Tap 2 Donate Privacy Policy
This Privacy Policy sets out the basis on which we will process any Personal Data that we may collect about you as a visitor to our website located at www.tap2donate.ie, www.tap2tip.io or www.tap2tip.ie (our “website”) or our customers or potential customers, or other business partners, or in any other cases where we specifically state that this policy will apply. This policy further sets out how we protect your privacy and your rights in respect of our use of your Personal Data.
WHO IS THE DATA CONTROLLER?
A “data controller” is a person or organisation who alone or jointly determines the purposes for which, and the manner in which, any personal data is, or is likely to be, processed. In this sense, GJP Enterprises Limited, RDI Hub, Killarney Rd, Anglont, Killorglin, Co. Kerry, Ireland, V93 KP68 (“Tap 2 Tip/Tap 2 Donate”, “we”, “us”, “our”) is the data controller. If you have any questions about data protection at Tap 2 Tip/Tap 2 Donate in general, you can reach us by email using info@tap2donate.ie or info@tap2tip.ie with "Data Protection" in the subject line.
WHAT IS PERSONAL DATA?
Personal data is any information that relates to an identified or identifiable living individual. Different pieces of information, which collected together, can lead to the identification of a particular person, also constitute Personal Data.
WHY DO WE HAVE A PRIVACY POLICY?
Ireland’s Data Protection Act (“DPA”) and the EU's General Data Protection Regulation (“GDPR”) control how your Personal Data is used by us. We are also required to explain which Personal Data we collect from you via our website and shop, what we use it for, when we delete it and how your data is protected.
WHAT ARE THE LEGAL BASES FOR PROCESSING PERSONAL DATA
All Personal Data that we obtain from you via our website will only be processed for the purposes described in more detail below. This is done within the framework of the DPA and the GDPR and only if at least one of the following applies: a) you have given your consent, b) the data is necessary for the fulfilment of a contract / pre-contractual measures, c) the data is necessary for the fulfilment of a legal obligation, or d) the data is necessary to protect the legitimate interests of our company, provided that your interests are not overridden.
WHAT PERSONAL DATA DO WE COLLECT FROM YOU?
a) Collection of access data and log files
When you visit our website, we collect the Personal Data that your browser automatically transmits to our server. This is technically necessary for us to display our website and to ensure its stability and security. In this sense, we collect the following data: a) IP address of the requesting computer, b) Date and time of access, c) name and URL of the file accessed, d) website from which the access was made (referrer URL), e) browser used, and, if applicable, the operating system of your device as well as the name of your access provider. The legal basis is our legitimate interest.
To provide our website, we use the services of Blacknight, who process the above-mentioned data and all data to be processed in connection with the operation of our website on our behalf. The legal basis is our legitimate interests in an efficient and secure provision of the website and services in conjunction with the provision of our contractual services.
We use so-called cookies on our website. Cookies are pieces of information that are transmitted from our web server or third-party web servers to your web browser and stored there for later retrieval. Cookies may be small files or other types of information storage. There are different categories of cookies: i) Essential Cookies. Essential cookies are cookies to provide a correct and user-friendly website; and ii) Optional Cookies. Optional Cookies are any cookies that do not fall within the definition of essential cookies, such as cookies used to analyse your behaviour on a website (“analytical” cookies) or cookies used to display advertisements to you (“advertising” cookies). For further information on the cookies we use, please refer to our Cookie Policy. The legal basis for processing is our legitimate interest and your consent.
d) Cookie consent
As set out in Ireland’s European Communities (Electronic Communications Networks and Services) (Privacy and Electronic Communications) Regulations 2011 (“2011 Regulations”) and the EU's Privacy and Electronic Communications Directive (“PECD”), we need to obtain consent for the use of Optional Cookies. For this purpose we use a cookie consent tool to obtain your consent to the storage of cookies and to document this consent. When you enter our website, the following Personal Data is transferred to us via our cookie consent tool: a) Your consent(s) or revocation of your consent(s); b) Your IP address; c) Information about your browser; d) Information about your device; e) Time of your visit to our website. The basis for processing is our legitimate interest and your consent.
e) Fonts
We use Google Fonts by Google on our website to display external fonts. To enable the display of certain fonts on our website, a connection to a Google server is established when our website is accessed. The connection to Google established when you call up our website enables Google to determine which website sent your request and to which IP address the display of the font is to be transmitted. This represents a legitimate interest.
a) reCAPTCHA
We also use Google`s reCAPTCHA to check whether data input is made by a human being or by an automated program. For this purpose, reCAPTCHA analyses the behaviour of the website visitor on the basis of various characteristics. This analysis begins automatically as soon as the website visitor enters the website. The legal basis for using reCAPTCHA is our legitimate interest.
f) YouTube Videos
We have integrated videos from YouTube (Google). The integration requires that YouTube can perceive the IP address of the user. The IP address is required in order to send the video content to the user's browser. If you click on a YouTube video on our website, your internet browser will be prompted to download a corresponding representation of the video and places certain cookies. In this way, YouTube knows which specific sub-pages you have visited. The legal basis for the data processing is our legitimate interest and your consent.
g) Analytics
For business reasons, we analyse the data we have on web and server traffic patterns, website interactions, browsing behaviour, etc. The analyses serve us alone and are not disclosed externally and processed using anonymous analyses with summarised and/or anonymised values. For this purpose we use Google Analytics. The legal basis is our legitimate interest and your consent. For further information, please refer to our Cookie Policy.
h) Contact options
We process and store the Personal Data provided in the contact enquiry solely for the purpose of processing and responding to your enquiry and contacting you. If you contact us, we will process the data you provide to respond to you and answer your questions and requests. In doing so, the principle of data economy and data avoidance is observed in that you only have to provide the data that we absolutely need from you in order to contact you. These are usually your first and last name, your email address, the topic selection, and the message itself. The legal basis for processing is our legitimate interest, the provision or initiation of a contractual service, and your consent.
i) Registration
As part of the registration process, users provide their name, e-mail, phone number, business details and contact information, and password. The data provided will be used for the purposes of creating and using the account and providing and/or using our services. In the context of the use of our log in and sign-up functions, as well as the use of the user account, the legal basis for the data processing is the fulfilment of our contractual obligations and, in individual cases, the fulfilment of our legal obligations as well as consent.
j) Contracting with us
We process the Personal Data that arises when you enter into a contract with us in order to provide our contractual services. In this regard, we typically process your contract and contact information as well as other data relevant to the fulfilment of our obligations. This in particular includes our support, correspondence with you, invoicing, fulfilment of our contractual, accounting, and tax obligations. Accordingly, the data is processed on the basis of the fulfilment of our contractual obligations and our legal obligations.
k) Using our services
If you wish to use our services, we process the data you provide to provide you with our services (“Service Data”). The data you provide typically includes:
Registration and Identification information: e.g., identification number, ID, passwords, or equivalent; business related information - address, phone number, email address and communication, name, website, social media; company-related information—registration number, tax residency information and tax identification number, directors, officers, owners, nature of the business; details of the primary contact for the account and representative—names, phone number, date/place of birth, nationality, address.
Account-related information: merchant identification number (used for internal purposes), country, legal type of the entity, when and how you registered for our services, status of the account, login and registration-related data, information about the services.
Financial information: e.g., bank details, card information, overview of the transactions, transactional history, credit history (including credit checks results when applicable), information related to invoices that we have issued.
Know your customer-related information: in addition to registration and account information, proof of business/address and a copy of identification, information related to AML/CTF-related processes and checks, including with third parties, and your image in photo or video form (where required as part of our KYC checks, to verify your identity).
The purposes we process your Service Data typically include:
● to provide our Services and products and administer our business relationship with you;
● confirming your identity and verifying your personal and contact details;
● solving disputes, enforcing our contractual agreements, and establishing, exercising, or defending legal claims or collection procedures;
● processing payments, refunds and chargebacks, proving that transactions have been executed;
● securing the payment processing;
● providing receipts to your customers;
● improving our Services and for general business development purposes;
● carrying out risk analysis, fraud prevention, and risk management, preventing misuse of our services.
● maintaining and protecting the security of our services and websites;
● preventing and detecting security threats, fraud or other criminal or malicious activities;
● ensuring compliance with legal obligations;
● complying with internal procedures and industry standards;
We ensure that access by our employees to your Service Data is only available on a need-to-know basis, restricted to specific individuals, and is logged and audited. We communicate our privacy and security guidelines to our employees and enforce privacy and protection safeguards strictly. The legal basis for the processing of your Service Data is our obligation to fulfil the contract we have with you.
Please note: Some jurisdictions may require you to disclose your use of our services and us as your processor in your privacy policy and/or data processing agreement as applicable. For this purpose, all Service Data processed by us will be sorted using the services of AWS (Amazon) and we take appropriate legal precautions and corresponding technical and organisational measures to ensure the protection of your Service Data.
l) Administration, financial accounting, office organization, contact management
We process data in the context of administrative tasks as well as the organisation of our business and compliance with legal obligations, such as archiving. In this regard, we process the same data that we process in the course of providing our contractual services. The processing bases are our legal obligations and our legitimate interest.
OTHER USES OF YOUR PERSONAL DATA
We may also collect, store, and use your Personal Data for the following purposes:
● to operate, manage, develop, and promote our business and, in particular, our relationship with you and related transactions, including, for example:
○ marketing purposes (when we have either gathered prior opt-in consent and/or have a legitimate interest to send you communications which we believe to be relevant and of use to you);
○ to operate, administer, and improve our website and other aspects of the way in which we conduct our business;
○ to offer you our services;
○ to provide you with services or information that you may have requested; and
○ to keep you informed and updated on relevant topics or services you may be interested in.
● to protect our business from fraud, money laundering, breach of confidence, theft of proprietary materials, and other financial or business crimes;
● to comply with our legal and regulatory obligations, bring and defend legal claims, and assert legal rights; and
● if the purpose is directly connected with an assigned purpose previously made known to you.
We will only process your Personal Data as necessary so that we can pursue the purposes described above and where we have a legal basis for such processing. Where our lawful basis for processing is that such processing is necessary to pursue our legitimate interests, we will only process your Personal Data where we have concluded that our processing does not prejudice you or your privacy in a way that would override our legitimate interest. In exceptional circumstances, we may also be required by law to disclose or otherwise process your Personal Data.
CHANGE OF PURPOSE
We will only use your Personal Data for the purposes for which we collected it as detailed above, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your Personal Data for an unrelated purpose, we will notify you, and we will explain the legal basis which allows us to do so.
DATA SHARING
In certain cases, it is necessary to transmit the processed Personal Data in the course of data processing. In this respect, there are different recipient bodies and categories of recipients.
a) Internal
If necessary, we transfer your Personal Data within Tap 2 Tip/Tap 2 Donate. Access to your Personal Data is only granted to authorised employees who need access to the data due to their job, e.g., to provide our services or to contact you in case of queries.
b) External bodies
Personal Data is transferred to our service providers in the following instances:
● in the context of fulfilling our contract with you,
● to use marketing services and to advertise our services online,
● to communicate with you,
● to provide our website, and
● to state authorities and institutions as far as this is required or necessary.
c) International transfers
We may transfer your Personal Data to other companies as necessary for the purposes described in this Privacy Policy. In order to provide adequate protection for your Personal Data when it is transferred, we have contractual arrangements regarding such transfers. We take all reasonable technical and organisational measures to protect the Personal Data we transfer.
MARKETING
Insofar as you have given us your consent to process your Personal Data for marketing and advertising purposes, we are entitled to contact you for these purposes via the communication channels you have given your consent to. Our marketing generally takes the form of email but may also include other less traditional or emerging channels. These forms of contact will be managed by us or by our contracted service providers. Every directly addressed marketing message sent by us or on our behalf will include a means by which you may unsubscribe or opt out.
LINKED SITES
For your convenience, our website may contain hyperlinks to other websites. We are not responsible for the privacy practices of linked websites or companies that are not owned or controlled by us, and this Privacy Policy does not apply to them. The links on our website may collect additional information in addition to the information we collect.
We do not endorse any of these linked websites, their products, services, or any content on their websites. We encourage you to read the privacy policies of each linked website you visit to understand how the information collected about you is used and protected.
SOCIAL MEDIA
We are present on social media based on our legitimate interest. If you contact or connect with us via social media, we and the relevant social media platform are jointly responsible for the processing of your data and enter into a so-called joint responsibility agreement. The Personal Data collected when you contact us is used to process your request, and the basis for this is both your consent and our legitimate interest.
HOW LONG DO WE KEEP YOUR PERSONAL DATA?
We will delete your Personal Data when we no longer need such Personal Data, for instance, where:
● it is no longer necessary for us to retain your Personal Data to fulfil the purposes for which we had collected it;
● we believe that your Personal Data that we hold is inaccurate; or
● in certain cases where you have informed us that you no longer consent to our processing of your Personal Data.
Sometimes, however, there are legal or regulatory requirements which may require us to retain your Personal Data for a specified period, and in such cases we will retain your Personal Data for such specified period; and we may need to retain your Personal Data for certain longer periods in relation to legal disputes, and in such cases we will retain it for such longer periods to the extent required.
DATA SECURITY
Our website uses SSL or TLS encryption to ensure the security of data processing and to protect the transmission of confidential content, such login data, or contact requests that you send to us. We have also implemented numerous security measures (“technical and organisational measures"), for example, encryption or need-to-know access, to ensure the most complete protection of Personal Data processed through our website.
YOUR RIGHTS AND PRIVILEGES
a) Privacy rights
You can exercise the following rights:
● The right to access;
● The right to rectification;
● The right to erasure;
● The right to restrict processing;
● The right to object to processing;
● The right to data portability;
b) Update your information and withdraw your consent
If you believe that the information we hold about you is inaccurate or request its rectification, deletion, or object to legitimate interest processing, please do so by contacting us.
c) Access Request
In the event you want to make a Data Subject Access Request, please contact us. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days, we will tell you why and when we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we will tell you why.
d) Complaint to a supervisory authority
You have the right to complain about our processing of Personal Data to a supervisory authority responsible for data protection. The supervisory authority in Ireland is: The Data Protection Commission (DPC) (www.dataprotection.ie). However, we would appreciate the opportunity to address your concerns before you contact the DPC or any other supervisory authority.
e) Data Breaches and Notification
Databases or records containing Personal Data may be breached accidentally or through unlawful intrusion. As soon as we become aware of a data breach, we will notify all affected individuals whose Personal Data may have been compromised, and the notification will be accompanied by a description of the measures that will be taken to repair the damage caused by the data breach. Notifications will be sent as soon as possible after the violation is discovered.
● We do not request Personal Data from minors and children without obtaining parental or legal guardian consent;
● We do not sell your Personal Data;
● We do not process Special Category Data without obtaining prior specific consent; and
● We do not use automated decision-making, including profiling.
HELP AND COMPLAINTS
If you have any questions about this policy or the information we hold about you, please contact us by email using info@tap2donate.ie or info@tap2tip.ie with "Data Protection" in the subject line.
CHANGES
The first version of this policy was issued on Wednesday, 22 January, 2025, and is the current version. Any prior versions are invalid, and if we make changes to this policy, we will revise the effective date.