Issue date 30.04.2019 version 1.0
- 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 N Go LTD; and
- Email, other electronic messages including SMS, telephone, website/portal and other communications between you and Tap N Go LTD.
Together these are all referred to in this policy as “Services”.
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 N Go 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 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 www.tap.global.
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.
- Outsource and Service providers - such as credit card processors, e-KYC solutions providers, auditors, advisors, consultants, live help/chat providers and contractors Tap N GO '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 N Go 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 N GO 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.
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 via email@example.com .
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 N GO 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 N Go 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.
All complaints or concerns and appropriate resolution relating to the practices of handling personal information will be logged. Any complaints of this nature should be made to Customer Services at: firstname.lastname@example.org.
You also have the right to lodge a complaint with a supervisory authority, such authority in Gibraltar being the Gibraltar Regulatory Authority, details of which can be found at www.gra.gi.