Truly Simplistic Innovations Inc. (“we” or “The Tap Project”) respects the privacy of its online visitors and customers of its products and services and complies with applicable laws for the protection of your privacy, including, without limitation, the British Columbia Privacy Act (“BCPA”), the Personal Information Protection Act (“PIPA”) and, for our users based in the European Union, the General Data Protection Regulation (“GDPR”).
Wherever we talk about Personal Data below, we mean any information that can either itself identify you as an individual (“Personally Identifying Information”) or that can be connected to you indirectly by linking it to other Personally Identifying Information. The Tap Project also processes anonymous data, aggregated or not, to analyze and produce statistics related to the habits, usage patterns, and demographics of customers as a group or as individuals. Such anonymous data does not allow the identification of the customers to which it relates. The Tap Project may share anonymous data, aggregated or not, with third parties.
2. Consent to Collection and Why The Tap Project Collects and Processes Data
As required by law, we will seek your consent before using Personal Data for any purpose beyond the scope of your original consent. You may withdraw your consent at any time, subject to legal and contractual restrictions and reasonable notice. Please note, however, that withdrawing consent may affect our ability to provide services to you.
2.2 Why We Collect and Process Data
The Tap Project collects and processes Personal Data for the following reasons:
a) where it is necessary for the performance of our agreement with you to provide a full-featured gaming service and deliver associated Content and Services;
b) where it is necessary for compliance with legal obligations that we are subject to (e.g. our obligations to keep certain information under tax laws);
c) where it is necessary for the purposes of the legitimate and legal interests of The Tap Project or a third party (e.g. the interests of our other customers), except where such interests are overridden by your prevailing legitimate interests and rights; or
d) where you have given consent to it.
These reasons for collecting and processing Personal Data determine and limit what Personal Data we collect and how we use it (section 3. below), how long we store it (section 4. below), who has access to it (section 5. below) and what rights and other control mechanisms are available to you as a user (section 6. below).
3. What Data We Collect and Process
3.1 Basic Account Data
When setting up an Account, The Tap Project will collect your email address, date of birth and country of residence. You are also required to choose a username and a password. The provision of this information is necessary to register a Tap Platform User account. During setup of your account, the account is automatically assigned a number (the “User ID”) that is later used to reference your user account without directly exposing Personally Identifying Information about you.
We do not require you to provide or use your real name for the setup of a Tap Project User Account.
3.2 Transaction and Payment Data
In order to make an Ethereum transaction on The Tap Project (e.g. to purchase Subscriptions for Content and Services or to fund your Tap Project Wallet), you may need to provide your Ethereum wallet address to The Tap Project to enable the transaction. The Tap Project will process and transmit the payment and receive the information that is publicly accessible via etherscan (i.e. transaction amount, date, to/from information, hash etc).
3.3 Other Data You Explicitly Submit
We will collect and process Personal Data whenever you explicitly provide it to us or send it as part of a communication with others on the Tap Platform, e.g. in Tap Project Community Forums, chats, or when you provide feedback or other user generated content. This data includes:
● Information that you post, comment or follow in any of our Content and Services;
● Information sent through chat;
● Information you provide when you request information or support from us or purchase Content and Services from us, including information necessary to process your orders with the relevant payment merchant or, in the case of physical goods, shipping providers;
● Information you provide to us when participating in competitions, contests and tournaments or responding to surveys, e.g. your contact details.
3.4 Your Use of The Tap Project Client and Websites
We collect a variety of information through your general interaction with the websites, Content and Services offered by The Tap Project.
Personal Data we collect may include, but is not limited to, browser and device information, data collected through automated electronic interactions and application usage data.
Likewise, we will track your interactions across our websites and applications to verify that you are not a bot and to optimize our services.
3.5 Your Use of Games and other Subscriptions
In order to provide you with services, we need to collect, store and use various information about your activity in our Content and Services. “Content-Related Information” includes your User ID, as well as what is usually referred to as “game statistics” and analytics. By game statistics we mean information about your games’ preferences, progress in the games, playtime, as well as information about the device you are using, including what operating system you are using, device settings, unique device identifiers, and crash data.
3.6 Tracking Data and Cookies
When you visit any of our services, our servers log your global IP address, which is a number that is automatically assigned to the network your computer is part of.
3.7 Google Analytics
On The Tap Project website, IP anonymization has been activated. The IP addresses of users visiting Tap Project will be shortened. Only in exceptional cases will a complete IP address be transferred to a Google server in the United States and converted to a shortened one there. On behalf of The Tap Project, Google will use this information for the purpose of evaluating the website for its users, in order to compile reports on website activity, and to provide other services relating to website activity and internet usage for website operators.
Furthermore, users can prevent the collection of data about their use of the website (including their IP address) generated by the cookie, and the processing of data by Google, by downloading and installing the browser plug-in through the following link: http://tools.google.com/dlpage/gaoptout?hl=en.
3 .8 Content Recommendations
We may process information collected under this section 3 so that content, products and services shown on The Tap Project store pages and also in update messages displayed when launching The Tap Project Platform can be tailored to meet your needs and populated with relevant recommendations and offers. This is done to improve your customer experience. You can prevent the processing of your data in this way by turning off the automatic loading of The Tap Project store page and also Tap Project notifications in the “Interface” section of The Tap Project Client settings.
Subject to your separate consent or where explicitly permitted under applicable laws on email marketing, The Tap Project may send you marketing messages about products and services offered by The Tap Project to your email address. In such a case we may also use your collected information to customise such marketing messages as well as collect information on whether you opened such messages and which links in their text you followed.
You can opt out or withdraw your consent to receive marketing emails at any time by either withdrawing the consent on the same page where you previously provided it or clicking the “unsubscribe” link provided in every marketing email.
3.9 Information Required to Detect Violations
We collect certain data that is required for the detection, investigation and prevention of fraud, cheating and other violations under the Business Corporations Act and applicable laws (“Violations”). This data is used only for the purposes of detection, investigation, prevention and, where applicable, responding to such Violations and stored only for the minimum amount of time needed for this purpose. If the data indicates that a Violation has occurred, we will further store the data for the establishment, exercise and/or defense of legal claims during the applicable statute of limitations or until a legal case related to it has been resolved. Please note that the specific data stored for this purpose may not be disclosed to you if the disclosure will compromise the mechanism through which we detect, investigate and prevent such Violations.
4. How Long We Store Data
We will only store your information as long as necessary to fulfil the purposes for which the information is collected and processed or — where the applicable law provides for a longer storage and retention period — for the storage and retention period required by law. After that your Personal Data will be deleted, blocked or anonymized, as provided by applicable law.
● If you terminate your Tap Project User Account, your Personal Data will be marked for deletion except to the degree legal requirements or other prevailing legitimate purposes dictate a longer storage term.
● In certain cases, Personal Data cannot be completely deleted in order to ensure the consistency of the gameplay experience or The Tap Project Community Market. For instance, matches you have played that affect other players’ matchmaking data and scores will not be deleted; rather, your connection to these matches will be permanently anonymized.
● Please note that The Tap Project is required to retain certain transactional data under statutory commercial and tax law for a period of up to ten (10) years.
● If you withdraw your consent to the processing of your Personal Data or of the Personal Data of your child, we will delete your Personal Data or the Personal Data of your child without undue delay to the extent that the collection and processing of the Personal Data was based on the withdrawn consent.
● If you exercise a right to object to the processing of your Personal Data, we will review your objection and delete your Personal Data that we processed for the purpose to which you objected without undue delay, unless another legal basis for processing and retaining this data exists or unless applicable law requires us to retain the data.
5. Who Has Access to Data
5.1 The Tap Project and its subsidiaries may share your Personal Data with each other and use it to the degree necessary to achieve the purposes listed in section 2.2 above. In the event of a reorganization, sale or merger we may transfer Personal Data to the relevant third party subject to applicable laws.
5.3 In accordance with internet standards, we may also share certain information (including your IP address and the identification of Tap Project content you wish to access) with our third party network providers that provide content delivery network services and game server services in connection with The Tap Project. Our content delivery network providers enable the delivery of digital content you have requested, e.g. when using Tap Project, by using a system of distributed servers that deliver the content to you, based on your geographic location.
5.4 We make certain data related to your Tap Project User Account available to other players and our partners through The Tap Project API’s. This information can be accessed by anyone by querying your User ID or username. At a minimum, the public persona name you have chosen to represent you on The Tap Project and your Avatar picture are accessible this way, as well as whether you have received a ban for cheating in a multiplayer game. The accessibility of any additional info about you can be controlled through your Tap Project Community user profile page. Data publicly available on your profile page can be accessed automatically through The Tap Project API.
In addition to the publicly available information, game developers and publishers have access to certain information from The Tap Project API directly relating to the users of the games they operate. This information includes as a minimum your ownership of the game in question. Depending on which Tap Project services are implemented in the game it may also include leaderboard information, your progress in the game, achievements you have completed, your multiplayer game matchmaking information, in-game items and other information needed to operate the game and provide support for it.
While we do not knowingly share Personally Identifying Information about you through The Tap Project API such as your real name or your email address, any information you share about yourself on your public Tap Project Profile can be accessed through The Tap Project API, including information that may make you identifiable.
5.5 The Tap Project community includes message boards, forums and/or chat areas, where users can exchange ideas and communicate with each other. When posting a message to a board, forum or chat area, please be aware that the information is being made publicly available online; therefore, you are doing so at your own risk. If your Personal Data is posted on one of our community forums against your will, please use the reporting function and The Tap Project help site to request its removal.
5.7 The Tap Project may release Personal Data to comply with court orders or laws and regulations that require us to disclose such information.
6. Your Rights and Control Mechanisms
The data protection laws of British Columbia and other territories grant their citizens certain rights in relation to their Personal Data. While other jurisdictions may provide fewer rights to their citizens, we make the tools designed to exercise such rights available to our customers worldwide.
To allow you to exercise your data protection rights in a simple way we are providing a dedicated section on the Tap Platform Settings. This gives you access to your Personal Data, allows you to rectify and delete it where necessary and to object to its use where you feel necessary. To access it, log into the Tap Platform and choose the menu items “Settings”.
As a resident of British Columbia or the European Union , you have the following rights in relation to your Personal Data:
6.1 Right of Access.
You have the right to access the Personal Data that we hold about you, including (i) information regarding whether your Personal Data is retained, (ii) access to and/or (iii) duplicates of the Personal Data retained. You can use the right to access your Personal Data through the Tap Platform. If the request affects the rights and freedoms of others or is manifestly unfounded or excessive, we reserve the right to charge a reasonable fee (taking into account the administrative costs of providing the information or communication or taking the action requested) or refuse to act on the request.
6.2 Right to Rectification.
If we process your Personal Data, we shall endeavor to ensure by implementing suitable measures that your Personal Data is accurate and up-to-date for the purposes for which it was collected. If your Personal Data is inaccurate or incomplete, you can change the information you provided via the Tap Platform.
6.3. Right to Erasure.
You have the right to obtain deletion of Personal Data concerning you if the reason why we collect it (see section 2. above) does not exist anymore or if there is another legal ground for its deletion. For individual items of Personal Data please edit them through the Tap Platform or request the deletion via The Tap Project support page. You can also request the deletion of your Tap Project user account via The Tap Project support page.
As a result of deleting your Tap Project User Account, you will lose access to Tap Project services, including The Tap Project User Account, Subscriptions and game-related information linked to The Tap Project User Account and the possibility to access other services you are using The Tap Project User Account for.
We allow you to restore your Tap Project User Account during a grace period of 30 (thirty) days from the time you request deletion of your Tap Project User Account. This functionality prevents you from losing your account by mistake, by losing your account credentials or due to hacking. During the suspension period, we will be able to finalize financial and other activities that you may have initiated before sending The Tap Project User Account deletion request. After the grace period, Personal Data associated with your account will be deleted subject to section 4. above.
In some cases, deletion of your Tap Project User Account, and therefore Personal Data deletion, is complicated. Namely, if your account has a business relationship with The Tap Project, such as due to your work for a game developer, you will only be able to delete your Tap Project User Account after you have transferred this role to another user or have dissolved the business relationship. In some cases, considering the complexity and number of the requests, the period for Personal Data erasure may be extended, but for no longer than two further months.
6.4 Right to Object.
When our processing of your Personal Data is not based on legitimate interests according to the BCPA, PIPA or GDPR you have the right to object to this processing. If you object we will no longer process your Personal Data unless there are compelling and prevailing legitimate grounds for the processing as described in the BCPA, PIPA, or GDPR, in particular if the data is necessary for the establishment, exercise or defense of legal claims.
6.5 Right to Data Portability
In certain circumstances, you can ask that we transmit the Personal Data we hold about you to another data controller.
6.6 Right to withdraw consent
You have the right to withdraw at any time your consent to our processing your Personal Data. This includes opting out of marketing messages you receive from us.
Should you wish to exercise any of the rights listed above, we may request you to provide us with additional documents to verify your identity.
You also have the right to lodge a complaint with a local supervisory authority if you believe that we have not complied with applicable data protection laws.
7. Transfer of Personal Data
The Tap Project is global. Your Personal Data may be transferred outside of the country from which it was originally collected and may be shared within The Tap Project group, and also with third parties located in other jurisdictions, including those that do not have similar data protection laws. All international transfers of Personal Data will be made in accordance with applicable data protection laws.
When we transfer Personal Data internationally, we put in place safeguards in accordance with applicable law – including Articles 44 to 50 pf the EU General Data Protection Regulation. If you would like to know more about our data transfer practices and what measures we take to safeguard your Personal Data, please contact our privacy team at: firstname.lastname@example.org or email@example.com.
8. Security of your Personal Data
We have policies and procedures in place to prevent the loss, unauthorized access, modification or disclosure of your Personal Data.
No method of transmitting or storing information is completely secure. While we take appropriate measures to protect your Personal Data, there is always a risk that it may be lost, intercepted or misused. The Tap Project makes no warranty with respect to the integrity of any electric communications between us and you.
9. Disclosure without consent
PIPA allows The Tap Project to disclose information without consent in certain situations:
When a treaty requires or allows for disclosure without consent and the treaty is made under an Act or Regulation of British Columbia or Canada (section 18(1) (h)). • When the disclosure is necessary to comply with a subpoena, warrant or order by a court or other agency with jurisdiction to compel the production of personal information (section 18(1)(i)). For example, an organization may disclose personal information without consent when a court order is served on the organization. • When the disclosure is to a public body or a law enforcement agency in Canada to assist an investigation of an offence under the laws of Canada or a province of Canada (section 18(1)(j)). For example, disclosing personal information to WorkSafe BC to carry out an investigation of a workplace accident. • When the information is disclosed to respond to an emergency that threatens the health or safety of an individual or the public and if notice of the disclosure is mailed to the last known address of the individual to whom the personal information relates (section 18(1)(k)). For example, if an individual makes a serious threat against another person, the information may be disclosed to prevent the person from being injured, as long as you notify the individual about the disclosure. • When disclosure is needed to contact next of kin or a friend of an injured, ill or deceased individual (section 18(1)(l)). • When the disclosure is to a lawyer representing your organization (section 18(1) (m)). • When the disclosure is to an archival institution if the collection of the personal information is reasonable for research or archival purposes (section 18(1)(n)).
10. Contact Info
You can contact The Tap Project’s data protection officer at the address below.
While we review any request sent by mail, please be aware that to combat fraud, harassment and identity theft, the only way to access, rectify or delete your data is through logging in with your Tap Project User Account and selecting the menu items -> Settings
The Tap Project
Att. Data Protection officer
#250 – 997 Seymour St.
Vancouver, BC, Canada
For ease you may additionally submit to firstname.lastname@example.org or email@example.com
11. Additional Information for Users from British Columbia
In compliance with the guidelines, The Tap Project commits to resolve complaints about our collection or use of your personal information.
11. Right to refuse request
The Tap Project must refuse access to an individual’s personal information in the following circumstances: • The disclosure could reasonably be expected to threaten the safety or physical or mental health of another individual (section 23(4)(a)). • The disclosure could reasonably be expected to cause immediate or serious harm to the safety or to the physical or mental health of the individual who made the request (section 23(4)(b)). • The disclosure would reveal personal information about another individual (section 23(4)(c)). • The disclosure would reveal the identity of the person who provided you with the applicant’s personal information, and that person does not consent to the disclosure of his or her identity (section 23(4)(d)). For example, an applicant might be able to determine a person’s identity based on his or her handwriting, special knowledge or presence at an incident involving the applicant.