This is a courtesy translation. The legally binding version of this document is the Armenian one. In the event of any discrepancy between this English text and the Armenian original, the Armenian version prevails. Read the Armenian version.
1. DATA CONTROLLER
The controller of your personal data in connection with the use of the loyalty programme service operated under the trade name loyalita (hereinafter, the “Service”) is:
Gurin Dmitrii IE
(individual entrepreneur registered under the laws of the Republic of Armenia)
ՀՎՀՀ (TIN): 1708821015
Address: Yerevan, Republic of Armenia
Website: https://loyalita.am
Contact email: hello@loyalita.am
Phone: +374 55 117479
2. SCOPE
This Policy applies to natural persons who register and use the Service in order to take part in one or more loyalty programmes run by businesses (hereinafter, the “Users”). The Service is not directed at minors.
3. WHO SETS THE TERMS OF THE LOYALTY PROGRAMMES
Each business (restaurant, café or other establishment) that uses the Service (hereinafter, the “Business”) independently sets the terms of its loyalty programme: the number of stamps required for a reward, the discount percentage, the point accrual rules, tiers, restrictions and the validity of rewards. We provide the technical platform, but we are not a party to the sales contract between you and the Business.
4. PERSONAL DATA WE PROCESS
4.1. Registration and contact data
- First name and surname (or alias).
- Phone number.
- Email address.
- Language, country or city.
4.2. Data related to loyalty programmes
- Programmes and Businesses you have joined.
- Stamps, points, discounts and other rewards accrued or redeemed.
- Loyalty transaction history (date, time, Business, type of transaction).
4.3. Technical data and online identifiers
- IP address, device identifiers, operating system, app version, cookie identifiers. Under the law of the Republic of Armenia these are personal data.
- Access and usage data (date, time, sections viewed, actions carried out).
- Approximate geolocation data — only where you allow it in your device settings.
4.4. Communication and marketing preferences
- Your choice as to whether or not to receive commercial messages (email, SMS, push).
5. PURPOSES AND LEGAL BASES FOR PROCESSING
We process your personal data under the Law of the Republic of Armenia on the Protection of Personal Data, for the following purposes:
- Managing your registration and account — legal basis: performance of a contract.
- Applying the terms of the Businesses' programmes (calculating stamps, points and rewards) — legal basis: performance of a contract.
- Notifications necessary for the operation of the Service (registration confirmation, account security, expiry of rewards) — legal basis: performance of a contract.
- Commercial messages — legal basis: your separate consent, which you may withdraw at any time.
- Analysis and improvement of the Service in aggregated or pseudonymised form — legal basis: our legitimate interest.
- Fraud prevention and security — legal basis: our legitimate interest and obligations established by law.
Consent is given in writing or in an electronic form that allows the fact of it being given to be verified afterwards. We record the date, time and version of the document you agreed to. Withdrawing consent does not affect the lawfulness of processing carried out beforehand.
6. RECIPIENTS OF THE DATA
6.1. Businesses
When you join a Business's loyalty programme, we pass that Business the data needed to run the programme: your identifier, basic contact details and information about your visits and transactions at that Business. Each Business acts as an independent controller for the purposes it defines.
6.2. Service providers
We may give access to third parties who supply services necessary for the operation of the Service: hosting and technical maintenance, email, SMS and push notification providers, analytics tools and payment systems. They act solely on our instructions and under the relevant contracts.
7. CROSS-BORDER TRANSFERS
Some of our providers may be located outside the Republic of Armenia. In such cases, transfers are made only to countries recognised by the Personal Data Protection Agency as providing an adequate level of protection, or on the basis of standard contractual clauses approved by the Agency or other mechanisms provided for by law. For further information write to hello@loyalita.am.
8. RETENTION PERIODS
- Registration and account data — for as long as your account is active.
- Loyalty programme data — during your participation and for the applicable limitation period.
- Data for commercial messages — until consent is withdrawn.
- Technical logs — for the period necessary for security and maintenance.
- Data required by law (accounting, tax) — for the periods established by law.
9. YOUR RIGHTS
Under the Law of the Republic of Armenia on the Protection of Personal Data you have the right to:
- obtain information about the processing of your data and access it;
- request rectification of inaccurate or incomplete data;
- request erasure or blocking of data in the cases provided for by law;
- object to processing, including the receipt of commercial messages;
- withdraw consent at any time.
To exercise these rights, write to hello@loyalita.am or send a letter to Yerevan, Republic of Armenia, marked “Personal data”.
If you consider that your rights have been infringed, you may lodge a complaint with the Personal Data Protection Agency of the Ministry of Justice of the Republic of Armenia.
To exercise rights in relation to a specific Business's conduct, you must contact that Business directly as an independent controller.
10. SECURITY
We apply appropriate technical and organisational measures to protect data against destruction, loss, alteration and unauthorised access. In the event of a personal data breach that may pose a risk to your rights, we notify the Personal Data Protection Agency within 72 hours of becoming aware of it and inform you where necessary.
11. AUTOMATED DECISIONS
We may carry out simple segmentation (for example, by visit frequency) in order to show you more relevant information. We do not take decisions based solely on automated processing that produce legal or similarly significant effects for you. Should such a decision be taken, we will explain the logic involved and provide for human review.
12. CHANGES
We may update this Policy to reflect legislative, technical or business changes. The current version is always available in the Service, stating the date of the last update. We will inform you of significant changes in a visible manner.
Related documents: Privacy (users) · Terms and Conditions · Privacy (business) · Public Offer · Cookie Policy