TAPCLICKS PRIVACY POLICY &
GDPR PRIVACY NOTICE
Last updated [January 1, 2020]

INTRODUCTION

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 legal@tapclicks.com.

When you visit our website (tapclicks.com) (“Site”) and use our services, you trust us with your personal information. We take your privacy very seriously. In this privacy notice, we describe our privacy policy. We seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy policy that you do not agree with, please discontinue use of our site and our services.

By entering into a contract with TapClicks and/or by pressing “Accept” or similar affirmative button, you have agreed to TapClicks Privacy Policy.

Please read this privacy policy carefully as it will help you make informed decisions about sharing your personal information with us.

Table of contents
  1. WHAT INFORMATION DO WE COLLECT?
  2. HOW DO WE USE YOUR INFORMATION?
  3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
  4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
  5. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
  6. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
  7. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?
  8. HOW LONG DO WE KEEP YOUR INFORMATION?
  9. HOW DO WE KEEP YOUR INFORMATION SAFE?
  10. DO WE COLLECT INFORMATION FROM MINORS?
  11. WHAT ARE YOUR PRIVACY RIGHTS?
  12. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
  13. DO WE MAKE UPDATES TO THIS POLICY?
  14. HOW CAN YOU CONTACT US ABOUT THIS POLICY?

WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

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.
We collect personal information that you voluntarily provide to us when you:

If you use a social media platform or your mobile device (or other method of communication) to interact with TapClicks, the communication method or application may have a specific privacy policy that governs the use of Personal Information. We do not ensure that 3rd party providers honor their specific privacy policies.

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: Some information – such as IP address and/or browser and device characteristics – is collected automatically when you visit our websites.

We automatically collect certain information when you visit, use or navigate the Sites. This information does not reveal your specific identity (like your name or contact information) but may include IP address; profile information; aggregate user data; preferences; technical session information; browser type; information about your computer, hardware, software, or mobile device, including a device identifier; demographic information including gender, zip code and age; and navigational data including log files, server logs, clickstream data, and other data such as your location, where enabled, and language preference. User IP addresses are recorded for security and monitoring purposes. If you arrived at our website via a link from another webpage, we may receive aggregate or otherwise anonymous statistical information about your visit to our site. We monitor customer traffic patterns and site usage to help us develop the design and layout of the site, and to improve the content of our website to better match the interests of our website users. We may combine this automatically collected and other Non-Personal Information with Personal Information, in which case we will treat the combined information as Personal Information under this Privacy Policy.

Information collected from other Sources
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).

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:
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:

DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is available at allaboutcookies.org.

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.

We will use the information to gather statistical and other information necessary to utilize all of the features of our Platform. We obtain this information through the use of API’s, data transfer connections between our Platform and your third-party data providers. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party data provider. We recommend that you review their privacy policy to understand how they collect, use and share your personal information, and how you can set your privacy preferences on their sites and apps.

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.

If you are a resident in the European Economic Area, then these countries may not have data protection or other laws as comprehensive as those in your country. We will however take all necessary measures to protect your personal information in accordance with this privacy policy and applicable law.

Privacy Shield Framework. TapClicks complies with the EU-U.S. Privacy Shield Framework and the Swiss–U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Information transferred from the European Union and the United Kingdom and/or Switzerland to the United States, respectively. If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, please visit: https://www.privacyshield.gov/ and to view our EU-U.S. and Swiss-U.S. Privacy Shield Certification – click here.

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.

Requesting and/or limiting use of data. In addition to the rights provided in this Privacy Policy, please note the following: Because TapClicks personnel have limited ability to access data that our customers submit to our Services, if you wish to request access, to limit use, or to limit disclosure, please provide the name of the TapClicks customer who submitted your data to our Services. We will refer your request to that customer, and will support them as needed in responding to your request.

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

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.

HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy policy unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this policy will require us keeping your personal information for longer than [90 days/6 months/1 year/2 years/the period of time in which you have an account with us/90 days past the termination of your account/6 months past the termination of your account/1 year past the termination of your account/2 years past the termination of your account.

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.

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.

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 legal@tapclicks.com, so that we may delete the information.

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 customercare@tapclicks.com.
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: legal@tapclicks.com or write to us:

TapClicks, Inc.
ATTN: Legal Department
3031 Tisch Way, Suite 900
San Jose, CA 95128

Cookies and similar technologies:
What are cookies?
Cookies are text files placed on your computer to collect standard Internet log information and visitor behavior information. When you visit our websites, we may collect information from you automatically through cookies or similar technology.

How do we use cookies?

What types of cookies do we use? There are a number of different types of cookies, however, our website uses:
Managing cookies
Most Web browsers are set to accept cookies by default.

You may set your browser to block all cookies, including cookies associated with our Services, or to indicate when a cookie is being set by us. However, it’s important to remember that many of our Services may not function properly if your cookies are disabled. For example, we may not remember your language preferences. For more information about cookies and how to opt out of cookie functionality using your browser, Cookie Policy.

Some web browsers and mobile device operating systems offer Do Not Track (DNT) settings. Currently, there is no industry standard for offering or responding to this setting. As a result, TapClicks may not respond to DNT settings. Other third party sites may or may not respond to DNT signals. If you would like to learn more about these browser settings, click here. If you want to turn on these settings for your web browser, you may click: here for Google Chrome or here for Safari.

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.

TapClicks, Inc
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.

DO WE MAKE UPDATES TO THIS POLICY?

In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws.

TapClicks reserves the right to modify this Privacy Policy at any time, and we encourage you to review it frequently. Modifications will be posted to the Privacy Policy on the TapClicks website. If we make any material changes, we will notify you by means of notice on the website when a change is made. Your continued use of the Services signifies your acceptance of our Privacy Policy as modified.

HOW CAN YOU CONTACT US ABOUT THIS POLICY?

If you have questions or comments about this policy, contact us via email at customercare@tapclicks.com, or by post to:
TapClicks, Inc
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 juliet.oury@ocsolicitors.com or contact us by post at:
Oury Clark Solicitors
10 John Street,
London, WC1N 2EB


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