Privacy Policy

This policy explains what you can expect from us and what we need from you in relation to your personal data. Please read this carefully as this policy is legally binding when you use our Platform and Services.

Welcome to our Platform, we provide a personal finance platform to encourage users to set goals, monitor spending and increase their savings, integrate all bank and finance accounts under one login and create a personal financing plan and monitoring (the "Services"). Our Services available via website located at https://taptop.co.uk/home and TapTop mobile app (the "App") (jointly referred to as "Platform"). The Site, App and Services are owned and operated by TAPTOP FINTECH LTD ("Company," "TapTop," "we," "us").

We will be transparent with you about why and how we collect data.

PLEASE READ THIS PRIVACY POLICY CAREFULLY. BY ACCESSING OR USING THE PLATFORM AND SERVICES, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTAND, AND AGREE TO BE BOUND BY ALL THE TERMS OF THIS PRIVACY POLICY AND OUR TERMS AND CONDITIONS [link to]. BY ACCESSING OR USING OUR PLATFORM AND SERVICES, YOU SIGNIFY YOUR UNDERSTANDING OF THE TERMS SET OUT HEREIN.

We are committed to respect and protect the privacy of the personal information we obtain from you through our Platform and use of the Services and we have created this Privacy Policy to inform you about how we collect, use and share your personal information, and about our privacy practices in general.

Our Platform uses cookies and similar technologies. We have a separate Cookie Policy[link to], where we describe what cookies we use and for what purposes.

We are always ready to address your questions and concerns regarding this Policy and our privacy practices. If you would like to contact customer service, please contact us at the email address at the end of this Policy.

We continually strive to find new ways to enhance your experience with the Services and we may modify this Privacy Policy from time to time to reflect changes in our privacy practices. You are encouraged to review this Privacy Policy periodically and to check the "Effective Date" at the top of the Privacy Policy for the most recent version. If we make changes to this Privacy Policy, we will notify you here and in our sole discretion, by means of notice through the Platform.

For the purpose of the relevant data protection regulations, TAPTOP FINTECH LTD is the “Data Controller” of your Personal Data. Registered office address 167-169 Great Portland Street, Fifth Floor, London, England, W1W 5PE, company number13081681.

Data Processing

The Personal Data we gather from you helps us learn about your visit to the Platform or use of the Services. We use this information to provide the Services to you, to better tailor the features, performance and support of our products and services, to answer your requests, questions and concerns, and to offer you additional information and opportunities. Thus, we use your personal information for business purposes.

"Personal Data" is any information that allows us (or others) to identify an individual person and would include (for example) your name, username, address, email address, IP address or phone number, location, image, as well as other non-public information that is associated with or directly linked to such information.

Non-personal "Usage Data" is anonymous data about your use of the Platform that is tied to your computer and/or device through which you use the Platform.

Personal Data that We Collect

TapTop collects information about you, including information that directly or indirectly identifies you. We receive information in multiple ways, including when you record an activities using the Service. TapTop also collects information about how you use the Platform and Services. There are also several opportunities for you to share information about yourself and your activities with TapTop. Some examples are listed below.

Account information. We collect information such as name, email address, username, country and language to help us secure access to TapTop if you create an account. If you used your email address, we keep a record of your email to be able to identify you.

Verification. Information you provide for identity verification purposes, including your legal name, personal ID, passport, utility bill, date of birth, etc. We may also request video or photo verification as required by applicable law. As a result of money laundering regulations, we may need to verify the source of the funds which you are pay or investing via our Platform. We may therefore collect from you any of the following as evidence - a copy of your bank statement/ savings account statement, payslip, for example.

Usage information. We collect information about when you choose to work out (including date, time, exercise information, etc.), or otherwise use of the Platform and Services.

Financial information. Upon given consent we collect financial information such as bank accounts, funds, transaction statistics, payment reason, other information obtained with your consent from financial institutions, etc. This information will be used during our Service usage and to give an overview of your statistics.

Third-Party Accounts. If you choose to sign up and log in to the Platform using accounts you created with third-party services such as Sign in with Facebook, Apple or Google (collectively, Third-Party Accounts”) we will collect information that you agreed to make available such as name, email address and profile information. This information is collected by the Third-Party Account provider and is provided to the Company under their privacy policies. You can generally control what information they share with us by using their privacy settings.

Contact information. If you chose to provide us with your contact information, for example by emailing us, we will use this to respond to support requests and comments.

Use across our Services. We may combine information we collect from you with information obtained from other users, third parties and information derived from any other subscription, product or service we provide.

Technical information. We collect technical information from the devices and browsers you use to access TapTop. This information is used to analyse trends and protect and secure TapTop. The information collected includes network information; including operating system, browser, IP addresses, timestamps, log files, etc.

Cookies

Our Platform use cookies to distinguish you from other users. This helps us to provide you with a good experience and also allows us to improve our Platform and Services. For detailed information on the cookies we use and the purposes for which we use them see our Cookie Policy [link to].

Use of the Personal and Usage Data that We Collect

We use, process, and store your Information as necessary to perform our contract with you and for our legitimate business interests, including:

• To help us provide and administer our Platform and Services, authenticate users for security purposes, provide personalized user features and access, process transactions, conduct research, develop new features, and improve the features, algorithms, and usability of our Platform and Services.
• To communicate with you about your use of our Platform and Services, product announcements, and software updates, as well as respond to your requests for assistance, including providing account verification support if youre having difficulty accessing your account.
• To send you direct marketing emails and special offers about TapTop, from which you can unsubscribe at any time.
• To display user content associated with your account.
• To calculate aggregate statistics on the number of unique devices using our Platform and Services, and to detect and prevent fraud and misuse of those.

Usage Data may be used by us for administrative, analytical, research, optimization, security and other purposes. Specifically, we may use your Usage Data to help us learn more about your activities, personalize your content, compile statistics, respond to customer service inquiries, provide security and otherwise enhance your experience. Usage Data may also be used to help us provide you with advertising that better suits your interests.

Geolocation information will be used to determine the jurisdiction in which you're located so we can determine what set of laws apply to you.

Your device ID may be used so we can send you to push notifications (if you choose to allow that function) and track your use of our Platform so that we can better understand your preferences and tendencies which will help us best personalize your experience and provide you offers and notifications that are tailored to you.

Service Providers

We may employ third party companies and individuals to facilitate our Service (Service Providers”), provide Service on our behalf, perform Service-related services or assist us in analysing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Analytics

We may use third-party Service Providers to monitor and analyze the use of our Service.

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualise and personalise the ads of its own advertising network.

For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en

We also encourage you to review the Google's policy for safeguarding your data: https://support.google.com/analytics/answer/6004245.

Behavioral Remarketing

TapTop uses remarketing services to advertise on third party websites to you after you visited our Service. We and our third-party vendors use cookies to inform, optimise and serve ads based on your past visits to our Service.

Google Ads (AdWords)

Google Ads (AdWords) remarketing service is provided by Google Inc.

You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads

Google also recommends installing the Google Analytics Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.

For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en

Twitter

Twitter remarketing service is provided by Twitter Inc.

You can opt-out from Twitter's interest-based ads by following their instructions: https://support.twitter.com/articles/20170405

You can learn more about the privacy practices and policies of Twitter by visiting their Privacy Policy page: https://twitter.com/privacy

Facebook

Facebook remarketing service is provided by Facebook Inc.

You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950

To opt-out from Facebook's interest-based ads, follow these instructions from Facebook: https://www.facebook.com/help/568137493302217

Facebook adheres to the Self-Regulatory Principles for Online Behavioural Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.

For more information on the privacy practices of Facebook, please visit Facebook's Data Policy: https://www.facebook.com/privacy/explanation

Payments

We may provide paid products and/or services within Service. In that case, we use third-party services for payment processing (e.g. payment processors).

We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

Verification

We need conduct identity verification or KYC procedures before or during usage of our Service. In that case, we may use third-party services for this reasons.

We will not store or collect your ID details or other information unless required by applicable law. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their privacy policies.

Data Storage and Retention

Information submitted to the Company will be transferred to, processed, and stored in the United Kingdom, EU (EEA) and outside. When you use the Services on your computing device, the user content you save will be stored locally on that device and synced with our servers. If you post or transfer any information to or through our Platform and Services, you are agreeing to such information, including Personal Data and user content, being hosted and accessed in the United Kingdom, EU (EEA) and outside. Please note that the applicable privacy laws may be different from the privacy laws applicable to the place where you are resident.

We take measures to delete your Personal Data or keep it in a form that does not permit identifying you when this information is no longer necessary for the purposes for which we process it unless we are required by law to keep this information for a longer period. When determining the specific retention period, we take into account various criteria, such as the type of service provided to you, the nature and length of our relationship with you, and mandatory retention periods provided by law and the relevant statute of limitations.

Transfer of Data

Your information, including Personal Data, may be transferred to and maintained on – computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside European Economic Area (EEA) and choose to provide information to us, please note that we transfer the data, including Personal Data, to EEA and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

TapTop will take all the 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 organisation or a country unless there are adequate controls in place including the security of your data and other personal information.

Disclosure of the Personal Data

We may transfer your Personal and Usage Data to our affiliated entities, but such information shall continue to be governed by this Privacy Policy.

Except as otherwise stated in this Privacy Policy, we do not trade, rent, or share your Personal Data with third parties and we will not disclose financial information that is part of your Personal Data unless you ask us to do so.

We may share your Personal Data with third-parties to provide you with the products and services that we offer you through the Platform for payment processing, shipping and distribution processing, account inquiries, and marketing analytics. These third parties are required not to use your Personal Data other than to provide the products and services requested by the Company and are bound by confidentiality agreements with regard to their use of such information.

You expressly consent to the sharing of your Personal Data with our contractors and third-party service providers for the purpose of providing products, services and interest-based advertising to you.

Usage Data in aggregated, anonymous form may be shared with third parties who assist us with our internal operations such as administration, analytics, research, and optimization.

If another company acquires our company or our assets, that company will possess the Personal Data collected by us and it will assume the rights and obligations regarding your Personal Data as described in this Privacy Policy.

Regardless of any choices you make regarding your Personal Data (as described below), we may disclose your Personal Data if we believe in good faith that such disclosure is necessary to (a) comply with relevant laws or to respond to subpoenas or warrants served on the Company; (b) to protect and defend the rights or property of the Company, our users and/or others; (c) lawful requests by public authorities, including to meet national security or law enforcement requirements; (d) take action against illegal activity, suspected abuse; (e) unauthorised use of the Platform.

Your Privacy Rights

Upon request, the Company will provide you with information about whether we hold any of your personal information. You may access, correct, or request deletion of your personal information by logging in to your account and updating your personal information and confirming it by selecting the ‘Save’ button or contacting us at [your email address]. We will respond to your request within a reasonable timeframe.

Your principal rights under data protection laws in the EEA are

• the right to access;
• the right to rectification;
• the right to erasure;
• the right to restrict processing;
• the right to object to processing;
• the right to data portability;
• the right to complain to a supervisory authority;
• the right to withdraw consent.

You have the right to confirmation as to whether we process your Personal Information and, where we do, access to the Personal Information, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of Personal Information concerned and the recipients of the Personal Information. Providing the rights and freedoms of others are not affected, we will supply you with a copy of your Personal Information. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.

You have the right to have any inaccurate Personal Information about you rectified and, considering the purposes of the processing, to have any incomplete Personal Information about you completed.

In some circumstances, you have the right to the erasure of your Personal Information without undue delay. Those circumstances include the Personal Information are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes, and the Personal Information has been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.

In some circumstances you have the right to restrict the processing of your Personal Information. Those circumstances are: you contest the accuracy of the Personal Information; processing is unlawful but you oppose erasure; we no longer need the Personal Information for the purposes of our processing, but you require Personal Information for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection.

Where processing has been restricted on this basis, we may continue to store your Personal Information. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

You have the right to object to our processing of your Personal Information on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

You have the right to object to our processing of your Personal Information for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your Personal Information for this purpose.

You have the right to object to our processing of your Personal Information for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation unless the processing is necessary for the performance of a task carried out for reasons of public interest.

To the extent that the legal basis for our processing of your Personal Information is:

• consent
• that the processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your Personal Information from us in a structured, commonly used and machine-readable format.

However, this right does not apply where it would adversely affect the rights and freedoms of others.

To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection.

You may access your personal information that we hold by contacting us using the contact details below. We will provide you with a copy of the personal information we keep about you. However, we reserve the right to charge you a reasonable amount for providing copies of any personal information you request, to take into account the time, cost and effort involved. You may request that the personal information we hold about you be corrected by contacting us.

If we do not agree to your request for a correction, you may then request that we take reasonable steps to attach to the information a statement of the correction sought but not made.

Please be aware that some of these rights may be limited or unavailable where we have an overriding interest or legal obligation to continue to process the data, or where data may be exempt from disclosure.

Please note that we will try to verify your identity via the email address or other information such as the phone number that is associated with your request before deleting your account and your personal information. If another person makes this request on your behalf, please note that we will verify your identity and require them to prove that they have your written authorization to make the request on your behalf.

Minors

Our Service for general public, but we do not allow use by persons under 18.

While the Platform may be visited by children, we do not knowingly collect or use any Personal Information from children under the age of 13 and hereby specifically prohibit any user under the age of 13 from providing us with any Personal Information. If you are a parent of a child under 13 years of age and you believe your child has provided us with Personal Information, please contact us at [your email address] and we will delete the information from our IT system.

Security

It is entirely your choice whether or not you provide Personal Information to us. We and/or our third-party partners have put in place physical, electronic, and managerial procedures to attempt to safeguard and help prevent unauthorized access, maintain data security, and correctly use the Personal Information collected through the Platform. We take or obligate applicable third parties to take, reasonable precautions to protect our customers' Personal Information against loss, misuse, unauthorized disclosure, alteration, and destruction.

However, please remember that no transmission of data over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your Personal Information, we cannot ensure or warrant the security of any information that you transmit to us or from us, and you do so at your own risk. We cannot ensure or warrant the security of any information you transmit to us by email and you do so at your own risk.

When we use third parties to assist us in processing your Personal Information or credit card information, we take reasonable steps to require that they comply with this Privacy Policy and otherwise protect your Personal Information (including any credit card information).

If there is a breach of security involving your Personal Information from our Platform, we will inform you immediately and take commercially reasonable steps to rectify such breach.

If you believe your Personal Information is being improperly used by us or any third party, please immediately notify us via email at [your email address]

In the event you choose to establish an account with us, you should not share your login information with anyone.

Please note, this right is subject to certain exceptions, including if we need to comply with a legal obligation or complete a transaction for which we collected the information.

We are compliant with all applicable laws and regulations applicable to the processing of data, including the EU Regulation 2016/679 (the “GDPR”) and the Data Protection Act 2018 on the protection of natural persons with regards to the processing of personal data.

External Sources

Our Platform may link to external websites beyond our control. This Privacy Policy covers only the way we treat the Personal Information and Usage Data we collect on our Platform. By accessing any external websites, you are agreeing to the privacy policies of those websites.

Please note that the external websites may have different policies with respect to the collection, use and disclosure of your Personal Information. We have no control over and are not responsible for the privacy practices of such third parties. Therefore, you are encouraged to review the privacy policies of all third-party websites or apps. Without limiting anything in the following section, we are not liable in any way for the actions, inactions or policies of any external websites or apps.

Governing Law

This Policy shall be exclusively governed by and interpreted in accordance with the laws of the England and Wales, and any dispute hereunder shall be brought exclusively in the courts located at London, UK except where prohibited by UK laws.

Contact Us

If you:

1. have any questions, queries, inquiries or comments on our Privacy Policy;
2. have any concerns about how we process your Personal Information;
3. would like to opt-out of direct marketing activities;
4. would like us to update information or preferences you have provided to us;
5. have any other issues relating to this privacy policy, you may get in touch with us at hello@taptop.co.uk

If you feel that we have not addressed your questions or concerns adequately, you may make a request with the Information Commissioner's Office (UK).