Privacy Policy

As the operators of The Loyalty Experts and SmartScheme websites, City Consultants & Systems having its office address at 20 Hill Close, Bransgore, Dorset BH23 8BP ("We", "Us", “CCS”) is committed to protecting and respecting your privacy. This Privacy and Cookies Policy ("Policy") relates to services provided through our marketing website at theloyaltyexperts.co.uk (“Website”) and SmartScheme website at smartscheme.eu (“Services”) and sets out the basis on which the personal data collected from you, or that you provide to Us will be processed by Us. Please read the following carefully to understand our views and practices regarding your personal data and how We will treat it.

For the purpose of, the General Data Protection Regulation (“GDPR”), from the GDPR implementation date or, until GDPR implementation date, the Data Protection Act 1998 (collectively the “Data Protection Laws”):

in respect of the personal data of users of the Website and the Services business contacts and prospects of CCS, the Data Controller is City Consultants & Systems;
in respect of the personal data of cardholders of Loyalty and Gift Card Schemes which CCS handles on behalf of Customers (“Cardholder”) CCS shall process personal information as a data processor on behalf of its Customers, who use Our Services to assist with managing their Loyalty and Gift Card Schemes. Where you become a Cardholder with one of CCS’s Customers, our Customer’s privacy policy, rather than this Privacy Policy, will apply to our processing of your personal information.

Information we collect from you

We collect and process some or all of the following types of information from you:

Information that you provide by filling in forms on the Website. This includes information provided at the time of requesting further information or services and during support requests. We may also ask you for information when you report a problem with the Website.
If you contact Us, We may keep a record of that correspondence.
We may also ask you to complete surveys that We use for research purposes, although you do not have to respond to them.
Details of all actions that you carry out through the Website and of the provision of services to you.
Details of your visits to the Website including, but not limited to, traffic data, location data, weblogs and other communication data, the site that referred you to our site and the resources that you access.

The provision of your full name and e-mail address, your employer and/or your place of work and the url of the business that you work for is required from you when you register to use our Services.

Information we collect from other sources

From time to time we also obtain personal data from other sources as follows:

Cardholder personal information where input by a Customer in order to provide Our Services to the Customer;
names and contact details of Customer personnel who will be added as account members for the Customer’s account, may be added by existing account members;
names and contact details of individual contacts at prospective Customers from third party data providers and/or public sources, such as social networks, company websites and other online sources.

Uses made of your information

Where you are using our Services on behalf of our Customer, we rely on legitimate interests in performing our contract with our Customer as the lawful basis on which We collect and use your personal data.

We use information held about you in the following ways:

To carry out our obligations arising from any contracts entered into between our Customer (on whose behalf you are using the Services) and Us.
To notify you about changes to our Services and provide you with information that is relevant to your use of the Services.
Where you or your employer are a prospective Customer, to provide you with information about our Services for marketing purposes.

Disclosure of your information

We may disclose your personal information to third parties:

during the fulfilment of Customer orders for example the shipment of Loyalty Cards;
in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
if we or substantially all of our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets;
if we are under a duty to disclose or share your personal data in order to comply with any legal obligation or in order to enforce or apply our Website Terms and Conditions and other agreements, but we will endeavour to minimise such disclosure to only that reasonably necessary and, where possible, to provide you with notice of such disclosure; and/or
to protect the rights, property, or safety of City Consultants & Systems, the Website, the Services, our users and any third party we interact with to provide the Website.

How we store your personal data

Security

We take appropriate measures to ensure that all personal data is kept secure including security measures to prevent personal data from being accidentally lost, or used or accessed in an unauthorised way, for the duration of your use of our Website and/or Services. We limit access to your personal data to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where We are legally required to do so.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data for example using TLS encryption in transit, we cannot guarantee the security of your data transmitted to the Website and/or Services, therefore any transmission remains at your own risk. Once we have received your information, we will use strict procedures and security features in order to prevent unauthorised access.

Keeping your personal data up to date

If your personal details change you may update them by contacting Us using the contact details below. We will endeavour to update your personal data within thirty (30) days of any new or updated personal data being provided to Us, in order to ensure that the personal data We hold about you is as accurate and up to date as possible.

Where we store your personal data

The data that We collect from you and process as a result of your use of the Services may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for Us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your orders, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing.

In particular, your data may be i) stored by CCS’s hosting service provider on servers in the UK or in the EU, ii) used by our plastic card Suppliers in Israel.

If you would like further information please contact Us (see ‘Contact’ below). We will not otherwise transfer your personal data outside of the United Kingdom OR EEA or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries.

How long we keep your personal data

We will hold all the data for so long as we have an obligation to the Customer to provide the Services, and thereafter until such time as we delete the Customer’s account upon termination of their agreement.

Your personal information will be deleted on one of the following occurrences:

deletion of your personal information by you (or by another person engaged by the Customer); or
receipt of a written request by you (or another person engaged by the Customer) to us.

Your rights

Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:

access to your personal data and to certain other supplementary information that this Policy is already designed to address
require Us to correct any mistakes in your information which We hold
require the erasure of personal data concerning you in certain situations
receive the personal data concerning you which you have provided to Us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
object at any time to processing of personal data concerning you for direct marketing
object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
object in certain other situations to our continued processing of your personal data
otherwise restrict our processing of your personal data in certain circumstances
claim compensation for damages caused by our breach of any data protection laws.

For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.

If you would like to exercise any of those rights, please:

contact us using our Contact details below
let Us have enough information to identify you,
let Us have proof of your identity and address. Where you are a user of our Services you should email us from the email address that you used to register with the Customer. Receipt of an email from this address and response to a further request for confirmation will usually be sufficient to confirm your identity. In all other cases we may request one or more identification documents, such as a copy of your driving licence or passport and a recent utility or credit card bill; and
let Us know the information to which your request relates.

Third Party Websites

The Website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and terms of use and that we do not accept any responsibility or liability for these policies and terms of use. Please check these policies before you submit any personal data to these websites.

How to complain

We hope that We can resolve any query or concern you raise about our use of your information.

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: 0303 123 1113.

Changes to our privacy policy

We reserve the right to modify this Privacy Policy at any time. Any changes we may make to our Policy in the future will be notified and made available to you using the Website. Your continued use of the Services and the Website shall be deemed your acceptance of the varied Privacy Policy.

IP Addresses and cookies

We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration, customer support and to collect aggregate information for internal reporting purposes.

In addition, our Website and Services use cookies. A cookie is a small file of letters and numbers that we put on your computer if you agree. These cookies allow us to distinguish you from other users of the Website, which helps us to provide you with a good experience when you browse our Website and Services and also allows us to improve them.

The cookies we use are "analytical" cookies. Some of the common uses for our cookies are as follows:

to recognise and count the number of visitors and to see how visitors move around the site when they are using it. This helps us to improve the way our Website works, for example by ensuring that users are finding what they are looking for easily.
to identify and authenticate a user across different pages of our Website and Services, in a session or across different sessions. This is so that the user does not need to provide a password on every page the user visits; and
to be able to retrieve a user’s previously stored data, for example, information that the user previously submitted to the Website or Services, so as to facilitate reuse of this information by the user.

Contact

All questions, comments and requests regarding this Privacy Policy should be addressed to support@theloyaltyexperts.co.uk.