With the following information, we would like to give you an overview of the processing of your personal data within the scope of the installation and usage of the "Reward Cards App" mobile application (hereinafter referred to as app) and your rights from data protection laws.
Which data is processed and how this is used is based on if you use the app without explicit consent to this data protection statement (see section 2 a) to c)) or you have given consent to the processing of your personal data within the app (see section 2 d) to g)).
1. Data Processor.
Who is responsible for data processing and whom can I contact?
The responsible position is:
Oriel Technology Ltd.
Reward Cards App
5 Hadrians Drive
You can reach our data protection officer at:
Reward Cards App
Data protection officer
5 Hadrians Drive
Email address: firstname.lastname@example.org
2. Data Source and Use
What sources and data do we use?
In connection with the installation and usage of the app, we collect, process and use the data described below to find out which companies, products or other topics you are interested in and which information and offers from our partner companies are relevant for you to be able to use the functions of our app on this basis as needed and to provide you with the most relevant information and offers from our partner companies and Reward Stamps App in the app.
If you use the app, we collect, process and use the following data for the previously listed purposes to fulfill our contractual obligations in terms of art. 6 para. 1 b GDPR or based on entitled interest in terms of art. 6 para. 1 f GDPR (this means interest in the analysis, optimization and efficient operation of our app):
2.1) Card data: To be able to use the functions of the app, you have to provide your loyalty card/reward card and customer number from a card provider. This card data is converted for the contractually agreed upon purposes, this means into the respective barcode or QR code, and then used within the scope of the app as well as to protect against abuse and - if additionally agreed upon - the provision of other services.
2.2) Usage data: If you use the app, we collect and save how you use the card (for example, card used, time, number of points).
2.3) Location data: If you allow the app to access the location function on your mobile device, Reward Cards App is entitled to use the corresponding location data (so-called location-based data) to design the app as needed, to deliver location-related information and for advertising. Reward Cards App only accesses this data in an anonymous form. There is no further usage or sharing of this location-based data from the respective user. For the location-based data, the Reward Cards App app uses the GPS module from the mobile device, the IP address or cellular network data (cell ID) from the respective user.
We also use the previously listed data in an anonymized form for market research and to create anonymized statistics.
If you consent to the respective data processing within the scope of the app, we can process and use your data for the respectively specified purposes:
2.4) Registration data: When applying for a new loyalty card, usually your name and your email address and any other mandatory information are needed (basic data). This basic data and further voluntarily disclosed data (for example, telephone number) is collected, saved and used by Reward Cards App within the scope of the registration of the respective loyalty card. The basic data, any voluntary information and, if necessary, their changes (application data) will be sent to the partner company by Reward Cards App for the further processing and issuing of the respective customer card where you apply for the respective customer card. If you have agreed to have your application data forwarded to a partner company, this consent also applies to other customer cards that you apply for through the app. Any transfer of personal data to third parties going beyond this only occurs - except in the case of a concrete suspicion of abuse - if and provided that you have given Reward Cards App separate consent to this transmission. Furthermore, the customer card conditions from the respective partner apply, which are linked correspondingly and you have given separate consent.
2.5) Personalized offers: If you consent to the delivery of personalized offers from our partner companies (for example, rebate coupons), we can share your card number with general information about your usage of the app with the respective card provider so that we can send you personalized offers (including card-linked coupons) through the app or through other electronic channels (for example, by email or messenger).
3. Purpose of processing
What do we process your data for (purpose of processing) and on which legal basis?
We process personal data in agreement with the regulations of the General Data Protection Regulation (GDPR) and the German Data Protection Regulation:
3.1) To fulfill contractual obligations (art. 6 para. 1 b. GDPR)
The processing of data occurs primarily to be able to provide the services and functions from our app.
3.2) Within the scope of the consideration of interests (art. 6 para. 1 f. GDPR)
If necessary, we will process your data beyond the actual fulfillment of the contract to preserve entitled interests from us or third parties, for example,
to design the app as needed,
to examine and optimize the procedure for the analysis of requirements for the purpose of direct customer contact,
for advertising or market and opinion research, provided that you have not objected to the usage of your data,
to preserve IT security,
to control and develop our app.
3.3) Based on your consent (art. 6 para. 1 a GDPR)
If you have given us express consent (opt-in) to process personal data for the respective purposes within the corresponding functions of the app (for example, application for a customer card from a partner, login to your user account from a card provider, delivery of personalized offers (so-called card-linked coupons), the legality of this processing (for example, forwarding the data to third parties) is given on the basis of your consent. Granted consent can be revoked at any time. This also applies to the revocation of declarations of consent that have been granted to us before the applicability of the GDPR, therefore before May 25, 2018. The revocation of consent does not affect the legality of the data processed until revocation.
4. Third party integration
How are third-party services integrated?
On the basis of our entitled interests in terms of art. 6 para. 1 lit. f. GDPR (this means interest in the analysis, optimization and efficient operation of our app), we use the following third-party services:
4.1) Crashlytics: we use Crashlytics in our app - a service offered by Google Ireland Limited, with offices at Gordon House, Barrow Street, Dublin 4, Ireland to collect technical data from our app and website in a pseudo-anonymous manner so that we can better understand how users interact with our app. You can find more information about Crashlytics at https://try.crashlytics.com/terms/terms-of-service.pdf.
5. Data Share
Who gets my data?
Other than the processing listed above, your personal data will only be shared with your consent.
Within Reward Cards App, only those who need access to your data to fulfill our contractual and legal obligations will also receive access to it.
With the express consent to this data protection declaration, you give us consent to share your data as specified in section 2 d) - g) with the respective card provider or the respective partner company.
6. Data Transmission
Will data be transmitted to a third party country or an international organization?
Data transmission to sites in states outside of the European Union (so-called third-party states) occurs provided that
it is required to execute your orders,
it is legally prescribed,
within the scope of order data processing or
you have given us your consent.
If there are service providers in a third party state, they are additionally obligated to the written instructions through the agreement of the EU standard contract clauses or certification under the Privacy Shield to comply with the data protection level in Europe.
7. Data Storage
How long will my data be saved?
We process and save your personal data as long as it is required to fulfill our contractual and legal obligations. It must be considered that our business relationship is a continuing obligation that exists for years.
If the data is no longer required to fulfill contractual or legal obligations, it will be deleted regularly unless the limited further processing is required to preserve evidence within the scope of statutory limitation periods. According to §§ 195ff. of the Civil Code (BGB), these limitation periods can amount to up to 30 years, whereby the regular limitation period is 3 years.
8. Data protection rights
What data protection rights do I have?
Every affected person has the right to information according to article 15 GDPR, the right to correction according to article 16 GDPR, the right to deletion according to article 17 GDPR, the right to limit processing according to article 18 GDPR, the right to opposition from article 21 GDPR as well as the right to data transmission from article 20 GDPR. With the right to information and deletion, the restrictions according to §§ 34 and 35 GDPR apply. Furthermore, there is a right to lodge a complaint to a responsible data protection supervisory authority (article 77 GDPR in connection with § 19 GDPR).
You can opt out of the granted consent for the processing of your personal data. This also applies to opting out of declarations of consent, which have been granted to us before the applicability of the General Data Protection Regulation, therefore before May 25, 2018. Please remember that the opt-out will only work in the future. Processing that has occurred before the opt-out will not be affected by this.
9. Obligation to me
Is there an obligation to me providing data?
Within the scope of our business relationship, you have to provide personal data that is required for the beginning and execution of a business relationship and the fulfillment of the affiliated contractual obligations or for the collection of which we are legally obligated to. Without this data, we are normally not able to complete the contract with you or execute it.
10. Automated decision
What type of automated decision-making exists?
We do not use fully automatic decision-making in accordance with article 22 GDPR.
11. Data Profiling
Is there profiling?
Some of your data from section 2 are processed in an automated manner (so-called profiling) with the objective of designing the app to meet demands or to be able to inform you in the app about products and offers from our partners. This permits us communication and advertising as needed in the app including market and opinion research on the basis of anonymous data.