Effective Date: Jan 1, 2025
TAP Rewards (“TAP,” “we,” “us,” or “our”) is committed to safeguarding your privacy while providing a personalized and rewarding experience. This Privacy Policy explains how we collect, use, share, and protect your personal data in compliance with applicable privacy laws, including the General Data Protection Regulation (GDPR) for users in the European Union.
By using the TAP platform, including the app, website, and related services, you agree to the terms of this Privacy Policy.
1. Introduction
• Purpose:
This Privacy Policy outlines:
• The types of data we collect and why.
• How your data is used, stored, and shared.
• Your rights regarding your data and how to exercise them.
• Scope:
This policy applies to all users of the TAP platform, including:
• Individuals using the TAP app to earn and redeem rewards.
• Referred users who are invited to the platform.
• Merchants participating in the TAP Rewards ecosystem.
• Commitment to Privacy:
TAP adheres to the principles of transparency, accountability, and security to ensure your privacy is protected.
2. Data We Collect
This section outlines the types of data TAP Rewards (“TAP”) collects to provide services, improve user experiences, and comply with legal obligations. TAP is committed to collecting data transparently and responsibly.
2.1 Categories of Data Collected
A. Personal Data Provided by Users
When you interact with the TAP Platform, we may collect the following types of personal data directly from you:
1. Account Information:
• Full name, email address, phone number, and password.
• Optional demographic information such as date of birth, gender, or preferences.
2. Transaction Information:
• Details about purchases made through the TAP App, including amounts, merchants visited, and timestamps.
3. Referral Information:
• Data related to referrals you make, such as the email addresses or phone numbers of referred individuals (where legally permitted).
4. Customer Support:
• Information provided when you contact customer support, including inquiry details and any associated documentation or screenshots.
B. Automatically Collected Data
When you use the TAP Platform, certain information is automatically collected to optimize services and enhance functionality:
1. Device and Technical Data:
• Device type, operating system, browser type, app version, and unique device identifiers (e.g., IP address or mobile device ID).
2. Location Data:
• GPS-based geolocation to provide location-specific features (e.g., finding nearby merchants) with your consent.
• Approximate location based on your IP address.
3. Usage Data:
• Information about your interactions with the TAP Platform, including pages viewed, time spent on the app, navigation patterns, and links clicked.
4. Cookies and Tracking Technologies:
• Session cookies for maintaining your login.
• Persistent cookies and similar technologies for tracking preferences, analytics, and personalized promotions.
C. Anonymized and Aggregated Data
TAP creates anonymized or aggregated datasets from user activity that do not identify specific individuals. Examples include:
• Spending trends (e.g., average purchase size).
• Popular merchants or product categories.
• Regional engagement metrics.
This data is used to analyze platform performance, improve services, and provide merchants with valuable insights.
D. Data From Third Parties
TAP may collect data about you from the following external sources:
1. Linked Accounts:
• If you link your TAP account to third-party platforms (e.g., Google, Facebook), we may collect information from those accounts, such as your profile name and email address.
2. Payment Providers:
• Limited payment details from third-party processors (e.g., Stripe) to confirm transactions made through the TAP App. TAP does not store payment information such as credit card or bank account numbers.
3. Referrals:
• Data provided by other users who refer you to TAP, such as their referral code or email address.
2.2 Purpose of Data Collection
TAP collects this data to:
• Enable core platform functions, such as earning and redeeming rewards.
• Personalize user experiences, including recommendations, targeted promotions, and tailored communications.
• Provide merchants with anonymized user insights for better engagement and targeted offers.
• Improve platform functionality through performance analysis and troubleshooting.
• Ensure compliance with legal and regulatory requirements, such as fraud prevention and tax reporting.
2.3 Sensitive Data
TAP does not intentionally collect sensitive personal data (e.g., health information, religious beliefs, or biometric data). If users provide such data voluntarily (e.g., through support inquiries or optional fields), it will be handled securely and deleted when no longer necessary.
2.4 User Consent
Where required by law, TAP will request your explicit consent to collect and process specific types of data, such as:
• Location data for providing location-specific services.
• Use of cookies and similar tracking technologies for analytics and advertising.
You can withdraw your consent at any time by updating your preferences in the app settings or contacting customer support.
2.5 Data Collected for Minors
TAP does not knowingly collect personal data from individuals under the age of 18. If we discover that we have inadvertently collected data from a minor, it will be promptly deleted. Parents or guardians may contact TAP to request the removal of such data.
3. How We Use Your Data
This section explains how TAP Rewards (“TAP”) processes the data it collects to provide services, improve user experiences, and comply with legal obligations. TAP is committed to using your data responsibly and transparently.
3.1 Providing TAP Services
Your data is used to deliver the core functionality of the TAP Platform, including:
1. Transaction Processing:
• Recording purchases and earning points when transactions are completed through the TAP App.
• Validating eligibility for rewards, referrals, and promotions.
2. Reward Management:
• Allocating points for eligible activities.
• Facilitating the redemption of points in the TAP Rewards Marketplace.
3. Referral Program Administration:
• Tracking referrals to ensure that both the referrer and referee receive appropriate rewards.
3.2 Personalizing User Experiences
We use your data to enhance your experience on the Platform by:
1. Customized Recommendations:
• Suggesting relevant merchants, promotions, or rewards based on your preferences and past activity.
2. Targeted Notifications:
• Sending personalized offers, promotions, and updates through email, push notifications, or in-app messages (with your consent).
3. Localized Features:
• Providing location-based services, such as identifying nearby merchants or promoting region-specific offers.
3.3 Improving the Platform
Your data helps us analyze and optimize the TAP Platform by:
1. Platform Analytics:
• Monitoring user behavior to identify trends, improve usability, and enhance overall performance.
2. Feature Development:
• Testing and launching new features or services based on user preferences and feedback.
3. Troubleshooting and Support:
• Diagnosing technical issues and resolving user inquiries.
3.4 Data Sharing with Merchants
TAP shares anonymized, user-specific data with merchants to help them improve their services and target relevant offers to users. Examples of shared data include:
1. User Engagement Metrics:
• Information such as “User 123456 visited 5 times and spent €200.”
2. Trends and Insights:
• Aggregated data on spending trends, popular items, or visit frequency.
Important Notes:
• Merchants do not receive any personally identifiable information (PII), such as names, emails, or phone numbers.
• Data shared is anonymized to ensure user privacy and compliance with applicable laws.
3.5 Marketing and Communications
With your consent, TAP uses your data to:
1. Promote Relevant Offers:
• Notify you about rewards, new merchants, or promotional campaigns tailored to your interests.
2. Engage Through Multiple Channels:
• Send marketing communications via email, push notifications, or SMS, depending on your preferences.
3. Campaign Effectiveness:
• Measure the success of marketing campaigns and refine future initiatives.
3.6 Fraud Prevention and Security
We process your data to maintain the integrity and security of the Platform by:
1. Detecting Suspicious Activity:
• Monitoring transactions and referrals for fraudulent or abusive behavior.
2. Preventing Unauthorized Access:
• Using device data and other security measures to protect accounts from unauthorized access.
3. Compliance with Legal Obligations:
• Sharing information with law enforcement or regulatory authorities when required by law.
3.7 Legal and Regulatory Compliance
TAP processes your data to meet its legal and regulatory obligations, including:
1. Tax and Financial Reporting:
• Maintaining records of transactions and rewards for tax and audit purposes.
2. Dispute Resolution:
• Using data to address claims, disputes, or chargebacks related to user or merchant activities.
3. GDPR and Privacy Compliance:
• Processing personal data in accordance with GDPR and other applicable data protection laws.
3.8 Anonymized and Aggregated Data
TAP generates anonymized or aggregated datasets that are used for purposes such as:
1. Platform Improvement:
• Identifying patterns to enhance Platform performance.
2. Merchant Insights:
• Providing merchants with actionable data to improve their offerings.
3. Business Analytics:
• Using aggregated data to analyze the effectiveness of TAP’s business model and refine strategies.
This data does not contain PII and cannot be used to identify individual users.
3.9 Responding to User Requests
Your data is used to process and respond to user requests, including:
1. Data Access:
• Providing copies of personal data as requested under GDPR or other regulations.
2. Data Correction:
• Updating inaccurate or incomplete information in your account.
3. Account Deactivation:
• Processing account deletions and ensuring compliance with the “right to be forgotten.”
3.10 Consent-Based Uses
In certain cases, TAP will process your data based on your explicit consent, including:
1. Location Data:
• Using real-time GPS data to provide localized features.
2. Targeted Advertising:
• Serving ads based on your preferences and activity.
3. Email Marketing:
• Sending promotional emails tailored to your interests.
You can withdraw your consent at any time by updating your preferences in the app or contacting customer support.
3.11 Internal and Administrative Purposes
TAP uses data for internal operations, such as:
1. Audits and Reporting:
• Conducting internal audits to ensure the accuracy and effectiveness of Platform processes.
2. Team Training:
• Using anonymized data to train staff and improve customer service.
3. Policy Enforcement:
• Ensuring compliance with TAP’s Terms of Service and Privacy Policy.
4. Sharing Your Data
This section explains how TAP Rewards (“TAP”) shares your data with third parties, the safeguards in place to protect your privacy, and the purposes for which your data may be shared. TAP is committed to ensuring that data sharing is conducted securely, lawfully, and transparently.
4.1 Sharing with Merchants
TAP shares anonymized and user-specific data with participating merchants to help them improve their services, target offers, and engage more effectively with customers.
A. Types of Data Shared
1. Anonymized User-Specific Data:
• Data that is tied to an anonymized user ID (e.g., “User 123456 has visited 10 times and spent €250”).
• Includes metrics such as visit frequency, average spending, and reward redemption rates.
2. Aggregated Data:
• Group-level insights, such as overall spending trends, popular times, or categories of purchases.
B. Restrictions on Data Usage by Merchants
Merchants may only use the shared data for the following purposes:
• Offering targeted promotions or rewards to TAP users.
• Enhancing their products, services, or customer experience.
• Analyzing trends to improve operational efficiency.
C. Prohibited Activities
Merchants are explicitly prohibited from:
• Attempting to re-identify anonymized data to access personally identifiable information (PII).
• Sharing, selling, or transferring data obtained through the TAP Platform to unauthorized third parties.
• Using the data for purposes outside of their participation in the TAP ecosystem.
4.2 Sharing with Third-Party Service Providers
TAP collaborates with trusted third-party service providers to deliver and maintain the Platform. These providers are essential for ensuring smooth operations and high-quality services.
A. Types of Third-Party Providers
1. Payment Processors:
• Securely process transactions made through the TAP App (e.g., Stripe).
• TAP does not store payment details like credit card numbers or bank account information.
2. Cloud Service Providers:
• Host and secure TAP’s databases and infrastructure.
3. Analytics Providers:
• Provide insights into user behavior and Platform performance (e.g., Google Analytics).
4. Marketing Platforms:
• Deliver communications, such as emails and push notifications, based on user preferences and activity.
B. Safeguards for Third-Party Data Sharing
• Contractual Obligations: All third-party providers are bound by strict data protection agreements to ensure compliance with applicable laws (e.g., GDPR).
• Limited Data Access: Providers only receive the data necessary to perform their specific function.
• Security Standards: Providers must implement robust security measures, such as encryption, to protect shared data.
C. Transparency
A list of third-party service providers and their roles is available upon user request, subject to legal and confidentiality constraints.
4.3 Sharing for Legal and Compliance Purposes
TAP may disclose user data to comply with legal obligations or to protect the rights and safety of users, merchants, and the public.
A. Circumstances Requiring Disclosure
1. Legal Requirements:
• In response to subpoenas, court orders, or other lawful requests from government authorities.
2. Fraud and Security Investigations:
• Sharing data to investigate, detect, or prevent fraudulent activities, unauthorized access, or security breaches.
3. Protection of Rights:
• Sharing data as necessary to enforce TAP’s Terms of Service, defend against legal claims, or safeguard the rights and safety of TAP, its users, or the public.
B. User Notification
Where legally permissible, TAP will notify users before sharing their data with authorities. If prior notice is prohibited, TAP will inform users as soon as possible after disclosure.
4.4 Sharing for Business Transactions
In the event of a corporate transaction, such as a merger, acquisition, or sale of assets, your data may be transferred to the acquiring entity.
A. Protections During Business Transactions
1. Limited Access: Only data necessary for evaluating or executing the transaction will be shared.
2. Privacy Commitments: The acquiring entity must agree to adhere to TAP’s Privacy Policy or provide equivalent protections.
B. User Notification
Users will be informed of any significant changes in data handling practices following the transaction.
4.5 Sharing with Your Consent
TAP may share your data with third parties. Examples include:
• Sharing feedback or reviews with merchants.
• Participating in surveys, contests, or co-branded promotions.
• Linking your TAP account with other platforms (e.g., social media or loyalty programs).
You can withdraw your consent at any time through the TAP App or by contacting customer support.
4.6 Sharing Anonymized and Aggregated Data
TAP may share anonymized or aggregated data with external partners for purposes such as:
1. Research and Development:
• Collaborating with academic institutions or research organizations to improve industry insights.
2. Marketing and Partnerships:
• Providing general usage trends or demographic insights to potential business partners or advertisers.
This data is stripped of any information that could identify individual users.
4.7 User Control Over Data Sharing
TAP empowers users with tools to manage how their data is shared:
1. Opt-Out Options:
• Users can opt out of certain data sharing activities, such as receiving targeted promotions or participating in research.
2. Access Logs:
• Users can view which merchants or third parties have accessed their anonymized data via their account settings.
3. Data Sharing Preferences:
• Users can manage sharing preferences, such as toggling consent for optional data-sharing features.
4.8 Prohibited Data Sharing Practices
TAP does not engage in the following activities:
• Sharing Sensitive Data: TAP does not share sensitive personal data, such as health or biometric information, with external parties.
5. User Rights (Under GDPR)
As a user in the European Union, you have the following rights:
A. Access
• Request a copy of the personal data TAP holds about you.
B. Correction
• Update or correct inaccurate or incomplete information.
C. Deletion (Right to Be Forgotten)
• You have the right to request that TAP delete all personal data we hold about you.
• Exceptions: Data may be retained if required for legal, regulatory, or operational purposes (e.g., transaction records).
D. Restriction of Processing
• Restrict the processing of your data under certain conditions (e.g., for marketing).
E. Data Portability
• Request your data in a portable format to transfer to another service.
F. Objection
• Object to the processing of your data for specific purposes, such as direct marketing.
G. Consent Withdrawal
• Withdraw consent for processing activities based on your permission.
6. Data Retention
This section explains how long TAP Rewards (“TAP”) retains user data, the reasons for retention, and the processes for secure deletion once data is no longer required. TAP is committed to retaining data only for as long as necessary to fulfill operational, legal, and regulatory obligations while safeguarding user privacy.
6.1 Retention Periods
TAP retains your data for specific periods depending on the type of data and its purpose, as outlined below:
A. Account Data
• Retained for as long as your account remains active.
• If you deactivate or delete your account, data will be retained for a grace period of 90 to allow for reactivation, unless deletion is explicitly requested.
B. Transaction Data
• Retained for 7 years to comply with tax, financial, and legal reporting requirements.
• Anonymized transaction records may be retained indefinitely for analytical and business improvement purposes.
C. Rewards and Referral Data
• Data related to rewards, referrals, and promotional activities is retained for 3 years after the activity is completed or the reward is redeemed.
D. Customer Support Data
• Communications with customer support, including inquiries, complaints, or issue resolutions, are retained for 2 years for quality assurance and dispute resolution purposes.
E. Legal and Compliance Data
• Data required for compliance with legal obligations, such as fraud investigations or regulatory reporting, is retained for the duration mandated by applicable laws (e.g., financial records for tax audits).
6.2 Anonymized and Aggregated Data
TAP may retain anonymized or aggregated data indefinitely for purposes such as:
• Improving platform functionality and user experience.
• Providing merchants with actionable insights.
• Conducting research, analytics, and business planning.
This data does not contain personally identifiable information (PII) and cannot be used to identify individual users.
6.3 Factors Affecting Retention Periods
TAP may retain data beyond standard retention periods in certain cases, including:
• Active Disputes or Investigations: Data may be retained if it is subject to legal, regulatory, or contractual obligations (e.g., fraud investigations or chargebacks).
• User Requests: If a user requests data portability or deletion, TAP will comply within the timelines specified by GDPR or other applicable laws.
• Technical Constraints: In cases of complex system backups, complete removal of data may take additional time.
6.4 Secure Deletion
Once data is no longer needed, TAP ensures it is securely deleted or anonymized, depending on the type of data and applicable regulations. Secure deletion processes include:
• Permanently Erasing Data: Personal data stored in digital formats is securely wiped from servers and storage devices using industry-standard methods.
• Anonymization: Personal data may be stripped of identifiers and converted into aggregated or anonymized datasets.
• Destruction of Physical Copies: If personal data is stored in physical formats (e.g., printed documents), it is shredded or incinerated securely.
6.5 User Rights and Data Retention
You have the following rights regarding data retention:
• Request for Deletion:
• You can request the deletion of your personal data under the “right to be forgotten.” TAP will evaluate and process your request unless retention is required for legal or regulatory reasons.
• Data Portability:
• You can request a copy of your data before account deactivation to transfer it to another provider.
• Retention Transparency:
• You can request details on the specific retention periods applied to your data categories.
6.6 Legal and Regulatory Compliance
TAP’s data retention policies comply with applicable privacy laws and regulations, including:
• General Data Protection Regulation (GDPR) in the European Union.
• Local data retention laws in jurisdictions where TAP operates.
When legal requirements conflict with deletion requests or standard retention periods, TAP will prioritize compliance with regulatory obligations.
6.7 Notifications of Retention Changes
TAP reserves the right to update its retention policies to align with changes in legal requirements, business needs, or user expectations. Significant changes will be communicated via:
• Email notifications.
• Updates to this Privacy Policy on the TAP website or app.
7. Data Security
We use advanced measures to protect your data:
• Encryption: Personal data is encrypted during transmission and storage.
• Access Controls: Restricted access to data, limited to authorized personnel.
• Monitoring: Regular security audits and penetration testing to identify vulnerabilities.
8. Cookies and Tracking
TAP uses cookies to:
• Maintain user sessions.
• Track app usage and collect analytics.
• Deliver personalized promotions.
Users can manage cookies via browser or device settings.
9. Contact Us
For questions, concerns, or requests, contact TAP at:
• Email: team@gettaprewards.com