Note for the Loyalito team: this is a plain-language DPA reflecting how the product behaves. Have it reviewed by a data-protection lawyer, add your legal entity and signature process, and be ready to provide a countersigned copy — larger customers will ask.

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

3. Our obligations

4. Your obligations

5. Security measures

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.