PRIVACY POLICY

Last Updated November 28, 2022

Welcome to the Tapt App website (the “Site”) and mobile application (the “App”), which are operated by FCTI, Inc. (“FCTI,” “we,” “us,” or “our”). We provide access to a deposit account, debit card, and small-dollar credit line that you apply for and establish with our bank partner, as well as financial health tools, bank account aggregation and credit monitoring and reporting (the “Services”).

This Privacy Policy explains what Personal Information (defined below) we collect from or about visitors to the Site and/or the App, how we use and share that information, and your choices concerning our data practices. This Privacy Policy is incorporated into and forms part of our Terms of Service. Please note that this Privacy Policy generally does not apply to Personal Information collected through means other than the Site or the App. Personal Information processed in connection with the Services is also governed by a separate privacy notice and applicable agreements of our bank partner, as required by applicable law.

Before using the Site or submitting any Personal Information to us, please review this Privacy Policy carefully and contact us if you have any questions. By using the Site, you agree to the practices described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not access the Site or the App or submit any Personal Information to us.

NOTICE OF ARBITRATION PROVISIONS:

Your use of the Site, the App or the Services will subject you to binding individual arbitration of any disputes which may arise from the Site, the App, or the Services, as provided in Section 23 of the Tapt App Terms of Service. Please read the arbitration provisions carefully and do not use our Site, the App or the Service if you are unwilling to arbitrate any disputes you may have with us (including without limitation any disputes relating to this Privacy Policy or our privacy practices) as provided in the Terms of Service.

• PERSONAL INFORMATION WE COLLECT

We collect information that alone or in combination with other information in our possession could be used to identify you (“Personal Information”) as follows:

Personal Information You Provide: We collect Personal Information when you complete a form on the Site or the App, email us from the Site or the App, or otherwise interact with us through the Site or the App. The Personal Information collected during these interactions may vary based on what you choose to share with us, but it will generally include name, email, phone number, company, and title.

Personal Information We Collect Through Our Social Media Pages: We have pages on social media sites like Facebook, Medium, Twitter, and LinkedIn (“Social Media Pages”). When you interact with our Social Media Pages, we will collect Personal Information that you elect to provide to us, such as your contact details. In addition, the companies that host our Social Media Pages may provide us with aggregate information and analytics regarding the use of our Social Media Pages.

Personal Information We Receive Automatically From Your Use of the Site or the App: When you visit, use, and interact with the Site or the App, we may receive certain information about your visit, use, or interactions. For example, we may monitor the number of people that visit the Site or the App, peak hours of visits, which page(s) are visited, the domains our visitors come from (e.g., google.com, yahoo.com, etc.), which browsers people use to access the Sites (e.g., Chrome, Firefox, Microsoft Internet Explorer, etc.), broad geographical information, and navigation pattern. In particular, the following information is created and automatically logged in our systems: 

• Log data: Information that your browser automatically sends whenever you visit the Site or the App (“log data”). Log data may include your Internet Protocol address, browser type and settings, the date and time of your request, and how you interacted with the Site or the App. 
• Cookies: Please see the “Cookies” section below to learn more about how we use cookies.
• Device information: Includes name of the device, operating system, and browser you are using. Information collected may depend on the type of device you use and its settings. 
• Usage Information: We collect information about how you use our Site and the App, such as the types of content that you view or engage with, the features you use, the actions you take, and the time, frequency, and duration of your activities.

Cookies: We use cookies to operate and administer our Site, gather usage data on our Site, and improve your experience on it. A “cookie” is a piece of information sent to your browser by a website you visit. Cookies can be stored on your computer for different periods of time. Some cookies expire after a certain amount of time, or upon logging out (session cookies), others survive after your browser is closed until a defined expiration date set in the cookie (as determined by the third party placing it), and help recognize your computer when you open your browser and browse the Internet again (persistent cookies).

On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive a notification when you are receiving a new cookie and how to turn cookies off. Please see the links below for guidance on how to modify your web browser’s settings on the most popular browsers:

• Internet Explorer
• Mozilla Firefox
• Google Chrome
• Apple Safari

Please note that if you limit the ability of websites to set cookies, you may be unable to access certain parts of the Site and you may not be able to benefit from the full functionality of the Site.

Advertising networks may use cookies to collect Personal Information. Most advertising networks offer you a way to opt out of targeted advertising. If you would like to find out more information, please visit the Network Advertising Initiative’s online resources at http://www.networkadvertising.org and follow the opt-out instructions there.

If you access the Site on your mobile device, you may not be able to control tracking technologies through the settings. 

Email Pixels: We use pixels in our email campaigns that allow us to collect your email and IP address as well as the date and time you open an email or click on any links in the email.

Analytics: We use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help us analyze how users use the Site and enhance your experience when you use the Site. For more information on how Google uses this data, go to www.google.com/policies/privacy/partners/.

Online Tracking and Do Not Track Signals: We and our third party service providers, including Facebook, may use cookies, pixels, or other tracking technologies to collect information about your browsing activities over time and across different websites following your use of the Site and use that information to send targeted advertisements. Our Site currently does not respond to “Do Not Track” (“DNT”) signals and operates as described in this Privacy Policy whether or not a DNT signal is received. If we do respond to DNT signals in the future, we will update this Privacy Policy to describe how we do so.

ATM Transactions: In the process of providing cash and financial account access at an automated teller machine (“ATM”), we collect the following Personal Information:

• Terminal ID – The location at which the transaction is taking place.
• Partial PAN – A portion of the card number used for the transaction.
• Transaction Date and Time – The day and time of the transaction.
• Withdrawal Amount – The amount of money requested for dispense.
• Surcharge – The total amount charged by the ATM for the transaction to be processed.
• Response Code – The response from the queried financial institution.
• Transaction Code – The result of the transaction.

In some instances, when you use certain features of the Site, the App or the Service, we may collect the email addresses or other Personal Information of others that you may provide. Unless stated otherwise at the point of collection, we will treat any such Personal Information that you submit about other people in accordance with this Policy.

1. HOW WE USE PERSONAL INFORMATION

We may use Personal Information for the following purposes:

• To respond to your inquiries, comments, feedback, or questions;
• To send administrative information to you, for example, information regarding the Site and the App and changes to our terms, conditions, and policies;
• To analyze how you interact with the Site and the App;
• To maintain and improve the content, functionality, and security of the Site and the App;
• To develop new products and services;
• To consider you for employment.
• To prevent fraud, criminal activity, or misuses of the Site or the App, and to ensure the security of our IT systems, architecture, and networks; and
• To comply with legal obligations and legal process and to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or other third parties.

We do not sell the Personal Information we collect.

Aggregated Information. We may aggregate Personal Information and use the aggregated information to analyze the effectiveness of the Site and the App, to improve and add features to the Site and the App, and for other similar purposes. In addition, from time to time, we may analyze the general behavior and characteristics of users of our Site and/or the App and share aggregated information like general user statistics with prospective business partners. We may collect aggregated information through the Site, through cookies, and through other means described in this Privacy Policy.

Marketing. We may use your Personal Information to contact you to tell you about information, news, events, sweepstakes, products, or services we believe may be of interest to you. For instance, if you elect to provide your email or telephone number, we may use that information to send you promotional messages. You may opt out of receiving emails by following the instructions contained in each promotional email we send you. In addition, if at any time you do not wish to receive future marketing communications, you may contact us. If you unsubscribe from our marketing lists, you will no longer receive marketing communications but we will continue to contact you regarding management of your account, other administrative matters, and to respond to your requests.

• SHARING AND DISCLOSURE OF PERSONAL INFORMATION

In certain circumstances we may share your Personal Information without further notice to you, unless required by the law, as set forth below:

• Vendors and Service Providers: To assist us in meeting business operations needs and to perform certain services and functions, we may share Personal Information with vendors and service providers, including providers of hosting services, cloud services, and other information technology services providers, event management services, email communication software and email newsletter services, advertising and marketing services, payment processors, customer relationship management and customer support services, and web analytics services.
• Business Transfers: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of all or a portion of our assets, or transition of service to another provider (collectively a “Transaction”), your Personal Information and other information may be shared in the diligence process with counterparties and others assisting with the Transaction and transferred to a purchaser, successor, or affiliate as part of that Transaction along with other assets.
• Legal Requirements: If required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, including to meet national security or law enforcement requirements, (ii) protect and defend our rights or property, (iii) prevent fraud, (iv) act in urgent circumstances to protect the personal safety of users of the Services, or the public, or (v) protect against legal liability.

1. CALIFORNIA PRIVACY RIGHTS DISCLOSURES

California Civil Code Section § 1798.83 permits users of the Services that are California residents to request the categories of Personal Information we disclosed to third parties for their direct marketing purposes in the year preceding the request, the names and addresses of such third parties, and, in certain circumstances, examples of the products or services marketed by such third parties. California residents also have the right to request copies of all personal information held by a company, the right to request information about the personal information held by the company, and the right to request deletion of that personal information. These requests may be made once per year. To make such a request, please email us at contact@fcti.net or write us at:

FCTI, Inc.

Attn: Internal Control Office

11766 Wilshire Blvd., Suite #1100

Los Angeles, CA 90025

1. CHILDREN

The Site and the App do not direct content to minors and are not designed or intended for use by children under 13. Children under 13 are expressly prohibited from submitting any Personal Information to us, and if we discover that we have inadvertently gathered any such information from a child under 13, we will take appropriate steps to delete it.

By using the Site or the App, you represent that you are at least the age of majority in your state or province of residence.

If you allow your minor dependent (the “minor’) to access and use the Site and/or the App, you agree that you will be solely responsible for:

• The online conduct of such minor;
• Monitoring such minor’s access to and use of the Site and the App; and
• The consequences of any use by the minor.

1. LINKS TO OTHER WEBSITES

The Site and the App may contain links to other websites and services not operated or controlled by us, including social media services (“Third Party Sites”). The information that you share with Third Party Sites will be governed by the specific privacy policies and terms of service of the Third Party Sites and not by this Privacy Policy. By providing these links we do not imply that we endorse or have reviewed these sites. Please contact the Third Party Sites directly for information on their privacy practices and policies. 

1. SECURITY

You use the Site and the App at your own risk. We implement commercially reasonable technical, administrative, and organizational measures to protect Personal Information transmitted via the Site and/or the App from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or e-mail transmission is ever fully secure or error free. For example, e-mail sent to or from us may not be secure. Therefore, you should take special care in deciding what information you send to us via the Site, the App or e-mail. Please keep this in mind when disclosing any Personal Information to us via the Internet. In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the Site, the App or third party websites.

• YOUR CHOICES

In certain circumstances, providing Personal Information is optional. However, if you choose not to provide Personal Information that is needed to use some features of the Site or the App, you may be unable to use those features. You can also contact us to ask us to change, update, or correct your Personal Information.

• CHANGES TO THE PRIVACY POLICY

The Site, the App and our business may change from time to time. As a result we may change this Privacy Policy at any time. When we do, we will post an updated version on this page, unless another type of notice is required by applicable law. By continuing to use the Site and/or the App or providing us with Personal Information after we have posted an updated Privacy Policy, or notified you by other means if applicable, you consent to the revised Privacy Policy and practices described in it.

• CONTACT US

If you have any questions about our Privacy Policy and/or if you would like to access, correct, amend or delete any Personal Information we have about you, submit a request by either emailing our Internal Control Office at ico@fcti.net or by mail to:

FCTI, Inc.

Attn: Internal Control Office

11766 Wilshire Blvd., Suite #300

Los Angeles California 90025

Rev. March 25, 2022