Last updated: January 1, 2020
Thank you for choosing to be part of our community at TapClicks, Inc. (“company”, “we”, “us”, or “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us at [email protected]
TABLE OF CONTENTS
- What information do we collect?
- How do we use your information?
- Will your information be shared with anyone?
- How do we handle your social logins?
- Is your information transferred internationally?
- What is our stance on third-party websites?
- How long do we keep your information?
- How do we keep your information safe?
- Do we collect information from minors?
- What are your privacy rights?
- Do California residents have specific privacy rights?
- Do we make updates to this policy?
- How can you contact us about this policy?
1. WHAT INFORMATION DO WE COLLECT?
In Short: We collect personal information that you provide to us such as your name, postal addresses, email addresses, social media website user account names, telephone numbers, or other addresses at which you receive communications from or on behalf of TapClicks.
- Send TapClicks any electronic communication (via an email or other app or website database form);
- Complete a user account;
- Submit content, comments, and opinions in online forums and communities;
- Order services including free-trials;
- Submit online applications and forms to TapClicks;
- Subscribe to newsletters;
Types of Data collected
The personal information that we collect depends on the context of your interactions with us and the Sites, the choices you make and the products and features you use. The personal information we COLLECT can include the following:
- Name and Contact Data. We collect your first and last name, email address, postal address, phone number, and other similar contact data.
- Credentials. We collect passwords, password hints, and similar security information used for authentication and account access.
- Payment Data. We collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument. All payment data is stored by our payment processor and you should review its privacy policies and contact the payment processor directly to respond to your questions.
“Non-Personal Information” is information that, alone, cannot be used to identify or contact you. Such Non-Personal Information may include, for example, gender, birthdate, or zip code. You may be asked to submit Non-Personal Information with Personal information, or separately. All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.
Information automatically collected
In Short: We may collect limited data from public databases, marketing partners, social media platforms, and other outside sources.
We may obtain information about you from other sources, such as public databases, joint marketing partners, social media platforms (such as Facebook), as well as from other third parties. Examples of the information we receive from other sources include: social media profile information (your name, gender, birthday, email, current city, state and country, user identification numbers for your contacts, profile picture URL and any other information that you choose to make public); marketing leads and search results and links, including paid listings (such as sponsored links).
2. HOW DO WE USE YOUR INFORMATION?
In Short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.
We use personal information collected via our Sites for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests (“Business Purposes”), in order to enter into or perform a contract with you (“Contractual”), with your consent (“Consent”), and/or for compliance with our legal obligations (“Legal Reasons”). We indicate the specific processing grounds we rely on next to each purpose listed below.
We use the information we collect or receive:
To facilitate account creation and login processes (with your consent). If you choose to link your account with us to a third-party account (such as Google Analytics or Facebook), we use the information you allowed us to collect from those third-parties to facilitate account creation and login process.
- To operate and improve our websites and Services. Your information may help us manage our everyday business needs, such as website administration, fulfillment, analytics, fraud prevention, compliance with the law, or enforcement of our corporate reporting obligations, terms, and conditions, and aggregate anonymous data from our Services, used to benchmark, to improve the Services, and to provide data analysis.
- Facilitate orders for products or services. Your information may be used to fulfill and facilitate requests and orders for TapClicks products or services.
- Provide customers with offers for products and services. We may use the information you provide to evaluate eligibility of customers for certain offers, products, or services, as well as track redemption of products or services and perform other analytics. These may include offers based on variables, such as stated and anticipated customer interests.
- To deliver marketing information and targeted advertising to you. We and/or our third-party marketing partners may use your provided personal information to communicate and provide additional information that may be of interest to you about TapClicks, our merchants, and our business partners, such as news, special offers and coupons, announcements, and marketing materials.
- To send support and administrative information to you [for Business Purposes and/or with your Consent]. We may use your provided personal information to provide customer support, including support to our merchants or business partners. We may also use this information to send reminders, technical notices, updates, security alerts, administrative messages, service bulletins, or marketing materials, if this is in accordance with your marketing preferences. If you do not wish to be on our mailing list, you can opt out anytime by sending an email to [email protected] or clicking on the “unsubscribe” button on our communications. From time to time, we may use your Personal Information to send important notices to our customers regarding material changes to our terms, conditions, and policies or purchased products and services which you may not opt out of receiving if you are a current customer.
- To post testimonials [with your Consent]. We post testimonials on our Sites that may contain personal information. Prior to posting a testimonial, we will obtain your consent to use your name and testimonial. If you wish to update, or delete your testimonial, please contact us at [email protected] and be sure to include your name, testimonial location, and contact information.
- Request Feedback [for our Business Purposes and/or with your Consent]. We may use your information to request feedback and to contact you about your use of our Sites.
- To protect our Sites [for Business Purposes and/or Legal Reasons]. We may use your information as part of our efforts to keep our Sites safe and secure (for example, for fraud monitoring and prevention)..
- To enforce our terms, conditions and policies [for Business Purposes, Legal Reasons and/or possibly Contractual].
- To respond to legal requests and prevent harm [for Legal Reasons]. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
- For other Business Purposes. We may use your information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Sites, products, services, marketing and your experience.
3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
In Short: We only share information with your consent, to comply with laws, to protect your rights, or to fulfill business obligations.
We only share and disclose your information in the following situations:
- Compliance with Laws. We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
- Vital Interests and Legal Rights. We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
- Vendors, Consultants and Other Third-Party Service Providers. We will not disclose your Personal Information to third parties except to our service providers that provide services for us such as sending emails on our behalf and processing payments. Our service providers are bound by law or contract to protect the Personal Information and are only allowed to use the Personal Information in accordance with the terms of our service agreements with them. We do NOT share, sell, rent, or trade Personal Information with third parties for their own promotional purposes, and we will only share Personal Information as outlined herein or with your consent. From time to time, TapClicks may partner with other companies, such as our official partners, to jointly offer products or services. If you purchase or specifically express interest in a jointly–offered product or service from or through TapClicks, we may share Personal or Non-Personal Information about TapClicks customers collected in connection with your purchase or expression of interest with our partners. TapClicks does not control our business partners’ use of such information, and their use of the information will be in accordance with their own privacy policies. If you do not wish for your Personal Information to be shared in this manner, you may opt not to purchase or not specifically express interest in a jointly-offered product or service.
- Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
- Business Partners. We may share your information with our business partners to offer you certain products, services or promotions.
- With your Consent. We may disclose your personal information for any other purpose with your consent.
5. HOW DO WE HANDLE THIRD PARTY LOGINS AND DATA TRANSFER API’S?
In Short: If you choose to use our Platform you will be required to login to your data and advertising accounts.
Our Platforms offers you the ability to register and login using your third-party social media account and advertising accounts (like your Google Analytics and Facebook logins). Where you choose to do this, we will receive certain profile information about you from your Data provider. The profile Information we receive may vary depending on the media provider concerned, but may include your name, e-mail address other information that may incidentally or purposely identify you as the account user.
6. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
In Short: We may transfer, store, and process your information in countries other than your own.
Our servers are located within the United States. If you are accessing our sites from outside the United States, please be aware that your information may be transferred, stored and processed by us in our facilities and by those third-parties with whom we may share your personal information (see “Disclosure of Your information”) in the United States and other countries.
TapClicks is responsible for the processing of Personal Information it receives under the Privacy Shield Framework and subsequently transfers to a third party acting as an agent on its behalf. We comply with the Privacy Shield Principles for all onward transfers of personal data from the EU and Swiss, including the onward transfer liability provisions.
U.S. Federal Trade Commission. With respect to personal data received or transferred pursuant to the Privacy Shield Framework, we are subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
General Data Protection Regulation. TapClicks complies with the General Data Protection Regulation (GDPR). EU and Swiss individuals have the right to access, correct, transfer, erase, restrict collection, retention, and transfer of their personal data. TapClicks retains personal data for as long as it is necessary and relevant to the purpose of processing.
If you have any questions or concerns, we encourage you to write to us as indicated below. We will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal Information in accordance with the Privacy Shield Principles. If an issue cannot be resolved through our internal dispute resolution mechanism, individuals may contact or submit a complaint, at no cost, to the JAMS EU-U.S. or Swiss-U.S. Privacy Shield Program, which is based in the United States and which serves as our third-party alternative dispute resolution provider. We will cooperate with JAMS pursuant to the JAMS International Mediation Rules, which are accessible on the JAMS website at https://www.jamsadr.com/eu-us-privacy-shield. For residual complaints not fully or partially resolved by other means, you may be able to invoke binding arbitration as detailed in the Privacy Shield Principles.
If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm
7. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?
In Short: We are not responsible for the safety of any information that you share with third-party providers who advertise, but are not affiliated with, our websites.
8. HOW LONG DO WE KEEP YOUR INFORMATION?
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
9. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Sites is at your own risk. You should only access the services within a secure environment.
10. DO WE COLLECT INFORMATION FROM MINORS?
In Short: If you are under 18, or the age of majority in the jurisdiction in which you reside, you may only use the Services with the consent of your parent or legal guardian.
The Services are not intended for or targeted at children under 13, and we do not knowingly or intentionally collect information about children under 13. If you believe that we have collected information about a child under 13, please contact us at [email protected], so that we may delete the information.
11. WHAT ARE YOUR PRIVACY RIGHTS?
Our Company would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:
- The right to access. You have the right to request Our Company for copies of your personal data. We may charge you a small fee for this service. To request such information you may send a request to [email protected]
- The right to rectification. You have the right to request that Our Company correct any information you believe is inaccurate. You also have the right to request Our Company to complete information you believe is incomplete.
- The right to erasure – You have the right to request that Our Company erase your personal data, under certain conditions.
- The right to restrict processing. You have the right to request that Our Company restrict the processing of your personal data, under certain conditions.
- The right to object to processing. You have the right to object to Our Company’s processing of your personal data, under certain conditions.
- The right to data portability. You have the right to request that Our Company transfer the data that we have collected to another organization, or directly to you, under certain conditions.
If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us at our email: [email protected] or write to us:
ATTN: Legal Department
3031 Tisch Way, Suite 900
San Jose, CA 95128
Cookies and similar technologies:
12. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS? CCRP
In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.
California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
If you are under 18 years of age, reside in California, and have a registered account with the [Sites/ Mobile Application/ Facebook Application], you have the right to request removal of unwanted data that you publicly post on the [Sites/ Mobile Application/ Facebook Application]. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California.
ATTN: Legal Department
3031 Tisch Way, Suite 900
San Jose, CA 95128
We will make sure the data is not publicly displayed on the [Sites/ Mobile Application/ Facebook Application], but please be aware that the data may not be completely or comprehensively removed from our systems.
13. DO WE MAKE UPDATES TO THIS POLICY?
In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws.
14. HOW CAN YOU CONTACT US ABOUT THIS POLICY?
If you have questions or comments about this policy, contact us via email at [email protected], or by post to:
ATTN: Customer Care
3031 Tisch Way, Suite 900
San Jose, CA 95128
Please allow at least 30 days for a response.
If you are a resident in the European Economic Area, the “data controller” of your personal information is TapClicks has appointed Oury Clark Solicitors to be its representative in the EEA. If you have any further questions or comments about us or our policies, email us at [email protected] or contact us by post at:
Oury Clark Solicitors
10 John Street,
London, WC1N 2EB