In this Privacy Statement we describe who we are, how and for which purposes we process your personal data in this website, how you can exercise your privacy rights and other information that may be relevant to you.
We did our best to provide you with all information in a clear and readable format. However, if you have any questions about our use of your personal data after reading this Privacy Statement, you can always contact us through the contact details provided below.
Finally, we would like to point out that we are continually developing and improving the website. If this changes the way we process personal data, this will be reflected in this Privacy Statement. We therefore recommend that you regularly take notice of the Privacy Statement for any modifications.
Last modified: 3rd of April 2020
1. 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, the retailers. This is for instance, the case when you are participant of a loyalty programme. For reasons of completeness, we have also added the information we process, on behalf of our clients, when you participate in a loyalty programme. 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.
2. What do we do?
BrandLoyalty advises on, implements, provides, conducts and measures loyalty programmes 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 consumers if done properly. BrandLoyalty works with all of its clients and suppliers without compromising individual privacy.
3. Purpose of this Privacy Statement
With this Privacy Statement, BrandLoyalty aims to inform you how we treat and protect data relating to you and/or your device. Please take some time to read about what our business does by visiting any BrandLoyalty website, learn how we ensure that the data which is shared with us is collected and used safely, again not compromising individual privacy.
4. Which categories of (personal) data do we collect and/or process in relation to your and/or your devices?
BrandLoyalty processes (personal) data in relation to: website visitors, - on behalf of our clients - participants of a loyalty programme and (contact persons of) clients, suppliers or other business relations, as further described below (hereafter all data together is referred to as: ‘Customer data’). Please find below more information on BrandLoyalty’s processing of such data.
Functional, analytical and marketing cookies:
BrandLoyalty processes data relating to you and/or your device if you visit this website (‘Cookies’). In our Cookie Statement we describe how BrandLoyalty processes these cookies. In addition, we will explain how to manage, delete and/or block the processing of the cookies yourself.
On behalf of our clients BrandLoyalty may process data of you if you participate in one or more loyalty programmes of our clients.
BrandLoyalty may process the following data categories about you:
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 programme, 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:
BrandLoyalty collects and processes data relating to persons who work with BrandLoyalty such as clients, suppliers or other business relations.
BrandLoyalty may process the following data categories about you:
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).
5. 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|
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 sub purpose at stake), and not all legal bases simultaneously.
6. Who may receive your data from us?
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 programme|
|Provider of an e-mail service|
|Provider of financial administration|
|Provider of administration software|
|Provider of data sharing tool|
|Provider of KYC-system|
|Third party marketing partners|
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.
7. 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 programme 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.
8. 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.
9. How long will BrandLoyalty keep your personal data?
Customer 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:
10. 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 firstname.lastname@example.org.
If you feel we have not appropriately dealt with your complaint, you may also submit a complaint at a local data protection authority.
11. 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: email@example.com.
Brand Loyalty International B.V.
5211 BH ‘s-Hertogenbosch