TAPTYPE DIGITAL HEALTH INC.

2163 Sixth Line
Oakville, Ontario
L6H 3N7
Canada

1. Introduction

   1. TapType Limited and any subsidiaries and affiliates it may have (“TapType” or, in this privacy notice, “we”, “us”, “our”) is strongly committed to protecting your Personal Data (as defined below). This Privacy Notice sets out how we collect, use and protect your Personal Data. Please read the following carefully to understand our practices regarding your Personal Data processed via https://taptype.co (the “Website”) and how we treat and safeguard it. 

   2. This notice (“Notice”) has been developed to ensure our clients/ licensees (“Clients”), and Website users and all other Data Subjects whose Personal Data is processed under the control of TapType feel confident about the privacy and security of Personal Data, and to meet our obligations under EU Regulation 679/2016 General Data Protection Regulation (“GDPR”) and the Data Protection Acts of Ireland 1988-2018 (together “Data Protection Law”).

For the purposes of this Notice, Personal Data is information that identifies you as an individual or is capable of doing so (“Personal Data”).  

3. We must comply with the data protection principles set down in Data Protection Law and this Notice applies to all Personal Data collected, processed and stored by us that is subject to the laws described above. By providing us with information, you accept and agree to the practices described in this Notice. 

4. For the purposes of Data Protection Law, TapType Limited is the Data Controller of your Personal Data. You will find our contact details in the “Contact us” section below.

5. The terms “Data Subjects”, “Data Controller”, “Data Processor” and “process”, when used in this Notice, have the meanings given to them in Data Protection Law, unless otherwise indicated. 

2. What kinds of Personal Data do we collect?

   1. We may collect the following types of Personal Data:

      1. TapType Clients:

         1. Contact details of Clients including name, title, personal phone number, work phone number, email address and address; and

         2. financial information including VAT numbers (if you are based in a Member State of the EU);

      2. browsers of the Website:

         1. device identifiers, such as IP addresses or other identifiers constituting Personal Data (see further at sections 2.2 to 2.4 below); 

         2. if you contact us directly, we may receive additional information about you such as your name, email address, phone number, the contents of the message and/or attachments you may send us, and any other information you may choose to provide

   2. As noted above, even if you do not explicitly provide us with data when you interact with the Website, we may collect certain data. For example, our servers may keep an activity log that tracks all visitors to the Website. The information collected will often be anonymous and therefore may not identity you individually, however such information, or such information in conjunction with other information that we hold, may be capable of identifying you and so may constitute Personal Data (“Website Data”). Website Data may include among, other data:

      1. the country in which you reside;

      2. referring/exit URLS and other information that does not identify you directly or indirectly but may correspond with you or a particular device; and

      3. information about your browser type, device type and unique device information as well as your operating system, websites you visted before and after visiting the website(s), standard server log information and IP address. 

   3. If any Website Data constitutes Personal Data (whether directly or through linking or associating any Wesbite Data with any other information), the terms of this Notice will apply. Otherwise, we use and disclose Website Data in a non-personally identifiable form.

   4. The Website interact with other sites, including social media websites such as LinkedIn, (and may use social media plugins) to facilitate social media functions. We have no control over the information that other websites or social media websites or plugins collect, store, or use. Before you choose to access other websites or social media platorms from the Website, please be certain that you review the privacy notice of that social media platform or website. 

3. Legal basis for processing 

   1. We rely on the following legal bases under GDPR in processing Personal Data: 

      1. performance of a contract with you (in the case of Clients);

      2. consent (as indicated at the time of obtaining such consent); and

      3. legitimate interests (for example, in the event of a complaint or legal action being taken against us).

4. How we Collect Personal Data

We collect Personal Data from your interaction with us, for example:

1. when transacting with Clients;

2. when you browse the Website

3. when you otherwise contact us through, for example through the Website or via email. 

5. How we may use your Personal Data

   1. Except as set out in this Notice, we will not disclose Personal Data that we collect to any parties other than those with whom we partner or are affiliated with, without your consent. Except as set out below, we will not sell, share, trade, rent, or give away your Personal Data.

Information you directly provide 

2. We may use your Personal Data in the conduct of our business with you, for example, in order to fulfil our contract with you, upon your consent for the purposes of contacting you regarding our services.

Information you do not directly provide

3. As noted at section 2.3 above, we use Website Data to administer, operate, and improve the website(s).

6. Do we disclose Personal Data to anyone else?

   1. We shall disclose your Personal Data to third parties only when it is necessary as part of our contract with you, for the conduct of business or when there is a legal or statutory obligation to do so. Whenever we disclose your Personal Data to third parties, we will only disclose that amount of your Personal Data necessary to meet such business need or legal requirement. Third parties that receive your Personal Data from us must satisfy us as to the measures taken to protect the Personal Data such parties receive, in accordance with Data Protection Law and as stated in this Notice. Appropriate measures will be taken to ensure that all such disclosures or transfers of your Personal Data to third parties will be completed in a secure manner and pursuant to contractual safeguards.

   2. We may employ other companies and individuals to perform functions on our behalf, including professional advisors, outsourced services providers and contractors in order to fulfil our contract with you. These third-party service providers are authorised to use Personal Data only as needed to perform their functions on our behalf and are required to maintain the security of your Personal Data.

   3. TapType’s various entities may also share Personal Data internally (i.e. within the TapType group, including to TapType’s holding company) where necessary as part of business and in order to fulfil our contract with you.

   4. We may transfer your Personal Data to another company with which we have merged, or which has acquired all or some of our assets. We will advise you if such a change of ownership or change of corporate structure takes place and we will update this Notice accordingly. 

   5. We may provide your Personal Data when obliged to do so under relevant Data Protection Law and in response to properly made requests, for example, for the purpose of the prevention and detection of crime, and the apprehension or prosecution of offenders. We may also provide your Personal Data for the purpose of safeguarding national security. In the case of any such disclosure, we will do so only in accordance with the relevant Data Protection Law.

   6. We may also provide your Personal Data when required to do so by law, for example under a court order, and may transfer data to legal counsel where same is necessary for the defence of legal claims.

7. Transfers outside of the EEA 

   1. Your Personal Data may be processed by TapType or its trusted third party partners outside of the European Economic Area (“EEA”). Data privacy laws in the countries to which your personal data is transferred may not be equivalent to, or as protective as, the laws in the EEA. 

   2. We will implement appropriate measures to ensure that your Personal Data remains protected and secure when it is transferred outside of the EEA, in accordance with applicable Data Protection Law.  

8. How long do we keep Personal Data?

   1. The period for which we retain Personal Data varies according to the use of that information. In some cases, there are legal requirements to keep Personal Data for a minimum period of time. Unless specific legal requirements dictate otherwise, we will retain Personal Data no longer than is necessary for the purposes for which the Personal Data were collected and processed (as described above). 

   2. Personal Data of Clients will be retained for no longer than is necessary for the purposes for which it was collected. We will retain your Personal Data for as long as we continue to provide our services to you. Following termination of the provision of the services to you, your Personal Data shall be retained for as long as is necessary and permissible in accordance with statutory limitation periods.

9. How you can exercise your rights in respect of Personal Data we hold about you? 

Your rights

1. We shall vindicate all rights under European Data Protection Law. You have the right to request that we:

   1. provide you with information as to whether we process your data and details relating to our processing, and that we provide you with a copy of your data (‘access right’);

   2. rectify and/or update any inaccurate data we might have about your without undue delay (‘right to rectification’);

   3. the right to object to processing of data relating to you (‘right to object’);

   4. under certain circumstances, be restricted from processing your data (‘right to restriction’);

   5. under certain circumstances, erase your personal data without undue delay (i.e. the “right to erasure”); and

   6. under certain circumstances, furnish you with the personal data which you provided us with in a structured, commonly used and machine readable format (‘right to data portability’). 

2. Vindication of these rights shall not affect any rights which we may have under European Data Protection Law. 

Exercising your rights and managing Personal Data 

3. You can exercise any of your rights by making a request to us at the contact information provided below. If, for some reason, these rights are denied, we will provide an explanation of why this is the case.

4. We will process your request within 30 days of receipt.

10. security of your Personal Data

    1. We are committed to ensuring that all of your information, including Personal Data, is secure. In order to prevent unauthorised access or disclosure, we have put in place appropriate technical and organizational measures to safeguard and secure your Personal Data.

    2. Once we have received your Personal Data, we will use strict procedures and security features to try to prevent unauthorised access. 

    3. Unfortunately, the transmission of information through the Website is not completely secure. Although we will do our best to protect your Personal Data and apply appropriate safeguards, we cannot guarantee the security of your data transmitted through the Website and any transmission is at your own risk. 

11. How can you make a complaint about the Use of Personal Data?

    1. Complaints on the use, retention and disposal of Personal Data can submitted via email to contact@taptype.co.

    2. Under European Data Protection Law, you also have the right to lodge a complaint with the relevant supervisory authority of your country.

12. Review

    1. This Notice will be reviewed and updated from time to time to consider changes in the law and the experience of the Notice and TapType’s processing of Personal Data in practice. Any and all changes will be published on the Website. We encourage you to periodically review this Notice to stay informed about how we collect, use, and disclose Personal Data.

13. Contact information

    1. If you have questions about this Notice or our treatment of the Personal Data provided to us, please contact us at:

Name: TAPTYPE Limited

ATTN: Data Privacy Champion

Address: 95 Ardilea Crescent, Heidelberg, Ardilea, Clonskeagh, Dublin 14, Ireland

E-mail:  contact@taptype.co

Last updated: 2 Sept 2022.