Privacy & Data Protection Policy
Incentivesmart Limited, a company incorporated in England & Wales under company number 06556915, are fully committed to compliance with the requirements of the Data Protection Act 1998 and the new General Data Protection Regulation 2018 (GDPR). This Privacy and Data Protection Policy sets out our commitment to protecting personal data and how we implement that commitment with regards to the collection and use of personal data.
We are notified as a Data Controller with the Office of the Information Commissioner under registration reference ZA215970 and we are the data controllers and processors of personal data that you provide to us as a client or information we obtain from your customers, employees or affiliates as a result of participating in a programme or promotion managed by us. Any questions relating to this policy and our privacy practices should be sent to firstname.lastname@example.org.
In providing our products and services Incentivesmart is acting as data processor and the client is acting as a data controller. As stated in the Incentivesmart Managed Services Agreement each party must agree that, where applicable, in the performance of its respective obligations under this Agreement and under any Programme Specification, it will comply with the provisions of the relevant data privacy legislation, including but not limited to the Data Protection Act 1998 and the EU General Data Protection Regulation 2018 (Collectively referred to as DPA) to the extent it applies to them.
Types of information Incentivesmart collects:
- Contact information, such as name, email address, mailing address, fax or phone number;
- In some cases, we may take payment and financial information, such as credit or other payment card information, bank account, or billing address;
- Date of Birth is collected on registration to ensure legal compliance;
- Preference information such as product wish lists, order history, or marketing preferences.
- Information about your business such as company name, job role, or business type;
- Demographic information, such as age, gender, and interests;
- Device and other tracking information, such as browser information, device identifiers, operating system, geolocation, or information gained from cookies, pixels or other tracking technologies.
- Sometimes, we may combine personal information you provide with information from third-party sources. For example, we may confirm your address with the postal or courier service. We will treat the combined information in accordance with the terms of this Policy.
- We monitor usage patterns to continually improve the site.
- Phone calls may be recorded, and any recorded calls may be retained for a maximum of 6 months and only be used for training and quality purposes
Incentivesmart collect personal information:
We obtain information about you from the data controller in order to invite you to an online platform or programme which we provide. We collect further information when you use our website or register for a programme or promotion managed by us, either directly or on behalf of the client. We need this information to enable us to provide our services. This section sets out in more detail what information we collect, why we collect it, how we use it and how long we keep your information.
We collect personal information when you provide it to us. This can occur when you register, create accounts, complete a purchase, send in forms, take surveys, or fill in various online fields on our online applications. We also collect personal information when you contact us with enquiries or customer support requests.
We may also collect the personal information of third parties when you provide it to us. For example, if you choose to use our service to send a referral or gift to a friend or colleague, we will ask you for their name and address or email address depending on the service required. Incentivesmart stores this information for the sole purpose of completing the transaction. If you provide personal information of a friend or family member and they want us to delete this information, they should contact us at email@example.com.
How Incentivesmart use personal information:
Authorised employees of Incentivesmart and client administrators, defined by the client, will have access to some of your personal information for the following purposes:
- to provide you with the products and or services you were invited to or requested;
- to verify your identity and/or location in order to allow access to your accounts, conduct online transactions, and secure your personal information;
- to send you important information, such as changes to terms, conditions, and policies and/or other administrative information;
- to deliver rewards to your chosen delivery addresses;
- to respond to your enquiries and fulfil your requests;
- to track referrals;
- to personalise your experience on our systems by presenting content or offers tailored to you;
- to send you marketing communications you have signed up for or that we believe may be of interest to you. If you subscribe to newsletters, we will use your name and email address to send them to you. You may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails or accessing the email preferences in your account.
- to allow you to use various online system features.
Although we will do our best to protect your personal data using the latest SSL encryption, we cannot guarantee the complete security of your data transmitted; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to restrict unauthorised access. Where applicable credit and debit card data taken through our websites are encrypted in accordance with PCI-DSS.
The security of your personal information is important to us. All personal information is stored in databases hosted in ISO27001 compliant secure data centres inside the European Economic Area (EEA). Some of our third-party contractors are based outside of the EEA however, we have strict control over how and why your data can be accessed. By submitting your personal data, you are consenting to this transfer, storing or processing. If we transfer your data outside the EEA we will take steps to ensure that appropriate security measures with the aim that your rights continue to be protected as set out in this policy.
Retention of personal information:
We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal and regulatory obligations, resolve disputes, and enforce our agreements.
Access to personal information:
Anyone may request, at any time, a copy of the personal information Incentivesmart holds about them, at no cost. Should you wish to access or update the personal information that we hold, please contact us by sending a written request to Data Processing, Incentivesmart Limited, 7 Moulsoe Business Centre, Cranfield Road, Milton Keynes, MK16 0FJ or by email to firstname.lastname@example.org.
Removal of personal information:
If you wish to have the personal information Incentivesmart holds on your person removed, please request this in writing to: Data Processing, Incentivesmart Limited, 7 Moulsoe Business Centre, Cranfield Road, Milton Keynes, MK16 0FJ or by email to email@example.com.
If you are concerned that we are not using your information in accordance with the law, or are not satisfied with our response to a request made above, then you can complain to the Information Commissioner’s Office.