Privacy Policy

Prepared: 2026-06-15 · Version: 1.0 (legal-review)

Entity: KOMPOZITZYA, company no. 300975117 — Haim Herzog 7, Hod HaSharon, Israel

Audience: Players (people who use the PerkTap app to play and earn rewards)

Status: Draft for legal review — not yet effective.

This Privacy Policy explains how KOMPOZITZYA ("PerkTap", "we", "us") collects, uses, stores, and shares personal data when you use the PerkTap mobile application and related services (the "App"), whether you use it as a Guest or as a Registered Player.

We process personal data in accordance with the Israeli Protection of Privacy Law, 5741-1981 and its regulations, including Amendment No. 13 (in effect since August 14, 2025), and the Protection of Privacy Regulations (Data Security), 5777-2017.

This is the Player-side Privacy Policy. PerkTap maintains a separate Privacy Policy for business Clients (merchant operators); if you operate a merchant account, see the Client Privacy Policy.

1. Who We Are

PerkTap is a skill-based rewards game. You earn a virtual in-app currency ("Coins") by playing rounds, open reward chests using informed choice and skill, and redeem Perks at participating local businesses ("Merchants").

Data controller: KOMPOZITZYA, company no. 300975117, Haim Herzog 7, Hod HaSharon, Israel

Privacy contact: privacy@perktap.app

Data Protection Officer: Not currently appointed. This position is under review pending legal counsel's determination of whether Amendment No. 13 to the Protection of Privacy Law, 5741-1981 requires KOMPOZITZYA to appoint a DPO given the nature, scope, and volume of its data processing activities. [COUNSEL TO CONFIRM BEFORE PUBLICATION - if a DPO is required or appointed, this section must be updated with the DPO's name and contact details.] In the interim, all privacy queries are handled at privacy@perktap.app.

2. What Data We Collect

Under Israeli law, personal data includes online identifiers such as IP addresses, device identifiers, and geolocation data.

2.1 If you use the App as a Guest

You can play without creating an account. In Guest mode we collect only:

  • A device-level identifier (to keep your Coin balance and game progress on your device)
  • Technical data: device model, OS version, app version, IP address, crash logs
  • In-app activity: Coins earned, chests opened, screens viewed

Guest data is not linked to your name, phone, or email, because we do not have them. If you uninstall the App without registering, your Guest progress and balance may be permanently lost.

2.2 If you register an account

When you create an account (including via the "save your Coins" prompt shown to Guests), we additionally collect:

  • Name or nickname
  • Phone number and/or email address
  • Login credentials or third-party sign-in identifier (e.g., Sign in with Apple, Google)
  • Your Coin balance, reward history, and redeemed Perks (migrated from your Guest session, if any)

2.3 Redemption data

When you redeem a Perk at a Merchant, we record the Perk, the Merchant, the time, and the redemption status. The Merchant sees only what is needed to honor the Perk, not your full profile.

2.4 Location data

With your permission, we use approximate or precise location to show nearby Merchants and Perks. You can refuse or withdraw this permission in your device settings; the App will still work, with reduced location-based features.

2.5 What we do NOT collect

We do not knowingly collect especially sensitive data (e.g., health, biometric, or financial-account data) from Players. The App does not require or accept payment from Players.

3. Purposes and Legal Basis

We use the data above to:

  • Operate the App: maintain balances, run the chest game, deliver Perks
  • Prevent fraud and abuse (e.g., duplicate redemptions, balance manipulation)
  • Communicate with you about your account and rewards
  • Improve the App (aggregated analytics)
  • Comply with legal obligations

We collect personal data with your knowledge and explicit, freely given, informed consent, in accordance with Section 11 of the Protection of Privacy Law, 5741-1981 and Amendment No. 13. Your consent is obtained through an active, affirmative action - such as checking a consent box or tapping 'I Agree' - presented at the point of registration or, for optional data types (such as location), at the point of first relevant collection. When we ask for data, we will tell you: (a) whether providing it is required or voluntary; (b) the purpose of collection; and (c) to whom data may be transferred. You may withdraw consent at any time for optional processing (such as marketing messages or location services) using the mechanisms described in Section 7, without affecting the lawfulness of processing carried out before withdrawal. If you decline to register, you may continue as a Guest, but your Coin balance is device-bound and recovery is not possible if the App is uninstalled or your device is reset.

4. Sharing of Data

We share personal data only with:

  • Merchants — minimal redemption data, as described in 2.3
  • Service providers — hosting, analytics, push notifications, and customer support, operating under contractual confidentiality and data-security obligations
  • Authorities — where required by law or court order

No sale or advertising disclosure - we do not sell, rent, or license Player personal data to third parties, advertising networks, or data brokers. We do not share Player data for third-party advertising or profiling purposes.

We do not sell Players' personal data.

Transfers abroad: some providers store data outside Israel. Such transfers are made in accordance with the Privacy Protection (Transfer of Data to Databases Abroad) Regulations, 5761-2001.

5. Data Security

We implement technical and organizational security measures consistent with the Protection of Privacy Regulations (Data Security), 5777-2017, appropriate to the risk level of our database, including: (a) encryption of personal data in transit and at rest; (b) access controls and role-based permissions limiting access to authorized personnel only; and (c) periodic security reviews conducted at intervals appropriate to the nature of the data processed. In the event of a security incident involving personal data, we will notify the Privacy Protection Authority as required by law and, where required under Amendment No. 13 to the Protection of Privacy Law, will notify affected Players within the timeframes prescribed by applicable regulations. No system is perfectly secure; we cannot guarantee the absolute security of personal data. Players who become aware of any unauthorized access or security concern are encouraged to contact privacy@perktap.app immediately.

6. Retention

  • Guest data and technical logs (crash logs, IP address, device and app diagnostics): retained while the App is installed and for up to 12 months of inactivity or last log event, whichever is later, then deleted or anonymized.
  • Account data: retained while the account is active and for 7 years after closure, as needed for legal, accounting, and fraud-prevention purposes
  • Redemption records: 7 years (Merchant billing and audit requirements)

7. Your Rights

Under the Protection of Privacy Law you have the right to:

  • Access the data we hold about you (Section 13)
  • Correct or delete inaccurate, incomplete, or outdated data (Section 14)
  • Withdraw consent to optional processing (e.g., marketing, location)
  • Opt out of marketing messages — every marketing message includes an opt-out, per Section 30A of the Communications Law (Telecommunications and Broadcasting), 5742-1982 (the "Spam Law")

To exercise these rights, contact privacy@perktap.app. We will respond within the timeframes set by law.

8. Account Deletion

Registered Players can delete their account from within the App at Settings → Account → Delete Account, as required by Apple App Store Review Guideline 5.1.1(v). Deletion is permanent: Coins and unredeemed Perks are forfeited, and personal data is deleted or anonymized per the retention rules in Section 6, except where the law requires us to keep certain records. Redemption data previously shared with Merchants in connection with honored Perk Tickets is governed by those Merchants' independent data-controller obligations under the Client Terms; PerkTap cannot delete data held by third parties.

9. Children

The App is intended for users aged 13 and over. We do not knowingly collect personal data from children below this age.

10. Tracking and Analytics

The App uses the Meta (Facebook) SDK for measurement and advertising purposes, including tracking app installs, app opens, and selected in-app events, such as a returning-player signal when you start a second game. Meta may receive device identifiers and usage data to help us understand which advertisements brought you to PerkTap and to show PerkTap advertisements to similar players. On iOS, we may display Apple’s App Tracking Transparency prompt, allowing you to permit or deny the use of your device’s advertising identifier for this measurement. If you deny tracking, the App will continue to function normally; however, Meta may still receive aggregated measurement data through Apple’s SKAdNetwork, with less detailed information.

11. Changes to This Policy

We may update this policy. Material changes will be announced in the App. Continued use after the effective date constitutes acceptance.

12. Contact

KOMPOZITZYA · Haim Herzog 7, Hod HaSharon, Israel · privacy@perktap.app