Topps Total Football Mobile App Privacy Policy
Last Updated: September 22nd, 2021

The Total Football App mobile application software (App) is operated by Topps Europe Limited (Topps, we, our, or us), a subsidiary of The Topps Company Inc.
Topps respects your privacy and is committed to protecting your personal data. The purpose of this privacy policy is to help you understand what information we collect about you when you use the App, how we look after your personal data when you use our App and inform you of your privacy rights.
This policy (together with our end-user licence agreements as set out at, and respectively (EULA) and any additional terms of use incorporated by reference into the relevant EULA, together our Terms of Use applies to your use of:

•        The App available on the App Store (for Apple devices) and Google Play Store (for Android devices), once you have downloaded or streamed a copy of the App onto your mobile telephone or handheld device (Device).
•        Any of the services accessible through the App (Services) that are available.
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
Parents or guardians should explain this policy and the implications of it to any young children using the App. A copy of our Children’s Privacy Policy is available for you to view. Any use of the App by children should be supervised by their parent or guardian.
When downloading and using the App through your mobile platform, the app provider will typically collect certain device and app-related information. Topps does not control the requirements or processes of the app stores; you should review the privacy policy and terms of use of the mobile app stores before downloading or using any app and check your device settings for control options.
This policy is provided in a layered format so you can click through to the specific areas set out below.

Topps Europe Limited is the data controller and is responsible for your personal data.

Contact details
Our full details are:
•        Full name of legal entity: Topps Europe Limited
•        Email address:
•        Postal address: 18 Vincent Avenue, Milton Keynes, England, MK8 0AW
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues or other competent supervisory authority of an EU member state if the App is downloaded outside the UK.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under review.

This version was last updated on August 25th, 2021. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you when you next start the App. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the App.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.

•        When you use the App, we may process anonymised data to see how our users use the App. This data does not identify you as an individual and includes Transaction Data, Device Data, Profile Data, Technical Data and Usage Data. However, in the event that any of these types of data could directly or indirectly identify you, we will treat the data as personal data which will be used in accordance with this privacy policy.

•        When you sign-up to the app we may process an anonymised login token received from a sign-in provider such as Google or Apple. This data does not identify you as an individual and is instead a unique numerical ID. We may collect, use, store and transfer (we refer to this as “process” or “processing”) this data that you voluntarily provide in order to satisfy the expectation that you can login across multiple devices. If you trigger a support request that means we need to record this data, it will still be anonymised and only processed in order to satisfy that support request.

•        We also process your anonymised Location Data. You can generally limit or prohibit the collection of Location Data using the built-in settings on your mobile device. Check your device instructions for information on how to do so. We do not collect precise location information from the App.

•        We do process personal data in the form of Transactional Data. We process this personal data, which includes Contact Data such as a physical mailing address to administer the e-commerce transaction that you, the user, has voluntarily triggered and entered personal data in order to receive your order. The purpose for processing this data is to conform to user expectations for this transaction and make sure that the relevant parts of the process have the required information – e.g. Fulfilment Centre gets a delivery address. This data cannot be taken if you are under-18 as you require an active Paypal account to pass on this data. Paypal requires users to be 18 or over to register.

We explain these categories of data below.

We also process Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific App feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

We will collect and process the following data about you:

•        Information you give us. This is Transactional Data information you give us, through PayPal, when you place an e-commerce transaction, make an in-App purchase, contact us, request to retrieve a lost password, or access the App through different devices and when you report a problem with an App. This applies to any information provided when you use and carry out any activities in connection with our App. If you contact us, we will keep a record of that correspondence.
•        Information we collect about you and your device. Each time you use our App we will automatically collect data including Device Data, Technical Data and Usage Data. You can disable your Location Data in your settings at any time. Such data will be anonymised.

We process your personal data for the purposes set forth below. When required by applicable laws, we rely on certain legal bases to process your personal data, depending on how you interact with the Services. Most commonly we will use your personal data in the following circumstances:

•        Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
•        Where we need to perform a contract we are about to enter or have entered with you.
•        Where we need to comply with a legal or regulatory obligation.
If applicable laws require that we obtain your consent to process your personal data, we will do so at the time of collection.

Click here find out more about the types of lawful basis that we will rely on to process your personal data.

        Type of data
        Lawful basis for processing

To install the App and register you as a new App user
        Anonymised User ID
        Necessary for our legitimate interests (to provide the App to you and your email address is used to                 facilitate the logging into the App and for account retrieval (password reset) purposes.)

To process in-App purchases and deliver Services
        Anonymised Transaction
        Anonymised Device
        Anonymised Location
        Performance of a contract with you

To deliver physical cards that you have ordered        
        Necessary for our legitimate interests (to provide the physical cards ordered to you and support your inquiries and request relating to that order). This data cannot be taken if you are under-18 as you require an active Paypal account to pass on this data. Paypal requires users to be 18 or over to register.
        Performance of a contract with you
To manage our relationship with you including notifying you of changes to the App or any Services and         responding to your inquiries and requests.
        Anonymised Profile
        Performance of a contract with you
        Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ Services).
        Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions).

To administer and protect our business and this App including troubleshooting, data analysis and system testing
        Anonymised Device
        Anonymised Technical
        Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)

To monitor trends so we can improve the App and Services and understand how you use the App and Services
        Anonymised Device
        Anonymised Profile
        Anonymised Usage
        Anonymised Location
        Necessary for our legitimate interests (to develop our App and grow our business)

To provide optional in-game advertising        Anonymised Usage
        Anonymised Location        Performance of a contract with you (optional rewards that you request)
        Necessary for our legitimate interests (to analyse how customers use our products/ Services)
To comply with law or respond to a legal request        Contact
        Legal or regulatory obligation

We also share your personal data with the third parties set out below for the purposes set out in the table:
•        Internal Third Parties as set out in the Glossary.
•        External Third Parties as set out in the Glossary.
•        Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

As the Topps family of companies operates globally, we may need to transfer your personal data from our servers in the United Kingdom to other countries, and we may use cloud services whose servers may be anywhere in the world.

In addition, our external third parties may be based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

•        We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
•        Where we transfer personal data to other controllers or processors in other countries, we may use specific contracts approved by the UK which give personal data the same protection it has in the UK.
•        Where we use providers based in the United States, we will only process data from users also residing in the United States, affording the same level protection as users in Europe will also experience.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

All information you provide to us is stored on our secure servers. We do not process any payment transactions from you. All payment transactions will be administered and processed by the respective App Stores under their own terms and/or EULA and Paypal under their agreement. Where you have utilised a third-party login and password that enables you to access certain parts of App, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Once we have received your information, we will use procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.

Your anonymised data is retained for as long as you are a user of the App and will not be stored for longer than is necessary. Your Contact data, with Transactional Data, will be retained for as long as the transaction is active. Once the order has been completed, all of your data will generally be deleted from our systems after 3 days and our back-up systems after 14 days.

If your account is inactive, your data will be retained in order to allow you to log into the App to retrieve your account at any point. Our retention practice is as such given users will have purchases tied to their user account and would not expect their account to be closed due to inactivity.

Generally, you may request removal of your account then the account shall be closed immediately and your data will be removed from our live database. All of your data will generally be deleted from our back-up systems after 7 days. You should note that by law, however, we may have to keep certain information about you after you cease being an App user and there may be some exceptions to your right to erasure of your data. Please contact us if you would like further information regarding our data retention practices.

In some circumstances you can ask us to delete your data: see Your legal rights below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
You have the right to access, update and correct inaccuracies in personal data we collect through the App, subject to certain exceptions.

Under certain circumstances residents of an EEA member state may have the following rights under data protection laws in relation to your personal data.

Please click on the links below to find out more about these rights:
•        Request access to your personal data.
•        Request correction of your personal data.
•        Request erasure of your personal data.
•        Object to processing of your personal data.
•        Request restriction of processing your personal data.
•        Request transfer or your personal data.
•        Withdraw your consent

You can exercise any of these rights at any time by contacting us at We may retain certain information as necessary to pursue legitimate business interests or resolve disputes, or as required by applicable laws. To protect your privacy and the security of your personal data, we may take steps to verify your identity before granting your request.

If you are a California resident, you are entitled by law to request, once per year, information about third parties with whom Topps has shared personal information about you for their direct marketing purposes during the previous calendar year, and the categories of personal information shared. To make such a request, submit a request via email to or using the contact information set forth above specifying that you seek your "California Customer Privacy Notice." Please allow thirty days for a response.

Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. Where you give consent, you may withdraw your consent at any time by contacting us.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Other companies in the Topps family of companies acting as joint controllers or processors and who are based in the United Kingdom, European Union or the United States and assist with providing the App and Services.

•        Service providers acting as processors based in the UK and outside of the EEA who provide the technical expertise to develop the App, to host the App, to provide maintenance and security, to send emails on our behalf, to help us analyse and improve our offers and the user experience and to process any e-commerce transaction that you have entered into.
•        Law enforcement, regulators, and other third parties with whom we share your personal data if required by law or in a good faith belief that disclosure is necessary to: comply with legal process or respond to a legal request or subpoena; enforce our Terms or Use; protect the security or integrity of the App, Services, and our company; respond to your requests for customer service; and protect the rights, property or personal safety of Topps, its users and the public. Such third parties include, without limitation, HM Revenue and Customs, regulators and other authorities acting as processors or joint controllers based in the UK who require reporting of processing activities in certain circumstances.

Residents of an EEA member state have the right to:

•        Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
•        Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
•        Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
•        Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
•        Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
(a)  if you want us to establish the data’s accuracy;
(b)  where our use of the data is unlawful but you do not want us to erase it;
(c)  where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
(d)  you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

•        Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
•        Withdraw your consent to processing of your personal data, if we rely on consent as a basis for processing.

We will collect certain personal data (data that identifies you directly or indirectly) and anonymous data (e.g. data where your identity has been removed which will not be considered as personal data in law as this data will not directly or indirectly reveal your identity).

The types of data are as follows:

•        Contact Data: email address, physical mailing address, addressed recipient name, contact number.
•        Anonymised Transaction Data: includes details of in-App purchases.
•        Anonymised Device Data: includes the type of mobile device you use, and your mobile operating system.
•        Anonymised Profile Data: includes your username and password, in-App purchase history, preferences, feedback and survey responses.
•        Anonymised Usage Data: includes details of your use of our App or your visits, but not limited to, traffic data and other communication data.
•        Anonymised Location Data: includes your location disclosed by GPS technology.
•        Anonymised Technical Data: includes internet protocol (IP) address, your login data, time zone setting and location, and versions as well as information about the operating system, platform.