Last updated: 30 July 2021

1. Introduction

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

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If you live in the US, Taptap Send Payments Co. (“Taptap Send”, “we”, “us”, “our”) is responsible for the provision of financial services to U.S. users (e.g., payment-related information) as set forth in its Consumer Privacy Notice pursuant to the Gramm-Leach-Bliley Act (GLBA). In the event of conflict between the Consumer Privacy Notice and this notice, the Consumer Privacy Notice controls with respect to such financial services.

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Taptap Send offers a software platform and services to help individuals send money to emerging markets. We collect data about our customers and their payees (“Data”) when they use our platform, our services, and our websites (collectively, “Services”). This privacy policy describes how we collect, use, and disclose Data.

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In this privacy policy, we sometimes refer to “You”. “You” may be a Visitor to one of our websites, a customer of one or more of our Services (“Customer”), or a payor / payee of a Customer (“Payee”). This policy does not apply to third-party websites, products, or services even if they link to our Services, and you should consider the privacy practices of those third-parties carefully. If you object to the practices described in this policy, you should (a) remove cookies from Your computer after leaving our website, and (b) discontinue your use of our Services.

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We may change this Privacy Policy from time to time. We will post any changes, and such changes will become effective when they are posted. Your continued use of our Services following the posting of any changes will mean you accept those changes. We encourage you to review the Privacy Policy whenever you interact with us to stay informed about our information practices and the ways you can help protect your privacy.

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2. How we handle your data

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We receive Data from Visitors to our website, and Customers using our Services. The collection and use of data is crucial to providing our Services and keeping the Services safe. Data helps us increase the safety of your online payments, while reducing the risk of fraud, money laundering and other harmful activity. Generally, Data can be categorized into data that directly identifies you individually (“Personal Information”) and data associated with your activities (“Activity Information”).

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All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using Transport Layer Security technology. You are responsible for keeping confidential any passwords we give you. We ask you not to share this password with anyone else and not to use this password for other services or products.

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3. Collecting Personal Information

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You may have to provide us with Personal Information to sign up for, or make use of, our Services. This data includes the following, for yourself and your recipient:

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• Name
• Address
• Date of birth
• Place of birth
• E-mail address
• Demographic information (e.g., gender, profession)
• Phone number
• Evidence of your identity (for example, passport information, social security number)
• Financial information (including credit card, debit card, or bank account information),
• Payment reason
• Geographical location
• Government ID number and/or a copy of government issued photo ID
• Personal description,including professional status
• Photograph (e.g., a selfie of yourself)
• IP address
• Device ID
• Device settings (e.g., language preference, time zone)

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We may collect Personal Information about you from other sources. For example, we may:

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• Retrieve names associated with particular phone numbers from our payment service providers; and
• Verify your identity against third party databases (e.g., politically exposed persons (PEP) or sanctions databases) for anti-money laundering and fraud purposes.

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4. Collecting Activity Information

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We also automatically collect Activity Information based on your use of our Services. This data would include your activities on our website, or actions performed on our payment platform. For example, we may collect:

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• Details of the transactions you carry out when using our Services, including geographic location from which the transaction originates;

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• Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;

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• Information about your visit, including the full URL clickstream to, through and from our Website or App (including date and time); page response times, download errors, length of visits to certain pages, page interaction information, methods used to browse away from the page; and 

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• Any phone number used to call our customer support center, as well as a recording of that call. By continuing to speak to a customer support agent after calling our customer support center, you are agreeing to our collection of this data. 

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Our Website also uses cookies to distinguish you from other users of our Website. This helps us to provide you with a good experience when you use our Website and also allows us to improve our Website. By continuing to use our Website, you are agreeing to our use of cookies.

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Personal Information and Activity Information we collect is stored in compliance with our various regulatory obligations for anti-money laundering and fraud purposes.

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5. Data Use

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When you sign up to effectuate payments through our Service, you enter into a contract with us to make these payments on your behalf. We must process your Data to fulfil this contract. Further, we are required by law to collect, process, and retain your Data, in fulfilment of our anti-money laundering regulatory obligations. We use your Data for the following business purposes:

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• Carry out our obligations relating to your contracts with us and to provide you with the information, products and services that you request from us;

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• Provide, maintain, personalize, optimize, and improve the Services, including research and analytics regarding use of the Services, or to remember you when you leave and return to the Services;

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• Provide and improve our products and services;

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• Provide you with more relevant content in marketing, promotional or other communications to which you may be subscribed;

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• Detect, investigate, and prevent activities that may violate our policies or be fraudulent or illegal.

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We may combine information from the Services together and with other information we obtain from our business records or from third party sources.

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Taptap Send will only use your Data for marketing and promotional purposes if you "opt in" to such uses, and you can withdraw this permission at any time. You have the right to ask us not to contact you for marketing purposes by contacting us at privacy@taptapsend.com.

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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.

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6. Data Sharing

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We may share Data to ensure that we can continue providing you with the Services you have contracted.

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Taptap Send may share your Personal Information and Activity Information with:

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• 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 provide our Services;

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• Taptap Send Service Providers. We share Data with trusted service providers who help us provide the Services. Service providers help us with things like payment processing (i.e., banks, mobile network operators), website hosting, data analytics, information technology and related infrastructure, customer service, email delivery, auditing, and identity verification;

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• Third Parties Authorized by You. We share Data with parties directly authorized by a Customer to receive Data, such as when a Customer authorizes a third party application provider to access the Customer’s Taptap Send information through the third party’s own system or software. The use of Data by an authorized third party is subject to the third party’s privacy policy and any agreements the Customer has with the third party.

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• Authorized Financial Institution(s). We share Data with the financial institution that holds the account you have designated for the sending or receiving transaction. By requesting a payment, you are consenting to sharing of Data by and between both Taptap Send and the relevant Financial Institution(s) as necessary for the provision of payment services.

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• 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

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• Safety, Legal Purposes and Law Enforcement. We use and disclose Data as we believe necessary: (i) under applicable law, 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.

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7. How We Protect Your Data

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All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using Transport Layer Security technology. 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 interaction with us is no longer secure (e.g., you believe your log in or other security credentials have been compromised), please contact us immediately.

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8. Storing Your Data

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Personal Information 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 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. It may also be processed by staff operating outside the US who work for us or for one of our payment processors or suppliers. Such staff may be engaged in, among other things, the fulfilment of your payment order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing.

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9. California Related Rights

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

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• 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.

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• 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.

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• “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).

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

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How to Exercise Your Rights

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

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

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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. 

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10. Our Partners

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Our Services may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates.  If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility for them.  Please check these policies before you submit any personal data to these websites.

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11. Changes to this Policy

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Any changes we may make to our Privacy Policy will be posted on this page and, where appropriate, notified to you by e-mail or in the App. Please check back frequently to see any updates or changes to our privacy policy.

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       11.  Contact us

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If you have any questions about this Privacy Policy, please email us at privacy@taptapsend.com.