Privacy Policy

Effective Date: January 20, 2025

1. Introduction

TAPP Engine, Inc. and its subsidiaries, including TAPP Engine Securities, LLC (a broker-dealer), TAPP Engine Advisors, LLC (an SEC-registered investment adviser), TAPP Engine Digital Assets (for crypto trading), and TAPP Cash (for cash management services), collectively referred to as "TAPP Engine," are committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you visit our websites, use our services, or interact with us.

2. Categories of Information We Collect

We may collect the following types of information:

Personal Information: Name, email address, phone number, mailing address, date of birth, Social Security number, and other identifying information as required by law to use the services.
Financial Information: Bank account details that include account numbers and transaction information, investment preferences, and transaction history.
Technical and Usage Information: IP address, browser type, device information, login and password details, and website usage data.
Cookies and Tracking Technologies: Information about your browsing behavior (see our Cookie Policy for details).

3. How We Use Your Information

We use the information we collect for purposes such as:

Providing and managing our financial services.
Processing transactions and verifying identities.
Enhancing user experience and improving our websites and services.
Ensuring compliance with legal and regulatory requirements.
Sending service updates, promotional offers, and customer support communications.
To verify your identity and authenticate you and your transactions.

4. How We Share Your Information

We do not sell your personal information. However, we may share it with:

Affiliated Entities: Subsidiaries and business partners within TAPP Engine.
Service Providers: Third-party entities for payment processing, technology platforms and information security, analytics, legal and regulatory compliance obligations, and marketing.
Regulatory and Legal Authorities: To comply with legal obligations or respond to lawful requests.
Financial Institutions: When necessary, we partner with or use financial institutions to support the services and financial transactions or financial advisory services. For information about our financial institution partners, see Account Agreement(s).

5. Data Security

We implement industry-standard security measures to protect your data, including encryption, access controls, and secure servers. However, no system is completely secure, and we encourage users to take precautions when sharing personal information online.

6. Your Privacy Rights

Depending on your jurisdiction, you may have the right to:

Access, correct, or delete your personal information.
Opt out of marketing communications.
Restrict or object to data processing.
Request data portability

To exercise these rights, please contact us at privacy-compliance@tappengine.com. Please also see the jurisdiction-specific terms at the end of this Privacy Policy.

7. Retention of Your Information

We retain personal data only as long as necessary to fulfill the purposes outlined in this policy or as required by law. After we stop providing services, we may retain your personal information: 1) to comply with legal and regulatory obligations; 2) to comply with contractual obligations, including obligations owed to financial institution partners; 3) to pursue or business purposes of detecting and preventing fraud; and 4) to comply with our tax, accounting, and financial reporting obligations.

8. Privacy of Minors/Children

Our services are not knowingly offered to minors under the age of 18. Our Account Agreement(s) and Terms of Service require users to represent that they are 18 years of age or older. We request that users under the age of 18 do not create an account or used the services or provide personal information through the services. If you believe a minor who is under the age of 18 has provided us with personal information, please contact us at privacy-compliance@tappengine.com.

9. Third-Party Links and Services

Our website may contain links to third-party sites. We are not responsible for the privacy practices of these external sites and encourage you to review their privacy policies.

10. Changes to This Policy

We may update this Privacy Policy periodically to reflect legal, technological, or business changes. We encourage you to review this policy regularly. Any significant changes will be communicated through our website or other appropriate channels.

State Resident Notices

Notice to Residents of Nevada

WE ARE PROVIDING YOU THIS NOTICE UNDER NEVADA STATE LAW. YOU MAY BE PLACED ON OUR INTERNAL DO NOT CALL LIST OR YOU MAY REQUEST TO EXERCISE YOUR “SALE” OPT-OUT RIGHTS UNDER NEVADA REVISED STATUTES CHAPTER 603A BY EMAILING US AT privacy-compliance@tappengine.com.

Notice to Vermont Residents

UNDER VERMONT LAW, WE WILL NOT SHARE ANY PERSONAL INFORMATION WE COLLECT ABOUT VERMONT RESIDENTS UNLESS THE LAW ALLOWS.

Pursuant to Vermont Regulation B-2018-01, TAPP does not share nonpublic personal information it collects about Vermont residents outside of our subsidiaries and affiliated companies unless legally permitted. For example, with your consent, we may share Vermont resident information to maintain your account or pursuant to joint marketing agreements with financial institutions with which we have executed agreements. Additionally, with your consent, we may share information about your creditworthiness with our subsidiaries and affiliated companies; however, we may share information about your transactions or our experiences with you with our subsidiaries and affiliated companies without your consent.

Notice to Residents of California

This section applies only to California residents. It describes how we collect, use, and share personal information of California residents when we act as a “business” as defined under California privacy laws, and their rights with respect to their personal information. For purposes of this section, “personal information” has the meaning given under California privacy laws but does not include information exempted from the scope of such laws. In some cases we may provide a different privacy notice to certain categories of California residents, in which case that notice will apply instead of this section.

Personal Information That We Collect, Purposes of Collection and Use, and Disclosures, “Sales,” and “Sharing” of Personal Information

We describe the categories of personal information we collect and may have collected about you in the preceding 12 months, and the categories of sources from which we collect such personal information, in the section above called “Personal Information We Collect.”

The specific business and commercial purposes for which we collect and use this information are described in the section above called “Use of Personal Information.” To the extent that we collect personal information that qualifies as “sensitive” under California privacy laws, we only use or disclose it for purposes permitted under those laws (e.g., to perform the Services, detect security incidents and prevent fraud, and to verify and maintain the quality of the Services). We do not collect or use sensitive personal information for the purpose of inferring characteristics about California residents.

Personal Information Disclosed for Business Purposes, “Sold,” or “Shared”

Each category of personal information listed above may be disclosed, and has in the preceding 12 months been disclosed to the categories of third parties set out in the section above called “Sharing of Personal Information” for the business purposes described in the Privacy Policy, such as to provide the Services or for research and development.

In addition, when we provide personal information to certain third parties or permit them to automatically collect personal information on the Services (such as our advertising partners like Google), California privacy laws may define this type of disclosure as a “sale” or “sharing” of personal information. Specifically, when we “sell” personal information, that means we are disclosing a California resident’s personal information to a third party for monetary or other valuable consideration. We do not sell your personal information. When we disclose personal information to third parties for purposes of cross-context behavioral advertising, whether or not for monetary or other valuable consideration, it qualifies as “sharing” under California law.

We may “sell” or “share,” and in the preceding twelve months may have “sold” or “shared,” (1) Individual Identifiers, and (2) Internet or Network Activity, in each case for purposes of advertising our Services, identifying new customers or potential customers, and the other purposes described above under the section titled “Use of Personal Information.” We do not knowingly “sell” or “share” the personal information of California residents under 16 years of age.

Retention of Personal Information

We will retain each of the categories of personal information listed above for as long as necessary to fulfill the purpose of collection, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish and defend legal claims, for fraud prevention purposes, or as long as required to meet our legal obligations. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

Your California Privacy Rights

California privacy law provides California residents with the rights listed below. Please note, these rights are not absolute and in some cases we may not be able to respond to your request, such as when a legal exemption applies or if we are not able to verify your identity.

Right to Access/Know. You have the right to request certain information about our collection and use of your personal information, including:

The categories of personal information we have collected about you.
The categories of sources from which the personal information is collected.
The business or commercial purpose for collecting, selling, or sharing personal information.
The categories of third parties to whom we disclose personal information.
The specific pieces of personal information we have collected about you.

Right to Delete. You have the right to request to delete personal information that we have collected from you, subject to certain exceptions.

Right to Correct. You have the right to request us to correct inaccurate personal information that we maintain about you.

Right to Opt-Out of Sales or Sharing. If we “sell” or “share” your personal information, you can opt-out.

Right to Nondiscrimination. You are entitled to exercise the rights described above without receiving discriminatory treatment.

Access/Know, Deletion, or Correction Rights. To exercise the access/know, deletion, or correction rights described above, please submit a request to us and provide the information we request that is required to verify your request by Emailing us at privacy-compliance@tappengine.com.

Right to Opt-Out of the “Sale” or “Sharing” of Personal Information. Under California law, some of the data we share with our advertising partners may qualify as a “sale” or “share” as defined under California law. To exercise your right to opt-out of such “sale” or “sharing”, please: Email us at privacy-compliance@tappengine.com.

When exercising your rights or otherwise assisting you, we may need to request specific information from you to help us confirm your identity. This is a security measure to ensure we do not, for example, disclose personal information to any person who is not entitled to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. The identity verification process may vary based on the type of request and how it is submitted.

You may also designate an authorized agent to make a request on your behalf. If you do so, we may require your proof of identification, the authorized agent’s proof of identification, and any other information that we may request in order to verify your request, including evidence of valid permission for the authorized agent to act on your behalf.

Please note, we will not be able to process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee or decline to comply with your request if your request is clearly unfounded, repetitive, or excessive.

“Shine the Light” Requests

Under California Civil Code sections 1798.83-1798.83, California residents are entitled to ask us, once per year, for a notice identifying the categories of information which we share with our affiliates or third parties for marketing purposes, and providing contact information for such affiliates or third parties. Requests will apply to information provided during the previous calendar year. If you are a California resident and would like a copy of this notice, please submit a written request to: support@tappcash.com with the subject heading: “California Shine the Light Request” or to TAPP Engine, Inc, privacy-compliance@tappengine.com (Attn: Privacy).

California Notice of Financial Incentive

We may offer certain financial incentive programs that can result in different price, rate, level, or quality of goods or services, provided that such programs are reasonably related to the value of your personal information to us. For example, we may offer additional content to users who sign up for our mailing list, or giveaways, sweepstakes, contests, or other similar promotional campaigns. We typically ask you to provide your email address or other contact information in order to participate in these programs or campaigns.

We offer these programs and campaigns because, among other things, the value of your personal information to us is related to the value of the free or discounted services, or other benefits that you obtain or that are provided as part of the applicable program or campaign. This value is based on the expense related to offering those services and benefits to participants, along with other factors such as whether and to what extent you take advantage of (or opt-out from) any offerings and whether we are able to use the data we collect from you.

When we offer any program or campaign, there is no obligation to opt-in, and you may withdraw at any time by contacting us using the designated method set forth in the applicable program rules.

Contact Us

If you have any questions regarding this Privacy Policy or our data practices, please contact us at:

TAPP Engine, Inc.
1400 Hancock Street, 6th Floor, Quincy, MA 02169
info@tappengine.com