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March 2023
This policy, our Terms and any additional terms of use incorporated by reference into the Terms, together our Terms of Use applies to your use of the Application and associated Services available on our website or hosted on our Application (Our Sites), once you have downloaded a copy of the Application onto your Device. This Privacy Policy applies to the Services, unless the Terms state that a separate privacy policy applies to a particular Service, in which case that privacy policy only applies.
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be collected, handled and/or processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
For the purpose of the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regards to the processing of personal data and on the free movement of such data, known as General Data Protection Regulation (GDPR) we as a “data controller” have to give you the following information:
Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies:
a) You have given consent to the processing of your personal data for one or more specific purposes;
b) Processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of your prior to entering into a contract;
c) Processing is necessary for compliance with a legal obligation to which we are subject;
d) Processing is necessary to protect the vital interests of your or of another natural person;
e) Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or
f) Processing is necessary for the purposes of the legitimate interests pursued by us or by a third party such as our credit card payment processing, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data.
Information you give us (Submitted Information)
You may give us information about you by filling in forms on Our Sites, or by corresponding with us (for example, by e-mail or chat). This includes information you provide when you register to use the Application and associated Services, download or register the Application, subscribe to any of our Services, search for an Application or Service, make an in-Application purchase, share data via the Application's social media functions, enter a competition, promotion or survey, scan a photo, document or other image (digital or not), register a valid credit or debit card with or in the Application, provide address information in accordance with any offer, promotion or otherwise for the purpose of the Merchants, us, or the Network Provider and when you report a problem with the Application, our Services, or any of our Sites. The information you give us may include your name, address, e-mail address and phone number, the type of Device, the Device's phone number, the Device ID number, other Device specific information (including but not limited to geographical location information of the Device), age, username, password and other user settings and registration information, financial, bank accounts information, transaction data from your bank and credit/debit card information, personal description and photograph, all photographs taken and uploaded to the Application or a third party website, social media presence or other platform accessible or used through the Application.
Each time you visit one of Our Sites or use our Application and associated Services we may automatically collect the following information: (i) technical information, including the type of mobile device (or other Device) you use, a unique device identifier (for example, your Device's IMEI number, the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting, application version number (Device Information); (ii) details of your use of the Application or your views and visits to any of Our Sites including, but not limited to, search terms, location data, duration data and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access (Log Information).
We may also use GPS technology geolocation and location presence awareness technology and functionality to determine your current location and to make the Application useful at the particular location it is being used. Some of our location-enabled Services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. To make the Application and Services operate better, and in accordance with the remainder of terms in this Privacy Policy and the Terms, we may also collect other information based on our technology signals, for example, the strength of the signal between our technology and the phone or other Device, the duration the phone or other Device is near our location technology, or the battery level of the location technology itself, including when the Application is in the background or not running. You can withdraw your consent and can opt out of these location services through the Services or through your Devices operating system.
We work closely with third parties (including, for example, affiliates, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them. We may also use additional methods to collect your information when you are physically visiting the store of one of our participating Merchants, such as when your Device scans participating product barcodes, check-ins, or based on presence location data from your Device when your AR ID is active. If you do not wish to have your personal information collected by these methods, you may not be able to earn and redeem rewards as part of the Services.
When you install or uninstall a Service containing a unique application number or when such a Service searches for automatic updates, that number and information about your installation, for example, the type of operating system, may be sent to us. If you contact us via any and all means, we may keep a record of that correspondence.
We may use cookies or storage to help us collect, maintain and use the information in order to distinguish you from other users of the Application and Our Sites. This will help us to provide you with a good experience when you use the Application and associated Services or browse any of the sites and also will allow us to improve the Application and Our Sites. We will endeavour to inform you when we introduce cookies to the Application and/or website, however we reserve the right to do this without informing you and publish such introduction as detailed in an updated Privacy Policy. To learn more, see our Cookie Policy
We may also use data collection tags such as pixel tags, Javascript scripts, API calls, or similar means (Usage Tracking) and the demographic or personality-linked data we have collected, and with third-party analysis partners, to analyse usage patterns of users anonymously and to serve advertisements to you that are tailored based on our analysis of what we believe you would like in light of the information that we have collected or accessed about you as described in this policy. A “pixel tag” is an electronic image that is placed on a web page and may be associated with cookies on your hard drive. Usage Tracking allows us to count users who have visited certain web sites and pages within web sites, or used applications or features, to analyse the behaviour of users of Our Sites and Application, in order to improve Our Sites, Application and associated Services, and to personalise and determine the effectiveness of promotional or advertising campaigns.
We use information held about you in the following ways:
1. Submitted and Device Information (personal): We use your such information only for the following purposes: (i) to provide, improve, change and optimise the Services, (ii) to personalise your experience, (iii) to provide you with software updates and/or product announcements, (iv) to better understand yours’ and other users' needs and interests, and (v) to provide you with further information, offers and promotions from us that we believe you may find useful or interesting, such as targeted advertising and promotional campaigns. We may match data from your transactions and usage with our Merchants, Network Providers and partners and/or the content information with our usage data in a personally identifiable form in order to perform accounting reconciliation and/or provide targeted offers and/or rewards or discounts to you. We will use your personal data for marketing purposes only with your prior consent.
2. Submitted and Device Information (not personal): We use information about our users generally, for purposes including but not limited to: (i) improving features and functionality of the Application and associated Services and to make these more relevant and up-to-date in the constant changing environment, (ii) analysing trends through aggregated demographic and personality-linked offers to users, (iii) sharing such information with our Merchants, Network Providers and other affiliates to allow them to assist us in delivering tailored advertisements, promotions, sweepstakes, discounts, offers and other incentives to you when you use the Application and associated Services (Any information shared with Merchants, Network Providers and other affiliates in this context will not contain nor be linked to your Personal Information unless you have given us your explicit consent through an “opt-in” mechanism on the Application)
3. We do not disclose information about identifiable individuals to our advertisers, but we may provide them with anonymous aggregate information about our users (for example, we may inform them that 1,000 men aged under 25 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in M1 or M2). We may make use of the personal data we have collected from you to enable us to comply with our advertisers' wishes by displaying their advertisement to that target audience.
We may disclose some or all of the data we collect from you when you download or use the Application to the following third parties in order to deliver our services, including:
We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006.
We may disclose your personal information to third parties:
1. In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
2. If Airtime Rewards Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
3. If we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request.
In order to (i) enforce or apply the Terms and other agreements or policies or to investigate potential breaches of the Terms and/or other agreements and policies; or (ii) protect the rights, property or safety of Airtime Rewards Limited our customers, or others (this includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).
The data that we collect from you may be transferred to, and stored at, a destination outside the United Kingdom (UK). It may also be processed by staff operating outside the UK who work for us or for one of our suppliers. These staff may be engaged in the fulfilment of your request, order or reservation, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.
All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted. Where we have given you (or where you have chosen) a pin code and/or password that enables you to access certain parts of Our Sites, you are responsible for keeping this pin code and/or password confidential. We ask you not to share a pin code or password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to Our Sites and therefore any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
We may collect and store personal data on your Device using application data caches and browser web storage (including HTML5) and other technology.
Certain Services (including but not limited to the Rewards When You Share program) include social networking features. Ensure when using these features that you do not submit any personal data that you do not want to be seen, collected or used by other users.
You have the right to ask us not to process your personal data for marketing purposes. We will obtain your consent (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by leaving blank certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at Airtime Rewards Ltd, 5th Floor, Queens House, Queen St, Manchester M2 5HT or by email at gdpr@airtimerewards.co.uk.
Under the GDPR, you have the right to:
Our Sites may, from time to time, contain links to and from the websites of our Merchants, Airtime Reward providers, partner networks, advertisers and affiliates (including, but not limited to, websites on which the Application or the associated Services are advertised). If you follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as contact and location data. Please check these policies before you submit any personal data to these websites or use these services.
If you don’t want us to use your personal data for any of the reasons set out in this Privacy Policy, you can let us know at any time by contacting us at gdpr@airtimerewards.co.uk. However, you acknowledge this may limit our ability to provide the best possible Services to you.
If you believe we have not processed any of your personal data in accordance with the GDPR and other applicable data protection legislation or you have been affected by non-compliance you can make a complaint to gdpr@airtimerewards.co.uk.
The GDPR gives you the right to access information held about you. Your right of access can be exercised by emailing us at gdpr@airtimerewards.co.uk. Repeated access requests may be subject to an administrative fee that we will advise you of in advance of providing information to you to meet our costs in providing you with details of the information we hold about you.
All personal information can be accessed, changed and deleted in the profile section of the Application.
1. We may use your historical transaction data to segment our customers into different categories of shoppers. This process is automatic and helps us predict where our customers are likely to shop in future so that we can tailor our services. You may ask us to stop this type of profiling by contacting us at gdpr@airtimerewards.co.uk but we will not be able to continue providing our services to you in that case as this is an integral part of our services.
2. In the event that we use personal data for the purposes of automated decision-making and those decisions have a legal (or similarly significant effect) on you, you have the right to challenge such decisions under GDPR, requesting human intervention, expressing your own point of view, and obtaining an explanation of the decision from us.
The right described in the above paragraph 2 does not apply in the following circumstances:
Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by SMS or by e-mail or when you next start the Application. The new terms may be displayed on-screen and you may be required to read and accept them to continue your use of the Application or the associated Services.
Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to Airtime Rewards Limited, 5th Floor, Queens House, Queen St, Manchester M2 5HT or via email at gdpr@airtimerewards.co.uk.