HOOCH, INC. dba TAP NETWORK 

PRIVACY POLICY

Updated June 1, 2020

Read this document to understand how TAP uses data.

Your privacy and security are paramount to us at HOOCH, Inc, d.b.a. TAP Network (“TAP”). This Privacy Policy is meant to explain how we collect, use, and share end user information. Our Site and Services are not intended for under-aged or minor individuals. We do not knowingly collect personal information from such individuals.

This product is linked to our partners, Brave Browser. To review their privacy policies please refer to https://brave.com/privacy/.

We have developed and continue to improve a system that allows the users of this platform (brave.tapnetwork.io) to exchange in the gift card portal from brands we have partnered with.

A certain level of permissioned access to your data, as provided by Brave, is required so that our system can correctly apply the exchange rewards amount to your account. Whenever data is required we use industry standard 3rd party partners (“Secure Data Gateway Partner” or “SDGP”) to securely access and record that information into our system. Before data is access, we surface a request for your permission in the TAP experience and give you the opportunity to grant permission to such 3rd party Secure Provider.

Once data is accessed with your permission, they are securely stored in a private database using advanced cryptography (“Encrypted Data”), separate from any personally identifiable information, such as your name, email address. Your Encrypted Data will be used within our system to identify earnings and rewards, and facilitate offers from brand advertisers. In no instance is your Encrypted Data ever transferred outside of our system to any parties without your permission.

 

TAP Services

When you use TAP or the TAP Services within any of our white label partners, including but not limited to Brave Rewards Market, the TAP Network protocol may ask you to optionally login to your Uphold account to verify qualified purchases via the Uphold 3rd party Secure Data Gateway Partner. TAP does not register nor download your wallet information and the exchange transaction happens entirely through the Uphold platform. Any Personally Identifiable Information (“PII”) such as your name, or your wallet information are masked by our SDGP and not sent to TAP. TAP does not store your full account information in our databases. We use your transaction history to identify qualified exchange(s) and confirm your gift card brand(s) and amount(s), and to maintain and improve the performance of TAP. 

 

Information we collect and receive

We collect different kinds of information. Some of it is personally identifiable and some is non-identifying or aggregated. Here are the types of information we collect or receive:

  • Account and profile information. The information we require to create your TAP account is name, an email address and password. Some white label partners may require full name and/or phone number for verification purposes and reducing fraudulent account creations. Together these account and profile information (“Profile Data”) are shared by you exclusively with our white label partner. You hereby grant additional permission to TAP for managing your Profile Data on behalf of our white label partners. 
  • Transactions Data. When using TAP or TAP Services, in order to exchange you will need to login into your Uphold account via their 3rd party Secure Data Gateway Partner. 
  • Log data. When you use our white label partner’s rewards platforms powered by TAP, our servers automatically record information, including information that your mobile device sends whenever you’re using it. This log data may include your IP address, your browser type and settings, the date and time of your request, information about your browser configuration and plug-ins, language preferences, and cookie data. Log data does not contain personally identifiable data and is not routinely deleted. The purpose of the information is for analyzing trends, administering the site, tracking users’ movement on the website, and gathering demographic information.
  • Device information. In addition to log data, we may also collect information about the device you’re using TAP on, including what type of device it is, what operating system you’re using, device settings, unique device identifiers, and crash data. Whether we collect some or all of this information often depends on what type of device you’re using and its settings.
  • Geo-location information. In some white label partner implementations, precise GPS from mobile devices may be collected only with your permission. WiFi and IP addresses received from your browser or device may be used to determine approximate location.
  • TAP usage information. This is information about which venue, features, redemptions you interact with within TAP and what related offers and services you use.
  • Information from partners or other 3rd parties. TAP may receive information from partners or others that we could use to make our own information better or more useful, such as aggregate level information about which IP addresses go with which zip codes or it might be more specific information about how well an online marketing or email campaign performed.

 

Protection of Personal Information

TAP takes the security of your personal information very seriously. We protect your personal information during transit using encryption such as Transport Layer Security (TLS). When your personal data is stored by TAP, we use leading industry secure storage solutions including but not limited to Amazon Web Services (“AWS”) with limited access housed in facilities using security measures.

 

How We Share and Store Your Information

We make every attempt and stay current with our technology to protect end user information in our possession. We use data protection controls such as data encryption, firewalls, access controls, and monitoring. Our controls are consistently reviewed against industry-standards.

We do not sell or rent user information to marketers or other third parties unless otherwise described in this Policy. We may share your information:

  • With your permission for rewards purposes to our white label partner or brand partners;
  • With our service providers, partners, or contractors in connection with the services they perform for us or our developers;
  • If we believe in good faith that disclosure is appropriate to comply with applicable law, regulation, or legal process (such as a court order or subpoena);
  • In connection with a change in ownership or control of all or a part of our business (such as a merger, acquisition, reorganization, or bankruptcy).

 

We may collect, use, and share information we collect in an aggregated or de-identified manner (that does not identify you personally) for any purpose permitted under applicable law. This includes creating or using aggregated or de-identified data based on the collected information to develop new services and to facilitate research.

We retain information we collect about you for as long as necessary to fulfill the purposes outlined in this Policy, unless a longer retention period is required or permitted under applicable law, regulation, or contract. As permitted under applicable law, even after you stop using an application or terminate your account with our developers we may still retain your information (for example, if you still have an account with another developer or if there is residual information within our databases or systems); however, your information will only be used and shared as required by law or in accordance with this Policy.

 

We use your personal information for the purposes of:

 

  • Providing TAP Services. We use information you provide to authenticate you and deliver content and services to you as well as issuing the rewards promised based on your spending with our partners.
  • Understanding and improving our products. To make the product better we have to understand how users are using it. We have a fair bit of data about usage and we intend to use it in many different ways to improve our products, including research. This policy is not intended to place any limits on what we do with usage data that is aggregated or de-identified so it is no longer tied to a specific user.
  • Improving redemption services and selections. We work with our vendors and brand partners to improve our rewards selections to better fit your preference, using information from your usage and aggregate usage from all users and deliver more customized services to you.
  • Investigating and preventing bad stuff from happening. We work hard to keep TAP secure and to prevent abuse and fraud.
  • Communicating with you. 
  • Solving your problems and responding to your requests. If you contact us with a problem or question, we will use your information to respond to that request and address your problems or concerns.
  • In-product communications. We may use the information you provide to contact you through TAP using in-app or desktop push notification or other in-product messaging tools.
  • Email messages. We may send you service and administrative emails. We may also contact you to inform you about changes in our services, or our service offerings. These messages are considered part of the service and you may not opt-out of them. In addition, we sometimes send emails to TAP users about new product features or other news. You can opt-out of these at any time.
  • Mobile Device Use. When you use the mobile application or mobile versions of our TAP or website, we may collect the unique device identifier assigned to that device by phone makers, carriers, or makers of the operating system (the “Device ID”). 
    • Device IDs allow TAP developers, advertisers, and others to uniquely identify your device for purposes of storing application preferences and other data.
    • We may use your Device ID to contact you directly through push notifications. Additionally, we may use Device IDs to monitor suspicious activity. For example, if we detect that a single account on a Site is being accessed from multiple devices, as determined by tracking the Device IDs that access an account, we may contact the user to ensure that such access has been authorized by the user.
    • Device information we process may be transferred to, stored, and processed in, the United States, or any other country in which TAP, TAP Services or its affiliates, subsidiaries, or service providers maintain operations. By using and providing information to us through the TAP or website, you agree and consent to the transfer, storage, and processing of your device information to any such country in order to provide TAP services.

Children Under 18

We understand the importance of taking extra precautions to protect the privacy and safety of children using TAP products and services. Children under the age of 18, or equivalent minimum age in the relevant jurisdiction, are NOT permitted to create their own accounts.

 

Children Under18

 

TAP and Uphold is not available for use for Children under 18 in any iteration. For questions, a parent or legal guardian must review the TAP and Family Sharing Disclosure and agree to the Consent to TAP’s Collection, Use and Disclosure of Your Child’s Information. 

 

Children’s Privacy Policy

 

We are committed to protecting the privacy of children who use our sites and applications. This Privacy Policy explains our information collection, disclosure, and parental consent practices with respect to information provided by children (“child” or “children”) under the age of 18 and uses terms that are herein defined in our general Privacy Policy. This policy is in accordance with the U.S. Children’s Online Privacy Protection Act (“COPPA”) and outlines our practices in the United States and Latin America regarding children’s personal information. For more information about COPPA and general tips about protecting children’s online privacy, please visit OnGuard Online (insert link here).

 

Location-Based Services

To provide location-based services on TAP and TAP Services network, with your explicit consent, partners such as maps data providers, may collect, use, and share precise location data, including the real-time geographic location of your phone device. Where available, location-based services may use GPS, Bluetooth, and your IP Address, along with crowd-sourced Wi-Fi hotspot and cell tower locations, and other technologies to determine your devices’ approximate location. This location data is collected anonymously in a form that does not personally identify you and is used by TAP and our partners to provide and improve location-based products and services. For example, your device may share its geographic location with applications which may alert you to local rewards offers.

 

Third party offers, advertisements, and data collection

 

We may offer a number of separate products and services offered by third parties advertised to you on our TAP and website. These third party offers may be complementary to your use of the TAP services and may be personalized based on information you provide to us, or other information. If you choose to use these separate products and services, provide information to the third party, or allow the third party to otherwise collect information about you, then their use of your information is subject to the applicable third party’s privacy policy and terms of service. You should review the practices of the third party before deciding to use their service or provide them with any information.

 

As a user of our TAP and services, you grant our white label partner, Secure Data Gateway Partner, Payment Processor, other partners the right, power, and authority to access and transmit your data as reasonably necessary for such a partner to provide respective services. In addition, you acknowledge and agree that your personal information will be treated by each partner in accordance with their respective private policy. You furthermore expressly grant all partners the right, power and authority to access and transmit your data to TAP and its partners as reasonably necessary to provide the services to you.

 

 

Our Cookie Policy

 

TAP and its apps and websites uses cookies, or similar technologies to record log data and help you stay logged-in to the white label partner site(s). We use both session-based and persistent cookies. Session-based cookies last only while your browser is open and are automatically deleted when you close your browser. 

 

Persistent cookies last until you or your browser delete them or until they expire.

 

Log-in cookies are associated with your TAP account and personal information in order to remember that you are logged in. Other cookies are not tied to your TAP account but are unique and allow us to do site analytics and customization, among other things.

 

TAP sets and accesses our own cookies on our company-owned domains. In addition, we use 3rd parties like Google Analytics for website analytics. You may opt-out of third-party cookies on their respective websites. We do not currently recognize or respond to browser-initiated Do Not Track signals as there is no consistent industry standard for compliance.

 

Security

 

We take reasonable steps to protect information you provide to us as part of your use of the TAP and TAP Services from loss, misuse, and unauthorized access or disclosure. When you enter sensitive information (such as sign-in credentials) we encrypt the transmission of that information using secure socket layer technology (SSL). We follow generally accepted standards to protect the personal data submitted to us, both during transmission and once we receive it. However, no electronic transmission or digital storage mechanism is ever fully secure or error free.

 

Our Company-Wide Commitment to Your Privacy

 

To make sure your personal information is secure, we communicate our privacy and security guidelines to TAP employees and strictly enforce privacy safeguards within the company.

 

Changes to this Privacy Policy

 

TAP will update this policy from time to time in order to upgrade its policy to match any new features we may add to the platforms, and if we do we’ll post any changes on this page. If you continue to use any TAP product and/or website after those changes are in effect, you agree to the revised policy. If the changes are material, we may provide more prominent notice or seek your consent to the new policy.

 

General Data Protection Regulation (GDPR)

 

We are a Data Controller of your information.

 

TAP’s legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Information we collect and the specific context in which we collect the information:

  • TAP needs to perform a contract with you
  • You have given TAP permission to do so
  • Processing your personal information is in TAP’s legitimate interests
  • TAP needs to comply with the law

 

TAP will retain your personal information only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your information to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Our Privacy Policy was generated with the help of GDPR Privacy Policy Generator and the Privacy Policy Generator.

 

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. If you wish to be informed what Personal Information we hold about you and if you want it to be removed from our systems, please contact us. 

 

In certain circumstances, you have the following data protection rights:

  • The right to access, update or delete the information we have on you.
  • The right of rectification.
  • The right to object.
  • The right of restriction.
  • The right to data portability
  • The right to withdraw consent

 

California Consumer Privacy Act (CCPA)

 

For Privacy Notice supplementing the information contained here for California Residents only, please visit (insert CCPA supplement link here)

 

Consent

 

By using our website, you hereby consent to our Privacy Policy and agree to its terms.

 

Contacting Us

 

Please also feel free to contact us if you have any questions about our Privacy Policy or practices. You may contact us at support@tapnetwork.io or at our mailing address below:

 

HOOCH, Inc. dba TAP Network

200 Broadway FL3

New York, NY 10038