1. Data Controller and Contact Information

Biagio Firetto trading as Tap Engage Solutions (operating Find Local Hub via findlocalhub.co.uk) acts as the Data Controller.

2. The Data Lifecycle (Collection & Methods)

We collect data through specific digital and physical touchpoints:

• Direct Registration: Business Partners and Referral Partners provide contact, industry, and financial data via HTML forms. This data is transferred via secure automation (Zapier) and stored within encrypted cloud environments (Google Sheets) for account management and Self-Billing (tax compliance).
• Passive Interaction (Scans): We monitor engagement via NFC tags and QR codes (on vehicles, shopfronts, and community assets). These are recorded as non-identifiable statistical "pings." We do not collect the personal identity, name, or phone number of the individual scanning.
• Active Interaction (Reviews & Challenges):
  • Reviews: Users must provide a Name and Email to ensure feedback is traceable and authentic (Consumer Protection compliance).
  • Community Challenges: Participants in "Scavenger Hunts" or "Orienteering" provide interaction data to verify prize eligibility.
• Media Capture: We perform on-site cinematic filming and photography. This footage is captured under signed creative-release agreements and stored securely for partner dashboards.

3. Lawful Basis for Processing

• Contractual: To provide directory listings, cinematic media, and referral payments.
• Legitimate Interests: To provide Capital Allocation & Marketing Effectiveness Analysis (identifying which physical assets drive the most ROI) and to facilitate community "Social Value" projects.
• Legal Obligation: To verify review authenticity and maintain accurate financial records for HMRC/Self-Billing.

4. Data Usage & Strategic Provision

• Performance Audits: We use interaction data to tell partners exactly which marketing assets (e.g., "Van QR" vs. "Exit Door NFC") are performing.
• Public Sector Integration: We aggregate and anonymize all interaction "pings" to create Economic Heatmaps and Foot Traffic Reports. These anonymized datasets are sold to local government bodies, municipal councils, and urban planners for infrastructure development.
• Corporate ESG/CSR: We provide anonymized engagement data to corporate sponsors of community assets (e.g., branded bins) to measure their social impact.

5. Data Sharing & Third-Party Processors

We use trusted third-party tools to facilitate our operations:

• Automation & Storage: Zapier (data transit) and Google Workspace (encrypted storage).
• Verification: We do not share personal partner data with third parties except for the purpose of processing payments or where required by law.

6. Retention and The Right to be Forgotten

In accordance with UK GDPR, all subjects (Partners and Reviewers) have the Right to be Forgotten.

• Financial Records: Retained for 6 years (Statutory requirement).
• Media/Reviews: Retained until a deletion request is made or the contract ends.
• Anonymized Data: Aggregate "pings" are kept indefinitely for trend analysis as they contain no personal identifiers.

7. Statutory Rights

You have the right to access, correct, or delete your data. Requests will be handled by our Data Protection Lead within 30 days. Complaints can be lodged with the Information Commissioner’s Office (ICO).