Privacy Policy

At NexTap ( “www.thenextap.com” , “NexTap platform”, “the platform”, “we”, “us”), we are dedicated to safeguarding your personal data while adhering to relevant privacy laws and regulations, including the California Consumer Privacy Act (CCPA) and the General Data Protection Regulation (GDPR). This Privacy Policy outlines how NexTap, based out of California, US, along with its affiliates, collects, processes, and secures your personal information.

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Scope

This Privacy Policy applies to all data processing activities conducted within any of our services, systems, platforms, and applications where personal data is handled and incorporates this policy or contains a reference to it. It also covers the processing of personal data from visitors to the NexTap website, representatives of our business partners, individuals who contact us through our website, and job applicants for positions at NexTap.

In the case of any discrepancies between this Privacy Policy and specific Privacy Policies applicable to certain NexTap products or services, the specific Privacy Policy shall take precedence.

NexTap as Data Processor

NexTap operates the NexTap Platform, which is comprehensive hotel management software that facilitates enterprise administration and operations, including reservation, order, and customer management. This NexTap Platform is used by various service providers, known as "Enterprises," based on contractual agreements with NexTap. In these instances, personal data is collected by the Enterprises, and NexTap acts as a data processor, processing the data under the instructions of the Enterprise, which acts as the data controller. The processing of this personal data is governed by the respective Enterprise's Privacy Policy.

What should the privacy policy include?

A standard privacy policy should include: what data you collect from visitors, how you collect it, why you are collecting the data, how you are using the data.

Definitions

• NexTap Platform:Refers to the collection of applications and systems provided by NexTap to Users and Enterprises.
• User:An individual who signs up to use the NexTap Platform.
• User Account:The user account created by a User on the NexTap Platform.
• Enterprise:A customer of NexTap entitled to use the NexTap Platform based on a separate contract.
• NexTap Personal Area:A part of the NexTap Platform that enables Users to manage their User Account and data, reservations, orders, and other services provided by Enterprises. It also facilitates communication with Enterprises and the use of other services as provided by Enterprises.
• NexTap Business Area:A part of the NexTap Platform that allows Users to act on behalf of Enterprises or NexTap.
• Enterprise Scope: A segment of the NexTap Business Area controlled by a single Enterprise. Within the Enterprise Scope, Users can manage data, settings, reservations, orders, applications, customers, and use other functionalities available in the NexTap Platform on behalf of that Enterprise. To access the Enterprise Scope, a person must be a User and have an Enterprise Profile.

A.Data Collection and Processing

At NexTap, we may collect and process the following categories of personal data when you interact with our services and platforms:

A1. NexTap Services:

• Identification details (first name, last name)
• Contact details, such as address, phone number, and email address
• Information about your reservations and orders, including past records
• Payment information, including credit/debit card details
• ID/passport information (if applicable for accommodation services reservations/orders)
• Enterprise Scopes you have been granted access rights to

A2. NexTap Website:

• Identification details (first name, last name)
• Contact details, such as address, phone number, and email address
• Events/webinars you signed up for
• Newsletters you signed up for
• Information about the company you work for and your work position
• Any additional information you provide to us

A3. NexTap Customer Verification:

For the purpose of verifying the identity of our customers entering into contractual relationships with us for NexTap services, we collect and process the following categories of personal data of company representatives and ultimate beneficial owners:

• Identification data (first name, last name, date of birth) and contact data, such as personal address, phone number, email address, job title/position, and citizenship
• Identification documents, such as passports, ID cards, driver's licenses, and proof of address documents
• Ownership information, including whether the person is a politically exposed person

A4. NexTap Customer Services:

• Identification details (first name, last name)
• Contact details, such as address, phone number, and email address
• Information about the company you work for and your work position
• Video/voice recordings of your interactions with our customer service center
• Any further information you choose to share with us

A5. NexTap Careers:

• Identification details (first name, last name)
• Contact details, such as address, phone number, and email address
• Information from your CV and Cover Letter, including details about your past positions, qualifications, etc.
• Any additional information you provide during the recruitment process

B. Data Processing Procedures

At NexTap, we process data in the following ways:

B1. NexTap Services:

When you create a User Account on the NexTap Platform, we process your log-in data (your email address) and data related to the services you reserve or order, including historical service and order information

For reservations or orders with accommodation providers, we also process information required for accommodation registration cards.

If you receive an invitation to an Enterprise Scope, we process the access rights granted to Enterprise Scopes within the NexTap Platform.

We process this data to deliver the functionalities of the NexTap Personal Area to you, as per the purpose and legal basis of such processing.

B2. NexTap Website:

For marketing purposes, NexTap may use your data if you sign up for our newsletter or other marketing communications that may be of interest to you based on your past preferences. These communications strictly adhere to applicable legal regulations. Any advertising and marketing materials from other parties will only be sent to you if you explicitly opted in to receive such communications, whether through our website, email, or other means. The legal basis for processing your data for marketing purposes is your consent or our legitimate interests.

You have the option to decide whether you want to receive marketing communications, and you can exercise this choice by using the opt-out feature described in each marketing email or communication. Additionally, you can opt-out by adjusting the settings in your User Account or by directly contacting NexTap. If you choose to opt out, NexTap will retain only the data necessary for providing services to you in accordance with the rules outlined in this policy.

B3. NexTap Customer Verification:

For customer verification, NexTap collects all the required information and data and submits it to payment processing providers to facilitate the KYC (know your customer) process, as mandated by anti-terrorism, anti-money laundering, anti-terrorist financing, financial services, and other applicable laws and regulations. As part of this process, NexTap also conducts identity verification and status checks for company representatives and ultimate beneficial owners through a third-party provider.

NexTap processes this data on the legal basis of performance of contract and legitimate interest of NexTap for the purpose of verifying customer identity.

B4. NexTap Customer Services:

At NexTap, we may record calls with our clients to process associated personal data based on legitimate interest. This is done for the purpose of ensuring evidence of the proper provision of services and to defend against any client claims.

Before the commencement of every call, we provide notice to our clients about the recording. By continuing the phone call, you agree to the recording taking place and capturing expressions of a personal nature. If you prefer to communicate with us in an alternative manner, please reach out to us at [email protected] .

We also record calls (audio and video) with our clients and potential clients for internal training, business intelligence, and note-taking purposes. This recording is based on your consent, obtained before the recording begins. By providing consent to the call recording, you agree with the recording taking place and capturing expressions of a personal nature. You have the right to withdraw your consent at any time by sending a message to [email protected] , and in such cases, we will promptly delete the recording.

B5. NexTap Careers:

If you apply for any open job positions at NexTap through our website or other means, we will process the personal data you provide to us. This is done for the purposes of evaluating your application and assessing your suitability as a candidate for any of our positions. As part of the evaluation process, we may conduct pre-employment screening to verify the information contained in your CV and other documents provided. For certain positions, you may be requested to provide us with your criminal record. Rest assured that the pre-employment screening adheres to proportionality, adequacy, and compliance with applicable laws. The legal basis for processing this data is the performance of contract or pre-contractual relations, or your consent where applicable. The respective NexTap affiliate to which you applied for a job position shall be considered the data controller.

With your consent, we may retain your CV in our internal database for future consideration for positions at NexTap. You have the right to withdraw your consent at any time, either through your User account or by sending a message to [email protected] .

B6. Legal Obligations:

In certain instances, legal regulations impose obligations on NexTap, requiring the processing of personal data. Examples include tax and accounting laws, as well as providing data to public authorities as mandated by law. Hence, we may process your data to fulfill our legal obligations and archive our internal records. The legal basis for processing such data is compliance with legal obligations.

C. Cookies and Other Technologies on Our Websites

At NexTap, we utilize cookies to collect information about individuals who visit our websites. Cookies are small, encrypted text files that are stored on your computer or other devices. These cookies are essential in operating our website and providing important features and functionality. Additionally, they play a crucial role in helping us understand how our website is being used.Please check this link for our detailed Cookie Policy

We use cookies for statistical and analytical purposes, enabling us to track and monitor various aspects such as the country of origin, visited pages, and the methods used to access our website. This valuable data aids us in improving user experiences and facilitating personalization.

Furthermore, cookies play a role in delivering online advertising that we believe is most relevant to you. They are also employed for profiling purposes. By using cookies, we can gain insights into how our website is utilized, including identifying any error messages that may occur during browsing. For more in-depth information about cookies, you can visit https://www.allaboutcookies.org.

Apart from cookies, NexTap also utilizes other technologies to analyze user behavior on our websites and to identify any issues with website features. Currently, we employ the following tools:

D. Data Retention

At NexTap, we adhere to the principle of retaining personal data for as long as necessary to fulfill the purpose for which it was processed. The duration of data retention also depends on the legal basis on which your data is processed.

• D1. Legitimate Interest:
  If data processing is based on legitimate interest, your personal data will be processed as long as the legitimate interest of NexTap is in effect.
• D2. Legal Obligations:
  For data processed based on legal obligations, the data retention period is determined by applicable legal regulations.
• D3. Performance of Contract:
  Data processed based on the performance of a contract will be retained for the duration of the contractual relationship and for any applicable limitation period.
• D4. Consent:
  If data processing is based on your consent, your personal data will be erased upon your withdrawal of consent. However, it is essential to note that the same data might also be processed based on other legal grounds, and your withdrawal of consent may not result in a complete erasure of your data in such cases.

NexTap is committed to collecting only relevant personal data and refrains from collecting an excessive amount of personal information or any data unrelated to the purposes for which the personal data is gathered.

• Data Retention for User Accounts:
  If you create a User Account with NexTap, we will process your data for the duration of your registration with us. You have the option to delete your User Account at any time, and you can also manage the data processed about you through your User Account.
• Customer Verification Process:
  Personal data collected as part of the customer verification process is processed for the duration of the contractual relationship between NexTap and its customers. After the termination of the contractual relationship, this data will be retained for an additional 3 Months.
• Phone Call Data:
  NexTap does not store data provided by you or collected during phone calls for longer than necessary, considering the purposes for which they were provided or collected. If you wish to withdraw your consent for the processing of your data, you can do so by sending a message to [email protected] , and we will promptly remove your data from our system.
• Job Applicants:
  The personal data of successful job applicants is processed and retained in accordance with our employee Privacy Policy. For unsuccessful job applicants who provided consent for consideration for future positions at NexTap, their data is processed for the period specified in the consent, and they have the option to withdraw their consent at any time. Unsuccessful job applicants who did not provide consent for retaining their personal data will have their data retained for as long as NexTap's legitimate interest requires to protect itself from legal claims and facilitate the hiring process.

E. Data Sharing, Processors, and Transfers to Third Countries

At NexTap, we prioritize the security and confidentiality of your personal data. We will not share your personal data with any third party except in the following situations:

• Necessary for Provision of NexTap Services
• Based on Your Consent
• Entrusting of Personal Data to Processors
• Legal Obligations or Public Authority Orders
• Payment Processing Providers for Customer Verification

To enable you to manage reservations and orders made with Enterprises, NexTap may share your personal data with the Enterprises solely for the purpose of making and managing your reservation/order, along with other services offered by the Enterprises.

E1. Categories of Processors:

NexTap engages trusted third-party providers who may, in certain instances, process personal data on our behalf, following the instructions provided by NexTap. These providers fall under various categories as follows (processors under CCPA):

• Data center and hosting providers
• Marketing providers
• Analytics and recording providers
• Providers of polls or surveys
• Business management providers
• Task management and communication providers
• Legal services, tax, accounting, and audit services
• Recruitment and applicant verification providers
• Information security providers

Rest assured, we carefully select and enter into contractual agreements with these processors to ensure that they maintain the necessary security measures and adhere to data protection regulations while handling your personal data on our behalf.

E2. Transfer to other Countries:

NexTap will transfer your data to countries outside the United States only in compliance with applicable legal regulations. This means that such transfers will take place under specific circumstances, ensuring the protection of your personal data in accordance with the California Consumer Privacy Act (CCPA).

For instance, if our service provider is located in a country that meets the requirements under the CCPA for data transfers, we will proceed with the transfer accordingly.

Moreover, when transferring data to third countries, we will implement appropriate measures to ensure the protection of your privacy rights with standards essentially equivalent to that guaranteed by the CCPA.

F. Data Security

At NexTap, we prioritize the security and protection of your personal data. We have implemented appropriate physical, technical, and organizational measures to safeguard all information collected through NexTap Services. Our goal is to prevent unauthorized or unlawful processing of your data and to protect against accidental or unauthorized access, use, transferring, processing, copying, transmitting, alteration, loss, or damage of your personal data.

While we strive to meet all the requirements set forth by applicable legal regulations and employ robust security measures, it is important to acknowledge that no data transmission or storage can be completely guaranteed as secure when transferred or transmitted in an unsecured manner.

To ensure the security of your data, NexTap employs the following measures:

• Encryption of Data:
  We use encryption to protect your data, making it unreadable to unauthorized parties during transmission and storage.
• Multiple Levels of Internal System Logs:
  NexTap maintains multiple levels of internal system logs, allowing us to monitor and detect any suspicious activities, ensuring the security of your data.
• Strong Password Policy and Hashing User Passwords:
  We enforce a strong password policy, and user passwords are securely hashed to prevent unauthorized access to your User Account.
• Penetration Testing:
  Regular penetration testing is conducted to identify and address potential vulnerabilities in our systems, bolstering the overall security of your data.

For more detailed information about the security measures in place within NexTap Platform, you can refer to Information Security NexTap.

While we take comprehensive steps to protect your data, it is essential to recognize your own responsibilities in securing your personal data. We encourage you to take proper measures, including regularly changing your passwords and refraining from using predictable usernames and passwords. Avoid sharing your password with others or granting access to your User Account or disclosing your personal data to unauthorized individuals.

Please note that NexTap will never ask for your password through unsolicited communication. If you suspect any unauthorized use of your User Account or a breach of security, please promptly notify us at [email protected] . We are committed to promptly addressing and resolving any security concerns.

G. Changes to Privacy Policy and Language Versions

NexTap may periodically update and revise the terms of this Privacy Policy. Any changes made to this Privacy Policy will be communicated by posting an updated version on the NexTap website.

Additionally, you can obtain a copy of the revised Privacy Policy through your User Account or the email address you have provided to NexTap.

In case of any inconsistencies between translated versions, if provided, and the English-language version of this Privacy Policy, the English version shall take precedence and govern all aspects.

H. Contact Details

If you have any questions about NexTap, the protection of your privacy, or concerns related to this Privacy Policy, you can reach out to NexTap at [email protected] .

Ensuring the accuracy of your data is essential to us. If you believe that any of the information processed by NexTap is incorrect or needs updating, please contact us at [email protected] . We greatly appreciate your cooperation in maintaining the accuracy and relevance of your personal information.