This “Privacy Notice” describes the practices of Paradigm Services, Inc., its subsidiaries and affiliates (collectively, “TAPLocal” “we,” and “us”, or “our”) and the rights and choices available to individuals, regarding personal data. Personal data means any information that related to an identifiable individual.
Tap Local Marketing may provide separate privacy notices that apply to specific products or services that we offer, in which case this Privacy Notice does not apply. Where this Privacy Notice applies, Tap Local Marketing may provide additional or supplemental privacy notices to individuals at the time we collect their data, which will govern how we may process the information provided at that time. We may alter this Privacy Notice as needed for certain products and services and to abide by local laws or regulations. This Privacy Notice does not apply to Tap Local Marketing’s processing of the personal data of its personnel, such as employees and contractors.
- The personal data we collect
We collect personal data about individuals from various sources described below. Where applicable, we indicate whether and why individuals must provide us with personal data, as well as the consequences of failing to do so.
Information that we collect directly from individuals and the parties with which we do business
We may collect personal data directly from individuals and the parties with which we do business, including prospects. These may include parties that interact with us directly (such as individuals who download our mobile applications or job applicants), parties to which we provide goods or services (such as clients, merchants, and individuals) (collectively, “clients”), parties that provide services to us (such as processors) (collectively, “service providers”), and other parties with whom we offer or provide products and services (such as independent sales organizations or referral partners) (collectively, “partners”).
We may collect information from these parties in a variety of contexts, such as when completing one of our online forms, making an application for one of our products or services, interacting with us on social media, or corresponding with us. The types of information we obtain in these contexts include:
- Contact information of the business entity and its personnel who interact with us, such as name, job title, address, telephone number, and email address
- Profile information, such as username and password that an individual may establish on one of our websites or mobile applications, along with any other information that an individual enters into their account profile
- Demographic details, such as date of birth, state of resident, and/or country of citizenship
- Information about individuals’ affiliation with a legal entity, such as an individual’s role, and whether he or she is a beneficial owner or authorized signatory
- Government-issued identification numbers (to the extent permitted under applicable law), such as a national identification number (e.g., a Social Security Number, tax identification number, or passport number), state or local identification number (e.g., a Driver’s License or other government-issued identification number), and a copy of your government-issued identification card
- Feedback and correspondence, such as information you provide when you request information from us, receive customer support, or otherwise correspond with us, including by interacting with our pages on social networking online sites or services
- Financial account information, such as payment card or bank account details
- Information about merchants, such as merchant name, merchant ID and category code, merchant location where a transaction occurred, and information about transactions processed by the merchant, including transaction volume, velocity, amounts, types of goods or services sold, and chargeback ratios
- Information related to the use of Tap Local Marketing products or services, such as account information, spending thresholds, spending activity and patterns, and information about the transactions we process
- Precise geolocation information, if you authorize our mobile application to access your location
- Marketing information, such as your preferences for receiving marketing communications and details about how you engage with our marketing communications
- Other information supplied by job applicants, such as professional credentials and skills, educational and work history, and other information of the type included on a resume or curriculum vitae
Information that we collect about individuals who do not interact with us directly
We may receive personal data about individuals who do not interact with us directly. For example, our clients, service providers, and partners may provide us with information about individuals other than themselves when using our products or services. In addition, due to the unique nature of Tap Local Marketing’s business, in many cases, Tap Local Marketing obtains personal data from other participants in a transaction processing chain, such as card associations and debit network operators and their members. The types of information we receive about third parties includes:
- Information about the personnel of our clients, service providers, or partners, such as the business contact information that our clients, service providers, or partners provide to us in the context of our contractual relationships with them
- Information about potential job candidates, such as when a recruiter contacts us about an individual who may become a candidate for a job at Tap Local Marketing
- Information about customers of our clients that our clients send to us or allow us to collect in the context of the services that Tap Local Marketing performs, such as information related to financial transactions initiated by the customer, account registrations, and in some cases information needed to verify a customer’s identity and details of products or services purchased, and as otherwise stated in an applicable specific privacy notice for a Tap Local Marketing product or service. Where our technology is incorporated into a merchant’s mobile application or website, we also may automatically collect certain information of the type described in the section below titled “Information collected via automated means.”
- Information obtained when processing transactions, such as information about payment transactions
Information we collect from private and publicly accessible sources
We and our service providers may collect information about individuals that is publicly available, including by searching publicly accessible government lists of restricted or sanctioned persons (such as the Specially Designated Nationals And Blocked Persons List), public records databases (such as company registries and regulatory filings), and by searching media and the internet. We and or our third party verification providers may also collect information from private or commercially available sources, such as by requesting reports or information from credit reference and fraud prevention agencies, to the extent permitted under applicable law.
Information collected via automated means
When you access our websites or use our mobile applications, we, our service providers, and our partners may automatically collect information about you, your computer or mobile device, and activity on our websites or mobile applications. Typically, this information includes your computer or mobile device operating system type and version number, manufacturer and model, device identifier (such as the Google Advertising ID or Apple ID for Advertising), browser type, screen resolution, IP address, the website you visited before browsing to our website, general location information such as city, state or geographic area; and information about your use of and actions on or in our websites or mobile applications, such as pages or screens you accessed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and length of access. Certain products or services that we provide, or which merchants may incorporate into their websites or mobile applications may automatically collect additional information, as may be further described in a separate privacy notice.
Our service providers and business partners may collect this type of information over time and across third-party websites. This information is collected via various mechanisms, such as via cookies, web beacons, embedded scripts, through our mobile applications, and similar technologies. This type of information may also be collected when you read our HTML-enabled emails, where applicable. Please refer to our Cookies Disclosure for more details. You can choose to disable cookies or to opt out of the use of your browsing behavior for purposes of targeted advertising. For opt out instructions, please review the “Targeted online advertising” portion of the “Your Choices” section of this Privacy Notice.
Sensitive personal data
In limited circumstances and when permitted by law, we may request sensitive information, such as racial or ethnic origin or information about disability. Outside of this context or otherwise as we specifically request, we ask that you not provide us with any sensitive personal data (meaning information revealing racial or ethnic origin, political opinions, religion or philosophical beliefs, trade union membership, genetic, health, or biometric information, information about sex life or sexual orientation, or criminal convictions or offenses) through our websites or mobile applications, or otherwise to us.
- How we use your personal data
We use your personal data for the purposes of:
Providing our products and services, which includes:
- Operating, evaluating, maintaining, improving, and providing the features and functionality of our products and services
- Fulfilling a payment transaction initiated by you (either with us or our client)
- Managing our relationship with you or your company
- Carrying out our obligations, and exercising our rights, under our agreement with you or your company
- Communicating with you regarding your account with us, if you have one, including by sending you service-related emails or messages (e.g., messages regarding account verification, changes or updates to the functionality of our products or services, technical and security notices and alerts, and support and administrative messages)
- Personalizing the manner in which we provide our products and services
- Checking for fraud or money laundering and/or managing either our or our clients’ risk
- Administering and protecting our business
- Providing support and maintenance for our products and services, including responding to your service-related requests, questions, and feedback
We may use your personal data to form a view on what products or services we think you may want or need, or what may be of interest to you.
We may contact you with marketing communications using the personal data you have provided to us if you have actively expressed your interest in making a purchase or have made a purchase from us and, in any case, you have not opted out of receiving that marketing, to the extent permitted by applicable law.
Where required by law, we will get your express opt-in consent before we share your personal data with any company outside the Tap Local Marketing group for marketing purposes.
You can ask us to stop sending you marketing messages at any time by contacting us using the details at Contact us section or clicking on the opt-out link included in each marketing message.
Should you choose to opt out of receiving our marketing messages, we will continue to carry out our other relevant activities using your personal data, including sending non-marketing messages.
Managing our recruiting and processing employment applications
We process personal data, such as information submitted to us in a job application, to facilitate our recruitment activities and process employment applications, such as by evaluating a job candidate for an employment activity, and monitoring recruitment statistics.
Complying with law
We use your personal data as we believe necessary or appropriate to comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities.
Compliance, fraud prevention and safety
We use your personal data as we believe necessary or appropriate to (a) enforce the terms and conditions that govern our products and services; (b) protect our rights, privacy, safety or property, and/or that of you or others; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
With your consent
In some jurisdictions, applicable law may require us to request your consent to use your personal data in certain contexts, such as when we use certain cookies or similar technologies or would like to send you certain marketing messages. If we request your consent to use your personal data, you have the right to withdraw your consent any time in the manner indicated when we requested the consent or by contacting us. If you have consented to receive marketing communications from our third party partners, you may withdraw your consent by contacting those partners directly.
To create anonymous data
We may create anonymous data from your personal data and other individuals whose personal data we collect. We make personal data into anonymous data by excluding information that makes the data personally identifiable to you and use that anonymous data for our lawful business purposes.
- How we share your personal data
Companies within the Tap Local Marketing group
We may disclose your personal data to our subsidiaries and affiliates for purposes consistent with this Privacy Notice.
We may employ third party companies and individuals to administer and provide services on our behalf (such as companies that provide customer support, companies that we engage to host, manage, maintain, and develop our website, mobile applications, and IT systems, and companies that help us process payments). These third parties may use your information only as directed by Tap Local Marketing and in a manner consistent with this Privacy Notice, and are prohibited from using or disclosing your information for any other purpose.
When Tap Local Marketing performs services for its clients, it may share personal data with those entities. For example, Tap Local Marketing may collect information about a client’s customers from or on behalf of the client, such as when Tap Local Marketing processes payment transactions, and Tap Local Marketing may provide personal data about those customers back to the client. We are not responsible for the privacy practices of our clients.
Participants in the transaction processing chain
Tap Local Marketing shares personal data with companies in the transaction processing chain in connection with processing a payment transaction, such as merchants, banks or other card issuers, card associations, debit network operators and their members.
Credit reference, fraud protection, risk management, and identity and verification agencies
Tap Local Marketing shares personal data with credit reference, fraud protection, risk management, and identity verification agencies to help guard against, detect, and respond to fraud or money laundering, and/or manage our or our clients’ risk, and ensure we comply with contractual, legal, or regulatory requirements.
We may disclose your personal data to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.
Compliance with Laws and Law Enforcement; Protection and Safety
Tap Local Marketing may disclose information about you to government or law enforcement officials (including tax authorities) or private parties as required by law, and disclose and use such information as we believe necessary or appropriate to (a) comply with applicable laws and lawful requests and legal process, such as to respond to subpoenas or requests from government authorities; (b) enforce the terms and conditions that govern our products and services; (c) protect our rights, privacy, safety or property, and/or that of you or others; and (d) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
Tap Local Marketing may sell or transfer some or all of its business or assets, including your personal data, in connection with a business transaction (or potential business transaction) such as a merger, consolidation, acquisition, reorganization or sale of assets or in the event of bankruptcy, in which case we will make reasonable efforts to require the recipient to honor this Privacy Notice.
To Other Parties with Your Permission or to Fulfill a Contract They Have With You
Tap Local Marketing may transfer your personal data to any third party who is not otherwise covered by the other listed categories above where you have given us permission to do so, or with whom you have entered into a contract when we need to transfer your personal data to that party in order to fulfil that contract.
- Your rights and choices
In this section, we describe the rights and choices available to all users. Users who are located in California may read additional information about their rights below.
You can ask us to stop sending you marketing messages at any time by contacting us or clicking on the opt-out link included in each marketing message. You may continue to receive service-related and other non-marketing messages.
Targeted online advertising
Some of the business partners that collect information about users’ activities on our websites or in our mobile applications may be members of organizations or programs that provide choices to individuals regarding the use of their browsing behavior or mobile application usage for purposes of targeted advertising.
Users may opt out of receiving targeted advertising on websites through participating members of the following organizations or programs:
Users of mobile applications may opt out of receiving targeted advertising in mobile applications through participating members of the Digital Advertising Alliance by installing the AppChoices mobile application, available here, and selecting the user’s choices. In addition, your mobile device settings may provide functionality to limit our, or our partners’, ability to engage in ad tracking or targeted advertising using the Google Advertising ID or Apple ID for Advertising associated with your mobile device.
Please note that we also may work with companies that offer their own opt-out mechanisms and may not participate in the opt-out mechanisms that we linked above.
If you choose to opt-out of targeted advertisements, you will still see advertisements online, but they may not be relevant to you. Even if you do choose to opt out, not all companies that serve online behavioral advertising are included in this list, and so you may still receive some cookies and tailored advertisements from companies that are not listed.
Do Not Track Signals
Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to do not track signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
Choosing not to provide your personal data
Where we request personal data directly from you, you do not have to provide it to us. If you decide not to provide the requested information, in some circumstances we, or our clients, may be unable to provide products or services to you. For example, we may be unable to process your transaction.
Accessing, modifying or deleting your information
You may access, change, or correct information that we have about you, at any time or by making a request to us contact us, in which case we may need to verify your identity before granting access or otherwise changing or correcting your information. We may not be able to provide access to, modify, or delete your information in all circumstances.
If you have a complaint about our handling of your personal data, you may contact our data protection officer using the contact information below. We request that a complaint be made in writing. Please provide details about your concern or complaint so that our data protection officer can investigate it. We will take appropriate action in response to your complaint, which may include conducting internal discussions with relevant business representatives. We may contact you for additional details or clarification about your concern or complaint. We will contact you to inform you of our response to your complaint. You also may have a right to file a complaint with a national or local regulatory agency.
Deactivating Your Account
If you wish to deactivate your account, you can do so by logging into your Tap Local Marketing account or by emailing us using the contact details provided below or calling us at (844) 899-8559.
You can opt out of receiving promotional messages from Tap Local Marketing by following the instructions in those messages, by informing the caller that you would not like to receive future promotional calls, or by changing your notification settings by logging into your Tap Local Marketing account. You may only opt-out of text messages from Tap Local Marketing by replying STOP. Opting out of receiving communications may impact your use of the Services. If you decide to opt out, we can still send you non-promotional communications, such as digital receipts and messages about your account or our ongoing business relations.
California Privacy Rights
California law permits residents of California to request certain details about our disclosure of your personal information to third parties for direct marketing purposes during the immediately preceding calendar year. If you are a California resident and would like to request this information, please contact us at [email protected].
- How we keep your data safe
We take reasonable measures, including administrative, technical, and physical safeguards, to protect your information from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction. Nevertheless, the internet is not a 100% secure environment, and we cannot guarantee absolute security of the transmission or storage of your information. We hold information about you both at our own premises and with the assistance of third-party service providers.
We maintain annual compliance with global Payment Card Industry Data Security Standard (PCI DSS) adopted by the payment card brands for all companies that process, store or transmit cardholder data.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
- This Website May Link to Other Websites
We may also link to third-party websites, mobile applications, and other content. Tap Local Marketing is not responsible for the privacy practices of any third party, and this privacy notice does not apply to such third party’s websites, mobile applications, or other content. Tap Local Marketing does not guarantee, approve, or endorse any information, material, services, or products contained on or available through any linked third-party website, mobile application, or other content. Tap Local Marketing is not responsible for any content on third-party properties to which we link. Tap Local Marketing provides links to third-party properties or content as a convenience, and visiting or using linked third-party properties or content is at your own risk.
- CHANGES TO THIS PRIVACY NOTICE
We reserve the right to modify this Privacy Notice at any time. We encourage you to periodically review this page for the latest information on our privacy practices. If we make material changes to this Privacy Notice, we will notify you by updating the date of this Privacy Notice and posting it on our website and in app stores where our mobile applications covered by this Privacy Notice are available for download. We may (and, where required by law, will) also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via e-mail (if you have an account where we have your contact information) or another manner through our website or mobile applications.
Any modifications to this Privacy Notice will be effective upon our posting of the new terms and/or upon implementation of the new changes (or as otherwise indicated at the time of posting). In all cases, your continued use of our products or services after the posting of any modified Privacy Notice indicates your acceptance of the terms of the modified Privacy Notice.
If you have any questions, concerns, or complaints about this Privacy Notice or our privacy practices, or to request access to your personal data, you may contact our Data Protection Officer at [email protected].
We also maintain a Customer Service line available from the United States, at (844) 899-8559. This line is the most appropriate contact for an urgent concern, such as to report a suspected data breach regarding your personal data; or, if you are a merchant, data of your customers.