Initial Rewards - Changing Loyalty

Privacy Policy

 

1. Introduction
This privacy policy (Privacy Policy) sets out the ways in which all members of Initial Rewards

(by which we mean Initial Rewards Limited and all of its subsidiaries) may use your personal data.
In this Privacy Policy:

  • ‘we’, ‘us’ or ‘our’ means the Initial Rewards entity with which you are interacting. We will make it clear to you which entity this is;
  • ‘the site’ means the Initial Rewards website you are visiting or engaging with; and
  • ‘you’ and ‘your’ means you, the person engaging with us, registering for our events or services or visiting our site.

By registering for our newsletter, subscribing to our services, visiting our site or otherwise interacting with us, you consent to our processing of your personal data in accordance with this Privacy Policy.
2. How you can contact us:
Address: FAO the Data Protection Officer, 4 Parr Road, Stanmore, Middx, HA7 1QP, UK
Email: whatsup@initialrewards.com
3. Information we may collect about you
Information you give us: We collect any information you provide to us when you complete registration forms, or provide us with your details over the phone, for example when you register an account with us, use our platform and services or subscribe to our mailing list. This information might include your name, address, email address, phone number and other information relevant to the service that you’re registering for
Information we collect about you: We will collect any information contained in any correspondence between you and us via contact forms on websites, and emails or telephone calls.

o We collect information about you visiting our website and how you use it. This may include your IP address, geographical location, device information, browser type, referral source, length of visit, operating system, number of page views, which pages you viewed and similar information. This information may be collected by a third-party website analytics service provider on our behalf and/or may be collected using cookies. We also use cookies and pixels in our emails to track delivery and open rates, the results of which are stored against your email address and profile. For more information on cookies please refer to paragraph 6 below
Information we receive from third parties: We may collect information about you from third parties that we work closely with for the purposes of delivering to you the services that you request from us. For example, we may engage third parties to assist us with our online registration systems or payment systems; these entities will collect information directly from you on our behalf. We may engage third parties to operate websites on our behalf; these entities will collect information directly from you about your visits to the website on our behalf.
o We may also receive information about you from third parties where you have consented to such third party sharing your information with us.

 

4. How we use information about you
We may use your information for the following purposes, depending on the relationship we have with you. Prior to submitting your personal data to us, we will provide you more specific information where necessary about how we will use your data and link you to this privacy policy.


We use personal data to:

The purpose of this is:

The applicable legal basis:

Provide you with information that you have requested from us, in relation to products and services we provide (for example new gifting technology or branded merchandise).

We will need to use your contact details to keep you updated about the products or services you have indicated you are interested in.

By specifically requesting information from us, you are consenting to us using your personal data for the purposes of communicating such information to you.

To keep in contact with you about other similar products or services of ours that may be of interest to you, or for research purposes after you have used one of our products or services.

To keep you up to date on similar products or services you have previously purchased from us in the past. To analyse the effectiveness of our products and offerings to you.

It is our legitimate interest to keep you up to date on similar products and services of ours you have used in the past. Where we rely on legitimate interests in this way, we will always offer an opt out, and unsubscribe option on any marketing information we send you.

Pass on your contact details to our logistics partners in order to send you merchandise, product information or product samples.

We engage logistic partners in order to deliver items globally. In order to send items to you for sampling or production purposes. We need to use your personal information *such as address) to ship these items to you.

Where we need to share these details with such logistic partners in order to perform the contract we have with you, the legal basis would be the performance of a contract.
In other circumstances, we have a legitimate interest to provide the details to our partners, because these services are required for delivery, and it is in your interest to be provided with this information. If you prefer us not to share these details with our logistics partners, you can us indicate using the opt out box when you register your details, or let us know during the contracting process.
 

Analyse user traffic to measure use of our websites and improve their content.

We may use information such as your IP address for analytical purposes of our pages, this could also include improving the content of our websites and services.

We have identified web analytics as a legitimate interest of our business, and allow us to better meet your needs as a customer.

To comply with or abide by legal obligations or requirements.

We may need to use or process your personal data to comply with some legal requirements.

Where we need to process your data for these reasons, the legal basis will be compliance with a legal obligation.

You can find out more information on the privacy notice provided at the time you submit your data to us or in your contract with us (if applicable).
5. Who we might share your data with 
In certain circumstances we may share your personal information with:

  • Other entities in the Initial Rewards Group. Where the relevant Group entity is outside the EEA, we would only transfer data where an appropriate safeguard such as EU model clauses or Privacy Shield certification exists between the entities.
  • Selected third parties that we work with, where necessary for the purposes of delivering to you services that you request from us. For example, shipping items via Fedex. Where we use such third parties, we enter contracts which ensure that the third party is obligated to provide at least the same level of data protection as the Initial Rewards entity entering into that contract, and we take reasonable, appropriate steps to ensure that the contractor effectively processes the personal data in a manner consistent with this Privacy Policy and our internal policies relating to the protection of Personal Data.
  • Any other Initial Rewards entity or selected third party that you consent to our sharing your information with for marketing purposes (such consent will be sought prior to our sharing of this data).
  • Any other third parties where necessary to enable us to enforce our legal rights, or to protect the rights, property or safety of our employees or where such disclosure may be permitted or required by law.

6. Cookies 
We use cookies to ensure that you get the most out of our site. Cookies are small text files which we store on the device you use to access the site. Cookies allow us to monitor your use of the software and simplify your use of the site. For example, a temporary cookie is also used to keep track of your "session". Without that temporary cookie (which is not stored after you quit your browser) you would have to log on every time you access a new page.
If you do not wish for cookies to be installed on your device, you can change the settings on your browser or device to reject cookies. For more information about how to reject cookies using your internet browser settings please consult the “Help” section of your internet browser (or alternatively visit http://www.aboutcookies.org). Please note that, if you do set your Internet browser to reject cookies, you may not be able to access all of the functions of our websites.
7. Third Party Content, Sites, and Contributions
Some of our websites may contain content and links to other websites or apps that are operated by third parties. We don’t control these third party websites or apps (including whether or not they store cookies) and this Privacy Policy does not apply to them. Please consult the terms and conditions and Privacy Policy of the relevant third party website or app to find out how that site/app collects and uses your information and to establish whether and for what purpose they use cookies.
8. How we look after your data and how long we keep it for
We use a variety of technological and operational security measures to protect your information against any unauthorised access to, unlawful use of, and modification and destruction of any personal data we store.
We will retain your information for as long as is necessary to provide you with the services that you have requested from us, or for as long as the law otherwise permits. If your information has been provided as part of a promotion or order where our systems are involved to process and deliver, data will be kept for 90 days and then hard-deleted from our system and servers.
Transmission of information over the internet can be insecure, and although we employ measures to protect your information from unauthorised access we cannot always guarantee the security of information sent over the internet.
9. Where we store your information
Initial Rewards servers are situated inside the European Economic Area (EEA) and all of the information that we collect about you will be stored on these servers.
In certain circumstances your information may be processed outside of the EEA such as when/if we engage third parties based outside of the EEA. In such circumstances, we will take all steps necessary to ensure that any of your information is adequately protected and processed in accordance with this Privacy Policy, and where necessary, we put in place relevant safeguards to ensure the safe processing of your data.
10. Your rights in relation to your Personal Data
You have the right to:

  • Request a copy of the personal data that we keep about you, by making a request in writing to the Data Protection Officer. Our Data Protection Officers details are provided on Page 1 of this policy. You can ask us to provide the data in a commonly used, machine readable format, and where we are able to; transmit this data to another organisation.
  • Contact the Data Protection Officer if you are concerned that any of the information we hold on you is incorrect, to have that data corrected.
  • Contact the Data Protection Officer to ask us to stop processing your data, or withdraw consent where we are relying on consent as the legal basis for any processing of your data.
  • Contact the Data Protection Officer to request that we delete your personal data.
  • To lodge a complaint with the data protection authorities if you believe we have not complied with any applicable data protection law. In the UK, the relevant authority is the Information Commissioners Office, you can find their details at www.ico.org.uk.

11. Changes to this Privacy Policy 
We may update this Privacy Policy from time to time. Updated privacy policies will be updated on the relevant Initial Rewards website, or provided to you at your request.

 

1.3        QUALITY & ENVIRONMENTAL POLICY

It is the policy of  Initial Rewards to maintain a quality system designed to meet the requirements of ISO 9001:2015 & ISO 14001:2015 (or any other standard in line with Annex SL Structure) in pursuit of its primary objectives, the purpose and the context of the organisation.

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  • It is the policy of Initial Rewards to:
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  • give satisfaction to all of our customers and other stakeholders and interested parties whenever possible, meeting and exceeding their expectations;
  • comply with all compliance obligations, codes of practice and all other requirements applicable to our activities including the nature, scale and environmental impacts of its activities, products and services;

 

  • the reduction of hazards, prevention of injury, ill health, protection of the environment, including prevention of pollution, sustainable resource use, climate change mitigation and adaptation, the protection of biodiversity and ecosystems and any other specific commitments which are relevant to the context of the organisation;
  • provide all the resources of equipment, trained and competent staff and any other requirements to enable these objectives to be met;

 

  • ensure that all employees are made aware of their individual obligations in respect of this quality & environmental policy;
  • maintain a management system that will achieve these objectives and seek continual improvement in the effectiveness and performance of our management system based on “risk”.

 

  • This quality & environmental policy provides a framework for setting, monitoring, reviewing and achieving our objectives, programmes and targets.
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  • Customer service is an essential part of the quality & environmental process and to ensure this is fulfilled, all employees receive training to ensure awareness and understanding of quality and environment and its impact on customer service and of the products or service in which we provide.
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  • To ensure the company maintains its awareness for continuous improvement, the quality and environmental system is regularly reviewed by “Top Management” to ensure it remains appropriate and suitable to our business.  The Quality and Environmental System is subject to both internal and external annual audits.
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  • Top Management