Privacy & Data Protection Policy

1. Introduction
2. Personal data is defined as:any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;

   ‘processing’ means:

   any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;

   ‘controller’ means:

   the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and transparency’);

3. collected for specified, explicit and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall, in accordance with Article 89(1), not be considered to be incompatible with the initial purposes (‘purpose limitation’);
4. adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (‘data minimisation’);
5. accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay (‘accuracy’);
6. kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) subject to implementation of the appropriate technical and freedoms of the data subject (‘storage limitation’);
7. processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and confidentiality’).

• The controller shall be responsible for, and be able to demonstrate compliance with, paragraph 1 (‘accountability’).

Rewards and Perks Ltd will ensure that it complies with all of these principles both in the processing it currently carries out and process your data with your consent.

For example, when you tick a box to receive email marketing

When collecting your personal data, we’ll always make clear to you which data is necessary in connection with a particular service

2.5.2 Performance of a Contract

Where the personal data collected and processed are required to fulfil a contract with the data subject, explicit consent is not required. This will often be the case where the contract cannot be completed without the personal data in question e.g. a delivery cannot be made without an address to deliver to.

Contractual

In certain circumstances, we need your personal data to comply with our contractual obligations. For example, if you order a card from us for postal delivery, we’ll collect your address details to deliver your card. To enable us to send you latest offers email as part of our membership service, we collect your email address.

Unless it is necessary for a reason allowable in the GDPR, Rewards and Perks Ltd will always obtain explicit consent from a data subject to collect and can either be an in-house resource or outsourced to an appropriate service provider.

Based on these criteria, Rewards and Perks Ltd does not require a Data Protection Officer to be appointed.

2.9. Breach Notification

It is Rewards and Perks Ltd’s policy to be fair and processes

These actions are reviewed on a regular basis as part of the management process concerned with data protection.