Last updated: 12 July 2021

1. Introduction

This Privacy Notice explains what you can expect from us and what we need from you in relation to your personal data. 

For candidates in the UK, the data controller is Taptap Send UK Limited at Epworth House, 25 City Road, Shoreditch, London, EC1Y 1AA. Our registration number with the Information Commissioner’s Office UK is ZA282361. We have appointed a Data Protection Officer (“DPO”) to oversee compliance with this Privacy Notice. If you have any questions about how we protect or use your data, please email our DPO at privacy@taptapsend.com.

For candidates in the EU, the data controller is Taptap Send Belgium SA at 31 Rue du Commerce, 1000 Bruxelles, Belgium with enterprise number 0754.970.695. We have appointed a Data Protection Officer to oversee compliance with this Privacy Notice. If you have any questions about how we protect or use your data, please email our DPO at privacy@taptapsend.com.

The Taptap Send Group (“Taptap Send”) offers a software platform and services to help individuals send money to emerging markets. In this Privacy Notice, we sometimes refer to “You”. “You” are a potential employee or contractor of Taptap Send. This notice sets out how we collect, use and disclose data about our candidates (“Data”) during the recruitment process.

2. How we handle your Data

We receive Data during the application and recruitment process, either directly from you or from a third party (such as recruiters or former employers). Generally, this is data that directly identifies you individually (“Personal Information”) and which serves our legitimate interests in determining whether you are suitable for the role.

3. Collecting Personal Information

In connection with your application for the role, you may have have to provide us with the following types of Personal Information:

• Name
• Address
• Work / academic qualifications 
• Other information provided to us in your CV or cover letter 
• Information provided to us during your interview 
• Information about your demographic, race and/or ethnicity

We may collect Personal Information about you from other sources. For example, as part of the application process, we may obtain reference information from recruiters or your former employer(s).

4. Data Use

We are required to process your Data in order to further our legitimate interests in determining whether to hire you for the role. We may use your Data in the following ways: 

• Assessing your skills, qualifications and suitability for the role
• Carrying out reference checks, where applicable
• Communicating with you about the recruitment process 
• Keeping records related to our hiring process 
• Complying with our legal and regulatory requirements

If you do not provide certain information to us when requested (e.g., evidence of your qualifications or work history), we may not be able to process your application successfully. 

As a regulated financial institution, we are required by law to store some of your Data beyond the termination of your relationship with us. After such time, your Data will only be accessed or processed if absolutely necessary. We will always delete Data that is no longer required by relevant legislation.

5. Data sharing

We may share Data where required by law, where it is necessary to administer the relationship with you or where we have another legitimate interest in doing so. 

Taptap Send may share your Data with:

• Taptap Send Group Affiliates. We share Data with members of the Taptap Send Group (i.e., entities that are under common control of Taptap Send Inc.) to help us with things like business management and planning, conducting performance reviews, or, where relevant, administering equity incentive plans; 
  

• Taptap Send Service Providers. We share Data with trusted service providers to help us with things like payroll processing, pension administration, IT services, or, where relevant, benefits provision and administration;   
  

• Successors-in-Interest. We will share Data with third parties in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings); and

• ‍Safety, Legal Purposes and Law Enforcement. We use and disclose Data as we believe necessary: (i) under applicable law, regulations or payment method rules; (ii) to enforce our terms and conditions; (iii) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (iv) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include authorities outside your country of residence.

6. How We Protect Your Data

All information you provide to us is stored on our secure servers. We take reasonable measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. If you feel your Data has been compromised in any way, please contact us immediately.

7. Your Rights

UK/EU Related Rights 

For candidates in the UK or EU, the following information applies to your Data that we have processed or collected:

Purposes of processing and legal basis for processing: As explained above, we process Data in various ways.  We process your Data on the following legal bases: (1) with your consent; and (2) as necessary for our legitimate interests in determining whether to appoint you to the role (as it would be beneficial to our business to appoint someone to that role), where those interests do not override your fundamental rights and freedom related to data privacy.  Where we process Data that is special category data (i.e., race or ethnicity information), we process Data on the additional legal basis that such processing is necessary for substantial public interest reasons (e.g., for equal opportunities monitoring). 

Right to lodge a complaint: You have the right to lodge a complaint about our data collection and processing actions with the supervisory authority concerned. Contact details for data protection authorities are available below.

Data that we collect may be transferred to, and stored and processed in, the United States or any other country in which we or our affiliates, subcontractors, or partner payment processors maintain facilities. The laws in the U.S. and other countries regarding personal information may be different from the laws of your state or country.  Any such transfers will comply with safeguards as required by relevant law. By submitting your Data, you agree to this transfer, storing or processing.

Individual Rights: You are entitled to certain rights under the General Data Protection Regulation (or any such similar legislation in the UK) (“GDPR”) over Data that we have processed or collected. We have listed below how these rights operate in the context of your employment or contractual relationship with us. You may contact us at privacy@taptapsend.com to request the exercise of these rights. We will make every effort to respond promptly, and in any case within 30 days of your request. We may take measures to verify your identity before processing a request.

• Your right of access. Upon request, Taptap Send will provide you with information about whether we hold any of your Data. We will also provide access to one copy of your Data that we may hold free of charge.
  

• Your right of rectification. You may request to review, delete or update your Data to ensure it is accurate. 
  

• Your right to be forgotten. You may request to have us erase your Data that we may hold if the data is no longer necessary for the purpose for which it was collected, you withdraw consent and no other legal basis for processing exists, or you believe your fundamental rights to data privacy and protection outweigh our legitimate interest in continuing the processing. We will inform you which of your Data may be erased without violating our legal or regulatory obligations.
  

• Your right to restrict or object to our processing. You have the right to ask us not to process your Data if we are processing your data based on legitimate interests or the performance of a task in the public interest as an exercise of official authority (including profiling); using your data for direct marketing (including profiling); or processing your Personal Information for purposes of scientific or historical research and statistics. You also have the right to ask us not to process your Data while a rectification request is pending.
  

• Your right to data portability. You have the right to request a copy of your Data.
  

• Your rights related to automated decision making and profiling. Taptap Send does not subject you to significant solely automated decisions. However, if you disagree with our decisions with respect to you you may request a review by contacting us.
  

California Related Rights

Residents of California are entitled to certain rights under the California Consumer Privacy Act (“CCPA”):

• Your right of access. You may request access to the Personal Information that we collected and maintained about you (along with information regarding its use and disclosure) over the past twelve (12) months upon appropriate verification. You may only make such requests twice (2) per every twelve (12) months.
  

• Your right of deletion. You have the right to request that we delete Personal Information collected and maintained about you, subject to certain exceptions. Once your request is verified and we have determined that we are required to delete that information in accordance with applicable law, we will delete your Personal Information accordingly. Your request to delete your Personal Information may be denied if it is necessary for us to retain your information under one or more of the exceptions listed in the CCPA. Please note that a record of your deletion request may be kept pursuant to our legal obligations.
  

• “Do Not Sell My Personal Information” You have the right to opt out of “sales” of Personal Information (as such term “sell” is defined under the CCPA). We do not “sell” Personal Information. We do not have actual knowledge of any “sale” of Personal Information of any individual under the age of sixteen (16).
  

• Right against discrimination. You have a right to not receive discriminatory treatment for the exercise of your rights under the CCPA.
  

How to Exercise Your Rights

You can make exercise your rights pursuant to this section by:

• Contacting us at privacy@taptapsend.com
• Calling us at +1 833 916 0670
  

We will make every effort to respond promptly, and in any case within 30 days of your request. Only you, or a person that you authorize to act on your behalf, may make a request related to your Personal Information. We must take measures to verify your identity before processing your request. We will ask you to provide sufficient information for verification purposes (including your first name, last name, middle initial, email address, phone number and address), and we may not process your request if we are unable to verify your identity. We will use this information only to verify your request. We will also need to verify the authority of any person acting on your behalf, such as by ensuring they have the proper documentation to validate such authority.

8. Contact Us

For candidates in the UK or EU, if you have any questions about this notice, please contact our DPO at privacy@taptapsend.com. If you feel that we have not addressed your questions or concerns adequately, you may make a complaint with the Information Commissioner’s Office in the United Kingdom or the Data Protection Authority in Belgium. You may access their details via https://ico.org.uk/global/contact-us/ or https://www.dataprotectionauthority.be/citizen/actions/contact.

For all other candidates, if you have any questions about this notice, please contact us at privacy@taptapsend.com.