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PRIVACY POLICY OF THE TAPINREACH

Revised on September 29th, 2023

  1. INTRODUCTION
  2. TERMS AND DEFINITIONS
  3. GENERAL PROVISIONS
  4. PURPOSES OF DATA COLLECTION AND PROCESSING
  5. THE VOLUME OF PROCESSED DATA
  6. PROCEDURE AND CONDITIONS FOR PROCESSING PERSONAL DATA
  7. COOKIES AND OTHER TRACKING TECHNOLOGIES
  8. HOW THE DATA IS STORED AND PROTECTED
  9. THE USER'S RIGHTS
  10. FINAL PROVISIONS
  11. CONTACT US
  12. HOW TO CONTACT THE APPROPRIATE AUTHORITY

1.Introduction

1.1. This Privacy policy of the Tapinreach (hereinafter referred to as the “Privacy policy”) is made for the purposes to set and define terms of processing of personal data of users of the website http://www.tapinreach.com (hereinafter referred to as the “Tapinreach” or the “Platform”) that is created, developed and operated by Tap-Talents Inc. (Tax ID (EIN) 320739839) (hereinafter referred to as the “Service provider”, “we”, “us”) – a legal entity incorporated under the laws of the State of Delaware, United States of America with registered address at: 1007 N Orange St., 4th Floor, Suite #2185, Wilmington, Delaware 19801, United States of America.
1.2. This Privacy policy is to be considered both as a separate agreement and as an integral part of the User agreement of the Tapinreach that is available via the following link https://tapinreach.com/user_agreement_en (hereinafter referred to as the “User agreement”) for you and users of the Platform who accepted the User agreement and continued using the Tapinreach. This Privacy policy contains terms that are used in their meanings and definitions set both in this Privacy policy and in the User agreement and in the event of any conflict between the provisions or terms meanings and definitions of the named documents the provisions and terms meanings and definitions of this Privacy policy for purposes of personal data processing regulation shall prevail.
1.3. For the purposes of developing and improving processes of provision services the Service provider constantly improves the Platform and reserves the right to add, change, replace or revise provisions of this Privacy policy which are to be read, understood and accepted by all the users of the Platform. The new versions of this Privacy policy come into force from the moment they are published on the Platform.
1.4. If You do not agree, understand and accept this Privacy policy and / or any provisions of this Privacy policy and / or changes due the clause 1.3 of this Privacy policy and / or you are not compliant with the age terms of usage the Platform set in the clause 3.3 of the User agreement, you shall not use the Platform and / or any features and services offered or executed on the Platform, leave the Platform immediately and uninstall / delete the Platform’s program components from your device.
1.5. If you have undisclosed in this Privacy policy and the User agreement questions about any term or provision of this Privacy policy, the Platform, the Service provider and / or the Services you can contact us by submitting a request via info@tapinreach.com.
1.6. If You are acting on behalf of a legal entity You must comply with the provisions of clause 3.9 of this Privacy policy.

2. Terms and Definitions

“Account” – a unique account created for and or by the User on the Tapinreach to access the Platform and the Services on terms of this User agreement. The option of creating (registering) the Account on the Platform is used as a temporary promotional marketing tool and may be restricted on the Platform on the Service provider sole decision and this restriction may not be considered as a breach of this User agreement.
“Cookies” – text files that are placed on your computer, mobile device, a digital tablet or other device as a result of using the Platform, they contain the details of your browsing history as You are browsing on website. Cookies are processed and stored by your web browser, they are harmless for the functionality of device and serve crucial functions for websites. Generally the Cookies can be easily managed - viewed and deleted.
“Device” – any device that can access the Tapinreach such as a computer, a mobile device, a digital tablet or other device.
“Data” (also the “data, “information” (in relation to the User)) – any information relating to (i) an identified or identifiable natural person (“data subject”) – who can be identified, directly or indirectly, in particular by reference to an identifier such as a full name (nickname, informal designations), date of birth, an identification number, phone number, location data, occupation, gender, photos, email address, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person; or (ii) technical and related information that is not personally identifiable, including, but not limited to, the operating system type and version, origin and nature of identified malicious system threats, and the software modules installed on an endpoint device. The term “Data” includes personal data, non-personal data and personally identifiable information.
“Processing” – any operation or set of operations which is performed on Data whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
“Services” – services offered, performed or executed on the Tapinreach regardless by the Service provider, by the Partners or by third parties.
“Usage data” refers to a data that is to be collecting automatically via the Platform, either generated by the use of website or from the website structure itself (e.g. the duration of a web page visit).
“You” (also “you”, the “User”) – the individual, or the company, or other legal entity on behalf of which such individual is accessing or using the Platform.

3. General Provisions

3.1. This Privacy policy defines the Service provider’s of the Tapinreach policies regarding the processing the Data that was provided to the Tapinreach.
3.2. This Privacy policy is publicly available on the Service provider’s official website: http://www.tapinreach.com.
3.3. This Privacy policy defines characteristics of data that the Service provider collects and how the Service provider uses, processes, discloses, shares, transfers, stores and protects Data obtained while the Users accessing the Platform.
3.4. You should fully and attentively read this Privacy policy before using the Tapinreach and providing your Data to the Service provider and / or on the Platform and make sure that You acknowledge, understand and consent to all its terms. While using the Tapinreach and filling out any forms and / or providing the Data to the Service provider the User shall mean full and unconditional acceptance by the User of all terms of this Privacy policy. In the event if You do not fully understand and / or do not fully accept terms of this Privacy policy or changes, additions and / or amendments thereto, You should immediately stop using the Tapinreach and / or to contact the Service provider as set in section 11 of this Privacy policy – “Contact us” – for receiving further instructions. By using the Platform and our services you agree to collection and use of your personal data and the Data in accordance with this Privacy policy.
3.5. The Service provider keeps this Privacy policy under a regular review and makes changes related to working practices or regulatory changes or the inner operational and service development reasons of the Platform. The Service provider places the named corresponding updates on the Tapinreach. The Service provider will notify the User at its sole discretion of the addition and / or modification of the Privacy policy in the manner that the Tapinreach deems most appropriate about all changes and amendments to the Privacy policy via pop-up windows and / or notifications on the Platform and / or by email.
3.6. The Service provider gives the User access to the Platform and to the Services on terms of the User agreement based on condition that the User shall acknowledge and comply with every change to this Privacy policy when using the Platform after those changes posted. Further use of the Platform, materials and functions offered on it at any time means (including by simply accessing and reviewing it) means for the Service provider that You have unconditionally accepted and agreed with any alterations made to this Privacy policy and with current version of this Privacy policy whole or in part, if You did not or changed Your mind – please stop using the Platform immediately and request the Service provider to delete Your account via email info@tapinreach.com and stop using the Tapinreach until this account is deleted.
3.7. By using the Platform the User fully and unconditionally accepts this Privacy policy, including by downloading, installing, using the Platform, providing the Data and other information to the Servce provider via any communication channel (e.g. email, any messenger, etc.) and filling out any forms posted on the Platform, the User confirms his consent to the Tapinreach processing of personal data and the Data and other information provided during registration or collected automatically, as well as provided by the User to other Users, Contractors, Partners and third parties, including, but not limited to User generated content: documents, photos, videos, images, drawings, comments, reviews, descriptions, revisions, design elements, sound files or links to third-party resources.
3.8. The Users acknowledge and agrees that it is his / her sole responsibility to review the Privacy policy periodically and become aware of any modifications and changes.
3.9. You shall acknowledge and agree that if You are acting as a legal entity representative it is Your sole responsibility to ensure having a corresponding sufficient and valid power of attorney or other document that is legitimately provide You with the rights to represent this legal entity in relationships with the Service provider, to accept this Privacy policy and to review this Privacy policy periodically and become aware of any modifications and changes and to accept them.

4. Purposes of Data Collection and Processing


4.1. The Tapinreach collects and / or processes personal data and the Data when the User accesses the Platform and the Services as defined in the User agreement, as also when using or otherwise interacting with the products and the Services offered on the Platform and in the corresponding Contracts on terms of this Privacy policy.
4.2. The Tapinreach collects and / or processes personal data and the Data for the purposes of registering the User on the Tapinreach, enabling its full use, providing the User with the Services, participating in research and marketing activities conducted by the Service provider.
4.3. The Tapinreach collects, stores and processes only the Data that is necessary for the provision of the Services on terms of the User agreement and corresponding Contracts (if they were concluded) to the Users or the performance of agreements and contracts with the User and / or the Partner, except in cases where the law provides for mandatory storage of personal data and the Data for a period specified by law, including for the purposes of:
4.3.1. identification;
4.3.2. providing the User with personalized services, facilities and performance of the Services due the corresponding agreements;
4.3.3. communication with the User, that means sending letters and notifications, requests and information related to the use of the Tapinreach and provision of the Services due the User agreement and corresponding Contracts and agreements (if applicable), as well as processing the User's requests and applications;
4.3.4. conducting statistical and other research based on depersonalized data;
4.3.5. distribution of advertising and information materials over communication networks, including through the use of phone, Internet, mobile radiotelephone communications, or through direct contacts;
4.3.6. conducting marketing campaigns for users, including for the purposes of distributing offers to participate in the promotion and receiving prizes / rewards provided for the promotion;
4.3.7. targeting newsletters, advertising materials and other information brought to the attention of the Users;
4.3.8. to resolve disputes and identify problems;
4.3.9. to prevent potentially prohibited and illegal actions as fraudulent activities, misuse of the Services.

5. The Volume of Processed Data

5.1. In the event when the User uses or accesses the Tapinreach, the User may provide and the Tapinreach may store and process the Data in volume set in its definition in this Privacy policy as part of execution of this Privacy policy and the User agreement.
5.2. The Service provider stores and processes data that is automatically transmitted to the Tapinreach in the background mode and by consent of the User in the course of using the Tapinreach by the software installed on the User's Device, including: IP-address of the Device, information from the Cookies, information about the User's browser or other program through which the facilities of the Tapinreach are accessed, geolocation, access time (e.g. local time and period of time), the address of the requested page, other data, including those provided by the User while and after creating the Account on the Tapinreach and accessing the Services.
5.3. There might be synchronized the User’s search history, settings and favorites in the User’s Account on the Tapinreach.

6. Procedure and Conditions for Processing Personal Data

6.1. The Tapinreach may use the User-provided information, including the Data, to ensure compliance with the requirements of applicable law (including for the prevention and / or suppression of Users' illicit and/or illegal actions).
6.2. The Tapinreach shall be entitled to:
6.2.1. carry out any operations (transactions) with the User's Data, whether automated or not, including gathering, copying, systematizing, accumulating, storing, clarifying (update, change), extracting, using, transferring (provision, access), and cases of disclosure due to national authorities requests (request of the court, law enforcement agencies, etc.), in accordance with information confidentiality requirements.;
6.2.2. use the Cookies, web beacons, pixel tags, transparent GIF files, JavaScript and local data storage and similar technologies to collect User's Data that can become personal identification information in combination with other information, in compliance with all necessary legal requirements regarding the privacy of the Users' Data by identifying Users and their representatives when it is applicable, counting and sorting them by the Service provider’s sole discretion and observing which pages of the Platform they visit. Providing customized information, remembering the User’s preferences for marketing and products, assisting users in finding the appropriate information (including for logging into specific Platform blocks or using their accounts), and analyzing the User’s behavior on the Tapinreach are all ways to ensure that the Users have the best possible experience. This includes making it simpler for the Users to find the information they need on the Tapinreach;
6.2.3. provide advertising messages and content by sending push or short-message-service (sms) notification messages, advertising notifications and messages via any communication channel provided by the User (e.g. email, any messenger, etc.) using the services and databases of both the Tapinreach itself and the services of third-party (external) services and resources on the Internet with full respect of General Data Protection Regulation (GDPR) rules;
6.2.4. communicate directly with the User, including by making phone calls and video calls.
6.3. The Data shall be processed upon the User’s acceptance of this Privacy policy and filling out the appropriate form for the purposes of provision the Services due the User agreement and / or the corresponding Contracts and agreements or provision of the Data in another form. The Data shall be stored until purpose of processing is achieved or the termination of the relationship between the Tapinreach and the User as a result of deleting the User’s Account or even of withdrawing consent by the User or an entity who provided such consent to processing the Data.
6.4. The Tapinreach may share your personal information with third party service providers when:
6.4.1. the User has expressed his consent to such actions due performance of corresponding Contract or other agreement signed by this User;
6.4.2. the User has independently openly shared the Data to be disclosed with other Users, including through the publication of user-generated Content due the terms of the User agreement or by choosing the «visibility for all» function (if applicable);
6.4.3. the transfer is required in order to access a particular Platform feature or service, and the user has been informed of it and has either consented to it or given the appropriate order;
6.4.4. the transfer is provided for by applicable law within the limits and purposes of the procedure established by law to satisfy the related authority’s request;
6.4.5. the transfer takes place as part of the sale or other transfer of rights for the Platform (in whole or in part), while all obligations to comply with the terms of this Privacy policy in relation to the information received by the acquirer are transferred to the acquirer.
6.5. Access to the Users' Data shall be possible within the Platform and the Service provider employees.
6.6. Without first receiving the User's consent, the Tapinreach shall not sell, lease, or divulge the Data to third parties for marketing purposes.
6.7. The Tapinreach shall make every reasonable effort to ensure that:
6.7.1. the Users’ Data is collected and processed by the Tapinreach only to the minimum required to provide the Services;
6.7.2. the Data is used exclusively for the purposes stated for its collection;
6.7.3. information about the Users is not transferred to third parties or disclosed, except as specified in this Privacy policy or by demand of applicable law;
6.7.4. the User’s Data is erased after the original goals of collecting are no longer relevant;
6.7.5. the Tapinreach shall store the User’s Data and protect it from unauthorized access and distribution in accordance with internal rules and policies;
6.7.6. the User's Data shall be kept confidential, except for cases set in this Privacy policy and when the User voluntarily provides information about himself or on his behalf for public access.
6.8. Due to the GDPR, the Service provider, who is both a controller and a processor, maintains the security and confidentiality of the Data when processing it in compliance with applicable legal requirements. To prevent unauthorized access, disclosure, distortion, or destruction of the information given by the Users to the Platform, the Tapinreach shall implement the necessary technological and operational security standards.
6.9. The Data is stored on the servers within the European Union. If the User's Account is removed or the Data is erased from the Platform for any reason, the corresponding Data will be kept by the Tapinreach for no longer than 30 (thirty) days in compliance with the User's entitlement to restore the corresponding Data. The duration specified in this clause is regarded as the shortest amount of time that may be achieved in order to complete all compliance checks and verify the User's will.
6.10. The User's data will be completely erased once the previously indicated term of storage has passed. The Data should be erased with certified software that guarantees destruction (in accordance with the predetermined properties for the installed software with guaranteed destruction).
6.11. Except in situations where non-automated processing of the User's Data is required for purposes associated with complying to the requirements of the relevant law, the Tapinreach shall only store and process the User's Data on servers using automated systems.
6.12. The User is aware that the Tapinreach is a resource run by an international business entity (the Service provider) that has operations in numerous nations throughout the world and does not object to this fact. It implies that the User’s Data may be moved to and kept on computers situated outside the User’s state, country or other governmental jurisdiction where the rules governing the protection of personal data may vary from the User’s jurisdiction. The User’s submission of such information signifies the User’s approval to such a transfer by acceptance of this Privacy policy that was followed.
6.13. No transfer of the User’s Data will take place to any organization or country unless there are adequate controls in place, including the security of the User’s Data and other personal information. The Tapinreach and the Service provider will take all steps reasonably necessary to ensure that the User’s Data are treated securely and in accordance with this Privacy Policy.

7.1. When You visit the Tapinreach, we may collect certain information from you automatically through cookies or similar technology and store and process it.
7.2. Cookies are text files that are downloaded to Your computer and used to store data such as visitor behavior and basic Internet log information. A cookie is used by the Platform to track the Users sessions and synchronize their responses to one form with those of other pertinent forms.
7.3. Cookies give the Tapinreach the ability to recognize Your Device as You and access various pages on the Tapinreach.
7.4. We To enhance the User’s experience on our website, we employ cookies in a variety of methods, such as:
- Keeping You signed in;
- Being aware how the User uses the Platform;
- Recognizing the User preferences to display information, choices, or features tailored to the User.
7.5. The Users have an ability to regulate cookies by configuring their browsers to determine how the platform uses cookies or to reject cookies, but doing so may prevent them from using all of the Platform's interactive features and make some features and Services inaccessible to them.
7.6. For further information on the Cookies we use, please see Cookies Policy of the Tapinreach via the following link www.tapinreach.com/cookies_policy_en.

8. How the Data is Stored and Protected

8.1. The Service provider takes the necessary organizational and technical precautions to maintain the security of the Data against accidental loss or destruction, unauthorized alteration, disclosure, or access, as well as against all other unlawful forms of processing.
8.2. However, we do remind You that no method of electronic storage or transmission over the internet is 100% secure. While the Service provider makes an effort to protect the User’s data with commercially reasonable measures, the Service provider cannot ensure its total security. The Service provider is storing the User’s Data on secure servers, sharing and granting access to it only as much as is necessary, subject to confidentiality restrictions when necessary, and whenever possible, anonymously. The Tapinreach also uses encryption technology to confirm the identity of anyone requesting access to the User’s information before granting them access.
8.3. To secure the User’s Data the Tapinreach holds on the following principles:
- confidentiality. Only a limited group of the Platform’s administrators who work on compliance and identity verification issues will have access to the User’s Data. All of our workers are held to strict confidentiality standards and any subcontractors or subprocessors who are not obligated to stick to strict confidentiality standards must sign a non-disclosure agreement.
Every time a legitimate employee has to access information, they can only do so via an protected connection. The IP-address of the User viewing the Data in a database must be pre-authorized in order to gain access.
Any device being used to access the Data has corporate antivirus software installed and is login protected by the service provider. Except when inactively used or moved under continuous monitoring, all on-site storage devices for the Data are always locked in a safe room. The Data is never kept on portable storage devices like DVDs and USB drives.
- transparency. The Service provider will always keep the Users up to date on any adjustments made to the procedures used to safeguard the security and privacy of the User’s Data, including the practices and policies. The User reserves the right to inquire at any time about the location, security, and use of the Data.
- integrity and isolation. To comply with the best standards for protecting confidentiality and data authenticity, the User’s Data transits are encrypted. By default, all access to the User’s Data is restricted. Only specifically authorized administrators are allowed access to the Data and they only get the minimal amount of access they require.
- the ability to intervene. The Service provider enables the User’s rights of access, erasure, rectification, blocking, and objection by providing the option to send instructions via the email address info@tapinreach.com or by informing and providing the Users with the option of objecting when the Tapinreach is preparing to implement changes to relevant practices and policies.
- monitoring. Security reports are used by the Service provider to keep track of the User behavior while granting access as well as to proactively identify and reduce security risks. To provide an audit trail in the event of unauthorized or unintentional changes, all administrative actions and system access are recorded. Services that monitor availability and performance of the Tapinreach’ features are used both internally and externally. In the event that the User's Data is compromised, Tapinreach will email the User and the appropriate Supervisory Authority within 72 hours (since the moment the breach was discovered) with details about the scope of the breach, the data that was affected, any effects on the Platform, and the Service Provider's action plan for steps to secure the personal data and limit any potential negative effects on the data subjects.

9. The User's Rights

9.1. The Tapinreach provides the User with the following rights:
- The right to request access to the User’s Data and information connected to our use and processing of the data listed in this sub-clause;
- The right to request the correction of any Data that the User considers to be inaccurate. Additionally, the User has the right to ask the Service provider to complete any information that the User feels is lacking;
- The right to erasure - under certain circumstances the User has the right to ask the Tapinreach to delete the User’s Data.
- The right to data portability, which allows the User to request the Tapinreach to transfer the User’s Data that had been collected to another organization or directly to the User under specific circumstances;
- The right to withdraw the User’s consent at any time at least 30 days before the anticipated date of termination of processing and using the Data. At the same time the named withdrawal of the User’s consent doesn’t have any bearing on the legality of how the Service provider used and processed the User’s Data up until the point where the withdrew the relevant consent.
-The User has the right to lodge a complaint with a supervisory authority in accordance with Article 77 of the GDPR.
9.2. If the User wants to file a request, the Service provider has 30 days to respond. If User would like to exercise any of the rights named above, the User needs to contact the Service provider as set in section 11 of this Privacy policy.

10. Final Provisions

10.1. Links to other information sources and services provided by third parties on the Internet may be found in the Tapinreach, these links are just provided for the Users' convenience. The Tapinreach does not express its endorsement of any products or information offered by third parties or the potential outcomes of using them, nor does it vouch for the veracity and applicability of the material provided. The User is solely responsible for any repercussions resulting from the usage of the services mentioned in this clause.
10.2. This Privacy policy shall apply only to the Platform and to the Services. The Tapinreach and the Service provider shall not control and can not be responsible for the services and offers of third parties to which the User can get access by clicking on external links available on the Platform and / or via email newsletters, including the protection of data and information provided by the User to those third parties.
10.3. The User shall independently and solely ensure the security (resistance to selection) and confidentiality of the means he selects to access the Account. In cases where the User voluntarily transfers any data and the Data for accessing the User's Account to third parties on any terms (including under contracts or agreements), the User shall be solely responsible for those actions (and their results) within or using the functionality of the Service under the User's Account. In this scenario, the User's Account shall be deemed to be used by the User to conduct all actions within or while using the Services on the Platform.
10.4. Data processors and subprocessors are required to comply with this Privacy policy and GDPR.
10.5. If You are under 18 years old, You cannot use the Platform and the Services and be a User. We do not knowingly and / or intentionally collect or storage information from anyone under 18 years old. If we become aware that a person under the age of 16 has provided us with personal information, we will delete it immediately.

11. Contact Us

11.1. If You have any questions about this Privacy policy, Your rights in relation to this Privacy policy, the data we hold on You, or You would like to exercise one of Your data protection rights, please do not hesitate to contact us via the communication channels specified on the Platform or via the following email: info@tapinreach.com, contact person (Data Protection Officer Ayodeji Olufemi): info@tapinreach.com. The data controller in respect to the Platform is the Service provider as we determine the purposes and means of the processing of the Data.
11.2. We shall make an effort to confirm your identification using that information if and when You seek access to Your data. We may require original or certified copies of specific documents in order to be able to authenticate Your identity before we are able to grant You access to Your information if it will not be possible to identify You from such information, or if we have insufficient information about You.

12. How to contact the appropriate authority

If You wish to report a complaint or if You feel that the Service provider or the Platform has not addressed Your concern in a satisfactory manner, You may contact the Information Commissioner’s Office: https://ec.europa.eu/info/ or Privacy Commissioner of Canada via https://priv.gc.ca/ if applicable.