Website Privacy Policy

Introduction

We from Tappa, Inc. (“Tappa”, “we”, “our”, “us”) recognize the need to protect and properly manage the personal information collected and processed by us. This Privacy Policy will help you understand what types of information we may collect on the users (“You”) of our website (the “Site”), how this information may be used, with whom the information may be shared, and what rights holders have concerning the protection of their personal data.

This Privacy Policy does not apply to information collected through use by customers of the Tappa Platform service, which is described under our Tappa Platform Privacy Policy.

Who We Are

In regard to the processing of your data, Tappa, Inc. acts as the controller. Our company is located at 43 West 29th Street, 4th Floor New York, NY 10001, USA. Our EU representative under the GDPR is Tappa Ops (Ireland) Limited.

How to Contact Us

For customer support, please email support@tappa.com.

For all data privacy matters, please contact our Data Protection Officer (DPO) at dpo@tappa.com.

How We Collect Your Information

We collect personal data about you in the following instances:

a) When you voluntarily give it to us: We may collect information when you contact or request information from us through our online forms when you interact with us, and give us your testimonials through our social media profiles or directly on our Site. We may also collect information when you submit your CV and when you engage in a commercial relationship with us. 

b) When other people give it to us: We may collect information from advertising and marketing partners in order to monitor, manage and measure ad campaigns. We also may collect information that is publicly available.

c) We may collect browsing data automatically when You visit our Site.

Which Information We Collect About You 

We may collect the following information from You:

When you contact us to request information or when you are interested in the services we offer, we may collect information contact information such as first name and surname, email address, telephone number(s), and address.

When you contact us interested in working with us, we may collect information such as contact information, employment history, professional qualifications, and any other information provided through the CV.

When you visit our Site, we may collect browsing information which is detailed in our Cookies Notice.

We do not knowingly collect data from children. If a parent or legal guardian learns that a child provided us with personal information, please contact us, and we will make commercially reasonable attempts to delete such personal information.

For Which Purposes We Collect Your Information

We use the information we hold about you for the following purposes and on the following legal bases: 

a) Reply to your inquiries and respond to your requests - Justified based on our legitimate interest in offering You our services.

b) Provide You with our services and administer and manage our relationship with you - Performance of a contract with you.

c) Gather statistical information from Site users and analyze for trends - Justified based on our legitimate interest to improve your experience when navigating through our Site and to improve our services.

d) Provide you with news and information related to our services and products that we believe may interest you - Justified based on our legitimate interest in offering you our services.

e) Evaluate your candidacy when you submit your CV to us - Performance of a contract with you.

f) Provide government agencies with information when required by law  - Necessary for us to comply with our legal obligations.

g) We may also collect your information in our legitimate interest to prevent fraud or harm to us or to any third party and ensure the security of our network and services.

Who We Share Your Information With 

We commit not to sell any personal information to third parties. However, we may disclose personal data to third parties if you consent to us doing so, as well in the following circumstances:

a) Our entities within the Tappa, Inc. group of companies;

b) Our third-party services providers, suppliers and partners that assist in providing our Services, such as system hosting, management, support, and data analysis;

c) Credit or reference providers or debt collection companies;

d) Our professional advisors, including lawyers, consultants, accountants, auditors and insurers;

e) Possible acquirers or investors (and our and their advisors) in the context of facilitating or implementing a business reconfiguration or reorganisation or a transfer or sale of all or part of our assets or business, including, but not limited to a divestiture, acquisition or business reconfiguration. Alternatively, we may seek to acquire other businesses or merge with them;

f) Competent governmental and public authorities, in each case, to comply with legal or regulatory obligations or requests.

Some of the service providers mentioned above may be located abroad, and, in this case, we adopt additional safeguards to guarantee an adequate level of protection for your personal data.

Transfer of Your Information

We from Tappa, Inc. will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy, and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information. 

In accordance with the GDPR, when we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring that we use specific controls approved by the European Commission, which give personal data the same protection it has in Europe.

How We Protect Your Information

To ensure that your personal information is secure, we communicate our privacy and security guidelines to all Tappa, Inc. employees and business partners and strictly follow precautionary measures regarding privacy within the company.

We strive to protect your personal information through physical, technical and organizational measures aimed at reducing the risks of loss, misuse, unauthorized access, disclosure and improper alteration of this data.

We make commercially reasonable efforts to ensure the security of our systems. However, please note that this is not a guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical technical or managerial safeguards. If we learn of a security systems breach, then we may attempt to notify you electronically so that you can take appropriate protective steps. We may post a notice on our Site or through other forms of communication.

How Long We Retain Your Information

We have determined retention periods based on the purpose of the processing and the rules set forth within the GDPR, as well as the legal and business requirements. For example, the GDPR requires us to remove data when it has served its purpose and is no longer of use. We review the personal data we regularly collect to ensure that the personal data we have is up-to-date and is not retained longer than needed or required by the regulation.

If you wish to have more detailed information about our retention times, please contact us at dpo@tappa.com.

Cookies

We use cookies and other similar technologies to collect data on how our website is used. Through this analysis, we are able to improve and optimize our website user experience. For example, we get information on which service pages you go to, what blog texts you might be interested and how you navigate between the pages. In order to develop our website, it is important to know what kind of website content is most efficient and functional; this way, we know what stays, what goes and what needs to be tweaked. The data we collect also helps us personalize services and marketing to you. We can, for example, define our customer personas and share content with you that you really respond to or might prove more useful. You can always disable cookies altogether in the browser settings, or you can delete cookies from the browser and disable all targeted advertising and communication based on your previous visits on our website.

For more information, please check our Cookie Notice.

Your Rights

Under the law, you are granted certain fundamental rights when data about you is being processed. We will ensure to reach out without undue delay (no more than 30 days) when you submit a request related to exercising your data subject rights. Although uncommon, when applicable for official or legal reasons, we may be unable to address the specific request you make related to your rights.

Also, if a request is manifestly unfounded or excessive, we may either:

• charge a reasonable fee taking into account the administrative costs of providing the information or communication or taking action requested; or

• refuse to act on the request.

In this scenario, will we inform you of the reasons we believe your request is the manifestly unfounded or excessive character of the request.

As a data subject, you have the right to:

• The right to request confirmation of whether we process Personal Data relating to you, and if so, to request a copy of that Personal Data;

• The right to request that we rectify or update your Personal Data that is inaccurate, incomplete, or outdated;          

• The right to request that we erase your Personal Data in certain circumstances provided by law;

• The right to request that we restrict the use of your Personal Data in certain circumstances, such as while we consider another request that you have submitted (including a request that we make an update to your Personal Data);

• The right to request that we export your Personal Data that we hold to another company, where technically feasible;

• Where the processing of your Personal Data is based on your previously given consent, you have the right to withdraw your consent at any time; and/or:

  • In some cases, you may also have the right to object to the processing of your Personal Data.

  • The right to non-discrimination is based upon your exercise of these rights.

If you feel that you have not received a satisfactory response from us, you may have the right under applicable laws to consult with the data protection authority in your country.

For your protection, we may need to verify your identity before responding to your request, such as verifying that the email address from which you send the request matches the email address that we may have on file. In some cases, we may need to collect additional information to verify your identity, such as a government-issued ID. You may personally exercise these rights or appoint a legal representative to make requests on your behalf.

If we no longer need to process Personal Data about you in order to provide our Services or our Sites, we will not maintain, acquire or process additional information in order to identify you for the purpose of responding to your request.

If you wish to exercise your rights, or if you have any other questions relating to your rights or this privacy statement, please contact us at dpo@tappa.com. 

You may also make such a request by writing to us at:

Attn: Data Protection Office

43 West 29th Street, 4th Floor

New York, NY 10001

You also have the right to lodge a complaint with a supervisory authority.

You can find a list of Supervisory Authorities here.

Modifications to This Privacy Policy

Tappa, Inc. reserves the right to change this Privacy Policy at any time by posting revisions on this web page. Such changes will be effective upon posting and the current version published on our website shall apply.

Please revisit this page to stay aware of any changes. If the Privacy Policy is part of an agreement with you, we will notify you by e-mail or other appropriate means in case of an amendment.