access, modify, or delete your personal data held by social media platforms. Only the respective social network can perform such actions. For more information on how social media platforms process your personal data, please review their privacy policies:
X (Twitter)
https://twitter.com/es/privacy
Instagram
https://instagram.com/privacy
LinkedIn
https://privacy.linkedin.com/es-es
TOPS.me (Phuket) Co., Ltd allows users to freely comment and interact on our social media pages. However, in order to ensure proper functionality and maintain a respectful and welcoming environment, the following participation rules must be observed.
We reserve the right to remove comments, images, or any other content if it:
Contains inappropriate language, including vulgarity, insults, profanity, hate speech, or any content considered offensive
Harasses, threatens, or targets any individual, brand, organization, or social group
Threatens fundamental rights or freedoms
Infringes the right to honor, personal or family privacy, or the right to one’s own image
Contains personal data of third parties or material protected by intellectual or industrial property rights
Includes viruses, malware, or any component that may damage or interfere with the normal functioning of our systems or those of third parties
Is used for commercial or promotional purposes unrelated to TOPS.me activities or is repeatedly posted (spam)
Is related to illegal activities
Users who violate these rules may be blocked, preventing further interaction or commenting. TOPS.me (Phuket) Co., Ltd reserves the right to inform the competent authorities and provide relevant data necessary to identify the author of content that violates applicable laws.
Please note that interactions on social media platforms are public by nature, depending on your privacy settings, and may be viewed or used by third parties. TOPS.me (Phuket) Co., Ltd cannot control how other users of social networks use publicly available information and is not responsible for such third-party use (e.g. unsolicited messages).
TOPS.me (Phuket) Co., Ltd uses Facebook pages for which it acts as a joint data controller together with Facebook Ireland Limited (or its successor entities).
As joint controllers, we only have access to anonymized statistical data regarding the use of our Facebook pages. Facebook provides information about its data processing activities through its Privacy Policy, available at:
https://www.facebook.com/privacy/explanation
The essential terms of the joint controllership agreement between Facebook and page administrators are available at:
https://www.facebook.com/legal/terms/page_controller_addendum
We do not have access to personal data processed by Facebook for these statistics. The legal basis for processing anonymized statistical data is our legitimate interest in understanding user engagement and interests on our Facebook pages.
When you participate in contests, promotions, or sweepstakes organized through our social media profiles, such activities will be governed by the specific legal terms and conditions applicable to each contest or draw.
Personal data provided in this context will be processed solely for the purpose of managing your participation. At a minimum, contact details are required to participate. Mandatory data will be clearly indicated in the contest rules or participation forms.
Personal data will not be shared with third parties except in the following cases:
Where disclosure is required by law
For winners, where their name may be published based on their consent or our legitimate interest in ensuring transparency of the contest, in accordance with applicable laws
Where the prize provider is a third party and delivery of the prize requires sharing data with that provider (you will be informed in advance in such cases)
Personal data will be retained for the duration of the contest or sweepstakes and thereafter in accordance with legally mandated retention periods. For example, in certain jurisdictions data may be retained for up to four (4) years for tax or regulatory purposes.
TOPS.me (Phuket) Co., Ltd integrates content from various classified advertisements and partner platforms into its Platform and directs relevant, high-quality traffic to such advertisements. In addition, we are able to generate additional traffic by delivering the right advertisement to the right user at the right time through our native advertising and recommendation products.
To provide our services in accordance with the Legal Notice and to ensure a relevant and satisfactory user experience, we use automated decision-making processes in response to your interactions and choices within the Platform’s search engine. These processes allow us to display results, advertisements, and recommendations that are aligned with your search criteria and preferences.
We also create user profiles to improve the relevance of content and advertising shown to you. For this purpose, we use cookies (where you have provided consent) and similar technologies that enable us to collect information such as:
Searches you have performed
Advertisements or sections you have clicked on
Advertisements you have recently viewed
Advertisements displayed to you on our websites or applications
This information allows us, for example, to suggest properties, services, or advertisements similar to those you have searched for or previously viewed, as well as to display personalized advertising related to your interests.
Where permitted by applicable law, we may also store a pseudonymized IP address in order to deliver commercial communications or content based on your general location.
Automated decision-making and profiling carried out by TOPS.me does not produce legal effects or similarly significant impacts on you, and you retain the right to object to such processing in accordance with applicable data protection laws.
The Platform may contain links to third-party websites, applications, or platforms that TOPS.me (Phuket) Co., Ltd considers potentially useful or informational for users.
Please note that TOPS.me does not control, endorse, or recommend the content, services, privacy practices, or terms of use of such third-party resources. We are not responsible for how these third parties collect, use, or process personal data.
We strongly recommend that you carefully review the privacy policies and terms of use of any third-party websites or platforms you choose to visit.
This Privacy Policy applies exclusively to personal data collected and/or processed by TOPS.me (Phuket) Co., Ltd through the Platform.
TOPS.me (Phuket) Co., Ltd will process your personal data solely in accordance with the Privacy Policy that is applicable at the time your personal data is collected.
We reserve the right to amend or update this Privacy Policy at any time by publishing the revised version on the Platform. For this reason, we recommend that you review the Privacy Policy each time you access the Platform. You can determine whether any changes have been made by referring to the “last updated” date indicated in this Policy. Continued use of the Platform after such changes constitutes your acceptance of the revised Privacy Policy.
If at any time we decide to process your personal data for purposes other than those stated at the time of collection, we will inform you of this decision by email, provided that we have your email address. Where required by applicable law, you will be given the opportunity to provide or withhold your consent for such new purposes.
If any provision of this Privacy Policy is held to be invalid, unlawful, or unenforceable, such provision shall be deemed severed and shall not affect the validity and enforceability of the remaining provisions, which shall remain in full force and effect in accordance with applicable laws.
Last Update Date
25 December 2025