Privacy Policy

1. Preamble and Governance

Top Margin is a digital intelligence platform operated by Genius Marketing FZ (“The Publisher,” “We,” or “Us”). The Publisher is incorporated in and legally anchored in Dubai Internet City (TECOM Group), United Arab Emirates, and our operations are governed by the laws of the UAE. This Privacy Policy governs the handling of Subscriber information collected through our Services (Newsletter, SMS Alerts, and Website) in connection with our coverage of geopolitics, defense-sector economics, and macroeconomic markets.

Our U.S. mailing address in Dover, Delaware is a registered mail-forwarding address maintained solely for receiving legal and administrative correspondence. It does not change our place of incorporation or governing jurisdiction, which remain the United Arab Emirates.

By accessing our Services, you acknowledge that our operations involve processing data across international borders, specifically between the UAE and the United States, where our newsletter and email infrastructure (Ghost(Pro), Mailgun, and Beehiiv) is hosted, subject to the safeguards described in Section 5.

2. Data Acquisition Architecture

We limit data collection to what is necessary for audience intelligence and service delivery.

2.1 Direct Subscriber Input

When you opt in to receive our intelligence reports, we collect your email address and, optionally, your mobile phone number for time-sensitive SMS market alerts. We do not require real names or physical addresses unless you voluntarily provide them for premium support. Any content or metadata attached to messages you send our support channels is archived for record-keeping and legal-defense purposes.

2.2 Consent Records

To document lawful consent for our email and SMS programs, we log the timestamp of your submission, the IP address from which it was submitted, the URL of the form used, and the state of each consent checkbox at the moment of submission. These records are maintained for regulatory compliance only.

2.3 Automated Digital Footprint

Our platform monitors engagement using tracking beacons to determine the timestamp of email/message engagement and the asset classes or topics (links) you investigate. We also log IP addresses, ISP data, and device types to prevent fraud, ensure distinct user counts, and enforce geo-compliance where applicable.

2.4 Interest Signals (Derived Internally)

To tailor our content and partner offers, we may derive inferences about your interests based exclusively on your own on-site behavior and engagement with our content. We do not cross-reference your email address or other personal data with external commercial identity graphs, data brokers, or profile-enrichment services (such as Clearbit or FullContact) to append professional or demographic attributes to your record. All interest signals are derived solely from your direct interactions with our platform.

3. Utilization of Data

Your data is processed to:

Segment audiences by interest in specific assets or topics to prevent irrelevant messaging;

Determine which partner offers or financial tools are displayed to you within our own communications;

Analyze IP and behavioral data to filter out bots and ensure valid human traffic;

Deliver our newsletters and alerts, maintain security, and meet legal obligations.

4. External Data Dissemination & SMS Privacy

We operate a strict “No-Sale” policy regarding your contact information. We do not sell your personal data for monetary compensation, and we do not share it for cross-context behavioral advertising. Data flows to external entities only under these conditions:

Infrastructure Processors: Ghost(Pro) (publishing and membership), Mailgun (email delivery for our Ghost platform), and Beehiiv Inc. (newsletter distribution) process outbound communications and host related data in the United States. They act solely as processors on our instruction, are bound by contractual confidentiality, and cannot use your data for their own marketing.

Strategic Partners (Pass-Through): We present curated partner content within our own newsletters. We do NOT hand your contact details to these partners. They receive your data only if you explicitly click a link and independently land on their domain, at which point their privacy policy governs.

Regulatory Compliance: We will disclose data only if compelled by TECOM Group authorities, UAE Courts, or recognized international law enforcement pursuant to valid legal process.

5. International Transfers

Because we are incorporated in the UAE and rely on infrastructure providers located in the United States, your personal data may be transferred to, stored in, and processed in jurisdictions outside your country of residence, including the UAE and the United States, which may maintain different data-protection statutes. Where required by applicable law, such transfers are carried out under appropriate safeguards — including, for transfers subject to the GDPR, the European Commission’s Standard Contractual Clauses, and for transfers subject to the UAE PDPL, contractual and technical measures designed to ensure an adequate level of protection.

6. Cookies & Tracking

We use cookies, tracking beacons, and similar technologies for essential functionality, performance and security, and to measure engagement with our content. You can control cookies through your browser settings and, where applicable, our cookie banner; disabling some cookies may affect functionality. Where the use of tracking pixels for retargeting constitutes “sharing” under California law, you may opt out as described in Section 7.

7. Data Retention

We retain personal data only as long as necessary for the purposes in this Policy, except where a longer period is required by law:

Newsletter subscriber data: for the duration of the subscription plus 12 months after unsubscription.

SMS opt-in records: for a minimum of four (4) years from the date of consent.

SMS opt-out and revocation records: for a minimum of ten (10) years.

Telemetry and technical data: individual records purged after 90 days; aggregated data retained thereafter.

8. Subscriber Controls & Rights

8.1 California Residents (CCPA/CPRA)

California residents have the right to know, delete, and correct personal information; to opt out of the sale or sharing of personal information; to limit the use of sensitive personal information; and to non-discrimination for exercising these rights. Top Margin does not sell personal data for monetary compensation, nor do we share it for cross-context behavioral advertising.

Do Not Sell or Share: To submit a request, contact us with the subject line “Do Not Sell Request.” We will respond within forty-five (45) days, and you will not be discriminated against for exercising this right.

8.2 UAE PDPL

Pursuant to UAE Federal Decree-Law No. 45 of 2021, you have the right to access your data; rectify inaccurate profile data; execute the “Right to be Forgotten” (erasure); restrict processing for specific marketing purposes; object to processing; and withdraw consent at any time without affecting prior lawful processing.

8.3 EU / EEA Residents (GDPR)

Where we accept subscribers in the EU/EEA, you have the rights of access, rectification, erasure, restriction, portability, and objection. We process newsletter and SMS data on the basis of consent (Art. 6(1)(a)); compliance recordkeeping on the basis of legal obligation (Art. 6(1)(c)); and security and integrity on the basis of legitimate interests (Art. 6(1)(f)). You may withdraw consent at any time and lodge a complaint with your local supervisory authority.

9. Protecting Minors

Our reports and services are engineered exclusively for a professional adult audience (18 years and older). We do not knowingly target or collect personal identifiers from individuals under the age of 18. If we discover that data from a minor has been inadvertently acquired, we execute immediate purging protocols.

10. Omnichannel Compliance (CAN-SPAM & TCPA)

10.1 Email (CAN-SPAM)

Every communication identifies the Publisher as the sender, uses non-deceptive subject lines, includes a functional single-click unsubscribe mechanism (processed within 10 business days), and includes our physical mailing address.

10.2 SMS (TCPA)

By providing your mobile phone number and opting in via a non-pre-ticked checkbox, you provide your prior express written consent under the Telephone Consumer Protection Act (TCPA) to receive recurring automated marketing and informational text messages, including messages sent via an Automatic Telephone Dialing System (ATDS), from Top Margin. You are not required to provide your phone number as a condition of accessing our research or purchasing any goods. Message frequency varies. Standard message and data rates may apply. Reply STOP, QUIT, or UNSUBSCRIBE to opt out; reply HELP for support. T-Mobile and all other wireless carriers are not liable for delayed or undelivered messages.

11. Security

We maintain reasonable administrative, technical, and physical safeguards designed to protect your data. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.

12. Changes to This Policy

We may revise this Policy from time to time. Updates will be indicated by the date at the top of this document. Continued engagement with our platform after an update constitutes acceptance of the revised Policy.

13. Contact

Our corporate registration is held in the United Arab Emirates. All physical correspondence, notices, and legal inquiries may be directed to our registered U.S. mailing address (for correspondence only):

Genius Marketing FZ

Mailing address for correspondence:

1151 Walker Rd Ste 100, PMB 827, Dover, DE 19904, USA