Version 2.1 – Last updated: 1 October 2020
Bink is operated by Loyalty Angels Limited, a company registered in England under Company number 09181487, whose registered office is at 2 Queens Square, Ascot Business Park, Lyndhurst Road, Ascot, Berkshire, SL5 9FE (“we”, “our”, or “us”).
For the purpose of the Data Protection Act 2018 and the EU General Data Protection Regulation 2016/679 (including any legislation incorporating it into local law), we are the data controller. This means that we are responsible for and control the processing of the Personal Information that we collect about you. “Personal Information” or “personal data” means information that can be used to identify or contact you.
Please note that some of the Bink features and uses of Personal Information as described below (including how we may communicate with you) may vary depending on which App you are using.
If you have any questions about our privacy practices, please email us at email@example.com with “Privacy” in the subject line.
PERSONAL INFORMATION COLLECTION
Once you enroll for Bink via the App, we may collect a variety of information about you, including some of the categories of information described below.
We may combine the information you provide to us directly with information we collect about you and information we receive about you from other sources, and use the combined information for the purposes set out below (depending on the types of information we receive).
We shall retain your Personal Information for as long as we provide Bink to you and for such additional period after that as is necessary to allow us to meet our legal and regulatory obligations.
1. Personal Information that you provide to us directly
You may provide Personal Information to us in various ways including when:
- registering to use Bink;
- filling in information;
- using Bink (such as registering your payment card or loyalty membership);
- corresponding with us using messaging features of the App or by e-mail or other form of communication;
- participating in discussion boards;
- contacting us through social media channels; or
- if you enter a competition, promotion or survey or provide us feedback.
Personal Information you give us may include your full name, address, e-mail address, age, date of birth, gender, phone number, financial and payment card information such as card number and expiry date and loyalty membership information which may include login details and other personal information.
2. Personal Information we receive about you from other sources
We may receive information about you from third parties we work closely with (including, for example, payment schemes, payment card issuers, retailers, loyalty programme providers, other business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers and search information providers). We receive this information so that we can provide Bink to you and as part of our legitimate interest to help us provide Bink to you in accordance with your requirements and to improve and personalise our services.
Specifically, we receive transaction information from your payment scheme (Visa, Mastercard and American Express) about purchases you make with your registered payment card (“Linked Payment Card”), including purchase amount, purchase time and date and the retailers and/or service providers who run loyalty programmes or membership programs who we have partnered with (“Partner Retailers”) for each transaction. We may also receive some or all of this information from the Partner Retailers or financial institutions who we partner with directly, such as where Bink is incorporated into an application operated by a Partner Retailer or a bank. This information will be used, for example, to ask the Partner Retailer to allocate rewards and other benefits to you, to provide you with an opportunity to join the Partner Retailer’s loyalty programme or to add an existing loyalty membership, and to provide the other aspects of Bink to you.
By connecting any Linked Payment Card via Bink, you authorise your payment network to examine transactions on your Linked Payment Card and to share the transaction data with us in order to facilitate your receipt of Bink and for reporting to the relevant Partner Retailer or financial institution. You give us the right to receive this transaction data from your Linked Payment Card until you remove your Linked Payment Card from Bink. You may remove your Linked Payment Card to prevent future transactions associated with the Linked Payment Card being shared with us. It may take a short period of time for the removal of your Linked Payment Card to take effect.
We may retain the data associated with your Linked Payment Cards for historical transactions which will be used to provide a historical transaction overview for you and Partner Retailers and financial institutions and which will allow you to monitor, preserve and track your collection of loyalty points, rewards balances and other benefits on loyalty programmes to which you belong.
If you have any questions about the data we keep in this context, please email us at firstname.lastname@example.org with “Privacy” in the subject line.
USE OF YOUR PERSONAL INFORMATION
We use your Personal Information on the following legal basis for the following purposes:
1. To perform our agreement to provide Bink to you including:
- to verify your identity;
- to provide you with Bink and carry out our obligations under our agreement(s) with you including, for example, to ask the Partner Retailer to allocate rewards and other benefits to you and to provide the other aspects of Bink to you;
- to provide you with information relating to Bink including loyalty programme balance updates;
- to provide you with information about Partner Retailers where you can use Bink, including information about new Partner Retailers joining Bink, presenting you with opportunities to join Partner Retailers’ loyalty programmes, or to register your existing loyalty membership, when you use your Linked Payment Card with the Partner Retailer for the first time and to provide details of the rewards and, other benefits, products and services available to you from the Partner Retailers;
- to provide you with information about our Bink partners including Partner Retailers, financial institutions and other organisations who join Bink;
- to provide you with information about products or services that you request from us; and
- to notify you about changes to Bink.
2. For our legitimate interest including:
- to develop and improve Bink, so that we can continue to provide attractive products and services to users and potential new users and to make sure we remain competitive;
- to personalise your use of Bink and provide tailored content to you so that you have a more relevant and better customer experience;
- to make automated decisions, known as “profiling”, using your Personal Information, such as decisions to provide information about particular rewards, benefits and promotional offers to you based on your previous transactions;
- to analyse and understand how Bink is used including carrying out technical and statistical analysis to monitor Bink;to ensure that content is presented in the most effective manner for you;
- to conduct market research;
- to tell you about any technical, operational or service issues;
- to offer you improved customer service and support;
- to comply with our contractual obligations;
- to prevent fraud;
- to ensure network and information security;
- to meet compliance, audit or insurance requirements; and
- to establish, exercise or defend legal claims.
3. To comply with our legal obligations including:
- preventing and prosecuting fraud; and
- meeting statutory, regulatory, data protection and information security legal requirements.
4. Anonymised information
We may also use anonymised Personal Information about you when we prepare aggregated data reports showing anonymised information for the purpose of advising ourselves, Partner Retailers and our other business partners regarding past and potential future patterns of spending, fraud, and other insights that may be extracted from this data.
SHARING YOUR PERSONAL INFORMATION
Where necessary to fulfil our obligations to you, we may pass your details to third parties where this is necessary to fulfil our obligations to you or for the operation, development and improvement of Bink. If you do not wish your Personal Information to be shared in this way, you must not register for Bink and you must not use Bink.
This may include sharing Personal Information about you with Partner Retailers, financial institutions and our business partners, suppliers and sub-contractors that join Bink or that we engage to help us provide Bink to you or to process your information including:
- Sharing information about your payment cards with payment schemes and service providers so that we can identify transactions you make using your payment cards – this information is protected by being “tokenised” for us by a service provider, which means your payment card number is replaced by a different token reference number which cannot be linked to your actual payment card number;
- Sharing information about how you use your payment card with Partner Retailers so that you receive the benefit of Bink (for example, so that you receive your rewards or other benefits of the Partner Retailers’ loyalty programme);
- Sharing information about you with a Partner Retailer so that they can enroll you in their loyalty programme, when you register for that programme through Bink, and so that we can ensure that the information we and the Partner Retailer hold is accurate and up-to-date and so that you receive the benefits of the Partner Retailer’s loyalty programme and other services;
- Sharing information with Partner Retailers and financial institutions who incorporate Bink into their own mobile/device application; and
- Sharing information about you with our other service providers so that we can provide customer service to you.
For further information about how we share your personal information, please email us at email@example.com with “Privacy” in the subject line.
We may share your Personal Information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries (“Loyalty Angels Group”).
As may be necessary for us to comply with our legal obligations, we may disclose your Personal Information to third parties (such as government or regulatory bodies, law enforcement agencies and professional services advisers) in order for us to comply with applicable laws and valid requests for information from government or regulatory bodies, or in order to enforce or apply the Bink User Terms and other agreements; or to protect our rights, our customers, or others. This may include exchanging Personal Information with other companies and organisations for the purposes of fraud protection and risk management.
1. Obtaining a copy of your Personal Information
At any point you can contact us to ask for a copy of the Personal Information about you which we hold and to request further information in relation to our processing of the Personal Information. If you do wish to receive copies of your Personal Information which we hold, please email us (including full details of your request) at firstname.lastname@example.org with “Privacy” in the subject line. Once we have received your request (and any additional information we may need from you to deal with your request) we will respond within one month.
In exceptional circumstances: a complex request that requires extra effort may take longer (up to an additional two months) but we will inform you of any such extension together with the reasons for the delay. In some instances we will not be able to agree to your request (for example, if we have a legitimate reason for not doing so or the request is manifestly unfounded or excessive); in these situations your request may be rejected entirely or responded to in part. We will comply with applicable legal requirements when we deal with your request.
We will provide a copy of your Personal Information free of charge, however we may charge a small fee based on administrative costs (not exceeding the maximum permitted by law) for any further copies of this information that you may request.
2. Changing, updating and erasing your Personal Information
We will strive to ensure that the Personal Information that we hold on you is up to date and accurate, based on the information we collect. If you believe that the Personal Information we hold on you is out of date, incomplete or incorrect, please email us at email@example.com marked “Privacy” in the subject line) and we will ensure that it is updated.
If you would like us to stop using your Personal Information, you can request that we erase the Personal Information we hold but, if you do, your account will be deactivated and we will no longer be able to provide Bink to you. Once we have processed your request, we will confirm whether all the Personal Information has been deleted or tell you the reason why any of it cannot be deleted. If you would like us to delete your Personal Information, please email us at firstname.lastname@example.org (marked “Privacy” in the subject line) with a request that we delete your Personal Information from our database.
We may retain an archived copy of your records (which may include your Personal Information).
We will comply with applicable legal requirements when we deal with your requests.
3. Objecting to processing of your Personal Information
You have the right to request that we stop processing your Personal Information but, if you do, your account will be deactivated and we will no longer be able to provide Bink to you. Upon receiving the request, we will contact you to tell you if we are able to comply or if we have legitimate grounds to continue such processing (e.g. if you have also said that you want to continue to use Bink). If you would like to ask us to stop processing your Personal Information, please email us (including full details of your request) at email@example.com and mark your email “Privacy” in the subject line. If Personal Information is no longer processed in accordance with your request, please note that we may need to continue to hold your Personal Information to comply with your other rights (e.g. if you want to unsubscribe to marketing communications, we will place your details on our unsubscribe list to ensure we do not contact you as requested) or our legal obligations. We will notify you of this in our response to your request to object to the processing. We will comply with applicable legal requirements when we deal with your request.
4. Portability of your Personal Information
You also have the right to receive your Personal Information in such a way that it can be transferred to another controller. Once we have received your request, we will comply where it is feasible to do so. If you would like to exercise this right, please email us (including full details of your request) at firstname.lastname@example.org (marking your email “Privacy” in the subject line). We will comply with applicable legal requirements when we deal with your request.
Where we use automated decision making based on your Personal Information (also known as “profiling”), you have the right to have a person intervene in that decision, to express your point of view, to an explanation of a decision reached and to challenge the decision. If you would like to exercise this right, please email us (including full details of your request) at email@example.com (marking your email “Privacy” in the subject line).
6. Make a complaint
You can make a complaint about how we have used your Personal Information to us by emailing us at firstname.lastname@example.org. To assist us in dealing with your complaint, please put ‘Privacy Complaint’ in the subject line.
To escalate to Bink’s Data Protection Officer (DPO) directly, please email email@example.com.
Alternatively, you can contact the relevant supervisory authority – for the UK this is the Information Commissioner’s Office, at https://ico.org.uk/.
We take the security of your Personal Information very seriously and use strict procedures and security features to prevent unauthorised access to your Personal Information.
We have put into place additional procedures to protect the Personal Information we hold about you from misuse and loss, and from unauthorised access, modification or disclosure. We work hard to maintain these procedures and keep them current and up to date.
We will keep your Personal Information for as long as you are our customer.
Once our relationship with you has ended, we will only keep your Personal Information for a period of time that is appropriate for the type of personal data, and the purpose for which we hold it.
We will only keep information that allows us to:
- maintain business records for reporting, analysis or audit purposes;
- monitor compliance with applicable laws and regulations;
- defend or take legal action;
- respect marketing preferences;
- deal with customer service enquiries or complaints;
- help with monitoring fraud.
After our relationship with you has ended, typically we will keep your Personal Information for up to one year in a live operational environment (or less than 30 days if you make a formal data deletion request) before we anonymise it and data which we need to hold for legal and regulatory reasons is typically archived for up to six years.
We will keep your Personal Information after this time only if we have to do so to comply with applicable law, if there are existing legal claims or complaints or for regulatory or technical reasons.
When contacted with an enquiry from someone who is not a registered user, we will hold the name and contact details only for the purposes of handling the enquiry.
Calls made to us may be recorded to protect the interests of all parties. Any call records which are created will generally be deleted within 30 days unless we need to keep them longer to meet our obligations.
CHANGES TO THIS POLICY