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Privacy statement

This Privacy Statement (“Privacy Statement”) explains to you how BrandLoyalty respects your privacy and handles your personal data. 

When you make use of this website or other services, BrandLoyalty processes your personal data for several purposes as described in this Privacy Statement.

In most cases, we are obliged to gather, store and share your data to provide requested services, meet regulatory requirements, execute service agreements as well as comply with our internal processes. In any event, BrandLoyalty will process your personal data in accordance with good privacy practices and applicable privacy laws.

Applicability and scope
The Privacy Statement is applicable to all consumers, clients, suppliers, visitors, contractors and other business relations of BrandLoyalty and all its affiliated companies worldwide.

Last modified: 9th of May 2022

Who are we? 
BrandLoyalty collects and processes data related to website visitors, app users and (contact persons of) clients, suppliers or other business relations (hereafter together referred to as: ‘you’). We are responsible for the processing of your personal data as described in this Privacy Statement and qualify as ‘data controller’ under applicable data protection laws. BrandLoyalty is established at Koningsweg 101, 5211 BH ‘s-Hertogenbosch, The Netherlands. 

However, we do not always act as a data controller. We can also process personal data on behalf of our clients. This is for instance, the case when you are participant of a loyalty program. For reasons of completeness, we have also added the information we process, on behalf of our clients, when you participate in a loyalty program. Specific data protection conditions imposed by the relevant retailer can apply to the processing of this information. Please check the privacy statement of the relevant retailer as well. 

What do we do?
BrandLoyalty advises on, implements, provides, conducts and measures loyalty programs and provides all necessary related retail (mobile) services. To do this we follow information usage practices based on our beliefs: first, that protecting user privacy is essential to the growth and success of online digital services provided by BrandLoyalty; second, that a personalized digital experience can provide significant benefits to our clients and their customers if done properly. BrandLoyalty works with all of its clients and suppliers without compromising individual privacy.

Which categories of personal data do we collect and/or process in relation to you and/or your devices?
BrandLoyalty processes personal data in relation to: website visitors, participants of a loyalty program, clients, suppliers and other business relations, as further described below. Please find below more information on BrandLoyalty’s processing of such data.

Functional, analytical, performance and marketing cookies:
BrandLoyalty processes data relating to you and/or your device if you visit this website (‘Cookies’). We also use Hotjar to better understand our users’ needs and to optimize the service and experience of our website. Hotjar is a technology service that helps us better understand our users’ experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. You can choose to interact with Hotjar by providing feedback or your email address through the Hotjar pop-up. Hotjar also uses cookies and other technologies to collect data about your behaviour on the website.

In our Cookie Statement more is described how BrandLoyalty processes cookies. In addition, we will explain how to manage, delete and/or block the processing of the cookies yourself. 

Consumer details:
On behalf of our clients BrandLoyalty may process data of you if you participate in one or more loyalty programs of our clients. 

BrandLoyalty may process the following data categories about you:

  • ·       Personal details: name.
  • ·       Contact details.
  • ·       Loyalty card number or other identification numbers.
  • ·       Loyalty program information, including transactional data.
  • ·       Any other personal data provided by you directly, for instance in surveys.
  • ·       Any personal data whose processing is required pursuant to, or necessary with a view to the application of legislation.

BrandLoyalty may have (partly) received your data from sources other than directly from yourself, i.e. by obtaining information from our clients who we help setting up and/or maintaining any loyalty program, intermediary parties, market research companies and social media companies. 

BrandLoyalty may process the following data categories about you when you make use of our customer services or contact us:

  • ·       Personal details: name.
  • ·       Contact details.
  • ·       Correspondence details: questions and complaints.
  • ·       Any other personal data you provide to us voluntarily.

Client details: 
BrandLoyalty collects and processes data relating to persons who work with BrandLoyalty, join one of our studio sessions or register for our newsletters such as clients, suppliers or other business relations. 

BrandLoyalty may process the following data categories about you:

  • ·       Personal details (name).
  • ·       Contact details.
  • ·       Company and job details.
  • ·       Country
  • ·       Any other personal data provided by you directly.
  • ·       Any personal data whose processing is required pursuant to, or necessary with a view to the application of legislation.

BrandLoyalty may have (partly) received your data from other sources besides directly from you, i.e. by obtaining information from the local Chamber of Commerce or to do other (legal) checks to prevent corruption, identity theft, financial fraud, money laundering and/or terrorist financing (Know Your Customer procedures).

For which purposes does BrandLoyalty process your personal data?
BrandLoyalty collects and processes personal data described above for multiple purposes, which can be subdivided as follows:

Categories

Purpose

One of the following legal bases

Consumer details:

  • For our loyalty program purposes;
  • Data validation, enhancement, information verification and suppression;
  • To comply with applicable laws and regulations or to respond to a lawful request for information received by us, whether or not a response is required by applicable law;
  • To enforce our terms of use and other agreements or to protect our rights;
  • To protect the safety of members of the public and users of the service;
  • Reporting.
  • Your consent
  • Legitimate interest of BrandLoyalty: i.e. to conduct core business activities / to facilitate regular business activities;
  • Necessary to fulfil legal requirement applicable to BrandLoyalty;
  • Necessary for performance contract between you and BrandLoyalty (or take pre-contractual arrangements).

Client details:

  • For our loyalty program services;­­
  • To contact clients, suppliers and other business relations;
  • To register visitors of our offices;
  • To process your registration for studio sessions and to send you follow-up emails about similar services.
  • To send you marketing emails, new offers and other business updates. 
  • To comply with applicable laws and regulations or to respond to a lawful request for information received by us, whether or not a response is required by applicable law;
  • To enforce agreements or to protect our rights
  • Reporting.

 

  • Your consent
  • Legitimate interest of BrandLoyalty: i.e. to conduct core business activities / to facilitate regular business activities;
  • Necessary to fulfil legal requirement applicable to BrandLoyalty;
  • Necessary for performance contract between you and BrandLoyalty (or take pre-contractual arrangements).

Please be aware that the processing of the data categories for the purposes, as mentioned above, are based on one of the legal bases mentioned (depending upon the specific data category and process at stake), and not all legal bases simultaneously.

Studio sessions and newsletters
BrandLoyalty offers studio sessions about relevant business topics and industry insights. Any visitor can choose to join the studio sessions by completing a registration on the website. After registration BrandLoyalty will be able to send you the invitation, a recording and updates on upcoming studio sessions you might find interesting. In every subsequent email, you will have the opportunity to unsubscribe from receiving these updates. For this processing we rely on our legitimate interest to improve our services or to contact you for similar services.

On the website you can also register to receive our newsletter, receive new offers and other updates. You can opt-out of receiving these marketing updates at any time by using the unsubscribe link in the emails or by contacting us through the contact details below. This processing is based on your consent, which is provided when you request to receive these our newsletter, receive new offers and other business updates.

Please note that if you have registered for the studio sessions and marketing, and you opt out of receiving marketing-related communications from us, we may continue to send you non-promotional communications such as follow-up studio sessions. 

Who may receive your data from us?
BrandLoyalty will only share personal data for limited purposes such as those provided in this Privacy Statement. This may include sharing information (1) to enable third party service providers to assist or facilitate in the services we provide to our clients; (2) to comply with applicable laws and regulations or to respond to a lawful request for information received by us, whether or not a response is required by applicable law; (3) to enforce our terms of use and other agreements or to protect our rights; (4) to protect the safety of members of the public and users of the service; (5) with other BrandLoyalty entities and clients for our loyalty program purposes; (6) with vendors, administrative service providers, technology providers, and carefully selected partners for services including, but not limited to, data validation, enhancement, information verification and suppression services; or (7) for any other purpose for which you provide up front consent.

Please find below a schedule with the (types of) partners we use:

Type of recipient 

You (in your personal account or when requested access)

Other BrandLoyalty-entities and/or its subsidiaries and affiliates

Provider of an accountancy program

Provider of an e-mail service

Provider of financial administration

Provider of administration software

CRM provider

Provider of data sharing tool

Provider of KYC-system

Third party marketing partners

Business partners

Clients

Publishers

While BrandLoyalty strongly encourages and where possible commits its clients and partners to adopt responsible approaches to the gathering and storage of personal data, BrandLoyalty is not responsible for the information practices of such clients and partners. 

In the event that BrandLoyalty is acquired by or merged with a third party, we reserve the right, in any of these circumstances, to transfer or assign the information we have collected from you as part of such merger, acquisition, sale, or other change of control. In the unlikely event of our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors' rights generally, we may not be able to control how your information is treated, transferred, or used.

Does BrandLoyalty protect your personal data?
The security of your information is important to us. We have implemented appropriate (technical and organizational) security measures to protect the information in our care, both in transit and at rest. We take technical and organizational security measures to protect our data from unauthorized access, as well as unauthorized disclosure or destruction of data. No transmission of data over the internet is guaranteed to be completely secure. While we strive to protect your data, it may be possible for third parties not under the control of BrandLoyalty to unlawfully intercept or access transmissions or private communications. Unauthorized entry or use, hardware or software failure, and other factors may compromise data security. BrandLoyalty cannot ensure or warrant the security of information you transmit to us. You acknowledge and assume this risk when communicating with BrandLoyalty. BrandLoyalty will inform you in case of a data security breach if required by applicable law or otherwise considered feasible in our opinion. 

Our philosophy on privacy at BrandLoyalty follows the framework of Privacy by Design. We integrate privacy in strategy, our loyalty program set up for our clients, our (mobile) product development, and more. We can protect consumer privacy while at the same time being able to provide our clients with the relevant information and conclusions they need. Ensuring the protection of privacy throughout the entire lifecycle of the data is of the utmost importance and BrandLoyalty is at all times careful to protect privacy as data is collected, used, and destroyed responsibly.

Does BrandLoyalty protect your personal data in case they are transferred outside the country where it is collected?
BrandLoyalty does not transfer personal data of EU consumers to receivers in third countries outside the European Union unless it is necessary for the purpose the data is collected that the data may be transferred to another country. In that case, BrandLoyalty will take the appropriate measures to ensure your data is protected within the limits set by law.

Personal data of non-EU consumers shall remain in the country where the consumers’ personal data is collected unless it is necessary for the purpose data is collected that the data may be transferred to another country. In that case, BrandLoyalty will take the appropriate measures to ensure your data is protected within the limits set by law.   

How long will BrandLoyalty keep your personal data?
Personal data will be stored as long as necessary for the purpose for which the data is collected and processed.

To determine the data retention period of a particular category of personal data, BrandLoyalty uses the following criteria:

  • BrandLoyalty takes maximum data retention periods, as suggested by local regulators, into account. 
  • BrandLoyalty complies with its legal requirements to record and/or store data or files for a certain minimum period.

Which rights can you exercise with regards to your personal data we process?
In general, you have the right to request BrandLoyalty to have access to your data. In certain circumstances, you have a right to rectify or delete your data, to block the data processing (e.g. if the data processing is no longer necessary for BrandLoyalty’s purposes), to object to the data processing (e.g. with regards to direct marketing and if you no longer wish to receive any direct marketing information from BrandLoyalty) and to invoke your right to data portability (e.g. if our data processing is based on your consent). You can invoke your rights by contacting BrandLoyalty’s Data Protection Officer privacy@brandloyalty-int.com.

If you feel we have not appropriately dealt with your complaint, you may also submit a complaint at a local data protection authority.

Who can you contact about my data?
If you have a question or would like to submit a complaint with regards to the collection and processing of your data by BrandLoyalty, you can contact BrandLoyalty’s Data Protection Officer: privacy@brandloyalty-int.com  

Brand Loyalty International B.V.
Koningsweg 101
5211 BH ‘s-Hertogenbosch
The Netherlands