1. Roles
The Venue is the controller of its members' personal data. StoreWallet is the processor. Apple and Google are independent controllers of their Wallet services.
2. Subject matter, nature and purpose
Operating the Venue's loyalty programme: issuing and updating Wallet passes, recording visits and rewards, sending messages the Venue instructs, showing the Venue its dashboard, and honouring members' rights requests. Duration: the life of the Venue's account plus the deletion period in section 10.
3. Data and data subjects
Members of the Venue's programme. Data: first name, email, optional phone and birthday, language, pass identifiers and device push tokens, visits, stamps and rewards, offers, consent records, source stand, message log, private messages sent from the review page, and the country of the venue where they joined. No special category data; no children under 16.
4. Instructions
We process only on your documented instructions: these terms, the dashboard settings you choose (fields collected, retention period, messages sent, erasures), and written instructions by email from an owner account. We will tell you if an instruction appears to break the law.
5. Confidentiality
Our staff who may access member data are bound by confidentiality and may access it only through a logged step-up for support you have requested or for security.
6. Security
The measures in the security annex, which we keep current and will not reduce without 30 days' notice.
7. Sub-processors
You authorise the sub-processors on the sub-processors page. We give 30 days' notice by email and on that page before adding or replacing one. You may object on reasonable grounds; if we cannot resolve the objection you may terminate the affected service for a prorated refund.
8. Assistance
Members' rights are handled largely by the self-service links on the card. For anything else we assist within the time you need to meet the statutory one month. We assist with data protection impact assessments and regulator consultations where our processing is involved.
9. Breach notification
We notify you without undue delay and in any case within 48 hours of becoming aware of a personal data breach affecting your members, with what we know, what we are doing, and what we recommend you do, and we update you as we learn more.
10. Deletion and return
You can export all member data at any time. After termination you have 60 days to export; we then delete member data within 30 days except where law requires retention, and confirm in writing.
11. Audits
We provide our security documentation, the summary of our latest penetration test, and our sub-processors' certifications on request. An on-site audit is available once a year for reasonable cause, on 30 days' notice, at your cost, under confidentiality.
12. International transfers
Data is stored in the European Union (Frankfurt, Germany). Any transfer outside the UK and the EEA is covered by the UK International Data Transfer Addendum to the EU Standard Contractual Clauses or an adequacy decision. For EU venues we enter into the EU Standard Contractual Clauses.
13. Liability and law
As in the terms of service. Governed by the law of England and Wales.