Last updated: 21 September 2023

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Introduction

Loyalty Circle is committed to protecting the privacy interests of its websites’ users and customers. In accordance with the principles of Data Protection Legislation this Privacy Policy explains the personal data collected by Loyalty Circle via our website and the purposes for which that information is held.

 

Collection of Personal Data

Website users can access our home page and browse this website without disclosing any personal data. During the course of any visit to our site, the pages you see, along with something called a cookie, are downloaded to your computer. Most, if not all, websites do this, because cookies allow the website publisher to do useful things like find out whether the computer (and probably its user) has visited the site before. This is done on a repeat visit by checking to see, and finding, the cookie left there on the last visit.

 

Any information that is supplied by cookies can help us to provide you with a better service and assists us to analyse the profile of our visitors. For example: if on a previous visit you went to, the about us page, then we might find this out from your cookie and highlight about us information on a second visit.

 

Aggregate information is passively collected by Loyalty Circle to monitor the use of our websites. This does not contain any personal data nor is it linked to personally identifiable information.

 

Any personal data gathered via the website is volunteered by visitors to the public or interactive areas of our websites. Loyalty Circle receives personal data about our website visitors if they send us an email, submit an enquiry or request form online, or complete an online application form.

 

Personal data about the customers of Loyalty Circle is received if they, or their representatives, provide such information within the interactive areas of our websites.

 

The personal data collected by Loyalty Circle via our website may include contact information (such as name, address and telephone number), identity information (such as date of birth and nationality) and invoicing information (such as hours worked and rate of pay). Online applicants for our services are not obliged to submit sensitive information (such as bank details) over the Internet.

 

Loyalty Circle does not request or collect personal data that is not relevant to the provision of our services and/ or related information.

 

Loyalty Circle does not collect supplementary information about the visitors to our websites from other sources such as public records or bodies. We may receive additional information about our customers from their recruitment company (or companies) or client(s).

 

Information about third parties, such as the name of a referring friend or recruitment company, may be collected from individuals who apply to use the services of Loyalty Circle.

 

Use and Protection of Personal Data

Personal data received by Loyalty Circle via our website is used only to supply the individual(s) in question with our services and/ or communicate relevant information about our services as necessary. This may involve the activities of our customer administration, marketing, research and development and website administration teams.

 

Personally identifiable information collected by Loyalty Circle is not used for purposes unrelated to the purpose for which the information was originally collected.

 

Loyalty Circle does not sell, loan or lease personal data to third parties.

 

Personal data is not shared with any parties outside of Loyalty Circle and its sister companies unless there is explicit permission given by the individual concerned.

 

Loyalty Circle reserves the right to treat these obligations of privacy as not applicable when obliged by law.

 

Security and Integrity of Personal Data

Loyalty Circle endeavours to protect the data transmitted from its website from unauthorised access or disclosure; to maintain data accuracy and completeness; and to ensure the appropriate use of information.

 

Security measures – including firewalls, encryption and intrusion detection technology, backup procedures and external audits – are employed by Loyalty Circle to reduce vulnerabilities to security and privacy threats. Unique passwords and usernames are also required to log into the restricted interactive areas of our websites.

 

Some personal data is held and processed by our Internet Service Provider. Such data is only held and processed for and on behalf of Loyalty Circle and under our instruction.

 

All members of staff are subject to strict confidentiality clauses in their contracts of employment. Access to personal or sensitive data is restricted to authorised employees.

 

Nonetheless, due to the inherent nature of the Internet, Loyalty Circle cannot guarantee the privacy of any information provided online and is not responsible for any breach of security.

 

Links On Our Website

The website of Loyalty Circle does not enable visitors to communicate with other visitors or to post information to be accessed by others.

 

Our website does not contain links to third-party ad servers or allow them to place tracking devices on our website.

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Our website may contain links to third-party websites for users’ convenience and information. If a visitor clicks on these links they will move to another website. Loyalty Circle is not responsible for the data policies or procedures, or the content of third party websites linked to our websites.

 

What is a cookie?

When you enter a site your computer will automatically be issued with a cookie. Cookies are text files that identify your computer to our server. Cookies in themselves do not identify the individual user, just the computer used. Many sites do this whenever a user visits their site in order to track traffic flows.

 

Cookies themselves only record those areas of the site that have been visited by the computer in question, and for how long. Users have the opportunity to set their computers to accept all cookies, to notify them when a cookie is issued, or not to receive cookies at any time. The last of these, of course, means that certain personalised services cannot then be provided to that user.

 

Cookies created by this website

This website creates a number of cookies, which are referred to as first party cookies as they are specific to the host site that created them. All the first-party cookies which are created do not store any personal or sensitive information, or anything that makes you personally identifiable to us. They are used for essential functionality such as security when processing form data or for analytics which helps us use anonymous visitor data to gain a better understanding of how people use our website.

 

Analytics

We use Google Analytics, which creates a number of first-party cookies, all prefixed __utm:

 

__utma contains a unique and anonymous identifying ID, which allows us to ensure that subsequent visits to our website are recorded as belonging to the same (unique) visitor. This cookie expires after two years.
__utmb used to establish and continue a unique user session. Each time you request another page from the website the cookie is updated to expire after 30minutes.
__utmc works with __utmb to determine when to create a new session for a website visitor. This is a session cookie and expires when you exit the browser.
__utmz tracks how you found us and is used to calculate traffic and navigation within the website.
__utmv You may also sometimes find this cookie is created which relates to custom reporting segments, a feature which we occasionally use on Google Analytics

 

Full details of the cookies which Google Analytics uses can be found in Cookies & Google Analytics in documentation for Google’s Analytics tracking code. You can also read Google’s Privacy Policy for Google Analytics.

 

We don’t share the data that Google Analytics collects, and we don’t believe that our use of Google Analytics is privacy-intrusive. We use the data that is collected in the following ways:

to report, in aggregate, how our visitors find and use our website;

to understand overall visitor behaviour; and

to inform how we update and improve our website.

 

To opt out of our use of Google Analytics you may wish to consider using the Google Analytics Opt-out Browser Add-on.

 

Cookies created by external services

In addition to our first-party cookies, you may be served one or more of the following third-party cookies during your visit to our website. By using our website we’ll assume that you are happy to receive all cookies on our website, but we have provided information at the top of this page on how you can set your browser to prevent cookies being created.

 

Third party cookies are cookies created by an external service when you use a page on our website. These cookies are specific to the third-party’s domain and accordingly the data held in them can be seen and managed by the third party and not by us. We control whether or not we use the third-party service with our website, and how it is integrated and presented on our website. We do not have control over the cookies themselves. We carefully select 3rd party services to use on our website; ones that are not likely to abuse your privacy according to the terms of their privacy policies.

 

Other cookies

From time to time we may use additional external services on our website which may create cookies on your device. As we add new services or make changes that use cookies, we will update this cookie policy with the details.

 

If you have any concerns about the cookies we create or the way we aim to attain consent from you, please contact us and we’ll be happy to answer your questions.

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Access to Personally Identifiable Information

Under applicable Data Protection Laws, data subjects may have the right to access the personal data held by Loyalty Circle in relation to them, and to request that inaccuracies be amended or updated.

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Individuals who wish to exercise such rights should contact Loyalty Circle. Any requests to access or amend personally identifiable information will be subject to rigorous ‘Know Your Client’ procedures.

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Changes To This Privacy Policy

This Privacy Policy may occasionally be updated. Any changes will be clearly notified on this website and on this policy.

 

Loyalty Circle will seek written consent from data subjects prior to using their personal data in a manner which is different to that stated in our Privacy Policy when their data was received.

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Contact Us

If you have any concerns or comments regarding this Privacy Policy please contact us using our “Contact Us” page.

 

For your protection telephone calls may be recorded and may be monitored.

 

To comply with the Privacy and Electronic Communications Regulations we periodically conduct a Cookie Audit of our website. Our website uses a number of cookies to store data on our visitor’s computers.

 

To find out how to control the cookies that are created on your device please see this page. For more information about managing cookies, please see http://www.aboutcookies.org/.