Privacy Policy

Principles of processing personal customer data by Tip-Tap Network OÜ, ie Privacy Policy

Valid from February 25, 2021.

1. General provisions

1.1. This principle of processing (collection, use, storage, protection and modification) of Tip-Tap Network OÜ customer personal data provides an overview of why, how and to what extent Tip-Tap Network OÜ processes customer personal data when its product is in use, to what extent individual customer rights are protected, how customers can exercise their rights, to whom and why customer data is passed on, and under what conditions the policy will be changed (and the customer will be notified).

1.2. By entering into a customer relationship with Tip-Tap Network OÜ, or expressing a wish to enter into a customer relationship, the customer agrees to the processing of his or her personal data under the conditions and pursuant to the procedure provided in these principles.

2. Basic principles of personal data processing

2.1. Tip-Tap Network OÜ proceeds from the general regulation 2016/679 of the European Parliament and of the Council for “Legality of the processing of personal data” when processing customer personal data, 1 al.pd a, b, c and f of the Data Protection Act to the extent applicable in private law, and other relevant legislation (as well as the requirements set out in these principles).

2.2. Tip-Tap Network OÜ and its employees are obliged to keep the customer’s personal data confidential indefinitely due to legislative requirements and in accordance with the employment or other similar contract entered into with them, and are liable for violation of the above obligations.

2.3. The customer’s personal data will be processed only with the consent of the customer and to the extent provided in the form which allows the customer to reproduce it in writing. An individual customer has the right to withdraw his or her consent to the processing of personal data at any time. There is no retroactive effect to the withdrawal of consent.

2.4. Tip-Tap Network OÜ collects and stores personal data in electronic form, extracting them in other forms if necessary.

2.5. Tip-Tap Network OÜ collects the customer’s personal data upon registration as a user of the Tip-Tap Network OÜ self-service portal, in the virtual Tip-Tap Multi-app marketplace, and during the use of the product by the customer. Public and private registers are also included (e.g. commercial register, register of taxable persons, Tax and Customs Board, customer undertaking).

2.6. Tip-Tap Network OÜ processes customer data in order to fulfill legal obligations arising from legislation (national laws, supervision instructions, regulations as well as European Union legislation), to fulfill the contract concluded with the customer, to prepare the contract, to process the customer’s application, and for Tip-Tap Network OÜ to protect its legitimate interests in legal disputes.

2.7. Tip-Tap Network OÜ’s legitimate interests are primarily expressed in promoting its business by offering better services and products to customers, developing its products, ensuring data and information security, debt management and defending itself in the event of legal disputes.

2.8. Tip-Tap Network OÜ uses profile analysis as a result of automatic processing of personal data, which is used to assess certain personal characteristics of the customer, for example to analyze or forecast a person’s personal preferences and interests.

2.9. Tip-Tap Network OÜ uses profile analysis for marketing purposes on the basis of the customer’s consent. Such data processing takes place on the basis of the legitimate interest of Tip-Tap Network OÜ or the service provider, respectively (e.g. direct marketing).

2.10. Profile analysis helps Tip-Tap Network OÜ to provide services to customers more efficiently and to avoid possible mistakes. For the purpose of such processing, including the creation of segments or profiles, Tip-Tap Network OÜ does not collect additional data about the customer and uses the data that is available about the customer.

2.11. The use of cookies and related data processing is carried out in accordance with the terms of use of cookies published on the website of Tip-Tap Network OÜ.

3. Composition and objectives of the customer data to be collected and its legal basis

3.1. Composition of customer data:

3.1.1. Display of an identifying document containing all the data reflected in the document: Name of the person; personal identification code, in the absence thereof, date of birth and place of residence or seat; document number; the issuer of the document; the period of validity of the document.

3.1.2. A facial image of a person that proves the identity of the person on the document.

3.1.3. Address of residence (to enable international bank transfers, or to contact the person if necessary). A photo from an invoice sent to this address (communication services, electricity, gas, etc.) or a bank statement containing the name and address of the account holder is suitable for this purpose.

3.1.4. Bank account number for making payments (due to the requirements of the Money Laundering and Terrorist Financing Prevention Act, its connection with the account holder must be verifiable, therefore we need a photo of a bank statement or a document confirmed by the bank).

3.1.5. System username – to identify users.

3.1.6. E-mail address – to communicate with the customer, to issue invoices for transactions.

3.1.7. Mobile phone number – to provide a service to a customer through a mobile app.

3.2. Customer data is collected to:

3.2.1. Successfully provide the service;

3.2.2. To prevent the use of the financial system and economic space of the Republic of Estonia for money laundering and terrorist financing. The collection of customer data respects the fundamental right to the protection of personal data and applies the principle of proportionality.

3.3. The legal basis for the collection of customer data is §§ 21 and 22 of the Money Laundering and Terrorist Financing Prevention Act.

4. Transmission of customer data

Tip-Tap Network OÜ has the right to transfer the customer’s personal data to third parties in the following cases and the customer does not consider it a violation of theobligations provided by the principles of personal data processing:

4.1. in case of breach of contract by the customer, to protect the rights of Tip-Tap Network OÜ in case of legal disputes;

4.2. in the event of a transfer of the right of claim against the customer to a new creditor. The data to be transmitted include contract data and debt data;

4.3. in case of fulfillment of obligations arising from legislation and international and mutual legal assistance agreements (e.g. transmission of data to investigative bodies, prosecutor’s office, notary, trustee in bankruptcy, Tax and Customs Board, Financial Intelligence Unit, Financial Supervision Authority, etc.).

5. Storage of customer personal data

Tip-Tap Network OÜ does not process the customer’s personal data for longer than is necessary to fulfill the purposes of processing such data, including the fulfillment of the data retention obligation provided for in legislation and the resolution of a dispute arising from a contract entered into with the customer.

6. Protection of the rights of an individual customer

6.1. Tip-Tap Network OÜ is responsible for processing customer data. Contact information is available on the website of Tip-Tap Network OÜ:

6.2. Customers may contact Tip-Tap Network OÜ in connection with inquiries and revocation of consents, and individual customers may request the exercise of their rights in the processing of personal data and submit complaints in connection with the processing of such personal data.

6.3. In addition, the customer has the right to turn to the Data Protection Inspectorate (website: or a competent court at any time in case of violation of his or her rights.

7. Modification and Application of Privacy Policy

7.1. Tip-Tap Network OÜ has the right to unilaterally change the principles at any time, based on the applicable legislation.

7.2. Tip-Tap Network OÜ notifies the customer of the change of the policy on the website, and/or via the means of communication agreed with the customer at least 1 (one) month before the change enters is enforced, unless the policy change is only due to changes in legislation, including to bring them into line with regulatory requirements, or where the changes do not affect the processing of existing customer data (e.g. when a new product is placed on the market).

7.3. The principles apply to the processing of customer data of all customers, as well as to customer relationships that have arisen before the enforcement of the principles.

8. Settlement of Disputes

Disputes between Tip-Tap Network OÜ and the customer shall be resolved primarily by agreement of the parties. If no agreement is reached, the dispute shall be settled by action in the Tartu County Court.