Privacy Policy

This Privacy Policy describes how Nextech Digital Operations ("Company," "we," "us," or "our") collects, uses, shares, and protects information about you when you visit https://tophealthfinds.com (the "Site"). The Site is operated from Brazil but is primarily targeted at users in the United States. This Policy applies to all visitors regardless of location.

By using the Site, you acknowledge you have read and understood this Policy. If you do not agree, please discontinue use of the Site.

1. Information We Collect

We collect the following categories of information when you visit the Site:

Identifiers

IP address, device ID, cookie IDs, and browser fingerprint collected automatically when you access the Site.

Internet & Network Activity

Pages viewed, links clicked, referring URL, time spent on pages, browser type, operating system, and session duration.

Approximate Geolocation

Derived from your IP address (city/region level; we do not collect precise GPS coordinates).

Inferences

Interest profiles inferred from your browsing behavior on the Site (e.g., interest in health supplements, specific product categories).

Email Address (voluntary)

Only if you voluntarily subscribe to our newsletter or contact us directly.

2. How We Use Your Information

• To operate, maintain, and improve the Site
• To analyze traffic and user behavior via Google Analytics 4 (GA4)
• To record session activity and generate heatmaps via Microsoft Clarity
• To serve and measure online advertising via Google Ads conversion and remarketing pixels
• To track affiliate referrals to our network partners (MaxWeb, BuyGoods, Digistore)
• To send marketing emails to subscribers who have opted in (you may unsubscribe at any time)
• To prevent fraud, ensure security, and comply with legal obligations

3. Online Advertising & Third-Party Vendors

(a) Use of data for online advertising: We use data collected on this Site — including cookies, device identifiers, and behavioral signals — to advertise online, including showing you ads for products and services we believe may be relevant to you.

(b) Third-party vendors showing ads across the Internet: Third-party vendors, including Google, use cookies and similar technologies to show our ads on websites and apps across the Internet based on your visits to this Site and other sites.

(c) Retargeting based on past visits: Third-party vendors, including Google, use cookies and/or device identifiers to serve ads to you based on your past visits to this Site or your use of apps associated with this Site.

(d) How to opt out of interest-based advertising: You may opt out of Google's use of cookies for interest-based advertising by visiting Google's Ads Settings. You may also opt out of third-party vendors' use of cookies by visiting the Network Advertising Initiative opt-out page or the Digital Advertising Alliance opt-out page. To control the use of device identifiers, use your device's privacy or advertising settings.

4. Microsoft Clarity

We partner with Microsoft Clarity and Microsoft Advertising to capture how you use and interact with our website through behavioral metrics, heatmaps, and session replay to improve and market our products and services. Website usage data is captured using first and third-party cookies and other tracking technologies to determine the popularity of products and services and online activity. Additionally, we use this information for site optimization, fraud and security purposes, and advertising. For more information about how Microsoft collects and uses your data, visit the Microsoft Privacy Statement.

5. Third-Party Recipients

We share data with the following third parties in the course of operating this Site:

Recipient	Purpose	Privacy Policy
Google LLC	Analytics (GA4), advertising (Google Ads remarketing & conversion tracking)	policies.google.com/privacy
Microsoft Corporation	Session recording & analytics (Microsoft Clarity)	privacy.microsoft.com
MaxWeb Inc.	Affiliate network — tracks referral clicks and commissions	maxweb.com
BuyGoods Inc. (Boise, ID)	Affiliate network and merchant platform — processes purchases when you click through	buygoods.com
Digistore24	Affiliate network and merchant platform	digistore24.com
Third-party merchants (e.g., individual product vendors)	When you click an affiliate link, you are redirected to the merchant's site, which may independently collect your data	See each merchant's privacy policy

We do not sell your email address or other directly identifying contact information to third parties.

6. Cookies & Tracking Technologies

We use the following types of cookies and similar technologies:

• Strictly Necessary: Required for the Site to function (session security, load balancing). Cannot be disabled.
• Analytics: Google Analytics 4 and Microsoft Clarity collect aggregated behavioral data to help us improve the Site. These cookies may be refused without affecting Site functionality.
• Advertising: Google Ads conversion and remarketing pixels measure ad performance and enable retargeted advertising based on your visit history.
• Affiliate Attribution: Cookies placed by MaxWeb, BuyGoods, and Digistore track referral clicks to attribute commissions.

You can control cookies through your browser settings. Note that disabling cookies may affect certain Site features. You can also manage advertising preferences through the opt-out links in Section 3.

7. Data Retention

• Analytics data (GA4): 14 months (Google's default retention setting)
• Advertising cookies (Google Ads): Up to 24 months
• Session recordings (Microsoft Clarity): 30 days
• Affiliate tracking cookies: 30–90 days depending on the network
• Email subscriber data: Retained until you unsubscribe, plus 12 months for legal compliance
• Financial and transactional records: 7 years as required by applicable law

8. International Data Transfers

This Site is operated by a Brazilian entity; however, data is processed primarily by US-based third parties (Google LLC, Microsoft Corporation). The United States is not deemed to provide an adequate level of data protection under EU law. We rely on the following safeguards for transfers from the EEA/UK/Switzerland:

• Google LLC is certified under the EU–US Data Privacy Framework (DPF).
• Microsoft Corporation is certified under the EU–US Data Privacy Framework (DPF).
• For transfers not covered by DPF, we rely on Standard Contractual Clauses (SCCs) as approved by the European Commission.

9. Your Rights — California & US State Privacy Laws

If you are a resident of California or another US state with a comprehensive privacy law in force (including Virginia, Colorado, Connecticut, Texas, Oregon, Montana, and others), you may have the following rights:

• Right to Know / Access: Request disclosure of the categories and specific pieces of personal information we have collected about you.
• Right to Delete: Request deletion of your personal information, subject to certain exceptions.
• Right to Correct: Request correction of inaccurate personal information.
• Right to Opt Out of Sale or Sharing: We may "share" your data with advertising partners (Google, Microsoft) for cross-context behavioral advertising, which qualifies as a "sale or share" under the CPRA. You may opt out by visiting our Your Privacy Choices page or clicking the "Do Not Sell or Share My Personal Information" link in the Site footer.
• Right to Limit Use of Sensitive Personal Information: If we ever collect sensitive PI (such as health condition data via a quiz), you may request we limit its use to necessary purposes only.
• Right to Non-Discrimination: We will not discriminate against you for exercising any of these rights.

Global Privacy Control (GPC)

We honor Global Privacy Control (GPC) browser signals. If your browser or extension sends a GPC signal when you visit the Site, we will treat it as an opt-out of sale and sharing of your personal information, consistent with California law.

How to Submit a Request

You may submit a privacy rights request through either of the following methods:

• Email: contact@tophealthfinds.com
• Online form: Your Privacy Choices page

We will respond within 15 business days for California requests (CCPA) or 45 days for other state laws (with a possible 45-day extension when reasonably necessary). We will not re-prompt you to opt back in for at least 12 months after an opt-out request.

You may authorize an agent to submit a request on your behalf by providing written authorization. We may verify the agent's authority before processing the request.

10. Your Rights — EEA, UK & Switzerland (GDPR / UK GDPR)

Although this Site is primarily targeted at US residents, visitors from the European Economic Area, United Kingdom, or Switzerland whose data we process have the following rights under applicable data protection law:

• Right of Access (Art. 15 GDPR): Obtain a copy of your personal data.
• Right to Rectification (Art. 16): Correct inaccurate data.
• Right to Erasure (Art. 17): Request deletion ("right to be forgotten") in certain circumstances.
• Right to Restriction of Processing (Art. 18): Limit how we use your data in certain circumstances.
• Right to Data Portability (Art. 20): Receive your data in a machine-readable format.
• Right to Object (Art. 21): Object to processing based on legitimate interests, including direct marketing.
• Right to Withdraw Consent (Art. 7): Where processing is based on consent, withdraw it at any time without affecting prior processing.
• Right to Lodge a Complaint: File a complaint with your local supervisory authority (e.g., the CNIL in France, the ICO in the UK).

The data controller for EEA/UK purposes is: Nextech Digital Operations, 489 General Bento Martins St, Apt 302, Porto Alegre, RS, Brazil, 90010-080. Contact: contact@tophealthfinds.com.

Legal bases for processing: legitimate interests (Site operation, analytics, fraud prevention); consent (advertising cookies for EEA/UK visitors); contract performance (email subscribers).

11. Children's Privacy (COPPA)

This Site is not directed to children under the age of 13. We do not knowingly collect personally identifiable information from children under 13. If you are a parent or guardian and believe your child has provided us with personal information, please contact us at contact@tophealthfinds.com and we will promptly delete that information.

12. Data Security

We implement commercially reasonable technical and organizational measures to protect your information against unauthorized access, disclosure, alteration, or destruction. However, no method of transmission over the Internet or electronic storage is 100% secure, and we cannot guarantee absolute security.

13. Third-Party Links

The Site contains links to third-party websites, including affiliate merchant sites. Once you leave our Site, this Privacy Policy no longer applies. We strongly recommend reviewing the privacy policy of every site you visit. We have no control over and assume no responsibility for the privacy practices of any third-party site.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we do, we will revise the "Last Updated" date at the top of this page. Continued use of the Site after any changes constitutes your acceptance of the updated Policy. For material changes, we will provide more prominent notice (such as a banner on the Site or, for subscribers, an email notification).

15. Contact Us

For questions, concerns, or data rights requests regarding this Privacy Policy, please contact us: