Privacy Policy

01Who we are

The website deeployalty.io and the Partner Portal are operated by DeepLoyalty OÜ, a company registered in the Republic of Estonia, registry code 16426155, correspondence address Ahtri tn 12, 10151 Tallinn, Estonia (“DEEPLOYALTY”, “we”). We are the controller of the personal data you provide through the website and the portal. Technical support and implementation in Ukraine are provided by our affiliate ТОВ «ДІПЛОЯЛТІ УКРАЇНА» (DeepLoyalty Ukraine LLC, company code 45643050, Dnipro), which processes data solely on our instructions. Customer data of our partners’ loyalty programmes is processed by us as a processor, on the partner’s instructions and under a data processing agreement. That data is covered by the relevant partner’s privacy policy, not by this one. 

02What data we collect

• “Schedule a call” form data: name, phone number, e-mail (optional), company, preferred meeting time and the page from which the request was sent.
• Partner Portal account data: login, business e-mail, role, organisation, sign-in and activity logs.
• Technical data: IP address, browser and device type, time of access — recorded automatically by the hosting server.
• Cookies — see the “Cookies” section.

We do not collect payment data and do not ask you to send sensitive information through the website. The website and portal are intended for business representatives aged 18 or over.

03Why we use it

• to contact you and arrange a meeting;
• to prepare a proposal for your bank or retail chain;
• to provide access to the Partner Portal, keep it secure and maintain an activity log;
• to perform our contract and keep accounting records;
• to protect the website from spam and abuse;
• to analyse website traffic — only with your consent;
• to send you information about our solutions — with your separate consent or, for existing partners, on the basis of legitimate interest, with an opt-out in every message.

Legal bases under the GDPR: steps prior to entering into a contract and performance of a contract (Art. 6(1)(b)); our legitimate interest in the secure operation of the website and in business communication (Art. 6(1)(f)); legal obligations regarding accounting (Art. 6(1)(c)); your consent — for analytics and newsletters (Art. 6(1)(a)). For visitors from Ukraine the Law of Ukraine “On Personal Data Protection” also applies.

04Who we share it with

We do not sell your data and do not share it for third-party advertising. Requests are accessible only to the DEEPLOYALTY and DeepLoyalty Ukraine staff who handle them and to service providers that help us operate: website hosting — NIC.UA (Ukraine); e-mail, calendar, forms and data storage — Google (Alphabet Inc.). They process data only on our instructions. The current list of sub-processors is available at deeployalty.io/sub-processors.

Request and correspondence data is stored on Google servers (EU data region); the website is hosted on NIC.UA servers in Ukraine. Transfers to Google are based on the EU-US Data Privacy Framework and the European Commission’s Standard Contractual Clauses; transfers to Ukraine — to our affiliate for support and to the hosting provider — are based on the Standard Contractual Clauses and additional safeguards.

We may disclose data upon a lawful request from public authorities.

05Cookies

The website uses its own cookies: lang — remembers your chosen language, stored for 1 year; cookie_consent — stores your cookie choice for 12 months; the Partner Portal session cookie.

Analytics cookies (Google Analytics via Google Tag Manager) are set only after you click “Accept” in the consent banner. You may equally click “Reject” — the website works without analytics. You can change your choice at any time via “Cookie settings” in the footer or in your browser settings. 

06How long we keep data

Request data — 24 months after the last contact or until you withdraw consent. Portal accounts — for the term of the agreement and 12 months after it ends. Server logs — 90 days. Contractual and financial documents — 7 years under Estonian accounting legislation.

07Your rights

• to know what data we hold about you and receive a copy;
• to correct inaccurate data or have it deleted;
• to withdraw consent — this does not affect the lawfulness of prior processing;
• to object to processing (including to marketing, at any time) or restrict it;
• to receive your data in a structured format for transfer to another provider;
• to lodge a complaint with the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon, www.aki.ee), the supervisory authority of your EU country, or the Ukrainian Parliament Commissioner for Human Rights. 

To exercise your rights, write to privacy@deeployalty.io. We respond within one month; for complex requests the period may be extended, and we will let you know.

08Security

The website and portal run over a secure HTTPS connection. Access to requests and portal data is limited to authorised staff by role; portal activity is logged. In the event of a personal-data breach we assess the risk and, where the law requires, notify the supervisory authority within 72 hours and you without undue delay.

09Changes to this policy

We may update this policy. The current version is always available on this page; the date of the latest update is shown at the top. Partner Portal users will be notified of material changes by e-mail at least 14 days in advance.

10Contact

DeepLoyalty OÜ, registry code 16426155, Ahtri tn 12, 10151 Tallinn, Estonia, privacy@deeployalty.io.