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1. Website privacy policy
This
is the Privacy Policy that governs how we use personal data that we collect,
receive and store about Customers in connection with the use of:
- The website/portal features and
services provided to you when you visit our websites or portals.
- When you apply to use and/or
use our service.
- Your use of software including
mobile and desktop applications provided by Tap Global LTD; and
- Email, other electronic
messages including SMS, telephone, website/portal and other communications
between you and Tap Global LTD.
Together
these are all referred to in this policy as “Services”.
INTRODUCTION
This
Privacy Policy explains our data practices and the choices you can make about
the way your personal data is collected and used in connection with our
Services. Data is collected and stored in accordance with the Data Protection
Act 2004 and subsequent amendment in 2018. In this Privacy Policy, personal
information or personal data means any information or data that may be used,
either alone or in combination with other data, to personally identify an
individual, including a person’s name, personal profile, e-mail address,
physical address or other contact information. We strongly urge you to read
this Privacy Policy carefully to understand our policies and practices
regarding your personal data and how we will treat it. If you do not agree to
this Privacy Policy, please discontinue and avoid using our Services. By
visiting www.tap.global (“Website”) and/or
using our Services, you are accepting and consenting to the practices described
in this Privacy Policy as may be updated from time to time.
WHAT INFORMATION DO WE
COLLECT AND WHY?
We
receive, collect and use the information listed below as it is necessary for
the adequate performance of the contract between you and us, to provide you the
Services, to support our legitimate interests in better understanding, securing
and improving our Services and overall performance, and to allow us to comply
with our legal and contractual obligations. We receive and collect
personal information from you when you provide us your name, e-mail
address and other information requested during signup. You may also provide us
with personal information when we communicate using email or another
communications mediums like telephones. We receive and collect personal
information from your browser about your use of the Services. We use
“cookies”, technical identifiers and other tracking technologies in order to
provide and enhance our Services (please see our separate cookies
policy). We receive and collect personal information from other sources,
such as, merchants, business partners, acquirers, payment service providers,
subcontractors in technical, payment and delivery services, advertising
networks, analytics providers, search information providers and fraud
prevention agencies. We collect the following information: Information
you give us: We receive and store any information including personal
and financial information you provide to us including when you (or your
business): enquire of or make an application for our Services; register to use
and/or use any our Services; upload and/or store information with us using our
Services; and when you communicate with us through email, SMS, a website or
portal, telephone or other electronic means. Such information may include you
or your customer’s:
- Company and business
professional contact information, including name, address, phone number,
fax number, e-mail address, domain names, and trade associations.
- Background information
regarding company management, such as beneficial ownership/persons of
significant control – including first name and family name, date of birth,
email address, billing address, username, password, address, nationality
and country of residence.
- Detailed company profiles.
- Company operational histories,
including territories, subsidiaries, affiliates, and lines of business.
- Detailed trade and business
credit information, including payment histories.
- Business information regarding
profitability.
Any
other information that you or your customer provide. Information we
collect about you: We receive and store certain information whenever
you interact with us; for example, by way of “cookies” or similar technology.
We also obtain certain information when your web browser or mobile APP accesses
our Services and other content provided by or on behalf of us on other web
sites, or when clicking on emails including: The Internet protocol (IP) address
used to connect your computer or device to the Internet, your login
information, browser type and version, browser plug-in types and versions,
operating system platform. Please also refer to our Cookies Policy, for more
information and see the separate Cookies section of this policy, below: Email
and Other Communications: We may receive information about you and
your use of our Services when we communicate with each other, including when
you open email, messages from us and from the use of electronic identifiers
(sometimes known as ‘device fingerprints’), for example, Internet Protocol
addresses or telephone numbers. Some of the information we collect may be
classified as “personal data” under European Union (EU) law as it is
information relating to an individual (e.g. a sole trader, a partnership, a
company director, a beneficial owner, a trustee, a professional contact etc).
This privacy notice provides the information we are required to give in
relation to the processing of personal data under EU law. Tap Global does not
seek to collect any information in relation to a customer’s race or ethnic
origin, political opinions, religious or philosophical beliefs, trade union
membership, health, sex life or sexual orientation, genetic or biometric data.
HOW WE WILL USE YOUR
INFORMATION
Your
information (as above) will include information about you (and / or your
business) and customers. If you give us information, including sensitive
personal data, about yourself or other people, you agree (and confirm that the
person the information is about has agreed) that we can use this information in
the way set out in this policy. We may use and share your information with our
subsidiaries or affiliated companies, business partners, financial
institutions, employees, professional advisors, sub-contractors, fraud
prevention agencies and third-party service providers to help us and them:
- To provide our Services to you
and your business including fulfilling our obligations to you or to
financial or other institutions in connection with the Services we provide
to you (and / or your business).
- To improve and develop our
business, including without limitation to optimize our websites/portals,
products and services.
- To provide you with the
information, products and services you have requested, or we think may be
of interest to you.
- To manage and enforce our
rights, terms of use or any other contracts with you (and/or your
business) for the provision of our Services.
- To identify and authenticate
your access to non-public parts of our Services.
- To send you service and
administrative e-mails and messages, including to inform you about
important changes or developments in our Services, to provide you with
important Services related notices, such as security notices, to notify
about your transaction and to respond to a “Contact Us” or administrative
request (for example, to change your password). These e-mails and messages
are considered an integral part of the Service and you may not opt-out of
them.
- To send you information we
believe you would find interesting including marketing and promotional
materials; by post, email, telephone, SMS text or other means, including
electronic means. You can object to marketing at any time, as explained
below.
- To identify and monitor for
fraud, we and other organizations may access and use information recorded
by fraud-prevention agencies.
- To assist in the course of any
investigation by us, other financial organizations or other third parties
into any suspected criminal activity.
- To obtain your views on our
services and our website.
- To develop and test services.
- To comply with local and
national laws, including card scheme rules and requests from law enforcement
and regulatory authorities; and.
- In respect of marketing, market
research and similar activities, we may use your personal data for such
purposes whether or not you are accepted as or continue to receive
Services. If you sign up to receive this information and then no longer
wish to receive the marketing or promotional information from us, please
let us know via the Contact Us section within your APP or via the address
shown on
WHO DO WE SHARE THIS
INFORMATION WITH?
We
may share or receive information about you with or from other sources and add
it to our account information, including when you use any of the other websites
we operate or other services we provide. We are working closely with third
parties including:
- Business partners and Sub-contractors for the performance of any
contract we enter into with them or you, or any services that we provide
to you.
- Acquirers and Payment Service
Providers (where allowed under any
Terms of Use or other contract): including the credit institution where
you (or your business) maintains its bank account and the card schemes
governing the issue and use of credit, debit, charge, purchase or other
payment cards, alternative payment schemes and any other financial
institutions who may process payments and who are not operating under Tap
Global control nor for whom whose actions or omissions Tap Global has
liability.
- Outsource and Service providers – such as credit card processors, e-KYC solutions
providers, auditors, advisors, consultants, live help/chat providers and
contractors Tap Global ‘s websites and business operations and we may
receive information about you from them or provide such information to
them. We contractually require these recipients to only use personal data
for the intended purpose of the disclosure and that they destroy or return
it when it is no longer needed.
- As required or appropriate in
order to protect our website, business operations or legal rights, or in
connection with a sale.
We
may disclose your personal information to third parties: Where we are
required or permitted to do so by law: we may be required by law to
pass information about you to regulatory authorities and law enforcement bodies
worldwide, or we may otherwise determine that it is appropriate or necessary to
do so. Such disclosures may also include requests from governmental or public
authorities, or with commercial organizations with whom you may have had
dealings and whom are seeking to mitigate fraud risk, or for the purposes of
litigation or legal process, national security or where we deem it in the
national or public interest or otherwise lawful to do so. Business
transfers: Tap Global may buy or sell business units or affiliates. In
such circumstances, we may transfer customer information as a business asset.
Without limiting the foregoing, if our business enters into a joint venture
with or is sold to or merged with another business entity, your information may
be disclosed to our new business partners or owners; and With your
permission: Your information may also be used for other purposes for
which you give your specific permission, or when required by law or where
permitted under the terms of the relevant data protection legislation. Except
where permitted as stated, Tap Global does not sell, rent, share or otherwise
disclose personal data about its customers to third parties for commercial
purposes. We may also transfer your data outside Gibraltar and the EEA only if
such a transfer will be subject to the appropriate and suitable safeguards such
as:
- ensuring of an adequate level
of protection for your Personal Data by the third country;
- an approved certification
mechanism or code of conduct with binding and enforceable commitments;
- a contract with the person or
entity receiving your Personal Data which incorporates specific provisions
as directed by the European Commission;
- permissibility of the transfer
by applicable laws;
- your explicit consent to the
transfer.
DATA RETENTION
Personal
data is stored for varying lengths depending on the nature and purpose for
which it was collected. We store personal data in line with any applicable
statutory minimum periods, and then review it periodically (usually annually)
to ensure it is still necessary to be retained for the purpose for which it was
collected. The data that you provide us is sent via a secure link (HTTPS) and
sensitive data stored is encrypted using standard encryption technology in
computer servers with limited access and in controlled facilities. We follow
generally accepted industry standards to protect personal data, however no
method of transmission over the Internet or method of electronic storage is
100% secure. All information you provide to us is stored on our secure servers.
Where we have given you (or where you have chosen) a password which enables you
to access certain parts of the Website, you are responsible for keeping this
password confidential. We ask you not to share a password with anyone. We will
never contact you and ask for your password. Unfortunately, the transmission of
information via the internet is not completely secure. Although we will do our
best to protect your personal data, we cannot guarantee the security of your
data transmitted to our Website or/and the Services; any transmission is at
your own risk. Once we have received your information, we will use strict
procedures and security features to try to prevent unauthorized access. All our
employees and data processors, who have access to, and are associated with the
processing of personal data, are obliged to respect the confidentiality of your
personal data. The Website may, from time to time, contain links to and from
the websites of our partner networks, advertisers and affiliates. If you follow
a link to any of these websites, please note that these websites have their own
privacy policies and that we do not accept any responsibility or liability for
these policies. Please check these policies before you submit any personal data
to these websites.
DATA SUBJECT RIGHTS
You
have the right to request from us confirmation of whether we are processing
your personal data, and if so, access to that information. If any of your
personal data is inaccurate you have a right to request rectification. We are
very keen to ensure the data we hold is accurate and up to date. Please contact
Customer Services. You have the right to object to our processing and/or
request it is deleted or restricted although please note that this may mean we
are unable to continue to provide you with the Services. In considering our
response we undertake to ensure your interests, fundamental rights and freedoms
are properly balanced against our legitimate interests. We will also look at
whether it is still necessary to process your data for the purpose it was
collected or whether applicable legislation means we are unable to erase a
piece of data. Please contact Customer Services for more information. We will
always observe your objection to receiving either our Tap Global marketing or
to us passing on your contact details to third parties for their direct
marketing purposes: please contact Customer Services including the name,
business name, address, telephone number and email address that you wish to
have excluded. Opting Out: If you have opted to receive
marketing-related messages from us and would prefer to no longer receive these,
or if you would prefer that we not share personal data about you with any of
our business partners, you may later opt-out of receiving messages from us or
from our future sharing of information about you by following the “unsubscribe”
instructions in the latest such message you have received. We will endeavour to
comply with your request as soon as reasonably practicable. Please keep in mind
that if you opt-out of receiving promotional messages from this Website, we
will continue to send you transactional messages and important account-related
information regarding this Website or Services offered through this Website.
Before we are able to provide you with any information or correct any
inaccuracies, we may ask you to verify your identity and to provide other
details to help us identify you and respond to your request.
HANDLING OUR CUSTOMERS’
DATA
Sometimes
our customers provide us with their business data, such as their customer,
supplier or prospect data – which may contain personal data – in order for us
to provide them a service. In these instances, we are the processor of any
personal data contained in their data. Different parts of the GDPR apply when
we act as a processor and we take these obligations very seriously. The above
notice does not apply to our data received from our customers as this does not
become Tap Global data (unless the customer has expressly agreed to this).
UPDATING THIS PRIVACY
NOTICE
We
strive for continuous improvement in our services, processes and protecting
data subject rights. We will therefore update this privacy notice from time to
time. Therefore, we advise you to check this notice on a regular basis, or if
requested we will send it to you on a regular basis.
CONTACT US