Draft: pending review
Privacy notice
Last updated
NAND Loyalty is a digital loyalty card that local businesses offer their customers. This notice explains in plain language what information the service collects, why, who can see it, and the choices you have. It covers customers who use a card and the business teams who use the business console.
NAND Loyalty is operated by [[OWNER: legal name]] (“we” in this notice).
What we collect
If you use a loyalty card:
- Your phone number. You sign in with it, and the businesses you join use it to recognize you.
- Your first name, only if you choose to give one. You can change it on Your details.
- Which businesses’ cards you joined, and when.
- What happens on each card: your visits and stamps (when, and at which of the business’s locations), the rewards you earn and use, rewards that expire, and any change the business’s staff make to your card, with the reason they picked.
- Your text-offer choices for each business: whether you said yes or no, when, how (for example on the join form, with the switch on your card, or by replying STOP), and which version of the wording you were shown.
- A record of the offers and reward texts sent to you and whether they were delivered. The record doesn’t include the message text or your phone number.
- Sign-in codes, stored only in scrambled form. They expire after 5 minutes.
- Security information: a shortened IP address (with its last part removed, for example 203.0.113.0) and your browser’s name, kept with each sign-in and in our security logs of important actions; and counts of recent requests per phone number and per IP address, used to block abuse.
We don’t ask customers for an email address, a birthday or a home address, and we don’t collect your phone’s location. A stamp records which of the business’s locations it happened at, not where you are.
If you use the business console:
- Your phone number, which you sign in with and are invited by, your role at the business, and whether you accepted the invitation.
- A record of important actions you take, such as changing the loyalty card, changing a customer’s stamps or rewards, sending a campaign or changing the team, with the time.
- The business details your team enters: the business name, colours, locations and their addresses, contact details, and a list of blocked phone numbers (for example employees’ numbers, which can’t join the card or collect stamps).
Why we use it
- To run your loyalty card: recognize you at each business, add your stamps and keep track of your rewards.
- To sign you in with a code sent by text.
- To send the text offers you agreed to and the reward texts a business has turned on, and to stop them when you ask.
- To prove consent: Canada’s anti-spam law (CASL) requires a business to be able to show when and how you agreed to its offers.
- To prevent abuse, such as too many stamps or sign-in attempts, and to keep the service and your account secure.
- To show each business totals for its own card, such as visits and rewards used. These totals don’t include anyone’s name or phone number.
We don’t show ads, and we don’t use advertising or tracking tools.
Who sees your information
- Each business you join sees your phone number (in full for its owners, admins and managers; only the last 4 digits for its other staff), your first name, and what happened on its card: your visits, stamps, rewards and your text-offer choice for that business.
- A business never sees your cards or your activity at other businesses.
- Counter screens, where staff approve stamps and rewards, show only your first name and the last 4 digits of your number. Analysts, a reporting-only role, see totals, not individual customers.
- Your phone number is shown to you on Your details. Other customers never see it.
- On a business’s team, its owners, admins and managers see each team member’s phone number and role.
- A business’s name and location appear on its card. Its mailing address and contact details appear in its request to send you offers and on the page the link in its texts opens.
Our service providers process information on our behalf, only to run the service: Neon (our database), Vercel (hosting for the website and its servers), Twilio (sending and receiving text messages, so it receives your phone number and the content of each text) and Sentry (reports of errors in our own software; we send it technical details only, never your phone number, name, address or IP address).
Our providers store and process information in the United States. [[OWNER: confirm data locations]]
Text messages
- Sign-in codes come from one number. Offers and reward texts come from another, so replying STOP to an offer never stops your sign-in codes.
- A business texts you offers only if you ticked the box to say yes to that business. Joining a card never signs you up.
- Offers are sent only between 9 a.m. and 9 p.m. in the business’s time zone. Each one starts with the business’s name and ends with an “Info & opt out” link. The link stops that business’s offers in one tap, without signing in.
- You can also turn a business’s offers off at any time with the Text offers switch on your card.
- Replying STOP to an offer or a reward text stops text offers from every business on NAND Loyalty. Our text provider also stops sending you any texts from that number, including reward texts, until you reply START. Replying START doesn’t turn offers back on.
- “Your reward is ready” texts are sent when a business has them turned on (they are on unless the business turns them off), at most one per business per day. The link in a reward text stops that business’s reward texts.
How long we keep it
- Your card information: while you have an active card, plus 2 years after your last activity, unless you ask us to delete it sooner.
- Shortened IP addresses and browser details in sign-in and security records: cleared after 12 months.
- Consent records: kept as long as needed to prove consent, as CASL requires, even after you withdraw it.
Your choices and rights
- Withdraw consent: turn text offers off on your card, use the link in any offer, or reply STOP. Withdrawals take effect right away.
- Access: My cards shows your cards, activity and rewards. To get a copy of all the information we hold about you, contact us.
- Correction: change your first name on Your details. For a mistake on your card, ask the business or contact us. Card history isn’t rewritten: a correction is added as a new entry, so the record stays accurate.
- Deletion: to ask us to delete your account and information, contact us.
If you aren’t satisfied with our answer, you can complain to the Office of the Privacy Commissioner of Canada.
Contact us
Questions and requests about your information: [[OWNER: privacy contact]]
Company: [[OWNER: legal name]]
Changes to this notice
When we change how we handle information, we update this notice and the “Last updated” date at the top of this page.