Privacy Policy

1. General Information

Tappa offers its services through a web based application (Tappa Services) which is provided by Cosmient Ltd, company reference number 09800262 (Tappa).
This policy (together with the terms and conditions as set out at (Terms & Conditions)) applies to your use of the Tappa Services and sets out the basis on which any personal data Tappa collects from you, or that you provide to Tappa, will be processed by Tappa.

2. What information does Tappa collect?

Tappa collects the following data from you.
(i) Tappa collects and processes the following personal data relating to you which you provide when you register for the Tappa Services:
• username (which may or may not contain your name, and may therefore not always be personal data);
• email address;
• telephone number;
• age;
• profile picture(s); and
• IP address.
(ii) Tappa collects and processes the following data called data-log files following access to the Tappa Services:
• name of website accessed;
• URL;
• date and time of retrieval;
• amount of data transferred;
• message about successful retrieval;
• browser type and version;
• user's operating system;
• referrer URL (previously visited page); and
• IP address and the requesting party Provider,
(Log Files)
(iii) Tappa collects, processes and uses the following location data about you:
• the city in which you are available for dates; and
• GPS location data if you have activated the EVA Chaperone function (see further at section 4 below),
(Location Data).
(iv) As part of the EVA Chaperone function, Tappa will collect and use contact data (name, email address and phone numbers) of individuals that have consented to being a Tappa user's nominated contact.
(v) App Content data - Tappa will collect and store chat data for security purposes only. This data will not be shared with Tappa third parties unless there is a suspected criminal or illegal activity requiring investigation by the appropriate authorities.

3. What is your data used for?

Tappa processes the following data in the following ways, and on the following legal bases:
• Your username and your age for the purposes of identification on the Tappa Services, for age verification and for your login credentials. Tappa does this on the bases that:
• it is necessary in Tappa's legitimate interest in providing the Tappa Services in an effective manner; and
• it is necessary for the performance of Tappa's contract with you under which it is obliged to provide you with the Tappa Services.
• Your profile pictures for the purposes of displaying you to other users of the Tappa Services. Tappa does this on the bases that:
• it is necessary in Tappa's legitimate interest in providing the Tappa Services in an effective manner; and
• it is necessary for the performance of Tappa's contract with you under which it is obliged to provide you with the Tappa Services.
In addition, Tappa processes your personal data in the following ways, and on the following legal bases:
• To carry out Tappa's obligations arising from any contracts entered into between Tappa and you. Tappa does this on the basis that it is necessary for the performance of Tappa's contract with you.
• To personalise your experience of the Tappa Services, to help Tappa respond better to your individual needs and to improve the Tappa Services. Tappa does this on the basis that it is necessary in Tappa's legitimate interest to ensure that the Tappa Services are being provided in the best possible way.
• To send you periodic email or notifications about the Tappa Services and any updates or changes to them. Tappa does this on the bases that:
• it is necessary in Tappa's legitimate interest to keep you up to date on the Tappa Services; and
• some communications with you are necessary for the performance of Tappa's contract with you under which it is obliged to provide you with the Tappa Services.
• To process transactions relating to subscriptions for Tappa's provision of the Tappa Services to you. Tappa does this on the basis that it is necessary for the performance of Tappa's contract with you.
• To verify users' contact details, and to confirm the identity of, conduct background checks on, and maintain security and safety standards in relation to, users of the Tappa Services. Tappa does this on the bases that:
• it is necessary for the performance of Tappa's contract with you, as part of that contract includes an obligation on Tappa to vet users, including you, for safety purposes; and
• it is necessary in Tappa's legitimate interest to ensure that all users of the Tappa Services are safe and secure at all times.
Tappa may review your personal data, the Log Files and/or the Location Data if it has reason to believe that the Tappa Services have been used unlawfully or illegally. Tappa does this on the bases that:
• it is necessary in Tappa's legitimate interest to ensure that the Tappa Services are being used appropriately and lawfully; and
• where relevant, it is necessary to protect your or any third party's vital interests - this will only be the basis where Tappa has reason to believe that you or any third party have or may come to harm.
Tappa uses Log Data for statistical analysis for the purpose of improved security and customer experience of Tappa Services. It does this on the basis that it is necessary in Tappa's legitimate interest to ensure that all users of the Tappa Services are safe and secure at all times.

4. EVA Chaperone Service

Users of the Tappa Services:
The EVA Chaperone Service is an optional service which you may choose to receive.
If you do choose to sign-up to the EVA Chaperone Service, then Tappa processes the following data in the following ways, and on the following legal bases
• Your profile picture, phone number and email address for the purposes of sending them to your nominated contact if the EVA alarm is triggered. Tappa does this on the bases that:
• it is necessary for the performance of Tappa's contract with you, as part of that contract includes providing your personal details to your nominated contact to ensure that they respond promptly; and
• it is necessary in Tappa's legitimate interest to ensure that users of the Tappa Services are safe and secure at all times.
• Your Location Data for the purposes of capturing your location at the various defined points on your date, for example upon setting off for your date, upon arrival at your date, at other set points during the date and/or if the EVA Chaperone alarm is triggered. Tappa does this on the basis that it is necessary for the performance of Tappa's contract with you, as the EVA Chaperone service cannot be provided without using your Location Data.
Tappa will process the contact details of your nominated contact for the purposes of sending them a SMS or email requesting their consent to be your nominated contact. Tappa does this via ClickSend and acts solely as the processor of your nominated contact's data on your behalf. Tappa will only process this data further if the nominated contact consents to being your nominated contact.
Nominated Contacts:
If you have been nominated as a nominated contact, and you consent to being contacted as such, Tappa will process your name, email address and telephone number for the purposes of:
• contacting you if the EVA alarm is triggered in relation to the user for whom you are chaperone; and
• to keep you updated on any changes to the EVA chaperone process.
Tappa does this on the basis that you have consented to such processing by responding to a SMS or email message confirming your consent.

5. Does Tappa disclose any information to third parties?

Tappa will send your phone number and email address to Hello Soda or any replacement provider, for the purposes of verifying the legitimacy and validity of the phone number and email address. Tappa does this on the bases that it is in its legitimate interest to prevent fake and/or fraudulent profiles being created.
Tappa does not sell, trade, or otherwise transfer your personal identifiable information to outside parties. This does not include trusted third parties who assist Tappa in delivering Tappa services to customers, so long as these parties agree to keep this information confidential.
Tappa will disclose your personal data to third parties:
• if Tappa sells or buys any business or assets, in which case Tappa will disclose your personal data to the prospective seller or buyer of such business or asset;
• if Tappa or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets; or
• if Tappa is under a duty to disclose or share your personal data in order to comply with any legal obligation, or to protect the rights, property, or safety of Tappa, you, other users or any third party. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

6. How does Tappa handle and protect your personal data?

All information collected, processed and used by Tappa is kept secure. Tappa implements a series of security measures to maintain the safety of your information.

7. How long does Tappa hold your personal data?

Tappa will retain your data throughout your subscription period with Tappa services and then for a further 24 months following your request to cancel your subscription.
Customers who have not formally cancelled their subscription but have shown no activity or use of Tappa services for 12 months will have their data retained for 24 months following this inactive period after which time their account will be deleted and their data will be removed.
Should the customer however resume activity within this 24-month period retention of their data will continue until cancellation or 12 months inactivity after which the 24-month data retention will renew.

8. Your Rights

Where Tappa relies on consent as the condition for processing your personal data, you have the right to withdraw that consent at any time.
You have various statutory rights in relation to your personal data. In particular, you have the right to:
• object to direct marketing communications at any time;
• request access to your personal data;
• rectification or erasure of your personal data, in certain circumstances;
• object to or restrict the processing of your personal data in certain circumstances;
• have your personal data stored in a manner in which it is portable from the Tappa environment to another environment; and
• file a complaint with the Information Commissioner's Office.

9. Does Tappa use cookies?

Tappa uses cookies in order to store session data and the user's geolocation (only if the user has given permission to use their location as part of Tappa services).

10. Changes to Privacy Policy

Any minor changes to this privacy policy will be posted on this page. Users will be notified of any significant changes through an updated privacy policy notice.
This privacy policy was last modified on 14 February 2018.

11. Contact

If you wish to contact Tappa in relation to this privacy policy, including in relation to any of the rights set out in section 8 above, please contact us at [email protected].