1. Roles
You are the data controller for your loyalty members. You decide what to collect, why, and what to send them. Loyalito is the processor: we handle that data only to provide the service, and only on your documented instructions — which, in practice, are the settings you choose in the dashboard and this agreement.
2. Scope of processing
- Subject matter: providing a digital loyalty program and its marketing features.
- Duration: for as long as your account is active, plus the deletion window in section 8.
- Categories of people: your loyalty members, and your own staff users.
- Categories of data: name, email address, phone number, optional birthday, visit and reward history, card identifier, wallet registration, marketing consent status, and staff attribution on reward hand-overs.
- Special category data: none. Do not put health, biometric or other special category data into Loyalito.
3. Our obligations
- Process personal data only on your instructions, unless legally compelled otherwise — in which case we tell you first, where the law allows.
- Ensure everyone with access is bound by confidentiality.
- Apply appropriate technical and organisational security measures (section 5).
- Assist you with data subject requests, impact assessments and regulator enquiries.
- Never use your customers' data for our own purposes, including marketing to them or training models for other businesses.
4. Your obligations
- Have a lawful basis for the data you collect, and collect valid consent for marketing.
- Give your members a privacy notice covering what you do with their data.
- Only upload members you collected yourself, with consent.
- Keep your account credentials and staff PINs secure.
5. Security measures
- Encryption in transit (TLS) for all connections, and encryption at rest for stored data.
- Passwords stored as salted hashes, never in plain text.
- Signed, expiring session tokens; staff PINs for reward attribution.
- Strict tenant isolation — every query is scoped to a single business.
- Access to production limited to staff who need it.
- Regular dependency updates and backups.
6. Sub-processors
You give general authorisation for us to engage the sub-processors listed on our sub-processor page. We impose equivalent data protection obligations on each, remain liable for their performance, and will update that page before a new one starts processing your data.
7. International transfers
Service data is stored in the EU. Where a sub-processor transfers personal data outside the EEA, that transfer is covered by Standard Contractual Clauses together with any supplementary measures required.
8. Deletion and return
You can export your members and their history at any time from the dashboard, and delete any individual member permanently. When your account closes, you keep export access for 30 days, after which we delete customer data from production and from backups on the normal backup rotation — except anything we must retain by law, such as invoices.
9. Data subject requests
Access, correction, erasure, restriction, objection and portability are all actionable by you from the customer’s profile page. If a member contacts us directly, we forward the request to you rather than acting on it ourselves, because you are the controller.
10. Breach notification
If we become aware of a personal data breach affecting your data, we will notify you without undue delay and provide the information you need to meet your own 72-hour notification duty.
11. Audits
On reasonable notice and no more than once a year (or after a breach), we will provide the information needed to demonstrate compliance with this agreement, and cooperate with an audit conducted by you or an independent auditor bound by confidentiality.
12. Precedence
Where this agreement conflicts with our terms of service, this agreement governs matters of data protection. Questions: hello@loyalito.space.