Ce texte n’a pas encore été vérifié par un avocat et changera avant le lancement de LoyaltyFlow. Les mots entre [crochets] restent à compléter.
Pour l’instant, le texte complet ci-dessous est en anglais, le temps de sa relecture juridique. Une traduction française sera publiée une fois cette relecture terminée.
En bref
- Nous collectons ce qu’il faut pour faire fonctionner les cartes de fidélité : les comptes des commerces, les accès des employés et les clients qui s’inscrivent à une carte.
- Les clients donnent un nom et un numéro de téléphone ou un e-mail. Nous ne vendons jamais leurs données, et nous ne leur envoyons jamais de messages publicitaires, ni par e-mail ni par SMS.
- Nous ne recevons jamais la localisation de qui que ce soit. Le téléphone détermine seul quand suggérer une carte.
- Ce site n’utilise aucun cookie de mesure d’audience ni de publicité.
- Les paiements par carte sont gérés par Stripe. Les numéros de carte ne nous parviennent jamais.
- Les clients peuvent supprimer leur carte à tout moment.
Sur cette page
01Who we are
LoyaltyFlow is a loyalty card service run by FPontes LTD (“we”, “us”), a company registered in [England and Wales] with company number [company number]. This policy explains what personal information we handle, why, who else handles it and how long we keep it.
It covers:
- this website, loyaltyflow.fpontes.com;
- the LoyaltyFlow app for businesses at app.loyaltyflow.fpontes.com, including the staff app;
- the join pages and card pages that shops share with their customers;
- LoyaltyFlow cards saved in Apple Wallet and Google Wallet.
Shops that use LoyaltyFlow decide how their loyalty programme uses their customers’ information. For that information the shop is the controller and we act on its behalf; see Shoppers who join a card. For everything else in this policy, we are the controller.
Questions or requests: info@fpontes.com.
02This website
- There are no analytics, advertising or tracking cookies, and our fonts are served from this site.
- If you choose a language or a currency, your browser remembers the choice on your device. It isn’t sent to us.
- The site is hosted by Cloudflare, whose servers handle each visit, including your IP address, to deliver and protect the site.
- If you message us on WhatsApp or by email, we use what you send to reply and to help you get started. WhatsApp is run by Meta under its own privacy policy.
03Shop owners and staff
When a business signs up, or a team member is added, we store:
- the business name, type, country, language and time zone, and the contact details you add (email, phone, website, Instagram);
- your shops’ addresses and their position on the map, which you confirm;
- logos, photos and colours you upload for your card;
- each user’s name, email address and role, and the password as a one-way hash we can’t read;
- staff PINs, also stored as one-way hashes, and the shop phones you pair (their name, when they were paired and when they were last used);
- sign-in sessions, with the IP address and browser description, to keep you signed in and spot misuse;
- an activity log of important actions, such as who added or redeemed stamps and who changed settings, so owners can see what happened.
To place a shop on the map, we send its address to OpenStreetMap-based services (postcodes.io for UK postcodes, and Nominatim). You confirm the pin before it is used.
We send service emails, such as email verification, password resets, invitations and messages about your trial, billing and setting up your card. The app uses one essential cookie to keep you signed in, and no analytics or advertising cookies.
04Shoppers who join a card
When you join a shop’s loyalty programme, the shop is responsible for your information and we look after it for the shop. Questions about how a shop uses your information are best sent to the shop, but you can also contact us.
What we store
- your name, and your phone number or email address;
- whether you agreed to the programme’s terms and whether you chose to get the shop’s news, with the time, the wording you agreed to and your IP address, as a record of your choice;
- your language, and your birthday if the shop asks for it and you give it;
- your card: stamps or points, rewards, and the history of each visit, including which staff member, phone and shop recorded it;
- if you were referred by a friend, that link; if the shop connects Square, the link between your card and the Square customer with the same phone number or email.
Your card in Apple Wallet and Google Wallet
When you save the card, your phone registers with our server so the card can be updated. For Apple Wallet we receive a device identifier and a push token from Apple; for Google Wallet we keep a reference to your card at Google. We use these only to keep your card up to date. Apple and Google handle cards in their Wallet apps under their own privacy policies.
Your card carries the shop’s location, so your phone can suggest the card when you are nearby. Your phone works this out by itself: we never receive your location.
Messages
We never email or text you marketing for a shop. A shop’s news only appears on your card, and only if you chose to receive it. If you try to join again with an email address that already has a card at that shop, we email you a link to your existing card.
Your choices
From your card page you can stop the shop’s messages or delete your card at any time. Deleting it removes your personal information and stops the card working; we keep anonymous totals so the shop’s figures still add up.
If a card isn’t used for 24 months it is deleted automatically, unless the shop has chosen a different period.
LoyaltyFlow isn’t designed for children. Shops should not sign up children without a parent’s permission. [Age wording to be confirmed in the legal review.]
05Payments
Subscriptions are paid through Stripe. You enter card details on Stripe’s own pages, so they never reach us. We give Stripe your business name, email address and an account reference, and Stripe tells us the state of your subscription. We keep Stripe’s references for you, your plan, billing period and subscription status. Stripe’s privacy policy covers payment details.
06Who else handles data
We use these providers to run LoyaltyFlow [list to be confirmed before launch]:
- Stripe: payments.
- Cloudflare: hosts this website and the LoyaltyFlow app, and protects our servers.
- Hetzner: runs the servers behind LoyaltyFlow [region to confirm].
- MongoDB Atlas: our database [region to confirm].
- Resend: sends our emails.
- Apple and Google: deliver cards and card updates to Apple Wallet and Google Wallet.
- OpenStreetMap services (postcodes.io, Nominatim): map positions for shop addresses.
- Sentry: error monitoring [to confirm].
- Square: only for shops that connect it.
- Image storage for logos and photos [provider to confirm].
Our staff can open an account when needed to support you or to keep the service running. We don’t sell personal information or share it for advertising.
07International transfers
Some of these providers are based in, or have staff in, countries outside the UK and the European Economic Area, such as the United States. Where that happens, we rely on adequacy regulations or on safeguards such as the UK International Data Transfer Addendum or the EU Standard Contractual Clauses. [To be confirmed in the legal review.]
08Why we use it
- To provide the service a business has signed up for. This is necessary for our contract with that business.
- To keep LoyaltyFlow secure, prevent misuse and improve it, which is in our legitimate interests. This includes sign-in records and the technical logs our servers keep for each request.
- To meet our legal obligations, such as keeping accounting records.
- For shoppers’ information, we act on the shop’s instructions, and the shop decides its lawful basis, for example consent for receiving its news.
09How long we keep it
- Business accounts, shops, team and cards: while the account is open. When a plan ends, members’ cards show that the programme has ended after 30 days, and we delete the account’s data after 90 days, emailing an export link first.
- A shopper’s card: until the shopper or the shop deletes it, it goes unused for 24 months (or the shop’s chosen period), or the shop’s account is deleted.
- Sign-in sessions: deleted automatically when they expire.
- Billing records: as long as tax law requires.
- Backups: overwritten after [backup period to confirm].
10Security
Connections are encrypted. Passwords and staff PINs are stored as one-way hashes. Connection tokens for integrations such as Square are encrypted with their own key. Our logs don’t contain phone numbers, email addresses or access tokens.
11Your rights
Under UK and EU data protection law you can ask for a copy of your information, ask us to correct or delete it, object to or restrict how we use it, and ask for it in a format you can take elsewhere. Email info@fpontes.com. If you are a shopper, we may pass your request to the shop, because it decides how its programme uses your information.
If you are unhappy with how your information has been handled, you can complain to the UK Information Commissioner’s Office (ico.org.uk) or to the data protection authority where you live, such as the CNPD in Portugal, the AEPD in Spain or the CNIL in France.
12Changes to this policy
If what we do with information changes, we will update this page and the date at the top, and email account owners about important changes.
Des questions sur ces documents ?
Écrivez à FPontes LTD à l’adresse info@fpontes.com.