Loyalty Pro Limited ("LPL") is committed to protecting and respecting the privacy of all members of loyalty schemes which are administered by LPL.
This policy (together with the terms and conditions of the loyalty rewards membership agreement (“Membership Agreement”) and any other documents referred to in it) [LINK] sets out the basis on which any Personal Data LPL collects, or that you provide to LPL, will be processed. Please read the following carefully to understand LPL’s practices regarding your Personal Data and how we will treat it.
For the purpose of data protection legislation, Loyalty Pro Limited of Network House, St. Ives Way, Sandycroft, Deeside, Clwyd, CH5 2QS (registered in England and Wales with company number 05907642) is the data controller.
As data controller, LPL determines the purposes for which and the manner in which your personal data will be, processed.
The Trader will also be data controller in common with LPL. In subscribing for the Customer Loyalty Rewards Programme you have freely given your specific, informed and unambiguous consent to receive marketing communications from the Trader regarding the Trader’s products, services, offers, loyalty rewards and other information which the Trader believes may be of interest to you.
In this policy, the following definitions are used:
Application: means a software application by which the Member registers for the Customer Loyalty Rewards Programme.
Customer Loyalty Rewards Programme: means the customer loyalty rewards programme(s) to which you have subscribed (a) in respect of a specific Trader; and/or (b) with LPL more generally.
Mastercard: means Mastercard Europe S.A.
Member/You: means you, a customer who has (a) subscribed for the Customer Loyalty Rewards Programme on the LPL website directly; or (b) via a Trader’s browser access.
Payment Provider: means a payment provider authorized pursuant to Condition 15.3.2 to provide Transaction Data to a TPP and includes, as at the date of these Conditions, Mastercard .
Personal Data: means any information relating to an identified or identifiable natural person.
Trader: means the third party trader on whose behalf LPL administer the Customer Loyalty Rewards Programme.
Transaction: means a point of sale purchase made by a Member with an enrolled payment card with either LPL directly and/or a Trader.
Transaction Data: means data supplied via a Payment Provider relating to a Transaction including the following: Merchant ID; card token; date; time; and amount.
Information LPL collects from you
LPL will collect and process the following data about you:
- Information you give LPL.
- This may include your name, address, e-mail address and phone number, financial and credit card information, personal description and photograph, and other information which is necessary for the administration of the Customer Loyalty Rewards Programme.
- We obtain this information in a number of ways:
- When you subscribe to the Customer Loyalty Rewards Programme either via our, or one of our traders websites.
- When you sign up using one of our secure web pages
Information you have provided to the Trader and authorised them to share with us so that we can administer the Customer Loyalty Rewards Programme.
- Information LPL collect about you. Whenever you access the Application or make use of the loyalty card issued in relation to the Customer Loyalty Rewards Programme, LPL will automatically collect the following information:
- technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, and your login information;
- Information LPL may receive from other sources. This is information LPL may receive about you if you use any other applications, services or websites LPL provide. In such cases LPL will inform you when LPL collects that data if LPL intends to share the data internally and combine it with data collected from you when you subscribed for the Customer Loyalty Rewards Programme. LPL will also tell you the purposes for which we may share and combine your data. LPL works closely with third parties (including, for example, banks, credit card companies, Traders, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies). Cookies
How we use your information
LPL will use information held about you in the following ways:
- Information you give to LPL. LPL will use this information:
- In the performance and administration of the Customer Loyalty Rewards Programme you have subscribed to and to provide you with the information, products and services that you request from LPL;
- To provide you with information about other goods and services which are offered by the Trader on whose behalf LPL are administering the Customer Loyalty Rewards Programme;
- To provide the Trader with all information they need in respect of the Customer Loyalty Rewards Programme you have subscribed to, including (but not limited to) for the purpose of administering your account and tracking loyalty points and rewards earned, issued, redeemed, cancelled and other information relevant to your account;
- to ensure that any of LPL’s content (whether on an Application or on any LPL or Trader website) is presented in the most effective manner;
- Information LPL collects about you. We will use this information:
- to administer the Application, LPL’s website or the Trader’s website for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- To ensure that the content we provide to you online is up to date, effective and secure.
- to allow you to participate in interactive features of the Customer Loyalty Rewards Programme, when you choose to do so;
- to help us understand the effectiveness of our advertisingvia the Application, LPL’s website or the Trader’s website (where this is used to access your account);
- to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.
Information LPL receive from the Trader and other sources. LPL will combine this information with information you give to LPL and information LPL collects about you. LPL will use this information and the combined information for the purposes set out above (depending on the types of information we receive).
Disclosure of your information
In order to provide you with the Customer Loyalty Rewards Programme, we may share your personal information with:
- Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries.
- the Trader who is participating in the Customer Loyalty Rewards Programme.
- Selected third parties including:
- business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
- third party suppliers who are engaged by LPL to connect your payment cards with rewards services or card-linked offers in connection with Transaction(s).
We will disclose your personal information to the above third parties:
- Transaction Monitoring. If you choose to register a payment card in connection with Transaction monitoring, you authorise LPL to share your payment card information with Mastercard so it knows you have enrolled. You authorise Mastercard to monitor Transactions on your registered card(s) to identify qualifying purchases, and for Mastercard to share such Transaction details with LPL to enable LPL to implement our offers , and to target other offers that may be of interest to you. You may opt-out of Transaction monitoring on the payment card(s) you have registered by [insert details – e.g. by emailing [ ] or following this link ].
- If LPL or substantially all of its assets are acquired by a third party, in which case personal data held by LPL about Members and the loyalty schemes administered by it will be one of the transferred assets.
- If we are under a duty to disclose or share your personal data due to a legal obligation,
- Or in order to enforce or apply the terms of the Membership Agreement and other agreements;
- Or to protect the rights, property, or safety of LPL, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
Where LPL will store your personal data
All information you provide to LPL is stored on LPL’s secure servers. Where LPL has given you (or where you have chosen) a password which enables you to access your account, you are responsible for keeping this password confidential. LPL asks you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although LPL will do its best to protect your personal data, LPL cannot guarantee the security of your data transmitted via an Application, LPL’s website or the Trader’s website; any transmission is at your own risk. Once LPL has received your information, LPL will use strict procedures and security features to try to prevent unauthorised access.
LPL’s website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that LPL does not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
THIRD PARTY PROCESSORS
How long lpl will store personal data
LPL will store your Personal Data for as long as is necessary to carry out your subscription to the Customer Loyalty Rewards Programme.
If you cancel, or end your subscription to the Customer Loyalty Rewards Programme LPL will retain your Personal Data for a period of six (6) years from the date of termination in order to enforce or apply the terms of the Membership Agreement and other agreements; or to protect the rights, property, or safety of LPL, the Trader, LPL’s customers, or others.
If you are an individual in respect of whom LPL processes Personal Data, you have the following rights:
- Right of access to your Personal Data
o you can request a copy of the Personal Data LPL holds about you. If your request is sent to LPL electronically LPL will supply this in a commonly used electronic form, unless you specifically request this in a different format.
o LPL will supply the data within 1 month of the date of your request free of charge. If your request is complex or numerous LPL may extend this period by a further period of two months (though LPL will inform you within one month of the receipt of your request if this is the case and explain why the extension is necessary).
o LPL reserves the right to charge a reasonable fee if you request additional copies of the information, to cover LPL’s administration costs. If access requests are unfounded or excessive LPL may charge a reasonable fee to provide the data, take the action requested, or refuse to act on the request.
- Right to request the rectification of your Personal Data
o However, in the event that you become aware that LPL holds any inaccurate or incomplete Personal Data, you can send a rectification request for LPL to correct any inaccurate data or to complete any incomplete data it holds.
o LPL will respond to a rectification request within 1 month of the date of your request. If your request is complex LPL may extend this period by a further period of two months.
o If LPL intends to take no action in respect of a notification request LPL shall explain this to you along with further information about your rights.
- Right to request the erasure of your Personal Data (the “right to be forgotten”)
o If LPL holds Personal Data :
- which you believe is no longer necessary for the purpose it was collected; or
- you withdraw your consent to the processing; or
- you object to the processing; or
- which you believe is being processed unlawfully
- you may request that we erase any Personal Data held by LPL.
o LPL will upon request erase any inaccurate Personal Data without delay unless LPL needs to retain the Personal Data for any of the purposes specified in GDPR.
- Right to request the restriction on processing of your Personal Data
o You may request LPL to restrict processing of your Personal Data:
- which you believe is being unlawfully processed but where you do not want us to delete the data completely;
- which you believe LPL no longer needs but which you wish LPL to store for you .
- Right to object to LPL’s processing of your Personal Data
o You may object to LPL’s processing of your Personal Data where processing is based on public interests or legitimate interests for direct marketing.
o If you object LPL will stop processing the Personal Data unless LPL:
- has a compelling legitimate ground for processing the Personal Data that overrides your interests; or
- needs to process the Personal Data to establish, exercise, or defend legal claims.
- Right to data portability in respect of your Personal Data.
o You have the right to request LPL to:
- supply your Personal Data in a commonly used and machine-readable format so that you may store it for further personal use on a private device;
- transmit the Personal Data to another data controller;
- transmit your Personal Data directly to another data controller where technically possible.
o However, this portability does not apply to all personal data processed by LPL, where you have requested that we restrict the use of your data and this right does not apply, we will contact you to explain
- Right to notification of any breach
o In the unlikely event of a Personal Data breach which is likely to result in a high risk to your rights, LPL will notify you of the breach without undue delay.
We will contact you within one month in order to confirm if we will be complying with your request, or if not, why not.
This policy will be updated from time to time, the policy was last updated on 23/05/18