last updated: July 2018
Any information stored on Oappso Loyalty's platform is treated as confidential. All information is stored securely and is accessed by authorized personnel only. Oappso Loyalty implements and maintains appropriate technical, security and organisational measures to protect Personal Data against unauthorized or unlawful processing and use, and against accidental loss, destruction, damage, theft or disclosure.
2. Collection and use
The following sections cover the specifics of each of the three groups from which data is collected: website Visitors, Digital loyalty card users and Users.
2.2 Website Visitors
If you are a Visitor to our website only, and not an individual user of our digigtal loyalty cards or platform, then this section is relevant for you.
By visiting this website, you consent to the collection and use of your Personal Data as described herein. If you do not agree with the terms set out herein, please do not visit this website. If required by applicable law, we will seek your explicit consent to process Personal Data collected on this website or volunteered by you. Kindly note that any consent will be entirely voluntary. However, if you do not grant the requested consent to the processing of your Personal Data, the use of this website may not be possible.
Such Personal Data may comprise your IP address, first and last name, your postal and email address, your telephone number, your job title, data for social networks, your areas of interest, interest in Oappso Loyalty products, and certain information about the company you are working for (company name and address), as well as information as to the type of relationship that exists between Oappso Loyalty and yourself.
Oappso Loyalty gathers data about visits to the website, including numbers of Visitors and visits, Geo-location data, length of time spent on the site, pages clicked on or where Visitors have come.
2.2.1 Purpose of processing personal data
Oappso Loyalty uses the collected data to communicate with Visitors, to customize content for Visitors, to show ads on other websites to Visitors, and to improve its website by analyzing how Visitors navigate its website.
2.2.2 Sharing personal data
Oappso Loyalty may also share such information with service vendors or contractors in order to provide a requested service or transaction or in order to analyze the Visitor behavior on its website.
2.2.4 Links to other sites
2.3 Digital loyalty card user
Digital loyalty card users should be aware that in by entering their name, & email, and any other personal details, they could be disclosing information that could make them personally identifiable to Oappso Loyalty Users. The security and privacy protection implemented on Oappso Loyalty platform does not cover this type of transfer or disclosure of personal information. Digital loyalty card users singing up for loyalty cards should be aware our Users have access to their information. Our Users may use Digital loyalty card users data to contact you with news relevant to their product or service, furthermore Oappso Loyalty has no responsibility to any inappropriate, or misuse of this data by the User. For more detailed information concerning the protection of privacy when adding a digital loyalty card, Digital loyalty card users may contact the entity offering the digital loyalty card. It is the User’s responsibility to ensure that collection and processing of data is done in accordance with applicable law. Oappso Loyalty will not process Personal Data of Digital loyalty card users for other purposes or by other means than instructed by its Users. Oappso Loyalty also will take no responsibilty in regards to offers, or rewards, issued by the User, or in the case of an offer or reward not being claimed or given, this must be resolved directly with the User who claims responsibility for their reward or offer.
If you wish to inquire about your Personal Data that may have been collected in a Oappso Loyalty Digital loyalty card, we recommend that you contact the entity that created or sent you the digital loyalty card. As Oappso Loyalty is a Processor, it does not control the Personal Data used or stored from the sign up to the digital loyalty card, but processes it on behalf of its User.
In order to provide services to its Users, Oappso Loyalty collects certain types of data from them. Furthermore, Oappso Loyalty Users collect information from Digital loyalty card users when they issued. This section will describe how these two types of data are collected and used by Oappso Loyalty. Data entered or transferred into Oappso Loyalty by Users such as texts, questions, contacts, media files, etc., remains the property of the User and may not be shared with a third party by Oappso Loyalty without express consent from the User.
2.4.2 Collection of User data
During a User’s registration and later on Oappso Loyalty’s platform, they provide information such as name, email, address, telephone, credit-card number and other relevant data. This information is used by Oappso Loyalty to identify the User and provide them with support, services, mailings, sales and marketing actions, billing and to meet contractual obligations.
Oappso Loyalty Users can at any time access and edit, update or delete their contact details by logging in with their username and password to Oappso Loyalty’s platform, or in any other case contacting Oappso Loyalty direct at email@example.com.
2.4.3 Collection of Digital loyalty card users data
Digital loyalty cards are created by Users, who make them available to relevant businesses, organizations, and more commonly individuals. It is the User’s responsibility to ensure that collection and processing of data is done in accordance with applicable law. Oappso Loyalty will not process Personal Data for other purposes or by other means than instructed by its Users.
The purpose of collecting Personal Data as part of signing up to a digital loyalty card, as set up by Oappso Loyalty Users. As Oappso Loyalty provides digital loyalty cards to a wide group of customers and businesses, the purpose may vary greatly. For Users in the EEA, or for Users providing surveys to Digital loyalty card users in the EEA, the User will be the “controller”, as defined in the Directive and the GDPR. The purpose will consequently be defined by Oappso Loyalty’s User.
Users agree to use data collected, or also specifically push messaging as required by applicable law with the digital loyalty card user. The user accepts responsibility for any breach in law they make, or any concern the digital loyalty card user may have.
If you or your organization are required under the European Union’s General Data Protection Regulation (GDPR) to enter into a contract, or other binding legal act under EU or Member State law, with your data processors, review and accept Oappso Loyalty’s Data Processing Agreement in your Oappso Loyalty account.
18.104.22.168 Processing in the European Economic Area (EEA)
For Users with accounts located in Oappso Loyalty's European Data Region, all processing of Personal Data is performed in accordance with privacy rights and regulations following the EU Directive 95/46/EC of the European Parliament and of the Council of 24 October 1995 (the Directive), and the implementations of the Directive in local legislation. From May 25th, 2018, the Directive and local legislation based on the Directive will be replaced by the Regulations (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data, known as the General Data Protection Regulation (GDPR), and Oappso Loyalty’s processing will take place in accordance with the GDPR.
Oappso Loyalty processes Personal Data both as a Processor and as a Controller, as defined in the Directive and the GDPR:
The Oappso Loyalty entity which you as a User entered an agreement with when using Oappso Loyalty’s platform, will be the Controller for User data, as outlined above in “Collection of User data” section.
For Digital loyalty card users data, as outlined in the “Collection of Respondent data” section, the User will be the Controller in accordance with Directive and GDPR, and Oappso Loyalty will be the Processor.
Oappso Loyalty adheres to the Directive of 1995 and the GDPR from May 25th, 2018. Consequently, Oappso Loyalty processes all data provided by its Users with accounts in its European Data Region, in the European Economic Area (EEA) only.
3. Retention and deletion
Oappso Loyalty will not retain data longer than is necessary to fulfill the purposes for which it was collected or as required by applicable laws or regulations. For digital loyalty card users data, Oappso Loyalty’s Users have control of the purpose for collecting data, and the duration for which the Personal Data may be kept. For Digital loyalty card users data, Users with an active account will therefore have the responsibility to delete data when required. When a users’s account is terminated or expired, all Personal Data collected through the platform will be deleted, as required by applicable law.
4. Acceptance of these Conditions
5. Our Legal Obligation to Disclose Personal Information
We will reveal a user’s personal information without his/her prior permission only when we have reason to believe that the disclosure of this information is required to establish the identity of, to contact or to initiate legal proceedings against a person or persons who are suspected of infringing rights or property belonging to Oappso Loyalty or to others who could be harmed by the user’s activities or of persons who could (deliberately or otherwise) transgress upon these rights and property. We are permitted to disclose personal information when we have good reason to believe that this is legally required.
6. For Further Information
If you have any further questions regarding the data Oappso Loyalty collects, or how we use it, then please feel free to contact us by email at: firstname.lastname@example.org, or in writing at:
PO BOX 3328