Privacy Policy

Effective Date: March 18, 2026

SECTION 1 -- OVERVIEW AND SCOPE

1.1 Purpose of this Policy

This Privacy Policy ("Policy") describes how Tbltap by Ngassa Holdings LLC ("Tbltap," "we," "us," or "our") collects, uses, stores, shares, and safeguards personal data of individuals and business entities that access, install, or use any Tbltap product, application, software, website, or service (collectively, the "Platform").

The Policy applies to all forms of personal data processed by Tbltap, whether collected online through the Platform, through integrated NFC/QR devices ("Table Tags"), or through offline interactions such as customer support or business correspondence.

1.2 Global Application and Legal Effect

This Policy applies globally, covering individuals in the United States, the European Union (EU), the United Kingdom (UK), and countries subject to data-protection regimes such as Indonesia's PDP Law (2022) and Singapore's PDPA (2012).

However, California law exclusively governs this Policy and all related disputes. Mandatory rights unaffected (international). Nothing in this Policy limits any non-waivable consumer rights under the laws of your country of residence (e.g., EU/UK GDPR). Where those laws apply, we comply with their mandatory requirements.

1.3 Binding Nature

By creating an account, using the Platform, or otherwise providing personal data to Tbltap, you acknowledge that you have read, understood, and agreed to this Policy and consent to the collection, processing, and storage of your personal information as described herein.

If you do not agree, you must refrain from using the Platform. Continued use constitutes ongoing consent.

1.4 Relationship to the Terms of Service

This Policy forms an integral part of the Tbltap Terms of Service ("TOS"). Any capitalized terms not defined herein have the meanings assigned in the TOS. In case of conflict, the TOS governs the interpretation of disputes.

1.5 Non-Applicability to Third-Party Services

This Policy does not apply to third-party websites, applications, or services that are integrated with Tbltap (e.g., payment processors such as Stripe or another processor disclosed for the relevant flow, analytics partners, or restaurant websites). Each third party is responsible for its own privacy practices. Tbltap assumes no responsibility for, and disclaims all liability arising from, such independent operations.

1.6 Scope of Processing

Tbltap collects and processes information from:

• Platform Users (individuals using food-discovery or media features);
• Business Customers / Restaurants (entities using Tbltap for menu hosting, analytics, or transactions);
• Tag Purchasers (customers purchasing Tbltap NFC products); and
• Visitors (non-registered users accessing public pages or media).

Processing covers personal and non-personal data used to operate the Platform, deliver services, fulfill contractual obligations, comply with legal requirements, improve the Platform, and ensure safety and compliance.

1.7 Service Requirements & Opt-Out Consequences

Certain Platform functions require specific processing activities (e.g., authentication/session cookies, security telemetry, fraud prevention, and core feature analytics) that are essential to provide the service (Contractual Necessity and/or Legitimate Interests). If you object to or disable essential processing, we cannot provide the Platform and you must discontinue use. Non-essential processing (e.g., marketing, A/B experiments, non-core analytics) is used only with a valid legal basis (consent where required). Refusing non-essential processing may limit personalization or promotions but will not block access to core features.

SECTION 2 -- IDENTITY OF THE CONTROLLER

2.1 Legal Entity

The Data Controller and Service Operator responsible for the processing of personal data under this Policy is:

Tbltap by Ngassa Holdings LLC
131 Continental Dr, Suite 305
Newark, Delaware 19713, USA
Email: [email protected]

Tbltap acts as both Controller (when determining purposes of processing) and Processor (when acting on behalf of Business Customers for limited transactional or analytics operations).

2.2 Representative Roles

• Ngassa Holdings LLC is the parent entity owning Tbltap's intellectual property, servers, and data-infrastructure rights.
• Tbltap Operations acts through contracted service providers (e.g., Supabase, Google Cloud, Stripe, Cloudflare, and any other processor or vendor Tbltap discloses for a specific service or market).
  2.2b EU/UK Representative Status.
  As of March 18, 2026, Tbltap has not published separate public EU or UK representative contact details. If Tbltap appoints a representative for a specific service, market, or legal requirement, Tbltap will update this Policy or its official documentation site with that information. Until then, privacy requests and regulatory correspondence should be sent to [email protected].

2.3 Contact Channels

• Privacy Inquiries: [email protected]
• Data Requests (Access / Deletion): subject line "Privacy Request"
• DMCA / IP Issues: subject line "DMCA Notice"
• Arbitration Opt-Out: subject line "Arbitration Opt-Out"

Tbltap maintains an internal privacy-compliance office that oversees all data-handling and incident-response functions.

2.4 Business DPA pointer

When Tbltap acts as a processor for Business Customers (e.g., restaurants), the parties may execute a separate data processing addendum where required for the applicable service or law. Tbltap does not currently maintain a separate public DPA page; requests for a DPA or current sub-processor information should be sent to [email protected].

3. Categories of Personal Data Collected

Tbltap collects and processes several categories of data depending on the nature of your relationship with the Platform. All data is collected for legitimate operational, contractual, and compliance purposes. Tbltap does not collect more information than necessary to fulfill those purposes.

3.1 Account and Identity Data

Information provided during registration, authentication, or profile creation, including:

• Full name, display name, and username or handle
• Email address and password hash (Tbltap never stores raw passwords)
• Date or year of birth for age verification
• Account identifier or user ID
• Contact details such as telephone number or social media handle (if voluntarily linked)
• Business registration information (for Restaurants): legal entity name, license number, tax ID, food permit details, and point of contact

3.2 Transactional and Payment Data

Tbltap processes limited payment and transaction metadata required to fulfill payments or subscriptions. This includes:

• Purchase and order identifiers
• Subscription tier and billing history
• Payment method token or fingerprint generated by the applicable processor (currently Stripe or another disclosed processor)
• Connected-account, invoice, refund, dispute, or subscription identifiers returned by the processor where relevant
• Transaction amounts, currency, and status codes
  Tbltap does not store or have access to complete card numbers, CVVs, or banking PINs. All sensitive payment data is processed by certified PCI-DSS-compliant partners.

3.3 Device, System, and Telemetry Data

Automatically collected information about your device and interactions with the Platform, such as:

• Device type, model, and operating system version
• Unique device identifiers and installation IDs
• Browser type, version, and user-agent string
• IP address and derived approximate location
• Application event logs (e.g., taps, views, errors, crash reports)
• Network latency and performance metrics
• Timestamped usage sessions and authentication events

3.4 Geolocation and Environmental Data

When enabled through device settings, Tbltap may collect:

• Precise GPS location coordinates for venue discovery or map rendering
• Wi-Fi and cellular network identifiers used for approximate positioning
• Region and language settings, time zone, and locale

You may disable location services at any time, although doing so may reduce functionality (e.g., nearby-venue results).

3.5 User-Generated Content

Tbltap hosts and moderates content uploaded by Users and Restaurants, including:

• Photos, videos, captions, reviews, ratings, and comments
• Metadata embedded in media files (e.g., camera type, timestamp, location tag)
• AI-assisted or edited content when disclosed under the Terms of Service

All submissions are stored with internal identifiers and may be processed by AI-based or human moderation systems to enforce content standards.

3.6 Communication and Support Data

Information exchanged when you contact Tbltap:

• Email correspondence, chat transcripts, and support tickets
• Call logs or voice messages (if customer support is contacted by phone)
• Feedback forms and survey responses
  Tbltap retains support interactions to improve service quality and maintain a record of inquiries and resolutions.

3.7 Marketing and Preference Data

When you consent to marketing communications, Tbltap may record:

• Subscription and opt-in status
• Marketing channels and engagement metrics (e.g., opens and clicks)
• In-app preferences for notifications, themes, and language
• Campaign attribution and tracking identifiers (through cookies or mobile SDKs)

3.8 Business Customer Data

For Restaurant or enterprise accounts, Tbltap collects:

• Business contact information of authorized representatives
• License and certificate copies for compliance verification
• Employee contact names and emails (when they manage accounts or locations)
• Payment and payout details linked to business bank accounts (handled via processors)
• Business performance analytics and Taste IQ aggregates generated by Tbltap's analytics systems

3.9 NFC/QR Device and Order Fulfillment Data

For purchasers of Tbltap NFC Table Tags:

• Order ID, shipping address, contact details, and delivery status
• Pairing logs confirming successful activation of tags
• Diagnostic data from the pairing application used to verify chip functionality

Tbltap does not collect environmental footage or audio from the tags; they contain no sensors beyond standard NFC chips.

3.10 Aggregated and Derived Data

Tbltap may generate statistical or analytical data derived from other categories above. Such data--when anonymized so that individuals are no longer identifiable--is outside the scope of "personal data" and may be used for analytics, AI-training, or commercial insight purposes consistent with Section 13 of the Terms of Service.

4. How Data Is Collected (Direct, Automated, and Third-Party Sources)

Tbltap collects personal data through multiple lawful and transparent channels. Each collection mechanism serves a defined purpose aligned with Platform operation, security, compliance, or improvement.

4.1 Direct Data Collection (User-Provided Information)

Tbltap obtains data directly from you when you voluntarily provide it. Examples include:

1. Account Registration and Login - When you sign up or authenticate, Tbltap collects credentials, identifiers, and verification data to create and secure your Account.
2. Profile Setup and Personalization - When you enter your name, date or year of birth, preferences, or business details.
3. Purchases and Payments - When you purchase subscriptions, order NFC Table Tags, or conduct transactions through Stripe or another processor disclosed for the relevant flow.
4. Communications - When you email [email protected], use in-app support chat, or respond to surveys, Tbltap records message content and metadata.
5. Content Uploads - When you post reviews, photos, or videos, Tbltap receives the files, captions, and metadata necessary to display and moderate the content.
6. Verification Requests - When you submit business documents, licenses, or certificates for compliance or re-verification.
7. Marketing Sign-ups - When you consent to receive newsletters, promotions, or push notifications.
8. Dispute and Warranty Claims - When you contact Tbltap regarding defective tags, chargebacks, or arbitration opt-outs.

You may decline to provide certain information, but doing so could limit functionality or prevent access to the Platform's features.

4.2 Automated Data Collection

Tbltap automatically collects data using technical means integral to Platform operation. This includes:

(a) Device and System Logging

Tbltap's servers automatically log requests, IP addresses, device type, operating system, time stamps, and diagnostic data. These logs are used to prevent fraud, ensure uptime, and analyze Platform performance.

(b) Telemetry and Analytics

Telemetry systems embedded in the Tbltap app (powered by Supabase, Cloudflare, and internal analytics) collect anonymized event data such as session duration, click paths, and error reports. These metrics inform optimization, product development, and bug remediation.

(c) Cookies and Local Storage

Tbltap uses cookies and local storage on web properties to maintain sessions, recognize returning users, and track consent preferences. Details are provided in Section 6 ("Cookies, Analytics, and Tracking").

(d) Geolocation

If location permissions are granted, Tbltap retrieves geolocation coordinates or approximate area data to show nearby venues. Location information is stored only as needed for service delivery and is subject to device settings.

(e) AI-Assisted Moderation and Classification

Tbltap employs automated content-analysis tools--such as machine-learning classifiers and computer-vision models--to identify prohibited content (e.g., nudity, violence, hate speech). These tools may evaluate uploaded media but do not create biometric identifiers or permanent user profiles beyond moderation functions.

(f) Crash Reporting and Performance Monitoring

Automated diagnostic tools capture stack traces and system state at the moment of error to resolve issues and maintain stability. No personal communications are inspected or stored beyond technical context.

4.3 Data Received from Third-Party Sources

Tbltap also receives personal and non-personal information from trusted third-party partners as part of Platform operations:

(a) Payment Processors (Stripe or another disclosed processor)

Tbltap receives limited metadata confirming transaction status, payment tokens, charge outcomes, and refund dispositions. Sensitive financial data remains with the processors.

(b) Cloud Infrastructure and Hosting Providers

Supabase, Google Cloud, and Cloudflare provide secure data-storage, database, and content-delivery services. Tbltap accesses only the information necessary to operate Platform functionality.

(c) Analytics and Telemetry Vendors

Third-party analytics solutions may provide aggregated, pseudonymized usage metrics (e.g., device models, geographic distribution, feature adoption). Tbltap configures such tools to minimize data exposure and prevent user re-identification.

(d) Verification and Compliance Partners

For Restaurants and Business Customers, Tbltap may confirm business identity or licensure through external verification systems or publicly available registries.

(e) Advertising and Marketing Platforms

If you interact with Tbltap marketing materials on third-party platforms (e.g., Meta, Google Ads), those platforms may provide aggregated conversion data or campaign analytics. Tbltap does not share personal identifiers with advertising networks without explicit consent.

(f) Public or Shared Content

Tbltap may collect data that you publicly post on the Platform or voluntarily make accessible to others, including tagged photos, ratings, and venue feedback.

4.4 Combined and Derived Data

Tbltap may combine data collected from different sources--direct, automated, and third-party--to maintain accurate records, detect fraud, and improve user experience.
When combining data, Tbltap employs pseudonymization or aggregation techniques to reduce identifiability wherever possible.

4.5 Legal Notice of Data Origination (GDPR Articles 13-14 Equivalence)

In jurisdictions requiring disclosure of data origin, Tbltap identifies the following potential data sources:

• The individual data subject (User, Business Customer, or visitor);
• Authorized representatives of Restaurants or Business Customers;
• Service providers and processors acting on Tbltap's behalf;
• Public registries or data made manifestly public by the user;
• Technical telemetry automatically generated by the user's device.

Tbltap does not obtain personal data from data brokers or third parties engaged in selling consumer information.

5.1 Core Operational Purposes

(a) Account Creation and Authentication (Contractual Necessity)

Tbltap processes account credentials, identifiers, and verification data to register users, authenticate logins, maintain sessions, and prevent unauthorized access.

(b) Platform Provision and Customization (Contractual Necessity / Legitimate Interest)

Tbltap uses account, telemetry, and preference data to deliver core Platform functions--venue listings, Taste IQ analytics, media content, and user interfaces--tailored to individual preferences and device context.

(c) Payment Processing and Subscription Management (Contractual Necessity / Legal Obligation)

Tbltap transmits limited transaction metadata to Stripe and Stripe Connect, or to another processor Tbltap expressly discloses for a specific flow or market, to execute payments, apply the 2% platform fee, manage billing cycles, support refunds and disputes, and comply with financial-reporting and anti-fraud regulations.

(d) NFC Tag Orders and Warranty Support (Contractual Necessity)

Tbltap processes order, shipment, and pairing data to fulfill tag purchases, verify warranty claims, and communicate replacement eligibility under Section 16 of the Terms of Service.

(e) Customer Support and Communications (Contractual Necessity / Legitimate Interest)

Tbltap records inquiries and correspondence to respond to issues, resolve disputes, and improve service quality.
Emails and chat transcripts may be reviewed internally for training and compliance.

(f) Security, Fraud Detection, and Compliance (Legitimate Interest / Legal Obligation)

Tbltap monitors usage patterns, IP addresses, and payment anomalies to detect fraud, enforce community standards, and comply with regulatory requests or court orders.

(g) Analytics and Product Improvement (Legitimate Interest)

Telemetry, aggregated ratings, and behavioral metrics are analyzed to improve performance, test features, and enhance usability.
Tbltap may use anonymized datasets for statistical modeling and feature optimization.

(h) AI Training and Algorithmic Development (Legitimate Interest / Consent where required)

Tbltap may transform anonymized or aggregated data into training sets for machine-learning models that power moderation, recommendation, and Taste IQ analytics.
Personal identifiers are removed prior to model ingestion.

(i) Marketing and Promotions (Consent / Legitimate Interest)

Tbltap processes contact and engagement data to send promotional emails, push notifications, or targeted in-app offers.
You may withdraw consent or opt out at any time (see Section 7).

(j) Legal and Regulatory Compliance (Legal Obligation)

Tbltap retains transaction records, tax documentation, and audit logs as required by accounting and consumer-protection laws, and cooperates with lawful governmental requests.

5.2 Special Processing Contexts

(a) Business Customer Verification

Tbltap processes corporate documents, licenses, and proof of health-code compliance to confirm restaurant legitimacy.
This protects consumers and upholds platform integrity.

(b) Community Moderation

AI and human moderators review uploaded content for policy compliance.
Such processing is necessary to enforce Tbltap's Terms of Service and maintain a safe environment.

(c) Research and Statistical Use

Tbltap may conduct internal analyses on aggregated, pseudonymized datasets to measure product adoption, geographic reach, and market performance.
Findings are reported in non-identifiable form.

5.3 Balancing Test for Legitimate Interests

Tbltap conducts internal assessments to ensure that legitimate-interest processing does not override the fundamental rights of users.
Where risk is high, Tbltap implements additional safeguards such as pseudonymization, access controls, and data-minimization measures.

5.4 Withdrawal of Consent

Where Tbltap relies on your consent, you may withdraw it at any time by changing settings in the Platform or emailing [email protected].
Withdrawal does not affect processing already performed before withdrawal.

5.5 Consequences of Non-Provision

Certain information (e.g., email address, payment details, or verification documents) is mandatory to access specific services.
Failure to provide required data may result in limited functionality or denial of service.

6.1 Definition of "Cookies" and "Similar Technologies"

For purposes of this Policy, "Cookies" refers to small data files stored on your browser or device that uniquely identify your browser, session, or preferences.
"Similar Technologies" includes:

• Local and session storage used by browsers or apps;
• SDKs (Software Development Kits) embedded within the Tbltap mobile app;
• Pixel tags, web beacons, and clear GIFs; and
• Device identifiers such as IDFA (iOS) or GAID (Android).

These mechanisms enable Tbltap and its processors to collect technical data automatically, consistent with Section 4.2.

6.2 Categories of Cookies and Trackers Used

Tbltap uses the following categories of cookies and related tools:

(a) Essential (Strictly Necessary)

Required for the Platform's core functions--authentication, session continuity, account security, and load balancing.
They cannot be disabled and do not store personally identifiable information beyond session identifiers.

(b) Performance and Analytics

Measure how users interact with the Platform. These cookies and SDKs collect anonymized usage data (e.g., page views, button clicks, dwell time, latency).
Tbltap uses such data to improve features and fix errors.

(c) Functional

Allow the Platform to remember user preferences (e.g., language, region, theme, or saved filters).
Disabling them may reduce customization.

(d) Marketing and Attribution

Used only where legally permitted or with consent. These cookies record referral links, campaign identifiers, and conversion events to measure marketing effectiveness.
Tbltap does not allow third parties to place direct advertising cookies without contractual safeguards.

(e) Security and Fraud Prevention

Detect and prevent unauthorized logins, suspicious behavior, or abuse of promotional features.

6.3 Third-Party Analytics and SDK Integrations

Tbltap integrates trusted analytics partners solely for legitimate operational and improvement purposes:

1. Supabase Analytics and Telemetry - Provides database-level performance, user-session tracking, and query latency metrics.
2. Google Analytics (GA4) - Collects anonymized interaction data such as navigation flow, engagement time, and geographic distribution.
3. Cloudflare Insights - Logs network requests for DDoS prevention and infrastructure monitoring.
4. OpenAI Models (content analysis) - May process text or image data temporarily for moderation or classification, under strict API usage and anonymization controls.
5. Firebase or AppCenter SDKs (mobile only) - Gather crash reports and performance telemetry on Android and iOS versions of the Tbltap app.

All third parties act as Processors under Tbltap's direction and are bound by confidentiality and data-protection agreements.

6.4 How Tbltap Uses Collected Data

Tbltap uses cookie and analytics data to:

• Authenticate sessions and maintain login persistence;
• Measure feature usage and retention;
• Analyze aggregated user flows to improve navigation;
• Debug technical issues and measure server performance;
• Detect and mitigate security incidents or fraud;
• Determine marketing reach and referral sources;
• Test interface variants and A/B experiments.

Tbltap does not use cookies to profile users for third-party advertising or cross-context behavioral targeting.

6.5 Retention and Lifespan of Cookies

Cookie duration varies depending on type:

• Session cookies expire when you close your browser or app;
• Persistent cookies remain for up to 12 months unless deleted manually;
• Security and compliance cookies may be stored longer where necessary to comply with audit or fraud-prevention obligations.

Tbltap reviews cookie retention periodically and purges obsolete identifiers.

6.6 Managing Cookies and Opt-Out Options

You can control cookie settings in the following ways:

1. Browser Controls: Adjust preferences in your browser to block or delete cookies.
2. Device Settings: Mobile users can reset advertising identifiers (IDFA/GAID).
3. In-App Settings: Tbltap may provide toggle options under "Privacy" → "Cookie Preferences."
4. Do Not Track (DNT): Tbltap recognizes DNT headers but treats them as opt-out of marketing cookies only.
5. Email Tracking: Tbltap's marketing emails may include tracking pixels to measure open rates. You can disable image loading in your email client or unsubscribe to stop receipt entirely.
6. We honor the Global Privacy Control (GPC) signal for applicable U.S. state laws. Marketing trackers are disabled when GPC is active.

Note that disabling cookies may affect the availability or functionality of certain features (e.g., persistent logins).

6.7 Legal Basis for Use of Cookies

Under California and international privacy principles, Tbltap's use of cookies is justified on the following bases:

• Essential cookies: Contractual necessity (required to deliver the Platform);
• Analytics cookies: Legitimate interest in improving services;
• Marketing cookies: Consent (explicit opt-in via preference banner or account settings).

Tbltap never installs non-essential cookies without a valid legal basis.

6.8 Cookie Banner and Consent Recordkeeping

Where required by Applicable Law, Tbltap displays a cookie-consent banner upon first access.
Consent preferences are recorded, timestamped, and stored for proof of compliance.
Users can modify consent at any time.

In the EEA/UK, we do not set non-essential cookies/SDKs (including analytics/marketing) until you consent via our consent manager. You may withdraw consent at any time in settings. Outside the EEA/UK, we use essential cookies under Contractual Necessity and analytics under Legitimate Interests, with opt-out controls where available.

6.9 Third-Party Links and Embedded Content

The Platform may embed third-party media (e.g., restaurant websites, video content, maps).
These third parties may set their own cookies once you interact with the embedded content. Tbltap does not control or assume responsibility for those external practices.

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6.10 No Sale or Cross-Context Advertising

Tbltap does not sell personal information, permit cross-context behavioral advertising, or allow third-party data brokers to track users across unaffiliated websites.

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6.11 Automated Decisioning Exclusion

Cookies and tracking mechanisms are never used to make decisions that produce legal or similarly significant effects on users.
They exist solely to maintain functionality and improve service quality.

7. Marketing Communications and Opt-Out Rights

Tbltap communicates with Users and Business Customers to share service information, account updates, promotional offers, and community features. All outreach complies with applicable U.S. and international communications laws and respects individual opt-out preferences.

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7.1 Types of Communications

Tbltap distinguishes among three categories of messages:

(a) Transactional or Service-Related
Messages essential to providing the Platform--such as account confirmations, password resets, billing receipts, warranty responses, or critical security alerts.
These messages are not subject to opt-out, as they are required to perform contractual obligations.

(b) Operational and Relationship Updates
Announcements concerning feature improvements, policy updates, or community notifications that materially affect use of the Platform.
Tbltap sends these on the basis of legitimate interest to keep users informed of service changes.

(c) Promotional or Marketing Communications
Emails, push notifications, or text messages containing advertising, special offers, or curated content.
These are delivered only where Tbltap has obtained valid consent or relies on a narrowly defined legitimate interest under California law.

7.2 Email Marketing

1. Tbltap may send promotional emails to the address associated with your Account when you opt in or have an existing customer relationship.
2. Each email clearly identifies Tbltap as the sender, includes accurate contact information, and provides a functioning unsubscribe link in accordance with the CAN-SPAM Act (15 U.S.C. § 7701 et seq.).
3. Opt-out requests are processed within ten (10) business days, and your choice is recorded to prevent future mailings.
4. Tbltap never purchases, rents, or sells email lists.

7.3 Push Notifications

1. Push notifications may appear through the Tbltap mobile application for updates, tips, or offers.
2. You may manage push-notification settings directly in your device's system preferences or within the Tbltap app under Settings → Notifications.
3. Disabling push notifications does not affect receipt of critical in-app alerts that relate to safety, payment, or account integrity.

7.4 SMS and MMS Messages

1. If you provide a mobile number, Tbltap may send limited text messages for verification, security authentication, or promotional purposes.
2. By supplying your number, you consent to receive such messages and acknowledge that standard carrier charges may apply.
3. You can withdraw consent at any time by replying STOP to a message or by emailing [email protected] with subject line "SMS Opt-Out."
4. Tbltap honors all opt-out requests consistent with the Telephone Consumer Protection Act (47 U.S.C. § 227) and associated FCC regulations.

7.5 In-App and On-Platform Messaging

Tbltap may display banners, inbox messages, or in-feed content promoting new features or campaigns.
These placements are part of the Platform experience and may be tailored using anonymized analytics but never through third-party ad networks.

7.6 Marketing Preferences Dashboard

Users and Business Customers can review or modify communication preferences at any time by visiting Account → Privacy & Communications within the Platform.
The dashboard allows granular control over:

• Email categories (product updates, newsletters, offers)
• Push notifications
• SMS/text messaging
• Participation in surveys or beta programs

Preferences are stored as consent records and may be updated or withdrawn at any time.

7.7 Cross-Channel Consistency

Tbltap synchronizes consent status across channels to prevent duplicate outreach.
If you unsubscribe from email marketing, Tbltap will not send equivalent offers by SMS or push without renewed consent.

7.8 Third-Party Marketing and Affiliates

Tbltap does not share user contact data with unrelated third parties for their own marketing purposes.
If Tbltap conducts a joint campaign with a partner (e.g., restaurant collaboration), the message will identify both parties, and any data exchange will be limited to aggregated or anonymized results.

7.9 Recordkeeping and Audit

Tbltap maintains logs of consent, opt-out actions, and preference changes for a minimum of three years to demonstrate compliance.
Records include timestamp, communication channel, and device or session identifiers.

7.10 Consequences of Opting Out

Opting out of marketing communications does not affect your ability to receive essential service messages or to use the Platform.
However, certain features that rely on notifications (e.g., promotional credits or event invitations) may no longer be available.

7.11 Legal Basis

Tbltap's communications practices rely on:

• Contractual necessity (for transactional messages),
• Legitimate interest (for operational updates), and
• Consent (for marketing, SMS, and push promotions).

Users may withdraw consent at any time without prejudice to prior lawful communications.

8. Data Retention, Anonymization, and Aggregation

Tbltap retains personal data only for as long as it is needed to fulfill the purposes for which it was collected, to comply with legal obligations, to resolve disputes, and to enforce agreements. Retention schedules differ depending on the category of data, the relationship with the user or business customer, and the applicable legal or operational requirement.

8.1 Retention Principles

1. Purpose Limitation -- Data is stored only for the purpose originally collected or for compatible purposes that are disclosed to the user.
2. Storage Minimization -- Tbltap regularly reviews storage systems to identify and securely delete redundant or obsolete records.
3. Legal Necessity -- Certain records (e.g., invoices, payment logs, arbitration outcomes) must be retained for statutory or audit reasons under U.S. and California law.
4. Technical Feasibility -- Due to database architecture and distributed storage, complete deletion may require anonymization rather than physical erasure.

8.2 Typical Retention Periods (by Category)

Data Category	Retention Period	Rationale
Account credentials & identifiers	Retained while account is active; deleted / anonymized within 30 days after closure	Necessary for authentication and fraud prevention
Payment and subscription metadata	7 years from transaction date	Accounting, tax, and regulatory record-keeping
Customer support records	3 years from resolution	Quality control and dispute management
Content uploaded by users	While account remains active or until user deletes content	Service continuity and moderation traceability
Business verification documents	Duration of subscription + 2 years post-termination	Legal compliance and anti-fraud verification
Telemetry and analytics logs	12 months (max) before aggregation or anonymization	Platform optimization
Cookie identifiers	Session to 12 months (depending on type)	Analytics / functionality
Warranty / NFC Tag claims	2 years from claim submission	Consumer rights defense and product traceability
Arbitration records	10 years from final award	Legal obligation / risk management

Tbltap may shorten these periods when practical or extend them if required by law, regulation, or litigation hold.

8.3 Deletion and Anonymization Process

When a user requests deletion or an account is terminated:

1. Logical Deletion -- Identifiers are flagged as inactive and removed from live user interfaces within 7 days.
2. Anonymization -- Personal identifiers (name, email, IP) are replaced with hashed or random tokens so records can no longer be linked to an individual.
3. Aggregation -- De-identified data points are combined with others to form statistical or analytical datasets (e.g., Taste IQ trends, venue engagement metrics).
4. Physical Deletion -- Data marked for purge is overwritten or cryptographically shredded during scheduled maintenance cycles, generally within 90 days.
5. Backups -- Backups are automatically purged or re-encrypted on a rolling 30- to 90-day cycle; Tbltap does not restore deleted accounts unless required for legal defense.

Tbltap verifies the irreversibility of anonymization through periodic audits and pseudonymization-risk assessments.

8.4 Aggregation for Analytics and AI Training

After anonymization, Tbltap may aggregate data to generate insights or train algorithms. Examples include:

• Taste IQ Analytics -- Computing aggregated food-preference trends by region without personal identifiers.
• Performance Optimization -- Analyzing latency and error patterns across anonymous device clusters.
• AI Model Training -- Using de-identified datasets to improve moderation models, recommendation systems, and business-intelligence scoring.
• Statistical Reporting -- Producing market and usage statistics for internal use or public reports without revealing individuals or businesses.

Aggregated datasets contain no direct or indirect identifiers (names, precise locations, emails, device IDs) and therefore fall outside the definition of "personal data."

8.5 Audit and Verification

Tbltap conducts annual retention-and-deletion audits to ensure compliance with this Policy and the Terms of Service. Reports are reviewed by the internal privacy office and retained for regulatory inspection if required.

8.6 User Requests and Proof of Erasure

Users may request confirmation of anonymization or deletion by emailing [email protected] with subject line "Data Deletion Request."
Tbltap will respond within a reasonable timeframe, typically 45 days, confirming completion or explaining any lawful basis for continued limited retention (e.g., accounting records, active disputes).

8.7 Retention During Legal Disputes

If Tbltap receives a lawful subpoena, regulatory inquiry, or arbitration notice, relevant data may be preserved under a litigation hold until the matter concludes. Preservation does not create new rights for the requester beyond those existing in law.

9. Data Sharing with Service Providers and Processors

Tbltap shares personal and operational data only when necessary to provide, secure, and improve the Platform, or to comply with legal obligations.
We do not sell personal data, trade user information for value, or permit external advertisers to use our systems for behavioral profiling.

9.1 Principles Governing Data Sharing

Tbltap applies the following principles to all data-sharing arrangements:

1. Purpose Limitation -- Data is shared solely for the specific service Tbltap has engaged the third party to perform.
2. Contractual Safeguards -- Each third party executes a Data Processing Agreement (DPA) or equivalent contract requiring confidentiality, restricted use, and compliance with security and privacy standards.
3. Minimum Necessary Access -- Third parties receive only the minimum data required to perform their duties.
4. No Secondary Use -- Processors may not use Tbltap data for their own commercial purposes or disclose it onward without express written authorization.
5. Oversight and Auditing -- Tbltap reviews vendor performance and may audit compliance with contractual and technical obligations.
6. Tbltap will provide current sub-processor information to Business Customers on request at [email protected] and may publish an official list in the future.

9.2 Categories of Recipients

Tbltap may share personal data with the following categories of recipients:

(a) Payment Processors

Tbltap's current standard restaurant payment setup uses Stripe, Inc. and Stripe Connect. Tbltap may also use another processor that it expressly discloses for a specific market, product, or flow. Only limited payment metadata (tokenized card ID, transaction status, timestamps, connected-account identifiers, invoice references, refund references, and dispute references) is shared. Sensitive payment information (full card numbers, CVVs) remains exclusively within the applicable PCI-DSS-compliant processor.
Tbltap may also receive reports of chargebacks, disputes, reversals, and fraud detection flags.

(b) Cloud and Hosting Providers

Tbltap's infrastructure is hosted in secure, multi-region environments, including:

• Supabase (application database and authentication)
• Google Cloud Platform (GCP) (object storage, compute resources)
• Cloudflare (network routing, content delivery, DDoS mitigation)
  These providers process data under Tbltap's direction and are bound by strict confidentiality and encryption standards.

(c) Analytics and Performance Partners

Tbltap employs analytics vendors to measure usage and performance, such as:

• Google Analytics (GA4) for web interaction metrics;
• Supabase telemetry for app-level analytics; and
• Cloudflare Insights for network performance and latency.
  All analytics data is pseudonymized, aggregated, and used solely for Platform improvement.

(d) Artificial Intelligence and Moderation Vendors

Tbltap uses secure API integrations (including OpenAI models and internal AI pipelines) to moderate, classify, or enhance uploaded content.
When data is sent to an AI service, Tbltap removes direct identifiers and transmits only the minimal text or media necessary for analysis.
Such data is processed transiently and not retained beyond the processing session.

(e) Identity-Verification and Compliance Partners

For Business Customers, Tbltap may share business names, license numbers, and documentation with verification services or government registries to confirm authenticity and health-code compliance.

(f) Logistics and Fulfillment Providers

Tbltap shares shipping names, addresses, and contact numbers with courier and logistics partners to fulfill NFC Table Tag orders or warranty replacements.

(g) Customer Support and Communication Tools

Tbltap may use customer service platforms (e.g., Zendesk, Intercom, or functionally equivalent systems**) to manage support tickets and chat interactions.
These processors have access only to relevant correspondence and user contact details.

(h) Legal and Regulatory Authorities

Tbltap may disclose personal data to law enforcement, regulatory agencies, or courts if legally required or if Tbltap determines disclosure is necessary to protect its rights, users, or the public.

(i) Affiliates, Successors, and Professional Advisors

Tbltap may share information with its affiliates, accountants, auditors, attorneys, or prospective investors for internal administration, due diligence, or corporate compliance--subject to confidentiality obligations.

9.3 Processor Obligations

All service providers acting as Processors for Tbltap must:

1. Process data only on Tbltap's documented instructions;
2. Implement industry-standard security measures and notify Tbltap of any breach within mandated timeframes;
3. Assist Tbltap in fulfilling data-subject rights requests (e.g., deletion, correction);
4. Return or delete personal data at the end of service provision; and
5. Allow Tbltap to audit or request documentation proving compliance.

Tbltap maintains a vendor register documenting the categories of processors and sub-processors, available upon legitimate request.

9.4 Sharing Between Users and Business Customers

Tbltap facilitates limited data exchange between Users and Restaurants in the ordinary course of using the Platform:

• When a User places an order or books a venue, Tbltap shares necessary order details and contact information with the Restaurant.
• Restaurants may view anonymized analytics about customer engagement but not personal identifiers unless explicitly provided by the user.
• Users are responsible for the information they voluntarily disclose in messages or reviews.

Tbltap disclaims liability for misuse of voluntarily shared information by Restaurants or other users.

9.5 Cross-Border Processing by Vendors

Certain vendors may process data outside the United States. Tbltap ensures such transfers are covered by appropriate Standard Contractual Clauses (SCCs), equivalent safeguards, or verified adequacy decisions where applicable (see Section 10).

Tbltap remains the ultimate Controller for all international data transfers and requires vendors to maintain consistent security and privacy standards.

9.6 No Unsupervised Data Monetization

Tbltap prohibits vendors from:

• Building advertising profiles on Tbltap users;
• Selling aggregated Tbltap data to data brokers; or
• Combining Tbltap data with unrelated datasets for independent analysis.

All vendor relationships are reviewed annually to ensure compliance with this prohibition.

9.7 Internal Access Control

Tbltap enforces a "least privilege" model internally:

• Employees receive access only to data necessary for their role.
• All internal data access is logged and auditable.
• Access credentials are revoked immediately upon termination or role change.
• Employees undergo privacy and security training annually.

9.8 Disclosures in Emergencies

Tbltap may disclose limited user information in emergencies (e.g., health or safety threats, fraud, or imminent harm) if necessary to protect life or property.
Such disclosures are narrowly tailored and consistent with Applicable Law.

10.2 Legal Mechanisms for International Transfers

When Tbltap transfers personal data outside its country of origin, the following safeguards apply:

1. International Transfer Mechanisms. For transfers from the EEA, we use the EU Standard Contractual Clauses (EU 2021/914); for the UK, we use the UK International Data Transfer Addendum. Where applicable, we participate in adequacy frameworks and perform transfer impact assessments.
2. Data Processing Addenda (DPAs).
   Each vendor or processor located outside the U.S. executes a DPA binding them to confidentiality, limited use, breach notification, and cooperation duties consistent with GDPR Art. 28 and California privacy statutes.
3. PDPA and PDP Law Compliance.
   For data originating in Singapore or Indonesia, Tbltap relies on:
   • Consent-based transfer authority under PDPA Sec. 26; and
   • Cross-border data transfer obligations under Indonesia's PDP Law Art. 56-59, using contractual clauses ensuring comparable protection.
4. Adequacy and Certification Frameworks.
   Where available, Tbltap aligns with adequacy frameworks such as the EU-U.S. Data Privacy Framework (2023) for recognized entities. Tbltap monitors evolving adequacy decisions and updates its compliance posture accordingly.

10.3 Technical and Organizational Safeguards

To secure cross-border transfers, Tbltap implements:

• End-to-end TLS encryption during data transit;
• AES-256 encryption for data at rest;
• Access control policies granting least-privilege permissions to authorized personnel only;
• Continuous vulnerability testing and third-party penetration assessments;
• Geofencing and logging to track the physical region of data processing; and
• Annual vendor risk reviews verifying adherence to SCCs and DPAs.

10.4 Transparency on Data Routing

Tbltap's systems may route data packets dynamically through the most efficient network path.
While temporary transit may pass through intermediate jurisdictions, Tbltap's encryption and contractual safeguards remain in effect throughout the transfer process. No foreign processor may decrypt or store content outside Tbltap's controlled environments.

10.5 User Rights in Cross-Border Contexts

Individuals located outside the United States retain the same access, correction, and deletion rights described in Section 11. Tbltap responds to such requests directly under California law, while honoring equivalent foreign rights (e.g., GDPR Arts. 15-22) to the extent technically feasible.

10.6 Government and Law Enforcement Requests

Tbltap reviews all foreign government or law-enforcement requests through a centralized U.S. legal process. Data is disclosed only upon receipt of a valid, binding U.S. legal order or an order enforceable under applicable mutual-assistance treaties.

Tbltap challenges overbroad or extraterritorial requests whenever permitted by law.

10.7 Accountability and Oversight

Tbltap's internal privacy-compliance office maintains documentation of:

• Each cross-border transfer, its legal basis, and applicable SCCs;
• Vendor certifications and security assessments; and
• Data-flow diagrams showing regional storage and access points.

These records are reviewed annually and are available to competent regulators or auditors under confidentiality.

10.8 Governing Law and Jurisdiction

Contractual relationships remain governed by California law; however, international transfers are governed by and performed under the SCCs/UK Addendum, which prevail to the extent required by law. Any dispute concerning international data handling shall be resolved exclusively in accordance with Section 21 of the Tbltap Terms of Service.

11. User Rights (GDPR, UK GDPR, CCPA, PDP Law)

Tbltap recognizes the fundamental privacy rights of all individuals interacting with the Platform.
While Tbltap operates under California law, we voluntarily extend the following rights to users and business customers worldwide, subject to verification and Applicable Law. All requests are processed through [email protected] with the subject line "Privacy Request."

11.1 Right to Access and Transparency

You have the right to request confirmation as to whether Tbltap processes personal data about you and, if so, to obtain:

• The categories and specific pieces of personal data Tbltap holds;
• The purposes of processing;
• The categories of recipients to whom the data has been disclosed;
• The data's source, if not collected directly from you; and
• The expected retention period or criteria used to determine it.

Tbltap provides this information free of charge up to two (2) verified requests per year, consistent with CCPA §1798.110.

11.2 Right to Rectification (Correction)

You may request correction of inaccurate or incomplete data maintained by Tbltap.
Where Tbltap is unable to verify or amend third-party records (e.g., payment processors), you will be directed to the relevant data source.

Tbltap updates verified corrections within 45 days unless an extension is reasonably necessary.

11.3 Right to Deletion ("Right to Be Forgotten")

You may request deletion of your personal data under any of the following conditions:

• The data is no longer necessary for the purposes for which it was collected;
• You withdraw consent and there is no other legal basis for processing;
• Processing was unlawful; or
• Deletion is required to comply with Applicable Law.

Tbltap fulfills deletion requests through anonymization and aggregation, ensuring that personal identifiers are permanently removed but system integrity and analytics continuity are preserved.

Tbltap may deny deletion requests where retention is required for:

• Completing transactions or warranties;
• Security or fraud detection;
• Legal obligations (e.g., accounting, arbitration); or
• Internal uses aligned with user expectations and the California CPRA.

11.4 Right to Data Portability

You may request a copy of your data in a structured, commonly used, machine-readable format (e.g., JSON or CSV).
Tbltap provides data that you have directly provided and that can be feasibly extracted without disclosing proprietary systems or other users' information.

Tbltap fulfills portability requests within 60 days of verification, subject to reasonable extensions where complex processing is involved.

11.5 Right to Object or Restrict Processing

You may object to processing of your data on legitimate-interest grounds, including profiling related to marketing or analytics.
If Tbltap cannot demonstrate compelling legitimate grounds that override your interests, processing will be restricted.

You may also request temporary restriction where:

• Data accuracy is contested;
• Processing is unlawful but deletion is not requested; or
• Tbltap no longer needs the data but you require it for legal claims.

During restriction, Tbltap limits access internally and marks the data as "Restricted" in its systems.

11.6 Right to Withdraw Consent

Where processing is based on consent (e.g., marketing emails, push notifications, or location sharing), you may withdraw that consent at any time.
Withdrawal does not affect the lawfulness of processing carried out prior to withdrawal.

To withdraw consent, adjust settings in your Account or contact [email protected].

11.7 Right to Non-Discrimination (CCPA)

Tbltap will not deny goods, services, or pricing to any user exercising their privacy rights.
However, certain features or benefits that rely on personal data (e.g., personalized recommendations or rewards programs) may be unavailable after opting out.

11.8 Verification of Requests

Tbltap must verify your identity before processing any request. Verification may include:

• Confirming control of your registered email address;
• Matching account credentials or recent activity;
• For business customers, confirming authorized representative status.

Requests that cannot be verified within a reasonable timeframe will not be fulfilled to protect user privacy.

11.9 Authorized Agents (California Residents)

California residents may designate an authorized agent to submit requests on their behalf.
Tbltap requires written authorization from the user and verification of the agent's identity consistent with Cal. Civ. Code §1798.135.

11.10 Response Times and Process

Tbltap endeavors to:

• Acknowledge receipt of requests within 10 business days; and
• Respond within 45 days, extendable by an additional 45 days for complex requests with notice.
• For EEA/UK residents, Tbltap responds within 1 month of verification (extendable by up to 2 months for complex requests), consistent with GDPR/UK GDPR.

Responses will be delivered electronically, unless another format is requested.

11.11 Appeals and Dispute Resolution

If Tbltap denies or partially fulfills a request, you may appeal the decision by submitting a written explanation to [email protected] with subject line "Privacy Appeal."
Tbltap will review the appeal internally and respond with a reasoned determination within 30 days.

Unresolved disputes are subject to binding JAMS arbitration in Los Angeles County, California, under Section 21 of the Terms of Service.

11.12 Recordkeeping

Tbltap maintains logs of all access, deletion, and portability requests for a minimum of 24 months to demonstrate compliance and monitor response timeliness.

12. Security Measures and Data Breach Procedures

Tbltap maintains a comprehensive information-security and risk-management framework to ensure the confidentiality, integrity, and availability of all personal and operational data processed through the Platform.
Security is embedded by design and enforced at technical, organizational, and procedural levels.

12.1 Security Governance

Tbltap's security program is directed by the Privacy & Security Office, which reports directly to executive management of Ngassa Holdings LLC.
Responsibilities include:

• Establishing and updating security policies and acceptable-use standards;
• Conducting risk assessments and vulnerability testing;
• Managing encryption keys and access-control systems; and
• Overseeing vendor security reviews and audits.

Tbltap follows the NIST Cybersecurity Framework (Identify → Protect → Detect → Respond → Recover) as its baseline methodology.

12.2 Technical Safeguards

Tbltap implements the following controls across its infrastructure:

1. Encryption in Transit and at Rest -
   All network traffic between users, servers, and vendors uses TLS 1.3 or higher.
   Stored data and backups are encrypted using AES-256 or stronger ciphers.
2. Access Control and Authentication -
   Role-based access, enforced through identity-management systems with multi-factor authentication (MFA).
   Privileged accounts are restricted to trained personnel and reviewed quarterly.
3. Network and Infrastructure Security -
   Firewalls, intrusion-detection systems (IDS), and rate-limiting protect against unauthorized access and denial-of-service attacks.
   Tbltap employs Cloudflare for perimeter protection and global content delivery.
4. Endpoint Protection -
   Employee devices use full-disk encryption, automatic patching, and mobile-device-management (MDM) compliance enforcement.
5. Application Security -
   Secure-coding standards, peer code review, static-analysis scanning, and dependency monitoring.
   Critical vulnerabilities are remediated within established SLAs (24 hours for high severity).
6. Data Segregation -
   Production, staging, and test environments are logically separated; anonymized data only is used in non-production systems.
7. Monitoring and Logging -
   Continuous monitoring of infrastructure, access logs, and anomalies using SIEM (Security Information and Event Management) tools.
   Logs are retained for a minimum of 12 months for forensic review.

12.3 Organizational and Administrative Safeguards

1. Employee Screening and Training -
   All employees and contractors sign confidentiality agreements and undergo background verification and annual security-awareness training.
2. Least-Privilege Principle -
   Access to personal data is granted strictly on a need-to-know basis. Permissions are reviewed at least semi-annually.
3. Vendor Risk Management -
   Third-party processors are evaluated before onboarding and annually thereafter against Tbltap's Vendor Security Questionnaire and DPA requirements.
4. Change and Patch Management -
   System updates follow documented approval workflows and rollback procedures. Emergency patches are tracked and validated.
5. Physical Security -
   Data centers used by Tbltap's hosting partners (Supabase, Google Cloud) are ISO 27001 and SOC 2-certified and employ biometric access, 24/7 surveillance, and redundant power systems.

12.4 Incident Detection and Response Plan

Tbltap maintains a formal Incident-Response Plan (IRP) covering detection, containment, investigation, eradication, recovery, and post-incident review.
The IRP defines escalation paths and assigns roles to the Privacy & Security Office, engineering leads, and legal counsel.

Incident Categories include:

• Unauthorized access to systems or data;
• Accidental or unlawful destruction or alteration of data;
• Credential compromise or loss of encryption keys;
• Denial-of-service or exploitation attempts; and
• Breaches or potential breaches reported by vendors.

12.5 Breach Notification Procedures

If Tbltap determines that a data breach has occurred that poses a risk to affected individuals, the following steps apply:

1. Initial Assessment (0-24 hours) - Detect anomaly, convene the Incident Response Team, and classify severity.
2. Containment and Remediation (24-72 hours) - Isolate impacted systems, revoke credentials, deploy patches, and secure backups.
3. Notification (within 72 hours of confirmation) -
   • Notify affected users by email or in-app alert describing the nature of the breach, data involved, mitigation steps, and recommended precautions.
   • Notify relevant vendors or processors involved in the event.
   • Where legally required, notify law enforcement or regulators.
4. Post-Incident Review (within 30 days) - Conduct root-cause analysis, update policies, and document corrective measures.

For U.S. users, Tbltap complies with the California Data Breach Notification Law (Cal. Civ. Code §1798.29 & §1798.82).
For EU/UK users, notifications are made consistent with GDPR Art. 33-34 timelines when applicable.

12.6 Continuous Improvement and Testing

Tbltap performs:

• Quarterly penetration testing by independent security specialists;
• Annual disaster-recovery drills and backup-restore validations;
• Ongoing vulnerability scans using automated tools; and
• Periodic policy reviews to reflect evolving threats and best practices.

Findings are logged, remediated, and tracked to closure under the company's risk-register process.

12.7 Liability and Disclaimer

While Tbltap employs industry-standard safeguards, no system is impenetrable.
Tbltap disclaims liability for unauthorized access, disclosure, or loss of data resulting from circumstances beyond its reasonable control, including acts of God, force majeure, or malicious third-party attacks.
Tbltap nevertheless commits to prompt notification and remediation consistent with this Section 12.

13. Children's Privacy (COPPA Compliance)

13.1 Platform Intended for Users Aged 13 and Older

Tbltap and all affiliated services, applications, and websites are designed for individuals aged thirteen (13) years and older.
The Platform is not directed to or intended for children under 13 years of age, and Tbltap does not knowingly collect personal information from anyone under that age threshold.

13.2 Parental or Guardian Consent Requirement

If Tbltap learns that it has inadvertently collected personal data from a child under 13 without verifiable parental consent, Tbltap will:

1. Delete the information from its systems as soon as reasonably practicable;
2. Disable the related account; and
3. Notify the parent or guardian, if contact information is available, of the deletion and reason.

Tbltap does not condition a child's participation in any activity on the disclosure of more information than is reasonably necessary to participate in such activity, consistent with COPPA §312.5(c)(5).

13.3 Age Verification for Registration

As part of the sign-up process, Tbltap requires users to provide their year of birth and reserves the right to require full date of birth for verification.
Tbltap's automated systems block registration attempts by individuals indicating an age under 13.
Business Customers must ensure that any individual operating or administering their account is at least 18 years old and authorized to bind the entity contractually.

13.4 Global Equivalents and Extended Protections

Tbltap extends similar protections internationally:

• For residents of the European Economic Area (EEA) and the United Kingdom, Tbltap will not knowingly collect data from individuals under the age of 16 without parental consent, consistent with GDPR Article 8(1).
• For residents of Indonesia, Tbltap adheres to PDP Law Article 22, requiring parental or guardian authorization for processing data of minors.
• For residents of jurisdictions with lower age thresholds (e.g., 13-15), Tbltap complies with the higher of the applicable standards to ensure protection.

13.5 Business Customer Responsibility

Restaurants and Business Customers that post or upload content involving minors are solely responsible for obtaining any necessary consents, releases, or authorizations under Applicable Law. Tbltap assumes no responsibility for verifying or maintaining such records.

13.6 Education and Awareness

Tbltap encourages parents and guardians to supervise their children's online activity, educate them about data sharing, and use device-level parental controls where appropriate.

13.7 Contact for Parental Requests

Parents or legal guardians who believe Tbltap may have inadvertently collected data from a child under 13 may contact:

Tbltap by Ngassa Holdings LLC
131 Continental Dr, Suite 305
Newark, DE 19713 USA
Email: [email protected]
Subject: "Child Data Inquiry"

Tbltap will respond promptly and remove any unauthorized child data within ten (10) business days of verification.

14. Automated Decision-Making and AI Training

Tbltap integrates machine-learning and artificial-intelligence ("AI") systems into portions of the Platform to enhance performance, security, and personalization.
These systems operate under human oversight and do not produce decisions that create legal or similarly significant effects for individual users.

14.1 Purpose and Scope of Automated Processing

Tbltap deploys automated technologies for the following legitimate purposes:

1. Content Moderation -- Detecting and filtering prohibited material (nudity, violence, hate speech, spam) using AI classifiers trained on de-identified datasets.
2. Taste IQ Analytics and Recommendation Engine -- Analyzing aggregated food-preference data to personalize venue or menu recommendations.
3. Fraud and Security Detection -- Identifying suspicious payment or account-access patterns.
4. Performance Optimization -- Predicting latency, load balancing, and caching behaviors to maintain stable service.
5. Anomaly and Abuse Prevention -- Flagging unusual API or network requests for review by Tbltap's Security Operations Center (SOC).

Automated systems support decision-making by staff but do not autonomously approve or deny user access, account suspension, or business-verification outcomes without human validation.

14.2 Data Used in AI Systems

Tbltap's AI models are trained or refined using:

• Aggregated usage telemetry and anonymized interaction data;
• De-identified text, images, and reviews voluntarily uploaded by users;
• Statistical derivatives of Taste IQ scoring; and
• Synthetic datasets generated internally for model calibration.

Prior to inclusion in model-training pipelines, Tbltap removes or pseudonymizes all direct identifiers (e.g., names, emails, IP addresses, payment tokens).
Data incorporated into AI training therefore ceases to qualify as "personal data" under Applicable Law.

14.3 Safeguards and Human Oversight

Tbltap applies the following safeguards to automated systems:

1. Pre-Deployment Review -- Each model undergoes bias and accuracy testing before release.
2. Ongoing Monitoring -- Model outputs are routinely sampled and evaluated by human reviewers for fairness and consistency.
3. Access Control -- Only authorized engineering personnel may modify or retrain models.
4. Audit Logging -- All model-training and inference activities are logged for accountability.
5. Transparency -- Tbltap labels AI-moderated or AI-assisted features where relevant (e.g., "AI-Reviewed Content").

Tbltap's moderation and analytics teams retain final discretion to review, override, or correct automated assessments.

14.4 Right to Human Review

Where automated processing materially affects a user--such as content removal, account limitation, or rating suppression--Tbltap provides an opportunity for human review upon request.
Users may email [email protected] with the subject line "AI Decision Review Request" within 30 days of notification.
Tbltap will ensure that a qualified human reviewer re-evaluates the decision and provides a written outcome within a reasonable period.

14.5 Opt-Out of Personalization

Users who prefer not to receive AI-based personalization (e.g., Taste IQ recommendations) may disable personalization features under Account → Privacy → Personalization Settings.
Disabling personalization does not affect anonymized data used for aggregate analytics or system improvement.

14.6 Data Retention for AI Training

Model-training datasets are stored separately from production databases and governed by Tbltap's internal Machine-Learning Data Retention Policy.
De-identified training data is retained as long as necessary to maintain or improve model performance, after which it is refreshed or re-anonymized.
Tbltap prohibits re-linking training data to individual users.

14.7 Disclosure of Third-Party AI Services

Tbltap may employ vetted external AI vendors (e.g., OpenAI API, Google Vertex AI) for limited text or image analysis.
Any such vendor operates solely as a Processor under Tbltap's instructions and contractual obligations prohibiting data retention, reuse, or training beyond the specific task requested.

14.8 Prohibition on Automated Legal Effects

Tbltap does not engage in automated processing that:

• Produces legal effects concerning a user;
• Significantly affects employment, credit, housing, or legal status; or
• Constitutes profiling with substantial consequences.

All consequential decisions remain subject to human discretion.

14.9 Transparency Commitment

Tbltap publicly documents its AI-governance framework in a separate AI Ethics Statement, available upon request.
The statement outlines guiding principles--fairness, accountability, transparency, and security--and details how Tbltap balances innovation with privacy and user rights.

15. Business Transfers and M&A Disclosures

Tbltap may, from time to time, undergo corporate transactions such as mergers, acquisitions, financings, reorganizations, or asset transfers. Because these activities may require limited disclosure or transfer of data, this section explains the applicable principles, procedures, and safeguards.

15.1 Continuity of Service and Ownership

If Tbltap (operated by Ngassa Holdings LLC) or its assets are acquired, merged, reorganized, or otherwise transferred, personal and operational data may form part of the transferred assets.
Such transfer is necessary to ensure continuity of Platform operations, uphold existing user contracts, and preserve Tbltap's legitimate business interests.

15.2 Lawful Basis for Disclosure

The lawful bases for processing and transfer in a business-transaction context are:

1. Legitimate Interest -- Ensuring business continuity, maintaining asset value, and enabling strategic transactions.
2. Contractual Necessity -- Honoring ongoing user and business-customer relationships.
3. Legal Obligation -- Compliance with due-diligence and disclosure duties under U.S. corporate and securities law.

All such processing is subject to strict confidentiality and data-minimization requirements.

15.3 Due Diligence Phase

During preliminary due-diligence reviews:

• Tbltap may share limited, pseudonymized or aggregated datasets with potential counterparties to evaluate the business.
• Any recipient must execute a Non-Disclosure Agreement (NDA) expressly prohibiting use of information for purposes other than the contemplated transaction.
• Personal identifiers (names, emails, payment data) are redacted unless disclosure is strictly required for valuation or compliance.

15.4 Transfer and Successor Obligations

In the event of a completed transaction:

1. Continuity of Privacy Commitments -- The successor entity inherits all obligations under this Privacy Policy and the Tbltap Terms of Service unless it issues a new policy consistent with comparable or stronger protections.
2. Notification -- Tbltap will provide reasonable notice via email, in-app alert, or website posting before any material change in ownership that affects data-controller identity.
3. User Options -- Users may delete or export their data prior to the effective transfer date by submitting a verified request to [email protected].
4. Post-Transfer Governance -- The successor must maintain the same level of security and confidentiality for transferred data and may process it only for previously disclosed purposes.

15.5 Corporate Restructuring and Internal Transfers

Tbltap may also reorganize internally within Ngassa Holdings LLC or its affiliates for operational efficiency.
Internal transfers follow identical safeguards as cross-border transfers (see Section 10) and remain governed by California law.

15.6 Investor and Financial Disclosures

Tbltap may disclose aggregated or anonymized usage metrics to investors, auditors, or financial institutions for fundraising or compliance purposes.
No personal data of identifiable users is shared for investment marketing or valuation beyond the anonymized statistical level.

15.7 Bankruptcy or Insolvency Events

In the unlikely event of bankruptcy or insolvency proceedings, Tbltap's user and business data would be treated as part of the company's intangible assets subject to court supervision.
Tbltap will seek to ensure that any transferee provides equivalent privacy protections or offers users an opportunity to withdraw consent before data is transferred or used inconsistently with this Policy.

15.8 Legal Notice of Transfer

Any notice of ownership change will specify:

• The name and contact information of the acquiring or successor entity;
• The effective date of transfer; and
• Any modifications to data-processing purposes or jurisdictional responsibilities.

Tbltap will provide at least 30 days' public notice before such changes take effect unless prohibited by law or confidentiality obligations.

16. Contact for Privacy and Legal Inquiries

16.1 Primary Contact Information

Questions, requests, or complaints regarding this Privacy Policy or Tbltap's data-handling practices should be directed to:

Tbltap by Ngassa Holdings LLC
Attn: Privacy & Security Office
131 Continental Dr, Suite 305
Newark, Delaware 19713 USA
Email: [email protected]
Subject Line: "Privacy Inquiry" or "Legal Notice"

Tbltap accepts inquiries only in English. All communications should include your full name, registered email address, a description of your request, and any supporting documentation needed to verify identity.

16.2 Response Protocol

1. Acknowledgment. Tbltap will confirm receipt of a privacy or legal request within ten (10) business days.
2. Verification. Tbltap may request additional information to verify identity or authority to act on behalf of another individual.
3. Resolution. Substantive responses will be provided within forty-five (45) days unless an extension (up to an additional 45 days) is required for complex cases; Tbltap will notify you of any delay and its reason.
4. Secure Delivery. All responses are sent electronically to the verified contact address unless another method is specifically requested and reasonably available.

16.3 Government, Law-Enforcement, and Regulatory Requests

No Voluntary Disclosure. Tbltap does not voluntarily disclose user or business-customer information to any government, law-enforcement, or regulatory authority. Tbltap requires a valid, binding legal process addressed to Tbltap and issued by a court or authority having proper jurisdiction (e.g., subpoena, court order, or warrant) before producing any information.

Scope and Minimization. When legally compelled, Tbltap will disclose only the specific data elements identified in the order and will object to, narrow, or challenge any demand that is overbroad, lacks lawful basis, asserts improper extraterritorial reach, or conflicts with Applicable Law (including data-transfer safeguards).

User Notice. Tbltap will notify affected users or Business Customers of any government or law-enforcement request for their information before producing data, so that they may seek legal remedies, unless (a) legally prohibited from providing notice, (b) notification would create a clear, imminent risk to life or safety, or (c) Tbltap reasonably determines that notice would be futile because the account no longer exists. If a legal prohibition later expires, Tbltap will provide delayed notice where feasible.

Process for Non-U.S. Authorities. Requests from authorities outside the United States must be made through Mutual Legal Assistance Treaty (MLAT) channels or other recognized international processes that result in a binding U.S. legal order, unless otherwise required by Applicable Law.

Emergency Disclosures. Tbltap will disclose information only when required by law and only if it has a good-faith belief that an immediate risk of death or serious physical harm requires disclosure. All such disclosures are logged, documented, and reviewed by Tbltap's Privacy & Security Office.

Transparency and Reporting. Tbltap may publish periodic, aggregate statistics about governmental requests--including the number received, granted, narrowed, or rejected, and the number subject to secrecy orders--through its official documentation site or another official channel. As of March 18, 2026, Tbltap has not published a separate public transparency-report page. Questions about governmental requests may be directed to [email protected].

Encryption and Technical Limits. Tbltap designs its systems to minimize its ability to access or decrypt user content. Where data are end-to-end encrypted or otherwise inaccessible to Tbltap, Tbltap may be technically unable to produce the requested information.

16.4 Regulatory Correspondence

Tbltap has not published separate EU or UK representative contact details as of March 18, 2026. Communications from foreign data-protection authorities or users may be addressed to the U.S. Privacy & Security Office listed above at [email protected] until this Policy is updated with any additional representative information.

16.5 Arbitration and Legal Service of Process

For purposes of serving legal notices relating to this Policy or data-privacy disputes, Tbltap's registered agent and venue are as follows:

Registered Agent: Ngassa Holdings LLC Legal Department
Venue: Los Angeles County, California, USA
Arbitration Forum: JAMS -- Comprehensive Arbitration Rules & Procedures

All notices served in connection with arbitration or litigation must also be emailed to [email protected] for tracking and acknowledgment.

16.6 Data-Protection Officer (DPO) Equivalent

Although Tbltap is not legally obligated to appoint a DPO under California law, Ngassa Holdings LLC has designated an internal Privacy Officer to oversee compliance with this Policy and handle incident response, risk assessments, and training. The Privacy Officer may be contacted via the same address above.

17. Changes to This Policy

17.1 Right to Modify

Tbltap reserves the right to modify, amend, or replace this Privacy Policy at any time and for any reason, consistent with Applicable Law and Tbltap's legitimate business needs.
Revisions may reflect changes in legal requirements, technological developments, product features, or data-handling practices.
All amendments are made under the authority of Ngassa Holdings LLC and take effect upon publication unless a later effective date is stated.

17.2 Version Control and Historical Record

Each iteration of this Policy is identified by an Effective Date appearing at the top of the document.
Tbltap maintains an internal archive of prior versions for a minimum of five (5) years.
Archived copies are available upon written request to [email protected] for compliance or audit purposes.

17.3 Notification of Material Changes

When Tbltap makes material changes--including substantial alterations to data categories, processing purposes, or user rights--Tbltap will provide prior notice by at least one of the following means:

1. Email Notification sent to the address associated with your account;
2. In-App or Website Banner displaying a summary of the key updates; or
3. Direct Prompt requiring acknowledgment before continued use of the Platform.

Tbltap will provide at least thirty (30) days' advance notice of material changes when legally required or when changes significantly affect user rights.

17.4 Non-Material Updates

Minor typographical, organizational, or clarifying edits that do not materially change user rights may be implemented without prior notice.
The Effective Date will still be updated to reflect the most recent revision for transparency.

17.5 User Acknowledgment and Continued Use

Your continued access to or use of the Platform after any update constitutes acknowledgment and acceptance of the revised Policy.
If you disagree with the updated terms, you must discontinue use of the Platform and may request deletion or export of your data in accordance with Section 11.

17.6 Interpretation and Relationship to Other Documents

This Privacy Policy forms an integral part of the Tbltap Terms of Service.
In the event of conflict between this Policy and the Terms of Service, the Terms of Service shall prevail with respect to dispute-resolution, governing-law, and arbitration provisions.
All undefined capitalized terms have the meanings assigned in the Terms of Service.

17.7 Effective Date

This Privacy Policy is effective as of March 18, 2026, and supersedes all prior versions.