1. What information will we use?
By participating in the Punti Verdi programme in the United Kingdom (the “Programme”), we will collect and use information about you and any additional collectors within your account ("your information"). This information includes your registration details, information about the use of your Programme account, shopping purchases and other information that you give us or that we collect, including about your use of internet connected devices.
2. How will your information be used?
We, companies participating in the Programme, and other organisations and service providers that we work with or partner with from time to time (as described in more detail in the 'Who will we share your information with?' section below), may use your information to:
- operate the Programme, for example to enable you to collect and redeem Points, provide other programme-related services and ensure that the applicable terms and conditions are observed;
- analyse how you use the Programme and our marketing channels such as our website and our app;
- assess the effectiveness of our marketing activities and the marketing activities we carry out on behalf of companies participating in the Programme;
- identify the devices you use to access the internet and when interacting with the Programme, and link such devices to you – for example your use of the Programme App on your tablet or mobile, and your use of partner Apps or websites which may link to the Programme;
- understand your behaviour based on the information available to us and to send or show you information, offers, surveys and online advertisements for the products or services which we believe are most likely to interest you.
One of the benefits of being part of the Programme is that we can show or send you offers or adverts that are relevant to you by various channels, including online. We decide what offers and adverts to show or send you using an automated decision making process which takes into account:
- the information you have provided to us as part of your participation in the Programme, including, amongst other things, purchases you have made when using your Programme account,
3. When we can use your information
We collect and use your information in the following situations:
- where our use of your information is necessary for us to perform the contract or contracts that we have with you. These contracts include the terms and conditions of our app, the Collector Rules, and any other agreements which we enter into with you from time to time;
- where our use of your information is for the purposes of our legitimate interests or the legitimate interests of companies participating in the Programme and we have made sure that your information, and your rights in relation to that information, are protected. For example, we may rely on this legal basis if we and/or the companies participating in the Programme use your information to understand and improve our (or their) products or services, to help find out what information, products and services are most likely to interest you, to send or show you information, offers, and online advertisements for these products or services, or to ensure that the Programme and its related services are delivered and used in accordance with the law and the terms and conditions that apply to them, including the Collector Rules;
- where we believe it is necessary to use your information to comply with a legal obligation to which we are subject; and
- where we have your consent. We will rely on your consent to:
- collect device identifiers from your devices, provided you have given consent to the App provider, your mobile phone provider, or via the device settings;
- use information about your location that we get from these technologies and the app to show you advertisements and offers which we think you may be interested in; and
- use your information for marketing to you by email, text message and other methods of electronic communication from time to time in accordance with your data choices.
Where we rely on consent to use your information, you have the right to withdraw that consent at any time.
4. The period for which we will keep your information
We will keep your information for as long as is necessary for us to fulfil the purposes that we describe in this policy. As a general rule, however, we will keep:
- the information you provide when you register with the Programme, together with any updates you make to that information, for the duration of your membership with the Programme;
- the information that we collect about you and your use of the Programme (including, for example, where you earn and redeem Points) for the duration of your membership with the Programme or, in some cases less time, based on the reason for holding such information and whether such information remains current are held for no longer than 12 months
If you do not earn or redeem Points for a period of 12 months we may in accordance with the Collector Rules, deem you to be inactive and suspend or close your account. Your information will be kept and securely stored anonymously for a further period of 12 months after you are deemed to be inactive, following which we will ensure that your personal data is no longer retained.
5. Who will we share your information with?
Your information will not be shared with any 3rd parties
We promise we'll never share your details with anyone else
6. Your choices and rights
You have a number of rights in relation to your information, and can make a number of choices about how we collect and use it. For example, you can decide not to receive marketing material from us, tell us how you want to receive marketing communications from us, and object to some of the ways in which we use your information.
Note that some of the choices or changes you make may impact our ability to maintain your account or provide you with Points or Rewards (for which you can exchange Points collected), and your account may need to be closed. We will notify you if such action is necessary.
You can log into the “admin” section of our website to:
- access and update the contact and personal details we hold about you;
- view your Points statement and Programme account transaction history;
- opt-out of receiving marketing communications to your device and/or by telephone including calls to your mobile or other number, SMS, and email from us;
- opt-out of receiving postal marketing communications from us and companies participating in the Programme;
8. Who we are
We are Punti Verdi Limited, a company registered in England under number 11271727. Our registered office is at 14–15 Lower Grosvenor Place | London SW1W 0EX