1. About this Policy
1.1 This policy explains when and why we collect personal information about our customers, and how we act as a "data processor" on their behalf. It covers how we use this data and how we keep it secure and your rights in relation to it.
.2 We may collect, use and store your personal data, as described in this Data Processing Policy and as described when we collect data from you.
1.3 We reserve the right to amend this Data Processing Policy from time to time without prior notice. You are advised to check our website ( http://gainloyalty.com ) regularly for any amendments (but amendments will not be made retrospectively).
1.4 We will always comply with the General Data Protection Regulation (GDPR) when dealing with your personal data. Further details on the GDPR can be found at the website for the Information Commissioner (www.ico.gov.uk). For the purposes of the GDPR, we will be the “controller” of all personal data we hold about our clients, and their customers.
2. Who are we?
2.1 We are Gain Loyalty Ltd. We can be contacted at 64 Southwark Bridge Road, London, SE1 0AS, email: hello@gainloyalty.com or phone 01473 396470.
3. What information we collect about our clients and why.
| Type of information | Purposes | Legal basis of processing |
|---|---|---|
| Client’s name, business name address, telephone numbers, e-mail address(es). | Managing the client’s service. | Performing our contract with the client. For the purposes of our legitimate interests in operating the Gain Loyalty service. |
| Business Name and the address(s) and telephone numbers of business premises | To enable us to show their business locations on a map for their customers (if enabled by the client). | Performing our contract with the client. |
| Staff name and email address |
To enable members of staff to sign in individually to our service. | Performing our contract with the client. |
4. What information we hold about our clients' customers as a "data processor" and why.
| Type of information | Purposes | Legal basis of processing |
|---|---|---|
| Customer’s e-mail address. | To act as a unique identifier that will enable a customer to sign in to their own account if this capability is enabled. | Performing our contract with the client. For the purposes of our legitimate interests in operating the Gain Loyalty service. |
| Customer’s e-mail address, name, telephone number | To enable a client to engage in permission-based communication with their customers. | Performing our contract with the client. |
| Other customer information | To enable the client to hold securely additional data fields as they see fit in their role as a "data processor". | Performing our contract with the client. |
| Customer’s historical loyalty transactions (including date and time) | To enable a customer to accrue loyalty points, and to have an auditable and transparent record of how these were earned. | Performing our contract with the client. |
5. How we protect your personal data
5.1 We will not transfer your personal data outside the EEA without your consent.
5.2 We have implemented generally accepted standards of technology and operational security in
order to protect personal data from loss, misuse, or unauthorised alteration or destruction. We
will notify you promptly in the event of any breach of your personal data which might expose you
to serious risk.
5.3 Please note however that where you are transmitting information to us over the internet this can
never be guaranteed to be 100% secure.
5.4 For any payments which we take from you online we will use a recognised online secure payment
system.
5.5 We will notify you promptly in the event of any breach of your personal data which might expose
you to serious risk.
6. Who else has access to the information you provide us?
6.1 We will never sell your personal data. We will not share your personal data with any third parties without your prior consent (which you are free to withhold) except where required to do so by law.
7. How long do we keep your information?
7.1 For clients, we will hold your personal data on our systems for as long as you subscribe to the Gain loyalty service or for as long afterwards as is necessary to comply with our legal obligations.
7.2 For loyalty scheme members, we will hold your personal data on our systems for as long as your loyalty scheme uses the Gain loyalty service or the data controller removes you from their service.
7.3 We securely destroy all financial information once we have used it and no longer need it.
8. Your rights
8.1 You have rights under the GDPR:
(a) to access your personal data
(b) to be provided with information about how your personal data is processed
(c) to have your personal data corrected
(d) to have your personal data erased in certain circumstances
(e) to object to or restrict how your personal data is processed
(f) to have your personal data transferred to yourself or to another business in certain
circumstances.
8.2 You have the right to take any complaints about how we process your personal data to the Information Commissioner:
https://ico.org.uk/concerns/
0303 123 1113.
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire SK9 5AF