Privacy Policy

ClicknShare Ltd  ·  Last updated: September 2026  ·  Company Reg. No. 16166273

1. Who we are

ClicknShare Ltd is a company registered in England and Wales (Company No. 16166273), with its registered office at 9 Journey Campus, Castle Park, Cambridge CB3 0AX. We are the data controller for personal data processed through the Topa platform.

For data protection enquiries, contact us at: [email protected]

2. Data we collect

Information you provide directly

• Identity data: full name, date of birth
• Contact data: email address, phone number, postal address
• Financial data: payment card details (processed securely by our payment partners), bank account information where applicable
• Transaction data: details of bill payments and transfers you make through Topa
• Communications: messages you send us, enquiry form submissions, investor interest registrations

Information collected automatically

• Technical data: IP address, browser type and version, device identifiers, operating system
• Usage data: pages visited, features used, time and duration of visits
• Cookie data: as described in Section 9 below

Information from third parties

• Identity verification data from KYC/AML service providers
• Fraud prevention data from fraud detection agencies

3. How we use your data

We use your personal data to:

• Create and manage your Topa account
• Process bill payments and money transfers on your behalf
• Verify your identity and comply with anti-money laundering (AML) obligations
• Detect and prevent fraud and financial crime
• Provide customer support and respond to your enquiries
• Send you transactional notifications (payment confirmations, receipts)
• Send you service updates and important notices
• Improve and develop our products and services
• Comply with legal and regulatory obligations
• Manage investor interest registrations (where applicable)

4. Legal basis for processing

We process your personal data on the following legal bases under UK GDPR:

• Contract performance: processing necessary to provide the Topa service you have requested
• Legal obligation: processing required to comply with AML, KYC, and financial regulation
• Legitimate interests: fraud prevention, security, improving our services, and direct marketing to existing customers (where you have not opted out)
• Consent: marketing communications to prospective customers and use of non-essential cookies (you may withdraw consent at any time)

5. Sharing your data

We share your personal data only where necessary, with:

• Payment processors and banking partners — to execute your transactions
• Identity verification providers — to fulfil our KYC/AML obligations
• Fraud prevention agencies — to protect against financial crime
• IT and cloud service providers — who host and support our platform under strict data processing agreements
• Regulatory authorities — where required by law (e.g. HMRC, FCA, NCA)
• Professional advisers — lawyers, accountants, auditors, under confidentiality obligations

We do not sell your personal data to third parties.

6. International transfers

Some of our service providers are located outside the UK. Where we transfer personal data internationally, we ensure appropriate safeguards are in place, such as UK adequacy regulations, standard contractual clauses, or binding corporate rules. Contact us if you would like details of the specific safeguards applied to any transfer.

7. How long we keep your data

We retain personal data only for as long as necessary for the purposes set out in this policy, or as required by law. Key retention periods include:

• Account and transaction records: 6 years after account closure (financial regulation requirement)
• KYC/AML records: 5 years after the end of the business relationship
• Marketing data: until you unsubscribe or withdraw consent
• Website usage data: up to 26 months

8. Your rights

Under UK GDPR, you have the right to:

• Access — request a copy of the personal data we hold about you
• Rectification — ask us to correct inaccurate or incomplete data
• Erasure — ask us to delete your data (subject to legal obligations)
• Restriction — ask us to restrict processing in certain circumstances
• Portability — receive your data in a structured, machine-readable format
• Object — object to processing based on legitimate interests or for direct marketing
• Withdraw consent — where processing is based on consent, withdraw it at any time

To exercise any of these rights, contact us at [email protected]. We will respond within one month. You also have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk.

9. Cookies

We use cookies and similar technologies on topa.click. Essential cookies are required for the site to function. We use analytics cookies (with your consent) to understand how visitors use our site. You can manage your cookie preferences through the cookie banner on our website or your browser settings.

10. Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, or destruction. These include encryption in transit and at rest, access controls, and regular security assessments. However, no internet transmission is completely secure, and we cannot guarantee absolute security.

11. Children

The Topa service is not directed at children under the age of 18. We do not knowingly collect personal data from children. If you believe we have inadvertently collected data from a child, please contact us immediately at [email protected].

12. Changes to this policy

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the updated policy on this page with a revised "last updated" date. Where required by law, we will seek your consent to material changes.

13. Contact us

For any questions about this Privacy Policy or how we handle your data:

• Email: [email protected]
• Post: ClicknShare Ltd, 9 Journey Campus, Castle Park, Cambridge CB3 0AX

You can also download the full policy document: