Last modified: 11 May 2022
Effective day 11 May 2022. You can see previous versions of our Privacy Policy here.
Protecting your data, privacy and personal information is very important to Personal Privacy Solutions Limited (Tapx), registered in England and Wales, with a registration number 11387482, having its registered office address at Bethesda Chapel, Victoria Square, Llanwrtyd Wells, Powys, Wales, LD5 4SS (“our”, “us” or “we” or “Tapx”).
We are registered by the ICO in the UK number ZA460946.
This policy (together with our End-user license agreement as available in the App Store and Google Play store, the Terms and Conditions Website and the App terms) applies to your use of:
“End User” means any category of individual that has access to or engages with the Tapx Platform.
“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.
“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 freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.
“Controller” has the meaning under the GDPR. Where indicated “Controller” also refers to a “Business” under the CCPA.
“Glitch NFT” means your digital identity in our Platform, which you would be granted with your TAP account creation.
“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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
“Partner” has the meaning of any legal entity that is part of our Platform and has an account with us (“Customer”).
“Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules, or regulations (collectively the “Data Protection Laws”).
“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.
2.1 We are the controller and are responsible for your personal data.
We have appointed a data privacy manager. If you have any questions about this privacy policy, please contact them using the details set out below.
2.2. Contact details
Our full details are:
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 our websites and products are being used and downloaded outside the UK.
2.3 Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review. 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 or log onto one of our Services websites. 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 or the Services.
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.
2.4 Third party links
Our Sites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact and Location Data. Please check these policies before you submit any personal data to these websites or use these services.
3.1 We may collect, use, store and transfer different kinds of personal data about you as follows:
We explain these categories of data in Section 11 below.
3.2 We also collect, use and share 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.
3.3 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.
4.1 We collect your personal data through a signup form on our website or Mobile App. We will collect and process the following data about you:
4.2 Device Data from the following parties:
5.1 We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:
5.2 We will only send you direct marketing communications by email if we have your consent. You have the right to withdraw that consent at any time by contacting us.
5.3 PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
Purpose/activity Type of data Lawful basis for processing
To install the App, register you as a new Identity
App user and verify your account. Contact
Device Your concent
To process in-App purchases and deliver Identity
Services including managing Contact transfers of tokens and collecting tokens Transaction Your concent
owned to us Ethereum Wallet Performance of a contract
Device with you
Marketing and communications
Location Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you, Identity Your consent
including notifying you of Contact
changes to the App Profile
or any Services Markeitng and
Communications
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 enable you to participate Identity
in a prize draw, competition Contact
or complete a survey Device
Contact
Device
Profile
Marketing and
Communications
To administer and protect our Identity Necessary for our
business and this App including Contact ligitimate interests
troubleshooting, data analysis Device (for running our
and system testing business, provision of administration and IT services, network security)
Identity
Contact
Device Consent
Content Necessary for our
To deliver content to you Profile legitimate interests
To monitor trends so we Usage (for running our
can improve the App Marketing and business,provision
Communication of adminirtration
Location and IT services, network security)
6.1 When you consent to providing us with your personal data, we will also ask you for your consent to share your personal data with the third parties set out below for the purposes set out in the table Purposes for which we will use your personal data:
7.1 Your Personal Data is maintained, processed and stored by us and our authorized Service Providers (defined below) in USA, Europe and UK. We may also retain your Personal Data in other locations as reasonably necessary for the proper performance and delivery of our Platform, or as may be required by law.
7.2 While privacy laws may vary between jurisdictions, TAP and its affiliates and Service Providers are each committed to protect Personal Data in accordance with this Privacy Policy and customary industry standards, and such appropriate lawful mechanisms and contractual terms requiring adequate data protection, regardless of any lesser legal requirements that may apply in their jurisdiction.
7.3 Customers based outside the EEA will be subject to local data privacy legislation. A full list of our third party Service providers/Sub-processors and details of their privacy policies can be found here, which will be updated from time to time.
7.4 By using our Platform you consent and agree with the Sub-processors we use above. Where we have made changes and have provided you with an updated list of our Sub-processors, we will provide you with a notification and provide 30 days’ notice to determine whether you agree with the changes and continue to use our Platform or alternatively you can discontinue using our Platform.
7.5 You acknowledge and accept that countries outside the EEA may not provide the same level of adequate protection for the rights and freedoms of data subjects in relation to the processing of personal data.
7.6 Your passwords are stored on TAP’s servers in encrypted form. We do not disclose your account details to anyone except when legally required to do so. It is your responsibility to keep your password secure. Unfortunately, the transmission of information via the internet is not completely secure. Although TAP will do its best to protect your personal data, we cannot guarantee the security of your data transmitted to our website, 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 any unauthorised access.
8.1 All information you provide to us is stored on our secure servers. Any transfer of TAP tokens transactions carried out by us or our chosen third-party provider of processing services will be encrypted using Transport Layer Security technology. Where we have given you (or where you have chosen) a password that enables you to access certain parts of Our Sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
8.2 Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way. We will store the data in external third party servers, namely: AWS. All data is being stored in the relevant legal entities UK datacenters. We use industry-standard encryption of passwords, by hashing the passwords by secure algorithm. We use TLS (Transport Layer Security) – traffic to and from our server. Company wide policy on Security.
8.3 We will collect and store your preferences on your Device using application data caches and browser web storage (including HTML5).
8.4 Certain Services may include social networking, chat room or forum features. Ensure when using these features that you do not submit any personal data that you do not want to be seen, collected or used by other users.
8.5 We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.
9.1 By law we have to keep basic information about our customers (including Contact, Identity, Ethereum Wallet and Transaction Data) for 6 years after they cease being customers for tax purposes.
9.2 In some circumstances you can ask us to delete your data: see Your legal rights below for further information.
9.3 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.
9.4 In the event that you do not use the App for a period of 1 year then we will treat the account as expired and your personal data may be deleted.
10.1 Under certain circumstances you have the following rights under data protection laws in relation to your personal data:
(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.
10.2 You also have the right to ask us not to continue to process your personal data for marketing purposes.
10.3 You can exercise any of these rights at any time by contacting us at privacy@tapx.com
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