Privacy Policy
Policy version: 30th May 2024
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Our rewards services are provided by RewardsBag Ltd (‘we’, ‘our’ or ‘us’). We trade as ‘Delight’ and are the provider of the customer-facing technology which is covered by this policy, and therefore we refer to ourselves as ‘Delight’ in this policy.
We are the processor of personal data obtained provided to us via our clients (retailers) when you carry out purchases via the retailer website, online store, application, platform or marketplace (Retailer Website), meaning the retailers are the organisations which are legally responsible for deciding how and for what purposes your personal data is used, as we act on the instructions of the retailers pursuant to our contract with them. For the purposes of data protection laws, this means that the retailers are controllers and we are acting as a processor.
We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share any information relating to you (your personal data) in connection with your use of the Delight Rewards Application when you make purchases on a Retailer Website. It also explains your rights in relation to your personal data and how to contact us or a relevant regulator in the event you have a complaint.
We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR). We are also subject to the EU General Data Protection Regulation (EU GDPR) in relation to goods and services we offer to individuals and our wider operations in the European Economic Area (EEA).
We do not expect the retailers to provide us with the personal data of anyone under 13 years old. If you are aware that any personal data of anyone under 13 years old has been shared with a retailer or us please let us know so that we can delete that data and/or advise the retailer accordingly.
This privacy policy is divided into the following sections:
- What this policy applies to
- Personal data we collect about you.
- How your personal data is collected.
- How and why we use your personal data
- Marketing
- Who we share your personal data with
- How long your personal data will be kept
- Transferring your personal data out of the UK and EEA
- Cookies
- Your rights
- Keeping your personal data secure
- How to complain
- Changes to this privacy policy
- How to contact us
What this policy applies to
This privacy policy relates to how we process personal data about you when you add rewards to your basket via the Retailer Website and/or complete an order on their site. This is because we have an agreement or arrangement with the retailer whereby, they are able to use our downloadable application which allows them to supply rewards and offers to you when you checkout on the Retailer Website or perform a qualifying action (the Delight Rewards Application). As part of that agreement or arrangement with the retailer, and to enable you to receive, redeem and claim the rewards attributed to you or which you have decided to proceed with, the retailers provide us with very limited personal information about you so that we can provide you with information about the reward you have claimed, and allow you to redeem it either via a pop-up on the Retailer Website and/or by you receiving an email from us on behalf of the retailer with the relevant information contained in it.
The retailers are third parties and Retailer Websites may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to retailers and the Retailer Websites, please consult their privacy policies as appropriate.
Personal data we collect about you
The personal data we collect about you is provided to us by the Retailer or directly from your device and includes the following:
Your first name, last name and email address
Your order ID
The personal data related to your name, email address and order ID is provided to us by the Retailer through the Delight Rewards Application which is integrated to the Retailer Website to allow us to fulfil our obligations to the Retailer and supply you with the rewards you have requested.
We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.
How your personal data is collected
We collect personal data from you indirectly, through the Delight Rewards Application integration available on the Retailer Website. We have established a secure channel between the retailer and us in order to obtain the limited personal data we require to provide you with rewards and offers that you have requested upon checkout on the Retailer Website.
How and why we use your personal data
As a supplier to the Retailers, under data protection law, we can only use your personal data provided that the Retailers have a proper reason, e.g.:
where you have given consent to the Retailers, or
for the Retailers’ legitimate interests or those of a third party
A legitimate interest is when the Retailers have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. The Retailers are responsible for ensuring they have an appropriate reason for processing your personal data and for supplying it to us in order to provide you with rewards. You can obtain more details of this by contacting the relevant Retailer (i.e., where you obtained the relevant rewards at checkout).
Special category personal data or Sensitive Personal Data
Certain personal data is treated as a special category data or sensitive personal data to which additional protections apply under data protection law. Examples of such data includes: personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership, data concerning health, sex life or sexual orientation.
Delight does not collect or process any special category data.
How and why we use your personal data—sharing
See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.
Marketing
We undertake no marketing based on your personal data. When we send you rewards emails with information on the reward and how you can redeem it, we are not sending marketing emails. Such emails are part of an automated communication sent to you on behalf of the retailers to provide you with details of rewards you have requested and obtained on checkout. This is a service email to fulfil your reward request, and for the purposes of privacy laws, is not email marketing.
We will always treat your personal data with the utmost respect and never sell or share it with other organisations outside the RewardsBag (Delight) group for marketing purposes.
Who we share your personal data with
We will store personal data as follows:
With third parties we use to help us run our business, e.g. data storage hosts and providers
We only allow those organisations to handle your personal data if we are satisfied they take appropriate measures to protect your personal data.
More details about where we host your personal data is set out below:
| Recipient | Operation (use) by recipient |
|---|---|
|
AWS |
For Web and data hosting services, ie stores a copy of your personal data on computer equipment so it can be accessed by us. |
|
RewardsBag |
Track order counts on the Delight Dashboard. |
|
Sendgrid |
Used to send you the email with reward and details on how to redeem the reward. |
|
MongoDB |
Used as our primary database to manage and store operational data securely. |
We will not keep your personal data for longer than we need it for the purpose for which it is used. For example, to provide the rewards to you as requested upon checkout with the Retailer.
Personal data is typically deleted once the reward has been claimed. Any Order ID retained is securely stored in our database and automatically deleted after 30 days, unless otherwise directed by the Retailer, who acts as the data controller.
Transferring your personal data out of the UK and EEA
For your information, the EEA, UK and other countries outside the EEA and the UK have differing data protection laws, some of which may provide lower levels of protection of privacy.
It might become necessary for us to transfer your personal data to countries outside the UK and EEA. In those cases we will comply with applicable UK and EEA laws designed to ensure the privacy of your personal data, such as where a retailer requires us to do so, or we have agreed with a retailer that we will store personal data outside the UK or EEA, or indeed where you or the retailer are based outside of the or EEA.
In the event we do transfer data outside of the UK or EEA, under data protection laws, we can only transfer your personal data to a country outside the UK or EEA where:
in the case of transfers subject to UK or EU data protection law, the UK government or the European Commission has decided the particular country ensures an adequate level of protection of personal data,
there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you (such as the conclusion of specific contracts known as the Standard Contractual Clauses or the UK Addendum), or
a specific exception applies under relevant data protection law
At the moment, we only store data in the EEA. Any changes to the destinations to which we send personal data or in the transfer mechanisms we rely on to transfer personal data internationally will be notified to you in accordance with the section on ‘Changes to this privacy policy’ below.
Cookies and other tracking technologies
A cookie is a small text file which is placed onto your device (e.g. computer, smartphone or other electronic device) when you use our website.
As we use a downloadable application for the Delight Rewards Application which is integrated into the checkouts of Retailer Websites, our technology does not operate through cookies. However, if this were to change we will inform you through updates to this Privacy Policy.
Please check Retailer Websites for their use of cookies and please review their cookies policies separately. We are not responsible for cookies placed on Retailer Websites.
Your rights
You generally have the following rights, which you can usually exercise free of charge:
| Access to a copy of your personal data | Access to a copy of your personal data |
|---|---|
|
Access to a copy of your personal data The right to be provided with a copy of your personal data
The right to withdraw consents |
If you have provided us with a consent to use your personal data you have a right to withdraw that consent easily at any time. Withdrawing a consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn |
|
Not to be subject to decisions without human involvement |
The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you We do not make any such decisions based on data collected by our website |
|
To object to use |
To object to use |
|
Data portability |
The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations |
|
Correction (also known as rectification) |
The right to require us to correct any mistakes in your personal data |
|
Erasure (also known as the right to be forgotten) |
The right to require us to delete your personal data—in certain situations |
|
Restriction of use |
The right to require us to restrict use of your personal data in certain circumstances, eg if you contest the accuracy of the data |
Keeping your personal data secure
We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine need to access it.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
If you want detailed information from Get Safe Online on how to protect your personal data and other information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
How to complain
Please contact us if you have any queries or concerns about our use of your personal data (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.
You also have the right to lodge a complaint with the Information Commissioner
The Information Commissioner may be contacted using the details at https://ico.org.uk/make-a-complaint or
by telephone: 0303 123 1113.
For a list of EEA data protection supervisory authorities and their contact details see here.
Changes to this privacy policy
We may update our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on our website, see here. We will keep the “Last updated” date at the top of this Privacy Policy current to inform you of any changes. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
How to contact us
You can contact us by post or email if you have any questions about this privacy policy or your privacy rights.
Our contact details are shown below
Our contact details
Attention: Privacy Team
RewardsBag (Delight)
West, 2-5 Rock Place, Brighton, East Sussex, United Kingdom, BN2 1PF