Privacy Policy

This Privacy Policy explains how dap collects, uses, stores, shares and protects personal data when you access or use dap.

dap is currently operated by Justin Kirk as an individual. References to “dap”, “we”, “us” and “our” mean Justin Kirk operating dap, unless dap is later incorporated, transferred, assigned, or operated through a legal entity.

This Privacy Policy applies to dap’s website, mobile application, web application, account features, wallet features, referral programme, founder access programme, promotional rewards, Spin the Wheel, card-related features, fiat on-ramp and off-ramp access, bank-transfer access, dap-to-dap transfers, sending and receiving features, trading features, yield features, customer support channels, social media pages, APIs and any other products or services provided through dap.

In this Privacy Policy:

• “dap”, “we”, “us” and “our” mean Justin Kirk operating dap.
• “you” and “your” mean any person who visits, accesses or uses dap.
• “Services” means the dap website, app, wallet, account features, sending and receiving features, referral features, promotional features, trading features, yield features and any other dap products or services.
• “Personal data” means information that identifies you, relates to you, or can reasonably be linked to you.
• “Partner” means a third-party provider that makes a card service, bank-transfer service, fiat deposit service, fiat withdrawal service, fiat on-ramp service, fiat off-ramp service, wallet infrastructure service, analytics service, fraud prevention service, notification service, hosting service, or other integration available through dap.

dap is responsible for the personal data it collects and controls. Some partner-provided features are operated by third parties. Those partners may be independently responsible for the personal data they collect and process when you choose to use their services.

By accessing or using dap, you acknowledge that your personal data will be handled as described in this Privacy Policy.

1Who controls your personal data

Justin Kirk is the data controller of personal data where dap decides why and how that personal data is processed.

This includes personal data used to:

• Create and operate your dap account
• Secure the app
• Provide customer support
• Operate referrals
• Operate founder access
• Operate promotional features
• Operate Spin the Wheel
• Maintain product analytics
• Make core dap features available

Some features may be provided by partners. Where a partner decides why and how it processes personal data for its own service, that partner acts as an independent controller. This means the partner is responsible for its own privacy notice, legal basis, retention periods, security measures and data rights process.

Where dap uses service providers to process personal data on its behalf, those providers act as processors and must process personal data only under dap’s instructions, subject to appropriate contractual controls.

2dap does not directly conduct KYC

dap does not directly conduct KYC as part of:

• Account creation
• Wallet access
• Sending
• Receiving
• dap-to-dap transfers
• Trading
• Yield features
• Referrals
• Founder access
• Promotional rewards
• Spin the Wheel
• Standard dap account use

dap does not directly collect identity documents for KYC as part of standard dap account use.

Certain optional partner-provided features may require identity verification before that partner makes its own service available. This may apply to:

• Card issuance
• Fiat deposits
• Fiat withdrawals
• Bank transfers
• Fiat on-ramp services
• Fiat off-ramp services

Where a partner requires identity verification, the partner may collect and process identity information under its own privacy policy, terms, licences and legal obligations.

dap may receive limited status information from that partner, such as whether your access to the relevant partner feature is approved, rejected, pending, restricted, unavailable, or requires further action.

Using dap does not automatically require identity verification. Identity verification only applies where you choose to use a partner-provided feature that requires it.

Trading, yield, sending, receiving, promotions, Spin the Wheel and standard dap account use are not KYC-triggering features within dap.

3Personal data dap collects

dap collects personal data that you provide, personal data created when you use dap, personal data collected automatically from your device, and personal data received from partners or service providers.

3.1 Account data

dap may collect: name, where provided; username; email address; phone number; country or region; language preference; profile details; referral code; invite code; founder access status; golden ticket status; daily streak status; account settings; login method; authentication status; account creation date; account status.

dap uses this data to create and manage your account, reserve usernames, operate referrals, operate founder access, provide support, secure your account and make dap features available.

3.2 Contact and support data

dap may collect: your name; email address; phone number; social media handle; support messages; complaint details; feedback; survey responses; attachments you provide; communications with dap.

dap uses this data to respond to you, provide support, investigate issues, improve dap, handle complaints and keep records of communications.

3.3 Wallet and blockchain data

dap may collect or process: public wallet addresses; linked wallet addresses; blockchain network identifiers; public transaction hashes; token balances displayed in dap; deposit records; withdrawal records; sending and receiving records; smart contract interactions; digital signatures; wallet connection metadata; transaction status; transaction timestamps; network fees; public on-chain activity linked to wallets you connect.

dap uses this data to provide wallet features, display balances, process transaction instructions, show transaction history, support sending and receiving, detect fraud, secure dap and troubleshoot issues.

Public blockchain data may be visible to anyone. Blockchain records may be permanent and may not be capable of deletion or alteration by dap.

3.4 Sending, receiving and transfer data

dap may collect: sender details; recipient details; wallet addresses; dap usernames; transfer amount; asset type; transaction reference; transaction status; timestamp; network information; failure or reversal status, where applicable; support notes related to a transfer.

dap uses this data to process transfers, show transaction history, provide support, prevent fraud, investigate failed transfers and maintain accurate records.

Sending, receiving and dap-to-dap transfers do not require dap to conduct KYC.

3.5 Trading data

Where trading features are available through dap, dap may collect: trading account identifiers; order activity; position data; asset balances; margin information; execution status; PnL information; liquidation or risk status; trading preferences; transaction records; product interaction data.

dap uses this data to display trading features, show balances, route instructions, calculate account information, provide support, monitor product performance, manage product risk and maintain records.

Trading features within dap do not require dap to conduct KYC.

3.6 Yield data

Where yield features are available through dap, dap may collect: yield allocation records; vault or strategy identifiers; deposit and withdrawal records; balance information; accrued yield information; APY or rate display data; transaction status; product interaction data.

dap uses this data to display yield features, show balances, calculate returns, process instructions, provide support, monitor product performance and maintain records.

Yield features within dap do not require dap to conduct KYC.

3.7 Card, fiat and bank-transfer partner data

Where you choose to use a partner-provided card, fiat deposit, fiat withdrawal, bank-transfer, fiat on-ramp or fiat off-ramp feature, dap may process limited information connected to that feature. This may include: partner service selected; partner account status; feature eligibility status; approval, rejection, pending, unavailable or restricted status; transaction status; card application status; fiat deposit status; fiat withdrawal status; bank-transfer status; on-ramp status; off-ramp status; last four digits of a card, where made available by the partner; card display metadata; currency; transaction amount; timestamp; failure reason or support code, where provided by the partner; customer support information needed to resolve the issue.

Where a partner requires identity verification for its own service, the partner may collect identity information directly from you. dap may receive limited status information from the partner so that dap can display the feature in the app, provide support and keep the app functioning correctly.

dap does not directly conduct KYC for these partner-provided features.

3.8 Referral and campaign data

dap may collect: referral codes; invite codes; referrer and referee relationship; referral status; campaign source; reward status; founder access status; golden ticket status; daily streak status; spin activity; prize or reward history; eligibility records; anti-abuse signals.

dap uses this data to operate referrals, rewards, founder access, campaigns, early access, waitlists, golden tickets, streaks, promotional features and anti-abuse controls.

3.9 Promotions, rewards and Spin the Wheel data

If you use dap promotional features, including Spin the Wheel, dap may collect and use information about your participation in those features.

This may include: account identifier; username; device identifiers; app identifiers; platform; app version; spin activity; charge level; daily streak activity; referral activity; reward result; reward history; timestamps; rule acceptance records; fraud prevention signals; abuse prevention signals; automation detection signals; duplicate account signals; technical issue records; customer support records relating to rewards.

dap uses this information to: operate promotional features; provide free daily spins; determine and issue rewards; apply campaign rules; maintain streaks; maintain referral rewards; prevent duplicate accounts; detect abuse or automation; investigate technical issues; resolve disputes; comply with legal obligations; keep accurate records of rewards issued.

Spin the Wheel rewards may include promotional credits, cash rewards, referral-related rewards, golden tickets, access perks, or other benefits shown in the app.

Where a cash reward or other reward is issued, dap may keep records of that reward and the account that received it.

dap may share limited information with service providers who help operate dap, host systems, prevent fraud, provide analytics, send notifications, or support customer service.

dap does not sell Spin the Wheel participation data.

dap keeps Spin the Wheel records for as long as reasonably needed to operate the feature, prevent abuse, resolve disputes, comply with legal obligations and maintain accurate reward records.

Spin the Wheel, free daily spins, promotional rewards, golden tickets, access perks and referral-related rewards do not require dap to conduct KYC.

3.10 Device and technical data

dap may collect: IP address; device type; device model; operating system; browser type; app version; language settings; time zone; device identifiers; session identifiers; crash logs; diagnostic logs; authentication logs; security events; API request logs; error messages; performance data; push notification tokens, where notifications are enabled.

dap uses this data to operate dap, secure accounts, detect abuse, prevent fraud, troubleshoot problems, monitor performance, maintain uptime and improve the app.

3.11 Usage and analytics data

dap may collect: pages viewed; screens opened; buttons clicked; feature usage; session length; referral-flow activity; login activity; navigation paths; conversion events; app performance events; campaign attribution; preference data.

dap uses this data to understand how dap is used, improve product design, measure campaign performance, test features, personalise the user experience and identify problems.

3.12 Marketing data

dap may collect: marketing preferences; email subscription status; push notification preferences; campaign engagement; referral campaign participation; waitlist participation; consent records; unsubscribe records.

dap uses this data to send product updates, service updates, launch communications, founder access messages, referral messages and marketing communications where permitted.

3.13 Push notification data

If you allow push notifications, dap may process: device push token; device type; app version; notification preference; notification delivery status; notification interaction data; security alert status; reward or campaign notification status.

dap uses this data to send account alerts, service messages, transaction notifications, campaign updates, referral notifications, Spin the Wheel reminders, streak reminders, reward notifications and other app notifications where permitted.

You can manage push notifications through your device settings.

3.14 Fraud, abuse and security data

dap may collect: risk signals; fraud indicators; abuse reports; suspicious activity indicators; account restriction records; device reputation signals; wallet risk signals; transaction risk signals; partner status information, where applicable; internal investigation records; security incident records.

dap uses this data to protect dap, protect users, prevent misuse, detect fraud, enforce terms, secure the app and comply with applicable laws.

4Personal data dap receives from third parties

dap may receive personal data or status information from: card issuing partners; fiat on-ramp providers; fiat off-ramp providers; bank-transfer providers; wallet providers; blockchain networks; blockchain analytics providers; fraud prevention providers; security providers; cloud hosting providers; customer support providers; analytics providers; marketing and referral providers; communications providers; app store platforms; social media platforms, where you interact with dap; other users, where they send funds to you, refer you, invite you, or include your details in a transaction.

Where a partner performs identity verification for its own service, dap may receive limited status information only, unless further sharing is required to provide support, prevent fraud, protect users, maintain security, or comply with applicable law.

5How dap uses personal data

dap uses personal data to:

1. Create and operate dap accounts.
2. Provide wallet access.
3. Enable sending and receiving.
4. Enable dap-to-dap transfers.
5. Display balances and transaction history.
6. Operate trading features.
7. Operate yield features.
8. Provide referral, founder access, golden ticket, streak and reward features.
9. Operate Spin the Wheel and other promotional features.
10. Provide free daily spins.
11. Determine and issue rewards.
12. Apply campaign rules.
13. Prevent duplicate accounts, abuse, automation and reward manipulation.
14. Connect users to optional partner-provided card, fiat, bank-transfer, on-ramp and off-ramp features.
15. Show partner feature status inside dap.
16. Provide customer support.
17. Resolve complaints and disputes.
18. Send service messages and security alerts.
19. Send reward, streak, referral and campaign notifications where permitted.
20. Maintain app performance and availability.
21. Detect, prevent and investigate fraud, abuse, unauthorised access and prohibited activity.
22. Protect dap, users, partners and infrastructure.
23. Enforce terms and policies.
24. Improve dap’s features, design, pricing, reliability and user experience.
25. Measure campaign performance and referral activity.
26. Send marketing communications where permitted.
27. Create aggregated, anonymised or de-identified analytics.
28. Comply with applicable laws, court orders, regulatory requests and legal obligations.

6Legal bases for processing

Where applicable law requires a legal basis, dap relies on one or more of the following.

6.1 Contract

dap processes personal data where necessary to provide dap to you, including account creation, wallet features, sending, receiving, transfers, referrals, promotional features, trading features, yield features, support and app functionality.

6.2 Legitimate interests

dap processes personal data where necessary for legitimate interests, including security, fraud prevention, abuse prevention, reward integrity, product improvement, analytics, customer support, business operations, dispute handling, enforcement of terms and service reliability.

dap considers and balances these interests against your rights and freedoms.

6.3 Legal obligation

dap processes personal data where necessary to comply with applicable laws, regulatory requirements, tax rules, accounting duties, court orders, law enforcement requests and other legal obligations.

This may include keeping accurate records of promotional rewards, cash rewards, user activity, fraud prevention measures and account activity where required.

6.4 Consent

dap relies on consent where required, including for certain marketing communications, optional cookies, optional analytics, push notifications, or other optional processing.

You may withdraw consent at any time. Withdrawal of consent will not affect processing already carried out before consent was withdrawn.

6.5 Vital interests

dap may process personal data where necessary to protect someone’s life, health or safety.

7Partner identity checks

dap does not directly conduct KYC as part of account creation, wallet access, sending, receiving, trading, yield features, referrals, founder access, promotional rewards, Spin the Wheel, or the standard dap user experience.

Certain optional features may be provided by third-party partners. Those partners may require identity verification before they provide their own services.

This may apply to partner-provided services such as: card issuance; fiat deposits; fiat withdrawals; bank transfers; fiat on-ramp services; fiat off-ramp services.

Where a third-party partner requires identity verification, the partner may collect and process information such as: full name; date of birth; nationality; residential address; government ID; selfie; proof of address; sanctions screening results; fraud prevention data; other information required by that partner for its own service.

dap does not directly collect identity documents for KYC as part of standard account use.

Where a partner performs identity verification, the partner is responsible for explaining what information it collects, why it collects it, how long it keeps it and who it shares it with.

dap may receive limited status information from a partner, such as whether your access to the relevant partner service has been approved, rejected, restricted, pending, unavailable, or requires further action. dap may use this information to make the relevant feature available in the app, provide customer support, prevent misuse, maintain account security and comply with applicable laws.

Using dap does not automatically require identity verification. Identity verification only applies where you choose to use a partner-provided feature that requires it.

Partners may process your personal data under their own privacy policies, terms, licences and legal obligations. You should review the relevant partner’s privacy policy before using that partner-provided service.

8Blockchain data and public networks

Some dap features interact with public blockchain networks.

Public blockchain data may include wallet addresses, transaction hashes, transaction amounts, timestamps, network fees, token movements and smart-contract interactions.

Public blockchain networks are generally transparent. Information recorded on a public blockchain may be visible to anyone and may remain available permanently. dap may not be able to delete, hide, edit or reverse public blockchain records.

You should not include personal information in public blockchain transaction messages, wallet labels, usernames or other public fields.

9Wallet security and private keys

dap may support self-custodial wallets, embedded wallets, wallet connections, social login flows, passkey flows, recovery tools or partner-supported wallet infrastructure.

Depending on the feature used, dap or its service providers may process: public wallet addresses; wallet connection metadata; authentication status; device metadata; encrypted session data; transaction instructions; digital signatures; recovery status metadata; security logs.

You are responsible for keeping your device, wallet, login credentials, passkeys, recovery information and authentication codes secure.

10Cookies and similar technologies

dap may use cookies, SDKs, pixels, local storage, device identifiers and similar technologies to: keep you signed in; remember your preferences; secure your account; detect fraud and abuse; measure website and app performance; understand how users interact with dap; attribute referrals and campaigns; operate Spin the Wheel and promotional features; maintain daily streaks; prevent duplicate accounts and reward abuse; improve features and design; send or measure marketing where permitted.

Some cookies and similar technologies are essential for dap to work. Others are optional and may depend on your settings or consent.

You can manage cookies through your browser or device settings. Blocking certain cookies may affect how some features work.

11Marketing and communications

dap may send you: service messages; security alerts; account notifications; transaction notifications; policy updates; support messages; founder access updates; referral updates; Spin the Wheel reminders; streak reminders; reward notifications; launch announcements; product updates; marketing communications where permitted.

You can opt out of marketing communications by using the unsubscribe link in emails or by changing your preferences where available.

You may still receive service, security, account, transaction and reward-administration messages where these are necessary for dap to operate.

12Promotions, rewards and Spin the Wheel

dap may offer promotional features, rewards, referral campaigns, founder access benefits, golden tickets, daily streaks, Spin the Wheel, free daily spins and other in-app benefits.

If you use dap promotional features, including Spin the Wheel, dap may collect and use information about your participation in those features.

This may include your account identifier, username, device or app identifiers, platform, app version, spin activity, charge level, daily streak activity, referral activity, reward result, reward history, timestamps, rule acceptance records and related fraud prevention signals.

dap uses this information to operate the promotional feature, provide free daily spins, determine and issue rewards, apply campaign rules, maintain streaks and referral rewards, prevent duplicate accounts, detect abuse or automation, investigate technical issues, resolve disputes, comply with legal obligations and keep accurate records of rewards issued.

Spin the Wheel rewards may include promotional credits, cash rewards, referral-related rewards, golden tickets, access perks, or other benefits shown in the app.

Where a cash reward or other reward is issued, dap may keep records of that reward and the account that received it.

dap may share limited information with service providers who help operate dap, host systems, prevent fraud, provide analytics, send notifications, or support customer service.

dap does not sell Spin the Wheel participation data.

dap keeps Spin the Wheel records for as long as reasonably needed to operate the feature, prevent abuse, resolve disputes, comply with legal obligations and maintain accurate reward records.

Spin the Wheel is part of dap’s promotional experience. It does not require dap to conduct KYC.

13How dap shares personal data

dap may share personal data with the following categories of recipients.

13.1 Service providers

dap may share personal data with companies that help operate dap, including cloud hosting providers, infrastructure providers, security providers, analytics providers, communication providers, customer support providers, fraud prevention providers, notification providers and software vendors.

13.2 Partners

Where you choose to use a partner-provided feature, dap may share or receive the information needed to make that feature available, display its status, provide support, prevent misuse and operate dap.

Partner-provided features may include card issuance, fiat deposits, fiat withdrawals, bank transfers, fiat on-ramp services and fiat off-ramp services.

13.3 Blockchain networks

Where you submit a blockchain transaction, the relevant transaction data may be broadcast to the applicable blockchain network. That network is public and operates independently from dap.

13.4 App stores and device platforms

Where you download dap through an app store or use dap on a device platform, the relevant app store or platform provider may process data under its own terms and privacy policy.

This may include download data, app diagnostics, crash reports, purchase status where applicable, device information and platform account information.

13.5 Professional advisers

dap may share personal data with lawyers, auditors, accountants, insurers, cybersecurity advisers and other professional advisers where necessary for business, legal, audit, insurance, security or compliance purposes.

13.6 Public authorities

dap may share personal data with courts, regulators, tax authorities, law enforcement agencies, government bodies or other public authorities where required or permitted by law.

13.7 Corporate transactions

dap may share personal data in connection with a future incorporation, merger, acquisition, financing, restructuring, sale of assets, transfer of business, insolvency process or similar transaction.

13.8 Protection of dap and users

dap may share personal data where necessary to protect dap, users, partners, infrastructure, rights, property, safety, security or service integrity.

14dap does not sell personal data

dap does not sell your personal data.

dap does not sell your Spin the Wheel participation data, referral data, reward history, wallet data, transfer data, trading data, yield data, account data, or support data.

15International transfers

dap, its service providers and partners may process personal data in countries other than the country where you live.

Where required by applicable law, dap uses appropriate safeguards for international transfers. These may include data processing agreements, standard contractual clauses, international data transfer agreements, transfer risk assessments, adequacy decisions or other lawful transfer mechanisms.

Partner-provided services may involve separate international transfers controlled by the relevant partner. Those transfers are governed by the partner’s own privacy policy and legal obligations.

16Data retention

dap keeps personal data for as long as reasonably necessary for the purposes described in this Privacy Policy.

Retention periods depend on: the type of personal data; the reason it was collected; the Services you use; whether your account remains active; legal, tax, accounting or reporting requirements; fraud prevention and security needs; promotional reward administration; reward dispute resolution; abuse prevention; technical backup cycles; applicable limitation periods.

Examples include: account data may be kept while your account is active; transaction records may be kept to provide account history, support, audit and dispute resolution; security logs may be kept to protect dap and investigate misuse; support records may be kept to evidence how issues were handled; marketing preferences may be kept to respect opt-outs; partner status records may be kept to show whether a partner feature is available to you; Spin the Wheel records may be kept to operate the feature, prevent abuse, resolve disputes and maintain accurate reward records; referral and campaign records may be kept to apply campaign rules, issue rewards and prevent duplicate claims; aggregated, anonymised or de-identified data may be kept for analytics and business purposes.

When personal data is no longer needed, dap deletes it, anonymises it, securely archives it, or otherwise handles it in accordance with applicable law.

Public blockchain data may remain available on public blockchain networks even after dap deletes or anonymises related off-chain records.

17Account deletion

You may request deletion of your dap account and associated personal data by contacting:

Where available, dap may also provide an in-app account deletion option.

When you request account deletion, dap will delete or anonymise personal data associated with your account unless it is reasonably necessary to retain certain information for legal, security, fraud prevention, reward administration, dispute resolution, accounting, tax, technical, or legitimate business reasons.

dap may retain limited records where needed to:

• Prevent fraud, abuse, duplicate accounts, reward manipulation, or unauthorised access
• Resolve disputes
• Comply with legal obligations
• Maintain accurate transaction or reward records
• Respect marketing opt-outs
• Preserve security logs
• Complete technical backup cycles
• Protect dap, users, partners, or service integrity

Public blockchain records cannot be deleted by dap because they are maintained by independent blockchain networks.

If your request relates to a partner-provided service, you may need to contact the relevant partner directly. dap may help direct you to the relevant partner where appropriate.

18Security

dap uses technical and organisational measures designed to protect personal data.

These may include: encryption; access controls; authentication controls; least-privilege permissions; monitoring; logging; secure infrastructure; vendor due diligence; security testing; incident response procedures; internal policies; backup and recovery processes; fraud monitoring; reward abuse monitoring.

No digital service is risk-free. You should keep your device, login credentials, wallet access, recovery information and authentication methods secure.

You should contact admin@dap.money immediately if you believe your account, wallet, device, login method or credentials have been compromised.

19Automated systems and risk controls

dap may use automated or semi-automated systems to help: detect fraud; prevent abuse; prevent duplicate accounts; detect automated use of promotional features; protect rewards from manipulation; identify security threats; protect accounts; monitor suspicious activity; apply account safety controls; check wallet or transaction risk; detect prohibited activity; maintain service integrity; route support issues; improve product performance.

These systems may use data such as device information, IP address, session behaviour, wallet activity, transaction patterns, reward activity, spin activity, charge activity, referral activity, risk signals, partner status information and security logs.

Where applicable law gives you the right to request human review of an automated decision that significantly affects you, you may contact dap using the details in this Privacy Policy.

20Your rights

Depending on where you live and which laws apply, you may have rights in relation to your personal data. These may include the right to: access personal data held about you; receive information about how your personal data is used; correct inaccurate or incomplete personal data; request deletion of personal data; restrict processing of personal data; object to processing of personal data; object to direct marketing; withdraw consent where processing is based on consent; receive a portable copy of certain personal data; complain to a data protection authority; request information about automated decision-making, where applicable.

Some rights may be limited where dap needs to keep or process personal data for legal, security, fraud prevention, transaction, reward administration, accounting, dispute resolution, public blockchain, or legitimate business reasons.

To exercise your rights, contact:

dap may ask you to verify your identity before responding to a rights request. This is to protect your account and prevent unauthorised disclosure of personal data.

Where your request relates to a partner-provided service, you may need to contact the relevant partner directly. dap may help direct you to the relevant partner where appropriate.

21Your choices

You can control certain uses of your personal data by: updating your account settings; changing marketing preferences; unsubscribing from marketing emails; managing cookie settings; managing device permissions; managing push notification permissions; disconnecting a wallet, where supported; choosing not to use optional partner-provided features; choosing not to use promotional features; contacting dap to exercise your rights.

Some personal data is necessary to provide dap. If you choose not to provide required information, certain features may not be available.

22Children

dap is intended for users who are at least 18 years old or the minimum age required to use the relevant service in their jurisdiction.

dap does not knowingly collect personal data from children. If dap becomes aware that a child has provided personal data to dap, appropriate steps will be taken to delete the data or close the account, subject to applicable law and any necessary security or record-keeping requirements.

23Third-party websites, wallets and services

dap may link to or integrate with third-party websites, wallets, apps, protocols, card providers, fiat providers, banking providers, on-ramp providers, off-ramp providers, social media platforms, analytics tools or other services.

These third parties operate independently from dap. Their privacy practices are governed by their own privacy policies and terms.

You should review the relevant third-party privacy policy before using any third-party service.

dap is not responsible for the privacy practices, security practices, content, availability, accuracy or conduct of third-party services.

24Changes to this Privacy Policy

dap may update this Privacy Policy from time to time.

If material changes are made, dap may notify you through the app, website, email, account notice, or another appropriate method.

The updated Privacy Policy will apply from the date stated at the top of the policy, unless stated otherwise.

Your continued use of dap after an updated Privacy Policy takes effect means that you acknowledge the updated Privacy Policy.

25Contact

If you have questions about this Privacy Policy, your personal data, your rights, or how dap handles privacy, contact:

Where required, you may also contact the relevant data protection authority in your jurisdiction.