—— 01Who we are
This Privacy Notice is issued by TAPLY Foundation, a foundation company incorporated in the British Virgin Islands ("we", "us", the "Foundation" or the "Controller").
For all matters relating to personal data, you may contact our Data Protection Officer at privacy@taply.network.
This Notice applies in addition to, and does not replace, applicable local privacy laws including the UK GDPR, the EU GDPR, and the Data Protection Act 2018, where relevant to a participant.
—— 02Data we collect
We collect personal data only where necessary to onboard, verify, and communicate with pre-sale participants and to comply with our legal obligations.
—— 03Purposes and legal bases
—— 04On-chain data — important notice
Once Tokens are issued to your wallet, certain data is recorded on a public blockchain (Ethereum or Solana). This includes your public wallet address, the amount of Tokens issued or transferred, and the timestamp.
Public-blockchain data is, by design, permanent, public, immutable and global. The Foundation cannot delete, modify or restrict blockchain entries. Your right to erasure under Article 17 GDPR cannot apply to on-chain data because the data is not held by us — it is held by a public, decentralised network.
You acknowledge this irreversibility before submitting a wallet address. We strongly recommend you use a wallet address that you do not associate with any sensitive off-chain identity.
—— 05Sharing with third parties
We share personal data only with carefully selected processors and partners, under appropriate contractual safeguards:
- KYC / AML providers — for identity verification, sanctions and PEP screening.
- Custody and treasury partners— for the security of the Foundation's wallets.
- Cloud hosting — for the secure storage of records.
- Legal, audit and tax advisors — under professional confidentiality.
- Regulators, courts, and law-enforcement agencies — where we are legally required to disclose.
- Acquirers or successors — in the event of a corporate reorganisation, subject to the same obligations.
We do not sell personal data. We do not share data with advertising networks.
—— 06International transfers
Personal data may be transferred outside your jurisdiction, including to the British Virgin Islands, the United Kingdom, the European Economic Area, and other jurisdictions where our processors are located. Where required, transfers are protected by Standard Contractual Clauses, an adequacy decision, or an equivalent safeguard.
—— 07Retention periods
- KYC records: retained for the duration of the relationship plus 5 years after termination (UK AMLR, EU AMLR equivalent).
- Transaction records: 7 years from the transaction date.
- Investor communications: 3 years from last contact.
- Marketing email lists: until you unsubscribe, or maximum 2 years from last interaction.
- On-chain data: permanent — see Section 4.
—— 08Your rights
Subject to applicable law (UK GDPR, EU GDPR or local equivalent), you may have the following rights in respect of off-chain personal data we hold about you:
- Access — receive a copy of your data;
- Rectification — correct inaccurate data;
- Erasure — request deletion, subject to legal retention obligations;
- Restriction — limit our processing in certain circumstances;
- Portability — receive your data in a structured machine-readable format;
- Objection — object to processing based on legitimate interests;
- Withdraw consent — where processing is based on consent.
To exercise any right, contact privacy@taply.network. We will respond within one month.
—— 09Cookies & analytics
Our public website uses only essential cookies and privacy-friendly analytics (no third-party advertising cookies). A cookie banner is presented to first-time visitors where required by applicable law.
—— 10Security
We apply technical and organisational measures appropriate to the sensitivity of the data, including encryption in transit and at rest, strict access controls, multi-factor authentication, segregation of duties, and regular security audits. No system is completely secure; we encourage you to use strong passwords and unique credentials.
—— 11Contact & complaints
Questions, requests or complaints: privacy@taply.network.
You also have the right to lodge a complaint with the data protection authority in your jurisdiction (in the UK, the ICO; in the EU, your national supervisory authority).