We, TAP It Holdings Limited, a Limited Liability company doing business as TAP (“TAP” or "We") explain in this Privacy Statement what information we receive and collect from and about you, a user of our TAP device or other device ("Device"), TAP mobile or web application (“TAP”), our mobile sites and websites that you can access with a Device and TAP (“TAP”), and/or updates to any of the foregoing (collectively “TAP”).
1. Server Locations and the Storage of your Data. We are headquartered in London. Our servers are in Europe and we process information in Europe and other countries. When you use TAP, you transmit data to Europe and other countries. We may store Personal Data itself or such information may be stored by third parties to whom we have transferred it in accordance with this Privacy Policy. We take what we believe to be reasonable steps to protect the Personal Data collected via the Services from loss, misuse, unauthorised use, access, inadvertent disclosure, alteration and destruction. However, no network, server, database or Internet or e-mail transmission is ever fully secure or error free. Therefore, you should take special care in deciding what information you send to us electronically. Please keep this in mind when disclosing any Personal Data.
2. Information We Collect. Information you actively provide: When you download TAP, register for an account, connect your Device to your account, use the TAP Service or send us requests, we may ask you to provide your first and last name, email address, postal addresses, account name, password, photo, gender, height, company information, and date of birth. You may also choose to upload your address book and Facebook contacts to our servers, or through email address lookup, so we can help you find contacts using TAP. Other information you may choose to input includes what you eat and drink, your mood, and other activities. We use information to provide you with useful information.
3. Information you automatically provide. When you use the TAP Service, it automatically transmits activity and physical information to us. This data is translated into information such as your activities undertaken and your trends and progress. When you use our apps you transfer information about your activity, you also transmit information about how you use the Service and interact with Service, and a time-stamped log of data exchanges.
4. Combinations. We may combine information we receive through the TAP Service with information we receive about you from other sources, for example, via our websites, requests you may send us, or promotional campaigns.
5. Use of Information. TAP uses your information to provide and improve our mobile sites, information, products and services; create statistics to promote our services and products; personalise your experience and customise content, marketing, and recommendations; respond to requests that you make, provide you with customer service, general informative announcements, and to send you promotional information about us or our products, or to aid us in serving you better; and protect, investigate, and deter against fraudulent, unauthorised, or illegal activity. We collect and use the Personal Data we collect in a manner that is consistent with this Privacy Policy. We may additionally use the Personal Data as follows:
5.1 Specific reason. If you provide Personal Data for a certain purpose, we may use the Personal Data in connection with the purpose for which it was provided.
5.2 Access and use. If you provide Personal Data in order to obtain access to or use of the Services or any functionality thereof, we will use your Personal Data to provide you with access to or use of the Services or functionality and to analyse your use of such Services or functionality.
5.3 Internal Business Purposes. We may use your Personal Data for internal business purposes, including without limitation, to help us improve the content and functionality of the Services, to better understand our Users, to improve the Services, to protect against, identify or address wrongdoing, to enforce our Terms of Service, to manage your account and provide you with customer service, and to generally manage the Services and our business. 5.4 Partner Emails. We allow Partners to use information gathered to contact Consumers who they have engaged with at an event or venue. The importing or exporting of email addresses or contact information will only be given with the prior consent of the Consumer, and for the purposes of delivering information to those who have proactively shown interesting in receiving such content. The Partner is responsible for sending emails in keeping with this Privacy Policy. 5.5 Other Purposes. If we intend to use any Personal Data in any manner that is not consistent with this Privacy Policy, you will be informed of such anticipated use prior to or at the time the Personal Data is collected or we will obtain your consent subsequent to such collection but prior to such use. 5.6 Aggregated Personal Data. In an ongoing effort to understand and serve our Users better, we conduct research on our customer demographics, interests and behaviour based on Personal Data and other information that we have collected. This research is typically conducted on an aggregate basis only that does not identify you. Once Personal Data is in an aggregated form, for purposes of this Privacy Policy, it becomes Non-Personal Data.
6. Sharing of Information. We do not rent, sell or otherwise share individual personal information with third parties, except as follows: With your consent, for example to connect with a third party app or service. We use affiliated and unaffiliated service providers that help us deliver our service and run our business subject to confidentiality agreements. We share aggregated usage statistics that cannot be used to identify you individually, for example through data stories on our website (www.tapitevents.com) or through the media. We may disclose your personal information to (a) comply with relevant laws, regulatory requirements and to respond to lawful requests, court orders, and legal process; (b) to protect and defend the rights or property of us or third parties, including enforcing agreements, policies, and terms of use; (c) in an emergency, including to protect the safety of our employees or any person, or (d) in connection with investigating and preventing fraud. Many users want to connect with friends and colleagues or prospective partners. When you use the TAP Service, the name and email address you register with the TAP Service may be shared with those you want to connect with. If you choose to be part of a TAP network or add people to your TAP network, you choose the TAP information you wish to share with your network. Be thoughtful of your own privacy needs as you choose what you share and with whom. We may share your Personal Data with our contractors and service providers who process Personal Data on behalf of TAP to perform certain business-related functions. These companies include our marketing agencies, database service providers, backup and disaster recovery service providers, email service providers and others. When we engage another company to perform such functions, we may provide them with information, including Personal Data, in connection with their performance of such functions. When you purchase tickets to, register for or donate to an event through the event page, or through a related fundraising page on the Services, we provide the Personal Data entered on the applicable event or related fundraising page to the Organisers of such event or related fundraising page. For fundraising pages, we may provide your Personal Data both to the Organiser charity of the fundraising page and the Organiser of the event to which the fundraising page is linked. We are not responsible for the actions of these Organisers, or their Third Party Organisers, with respect to your Personal Data. It is important that you review the applicable policies of the Organisers, and if applicable and available, their appointed Third Party Organisers, of an event (and the related fundraising page, if applicable) before providing Personal Data or other information in connection with that event or related fundraising page.
7. Choices about Your Information. You can choose general types of information you share. Any of your data that has been aggregated into anonymised system usage statistics will remain on our system. It is not possible to extract any individually identifiable information from this data.
8. How Long We Retain Your Personal Data. We may retain your Personal Data as long as you are registered to use the Services. You may close your account by contacting us. However, we may retain Personal Data for an additional period as is permitted or required under applicable laws. Even if we delete your Personal Data it may persist on backup or archival media for an additional period of time for legal, tax or regulatory reasons or for legitimate and lawful business purposes.
9. Security of Your Information. We apply organisational and technical measures to ensure access to your information is limited to persons with a need to know. Even though we have taken steps to protect your personal information, you should know that neither we -- nor any company -- can fully eliminate security risks. You can request access to some of your Personal Data being stored by us. You can also ask us to correct, update or delete any inaccurate Personal Data.
10. Business Transfers. As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganisation, dissolution or similar event, Personal Data may be part of the transferred assets. You acknowledge and agree that any successor to or acquirer of TAP (or its assets) will continue to have the right to use your Personal Data and other information in accordance with the terms of this Privacy Policy. We may also share your Personal Data with our future parent companies, subsidiaries and/or affiliates for purposes consistent with this Privacy Policy. Our parent companies, subsidiaries and affiliates will be bound to maintain that Personal Data in accordance with this Privacy Policy.
11. Data Processor. The TAP platform and services act as a data processor. As such, we process data when we provide the services to you. These include, but are not limited to; ticket purchasing, registration services, accreditation services, staff management services, attendance tracking, access control, lead engagement services, rewards programmes, and point of sales solutions. If you are unsure under which circumstances TAP is a data processor, please contact TAP for immediate clarification. Your use of the TAP platform and services, otherwise acknowledges that for the purposes of the Data Protection laws, you consent to TAP collecting and processing data, and you consent to TAP appointing third-party processors to provide you with the services. 12. Legal Requirements. We may disclose your Personal Data if required to do so by law in order to (for example) respond to a subpoena or request from law enforcement, a court or a government agency (including in response to public authorities to meet national security or law enforcement requirements), or in the good faith belief that such action is necessary to (a) comply with a legal obligation, (b) protect or defend our rights, interests or property or that of third parties, (c) prevent or investigate possible wrongdoing in connection with the Services, (d) act in urgent circumstances to protect the personal safety of Users of the Services or the public, or (e) protect against legal liability.
13. International Privacy Laws. Please be aware that you are sending information (including Personal Data) to where our servers are located. That information may then be transferred within the EU or the United States or back out of the EU or the United States, or to other countries outside of your country of residence, depending on the type of information and how it is stored by us. These countries may not necessarily have data protection laws as comprehensive or protective as those in your country of residence; however, our collection, storage and use of your Personal Data will at all times continue to be governed by this Privacy Policy. 14. EU - US Privacy Shield Notice. For Personal Data we receive from the EEA, TAP has certified its compliance to the EU-US Privacy Shield as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data from the European Union countries. We have certified that we adhere to the Privacy Shield principles of Notice, Choice, Accountability for Onward Transfers, Security, Data Integrity & Purpose Limitation, Access and Recourse, Enforcement & Liability when processing Personal Data from the EEA in the United States.
15. Contact Us. Should you have any questions or concerns regarding this privacy policy, please contact us. We may update this Statement from time to time. When we do, we will change the last Effective as of date below to let you know we made a change.
Effective as of: May 23, 2019