Top Hat takes User privacy seriously, and are committed to safeguarding the privacy of the Users of our Services.

This Notice details how we will treat your data when the data is subject to the California Consumer Privacy Act (CCPA).


Under CCPA, “Personal information” means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

A “Consumer” is a natural person who is a California resident, as defined in Section 17014 of Title 18 of the California Code of Regulations, including by any unique identifier.
Personal information includes, but is not limited to, the following:

  • (A) Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.
  • (B) Any categories of personal information described in subdivision (e) of Section 1798.80.
  • (C) Characteristics of protected classifications under California or federal law.
  • (D) Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
  • (E) Biometric information.
  • (F) Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement.
  • (G) Geolocation data.
  • (H) Audio, electronic, visual, thermal, olfactory, or similar information.
  • (I) Professional or employment-related information.
  • (J) Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99).
  • (K) Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

“Personal information” does not include publicly available information. For these purposes, “publicly available” means information that is lawfully made available from federal, state, or local government records, if any conditions associated with such information.

What Personal Information do we collect?

We may collect, store, and use the following kinds of information and Personal Information (“Collected Information”):

Information about your account and use of the Top Hat Services, including any transactions carried out between you and us on the platform, and information relating to any purchases you make of services.

This may include but is not limited to:

  • First name
  • Last name
  • Address
  • Date of birth
  • E-mail address
  • Country of residence
  • Location data
  • Online identifier or pseudonym, which includes IP addresses and cookie identifiers
  • Application usage data
  • Email communication data
  • Call recording data

Information that may be considered Personal Information when such information is combined with other information includes but is not limited to:

  • name of education Institution
  • student ID number
  • cell phone number

The purposes of processing Personal Information

To ensure our Users have the best experience with the platform, Personal Information, will be used for:

  • Allowing Users to create accounts on THM Services
  • Providing Users with the ability to access, download and use all THM Services as defined in the Terms of Service
  • Providing operational services such as Account Management and Technical Support
  • Detecting, preventing and addressing technical issues
  • Assisting Top Hat in improving, developing and creating products, services and content to meet the needs of Users
  • Communicating with Users regarding security, privacy, and administrative issues relating to Users use of products and services.
  • Providing Institutions with educational evaluation information necessary to implement the Service
  • Recording student location for secure attendance
  • Providing information about new products, services, newsletters, informative emails, and research on future product ideas or improvements (if Users have opted-in to receive such information)
  • Processing payments

Sharing Collected Information

We may share Collected Information about you:

  • (a) to enable our third-party sub-processors to provide services including but not limited to:
    • payment processing
    • data center hosting services
    • database provision
    • dialer infrastructure services
    • email sync services
    • marketing operations services
    • auditing
    • collecting debts
    • fulfilling orders
  • (b) to the extent that we are required to do so by law;
  • (c) in connection with any legal proceedings or prospective legal proceedings;
  • (d) mergers, acquisitions, financings, or corporate reorganizations
  • (e) in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);
  • (f) in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Security of Collected Information

We will take reasonable precautions to prevent the loss, misuse, or alteration of your Personal Data. Data transmission over the Internet is inherently insecure and we cannot guarantee the security of data sent over the Internet.

We will store all the Collected Information you provide or that we collect about you on our secure servers hosted by AWS.

Our full Security Policy can be found at

You are responsible for keeping your passwords confidential. We will not ask you for your passwords.

Retention of Your Personal Data

We maintain information about Users for as long as we provide services to the User, and for as long as it remains necessary for the identified purposes or as required by law, which may extend beyond the termination of service (unless by prior institutional arrangement).

We may retain certain data as necessary to:

  • prevent fraud or future abuse,
  • for legitimate business purposes, such as analysis of aggregated, de‑identified data,
  • account recovery,
  • or if otherwise required by law

Changes to This Notice

We may update this CCPA Notice from time-to-time by posting a new version on our website. You should check this page occasionally to ensure you are happy with any changes.

Third Party Websites

The website contains links to other websites. We are not responsible for the privacy policies of third party websites or such site operators’ actions, including the collection or use of your personal data.

Access to Your Personal Data

If you use this website, upon request, we will grant you reasonable access to your personal data and allow you to correct, amend or delete information that is demonstrated to be inaccurate or incomplete.
If you are a User of the Top Hat Services we depend on you to update and correct your personal data to the extent necessary for the purposes for which that data was collected, such as contact information you provide, so that we can provide you technical support services, account information notices and invoicing information.

You can update your personal data under settings and accessing “My Account.”
Full instructions for this can be found here:

Your Rights

Under the CCPA You have the right to request that a business that collects personal information about You disclose the following:

  • The categories of personal information it has collected about You.
  • The categories of sources from which the personal information is collected.
  • The business or commercial purpose for collecting or selling personal information.
  • The categories of third parties with whom the business shares personal information.
  • The specific pieces of personal information it has collected about You.

You may contact us if you wish to exercise any of your rights in respect of your personal data processed in this website or the platform.

Contact Us

To exercise your rights, or if you have any questions about this CCPA Privacy Notice, or our treatment of your personal information, please contact us using the following means:

Call Toll Free: 1-888-663-5491 x 1