The use by Webloyalty of cookies and other trackers on third-party websites

Webloyalty may use cookies or other tracking devices ("Technologies") on certain third-party websites in UK and Ireland for analytical and/or marketing purposes. The purpose of this page is to explain the commitments we make to ensure that these Technologies are systematically used in compliance with your rights and the applicable regulations (in particular the General Data Protection Regulation (“GDPR”) and all applicable national and international laws, regulations and other standards applicable to the processing of electronic communications data, the use of tracking technologies such as cookies and direct marketing (commonly known as "e-Privacy" rules).

We first ensure when designing these Technologies:

- that the use of personal data within these Technologies ("Data") is limited as much as possible, in application of the principles of Privacy by Design & Default of the GDPR;

- that the sensitivity of the Data collected and/or used is low, or reduced, if necessary by transforming the Data into pseudonymised data (using for example hashed algorithms such as SHA-256);

- that these Technologies and their operating environment offer adequate technical and organisational guarantees, in particular:

• by protecting the Data at rest in our databases and/or servers through encryption, using extremely robust algorithms (such as AES-256);
• by also protecting the Data when it is in transit by using encrypted transfer protocols such as (TLS 1.2);
• by limiting access to Data in our organisation to only those persons who would need it in the context of the use of these Technologies due to their role in our organisation (mainly our IT, analysts and marketing teams);
• by protecting the Data in our systems, through the implementation of adequate technical and organisational measures (including firewalls), to prevent access to the Data by unauthorised third parties.

- that the Data collected in the context of the use of these Technologies will be kept only for the length of time necessary for the purposes pursued, and that it will then be deleted and/or anonymised;

- and overall that these Technologies are built at the stage of their conception taking into account the regulations that apply to them.

In addition, before implementing our Technologies on third-party websites, we inform the third-party of the implications (including with respect to Data and compliance with applicable regulations), interests of the parties (of them, you, and us) and purposes of such Technologies, and seek their consent before using them on their websites. We also work with our partners to ensure that the legal requirements for using our Technologies on their websites are met, including:

• that appropriate information relating to these Technologies, in particular in terms of the Data collected/used, the purpose(s) and the life span of the tracker, appears in the collection platform of our partner’s sites (and, where applicable, also in their privacy/cookies policy), so that you can decide in full knowledge of the facts on their website(s) to accept or refuse the use of our Technologies on these sites on which you are browsing;
• that their categorisation in the collection platforms of our partner’s sites is consistent with the purpose(s) we are pursuing, and that appropriate consent is sought under e-Privacy rules before our Technologies are activated on those websites;
• that our partners maintain a record of consent given and/or withdrawn for the use of our Technologies on their website(s).

If you have any concerns about your Data in the context of the use of our Technologies on sites intended for the UK and Irish public or if you have any questions about this page, please send an email to our Data Protection Officer at dpd@webloyalty.fr or 124 rue Réaumur 75002 Paris (France) and registered in the Paris Trade and Companies Register under number 499 925 956.

If you are not happy with the response you receive or believe your data has not been used in accordance with the regulations in force, you may lodge a complaint with the UK data protection authority, the Information Commissioners Office (ICO), if you are resident in the UK, or the Irish data protection authority, the Data Protection Commission (DPC) if you are resident in Ireland.

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