Privacy Policy

The privacy policy stated below is issued by OZO Loyalty. (all references to “OZO”, “OZO Loyalty”, “we”, “us” or “our” in this policy refer to OZO Loyalty).

 

The purpose of this policy is to inform our customers how we collect and use their data that is captured from our mobile apps and website. We are not responsible for the content or privacy policies of any user registered as a merchant on the OZO Loyalty platform. As we set out below in the ‘Recipients of Data’ section, when a consumer participates in a particular merchant’s loyalty program through the OZO Loyalty app, we will share their personal data with that merchant. This includes name, date of birth, and gender. We therefore encourage consumers to refer to the relevant merchant’s privacy policy and practices. If you have any questions about our use of your personal data, please contact us at hello@ozoloyalty.com

Personal data that we collect and process

 

We collect and process personal data relating to our users in connection with their use of the OZO app and website and our relationship with them. This personal data may include:

  • name, age, gender and contact details, including email address

  • loyalty points transaction data as users collect and redeem OZO points

  • any other personal data relating to our users that they provide to us or that we generate about them in connection with their use of our app or website

Usage data

We use an application to collate and analyse certain statistical information about the use of the app. When our users use our app, the following information is retained about that user of the app:

  • the location and time when users have used the app in store; 

  • IP address, IMEI, IMSI, and device ID; 

  • location when users are using the map on our app; and

  • details about when the app crashes, time spent using the app, and details of how the app is used.

 

No attempt is made to identify individual users or to associate the technical details listed above with any individual.

Purposes of processing and legal basis

We will use personal data relating to our users for the purposes of:

  • providing services, including facilitating collection and redemption of OZO Points in-store, maintaining a record of the OZO Points collected, and facilitating redemption of OZO Points in-store;

  • improving and developing our app;

  • generating and analysing statistics regarding usage of the app, (where possible, personal data will be anonymised before being used for this purpose);

  • carrying out research and customer satisfaction surveys;

  • fraud prevention, investigation and detection; and

  • establishing, exercising or defending legal claims.

 

The legal bases on which we process users personal data are:

  • where our users have consented to our processing of their personal data;

  • to take steps at our users’ request prior to entering into a contract with them or to perform a contract with them;

  • our legitimate interests in conducting our business in a responsible and commercially prudent manner. We will not process any personal data for these purposes if to do so would constitute an unwarranted interference with our users’ own interests, rights and freedom;

  • that this is necessary to comply with our legal and regulatory obligations.

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Consent

Where we process user’s personal data on the basis of their consent, they have the right to withdraw their consent at any time.  They can withdraw their consent by contacting us at hello@ozoloyalty.com

 

Recipients of Data

We may disclose consumers’ personal data to other organisations in connection with the above purposes, including:

  • the merchants whose loyalty schemes they participate in through the OZO app;

  • to third parties who we engage to provide services to us in connection with this app, such as outsourced service providers, IT services providers, professional advisers and auditors;

  • to third parties, their agents and professional advisors, subject to confidentiality, for the purpose of a due diligence exercise by third parties in connection with any proposed merger, acquisition, re-organisation or transfer of our business and to any person proposing to participate in , or promote or underwrite or manage any such arrangement; and

  • to competent regulatory authorities and bodies as requested or required by law.

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Retention

We will not hold users personal data for longer than is necessary. We retain personal data for as long as we need it for the purposes described in this notice, or to comply with our obligations under applicable law and, if relevant, to deal with any claim or dispute that might arise between our users and us.

Requirement to Provide Personal Data

Our users are not under a statutory or contractual obligation to provide us with any personal data, however, in order to use the app users must provide us with the following minimum information: phone number, full name, gender, and date of birth.  If users do not provide us with this information, we will not be able to provide services of our app to them.

Transfers Abroad

In connection with the above we might transfer users’ personal data outside the European Economic Area, including to a jurisdiction which is not recognised by the European Commission as providing for an equivalent level of protection for personal data as is provided for in the European Union.  If and to the extent that we do so, we will ensure that appropriate measures are in place to comply with our obligations under applicable law governing such transfers. These may include entering into a contract governing the transfer that contains the ‘standard contractual clauses’ approved for this purpose by the European Commission or, in respect of transfers to the United States of America, ensuring that the transfer is covered by the EU-US Privacy Shield framework. If you would like to receive further details of the measures that we have taken in this regard, please contact us at hello@ozoloyalty.com

User’s rights

Our users have the following rights, in certain circumstances and subject to certain restrictions, in relation to their personal data:

  • the right to access personal data;

  • the right to request the rectification and/or erasure of personal data;

  • the right to restrict the use of personal data;

  • the right to object to the processing of personal data; and 

  • the right to receive personal data, which users provided to us, in a structured, commonly used and machine-readable format or to require us to transmit that data to another controller.

 

If you wish to exercise any of the rights set out above, please contact us at hello@ozoloyalty.com

Updates

We may occasionally update this notice. We encourage users to periodically review this notice for the latest information on our privacy policies. 

Complaints

If you are not happy with the way we are using your personal data or how we facilitate your rights or comply with our obligations under applicable data protection law, you have the right to make a complaint to the Data Protection Commission (www.dataprotection.ie).