PRIVACY POLICY
This Privacy Policy is developed and used by TTN Eesti OU ("we" / "Organizer") to regulate the collection, processing, use, transfer and other use of Personal Data of individuals participating in the Loyalty Program ("You" / "Participant"), whose terms are regulated by the Rules of the Loyalty Program, available at the following link: https://plus.priorbank.by/en/topic/rules (the "Loyalty Program Rules"/"Rules").
The Organizer collects and processes Personal Data of the Loyalty Program Participants for the purposes, which are somehow related to the implementation of the Loyalty Program. All details of Personal Data processing are defined by this Privacy Policy and the Rules of the Loyalty Program.
DEFINITIONS
Organizer - TTN Eesti OU, a company registered in accordance with Estonian legislation (address: Estonia, Harju Maakond, Tallinn, F. R. Kreutzwaldі 4-7 office 405, 10120).
Bank - "Priorbank" open joint-stock company, located at: The Republic of Belarus, Minsk, 31A V. Khoruzhey Street, the financial institution-issuer of Visa cards, participating in the Program.
Website means the Loyalty Program platform, which is a set of logically linked hypertext information, designed in the form of separate pages and available on the Internet at Plus.priorbank.by, which contains Participants' Accounts and where the processing of Participants' requests related to the exchange of Points for Awards in accordance with these Rules takes place.
The PriorPlus Loyalty Program (the "Loyalty Program" or the "Program") is a unique system designed to allow Participants to accumulate and exchange Points for Awards on the Website. The Loyalty Program is in effect in the Republic of Belarus.
Partner is a company that allows Loyalty Program Participants to exchange Points for Awards in accordance with the Rules. Participants can see the list of Partners on the Program Website. The Organizer reserves the right to change the list of Partners without prior notice to Participants.
Participant / Participant of the Loyalty Program - an individual who at the moment of registration in the Program has reached the age of 18 years, who is a cardholder, and has provided the Bank with a personal number or number of an identity document.
Card - a Visa bank card issued by the Bank, which allows the Cardholder to make non-cash payments for goods and services, receive cash and participate in the Loyalty Program in accordance with its Rules. In the context of participation in the Loyalty Program, this card is considered to be active if the cardholder has performed transactions using it, for which Points are awarded in accordance with these Rules. The following cards are eligible for participation in the Program: Visa Gold, Visa Gold Credit, Visa Infinite, Visa Platinum, issued by the Bank.
Data Protection Legislation - any and all data protection and privacy legislation, including but not limited to the legislation of the Republic of Belarus, the legislation of the country of registration of the Organizer, including the General Data Protection Regulation (EU) 2016/679 (GDPR) and any legislation and/or regulation that amends or replaces the Data Protection Legislation;
All other capitalized terms in this Privacy Policy shall be interpreted in accordance with the definitions contained in the Loyalty Program Rules.
GENERAL PROVISIONS
All Personal Data that you transmit directly to the Organizer shall be processed on the basis of the consent you have provided to the Organizer in the process of registering you as a Participant of the Loyalty Program. The Organizer may ask you to provide only those Personal Data that are necessary for the Organizer to achieve the objectives defined in this Privacy Policy, in particular for the purposes of the Loyalty Program.
The Organizer respects the right of the Participants of the Loyalty Program to protect the Personal Data processed by the Organizer as a result of your use of this Website, as well as within the framework of your participation in the Loyalty Program, and undertakes to take all reasonable measures necessary to maintain confidentiality and security of such data, including using generally accepted standards of technological and operational protection against the possible loss, improper use, modification or destruction of Personal Data. Taking into account that within the information space there may be a number of specific features and threats, the Organizer, nevertheless, cannot guarantee the absolute protection of the Participants' Personal Data, but will do its best to ensure that the Personal Data is protected as much as possible. Each Participant warrants that all relevant Personal Data provided by the Participant is lawful, accurate and reliable.
PURPOSES OF PERSONAL DATA PROCESSING
For the purposes of registration and participation in the Loyalty Program, for creation of an Account in the Loyalty Program on the Website, as well as for other purposes stipulated by this Privacy Policy, the Organizer may offer you to provide the following Personal Data: full name, date of birth, e-mail address, phone number, personal number of a citizen of the Republic of Belarus, your Card data, and other data that may be necessary to create an Account, in accordance with the Rules of the Loyalty Program. Your Card data may be used by the Organizer for the purpose of determining whether such Card participates in the Loyalty Program or not.
Once you have registered as a Participant, your Personal Information may be processed for purposes of crediting you Points as a Participant, as well as for purposes of canceling and writing off Points from your Account. For such purposes, we may process your Card information, information about the outlets where you paid with your Card, and the transactions you made with your Card. Also, some of your Personal Information may be processed for the purpose of enabling the use of Awards determined under the Loyalty Program in exchange for accumulated Participant Points.
Considering the information above, you are aware that if you do not provide the Personal Information required for registration and participation in the Loyalty Program, you will not be able to register and participate in the Loyalty Program.
You are aware and have no objections to the fact that the contact information you have provided may be used for the purposes of sending you obligatory technical notifications related to the Loyalty Program implementation. Also, your contact information may be used for the purposes of sending you news, information and / or promotional messages of the Loyalty Program, but provided that you yourself give your consent to such mailing when you register for the Loyalty Program. A Participant, at any time during participation in the Loyalty Program, has the right to change the settings for receiving notifications in their Account.
In any case, your Personal Data will be processed only for the purposes of the Loyalty Program, for the purposes specified in the Data Protection Laws, as well as for other purposes specified in this Privacy Policy.
DATA RECEIVED FROM THIRD PARTIES
The Organizer may receive data from the Bank and from Visa Inc. about the transactions, which are carried out with your Card, participating in the Loyalty Program, in order to allow the correct accounting of Points, credited to you within the Loyalty Program. Personal data, which the Organizer receives from third parties, is not processed for purposes not stipulated in this Privacy Policy.
DATA OF MINORS
The Organizer officially declares that it does not collect and does not process Personal Data of persons who are under 18 (eighteen) years old. By providing Personal Data to the Organizer, you guarantee that you are an adult with full legal capacity and capability. If the Organizer determines that the person who has registered for the Loyalty Program is a minor, the Account created by such person and all Personal Data provided by such person will be immediately deleted from the Loyalty Program, without informing such person about the deletion.
DATA TRANSFER
Personal data provided by the Participant to the Organizer, or that which may be obtained by the Organizer from third parties, may be transferred to third parties, the categories of which are defined in this Privacy Policy, solely for the purposes of the Loyalty Program the Participant takes part in.
Personal data may be shared with the following third parties:
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Partners. For the purpose of implementing the Loyalty Program, a Participant's Personal Information may be shared with companies that allow Loyalty Program Participants to exchange Points for Awards, which are available on the Website at the moment of exchanging Points for the corresponding Award, in accordance with the Rules of the Loyalty Program (hereinafter referred to as "Partners"). Participants may see the list of Partners on the Program Website. The Organizer reserves the right to change the list of Partners without prior notice to Participants.
For example, one of the partners in the territory of the Republic of Belarus, is "Reut Experiences" Limited Liability Company (legal address: 223054, Minsk region, Minsk district, Ostroshitskiy Gorodok, 1-3 Lenina street, room 3-1-42; Contacts: Tel: +375(29)6308308, email: li@reut.by).
When interacting with Partners, depending on the Award selected by the Participant, the respective Partner may additionally request or invite the Participant to provide Personal Information of both the Participant and other individuals accompanying the Participant or who, upon the Participant's request, should use the Award. The Organizer is not responsible for the purposes the Partners may additionally require or suggest that the Participant provide Personal Data. However, in order to understand how Personal Data is processed by the Partners, you are strongly advised to review the internal documents of the respective Partners governing the processing and use of Personal Data.
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Partners Providing Travel Services. Should the Participant for the purpose of exchange of accumulated Points, wish to use the Award for Travel Services, certain Personal Data of the Participant will be transferred by the Organizer to the appropriate Partner, which provides services for booking, issuing and selling tickets and other travel services. In particular, Personal Data provided by the Participant to create the Account will be transferred.
Travel Services Partner may ask or request the Participant to provide Personal Data about the Participant or other individuals accompanying the Participant or persons the Participant wishes to use the Award. To understand how Personal Information is processed by a Travel Partner, we strongly encourage to read the respective Travel Partner's privacy policy.
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Bank. In order to implement the Loyalty Program, your Personal Data, which are processed by the Organizer under the Loyalty Program, in particular the data on Points, may be transferred to the Bank-issuer of your Card, which authorizes the cardholder to make cashless payments for goods and services, receive cash and participate in the Loyalty Program in accordance with the Loyalty Program Rules, and receive Points for transactions using the Card on conditions determined by the Bank. All personal data that the Bank may offer you to provide or require from you in the process of communication with him, the Bank collects on its own behalf and within the framework of the purposes determined by the Bank itself. The Organizer has no information about the purposes for which the Bank may additionally request or offer you to provide Personal Data, and, accordingly, shall not bear any responsibility related to such circumstances. In this regard, we strongly recommend you to read the Bank's documents, regulating the procedure of processing and use of Personal Data.
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Assignee. In the event the Organizer decides to sell or transfer all or part of its business or assets the Organizer shall have the right to transfer any Personal Data held and processed by the Organizer to its assignee. In the event of such sale or transfer, Organizer will use its reasonable efforts to ensure that the assignee has documentation containing the same provisions as this Privacy Policy. However, the Organizer will attempt to obtain assurances from the assignee that the Personal Data transferred to it under the Loyalty Program is used solely for the purposes set forth in this Privacy Policy.
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State Authorities. The Organizer is entitled to transfer your personal data to state authorities, at their legal request, including cases when it is necessary for taxation purposes, accounting, as well as for the purposes of maintaining and submitting tax and statistical reports.
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Contractors. The Organizer may transfer Personal Data provided by you, or collected by the Organizer during the Loyalty Program, to individuals who act and process Personal Data on behalf of or at the direction of the Organizer. For example, these may be companies that provide technical support for the Website or provide services for organizing the mailing list of the Loyalty Program participants. It should be noted that processing of Personal Data by such third parties is subject to this Privacy Policy and for the purposes defined solely in this Privacy Policy.
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Visa Inc. The Organizer may transfer some statistical non-identifying information to Visa Inc., namely, the Organizer must provide Visa Inc. with Loyalty Program reports describing the number of Loyalty Program Participants and the number of Points accumulated and used in the Loyalty Program by all Loyalty Program Participants collectively. Therefore, we may use your Personal Data to generate reports for Visa Inc.; however, it should be emphasized that we do not share any Customer Personal Data or other identifying information with Visa Inc.
In the course of processing Personal Data, the Organizer may transfer your Personal Data to third parties located in third countries. For example, it may do so for the purpose of storing your Personal Data on servers located in the United States or the European Union. We do not transfer your Personal Data to third countries without your prior consent, which is provided by you during the registration process for the Loyalty Program.
PARTICIPANT RIGHTS
The Organizer respects the rights of each Participant who takes part in the Loyalty Program, and therefore takes all necessary measures to exercise the rights of such Participants. You, at any convenient moment, can obtain information about the Personal Data processed in the framework of the Loyalty Program, in particular those stored in your account, by sending us a request in the manner determined by this Privacy Policy.
You have the right to send the Organizer a request to delete your Personal Data, which are processed by the Organizer within the Loyalty Program, with the words "Please delete all my data. The Organizer undertakes to delete all your Personal Data, upon your request, as soon as reasonably possible. At the same time, you are aware that your request to delete Personal Data will be considered as your voluntary will to terminate your participation in the Loyalty Program.
You have the right to send the Organizer a request to suspend the processing of your Personal Data with the words "Please suspend the processing of my Personal Data". The Participant, when submitting the request, has the right to specify the purposes for which the suspension is necessary, as well as the period of suspension. The Organizer undertakes to suspend the processing of the Personal Data identified by you, at your request, as soon as reasonably possible. At the same time, you understand that receiving a request to suspend the processing of Personal Data, both for certain purposes and in general, is grounds for terminating your further participation in the Loyalty Program.
If the Participant becomes aware that his/her Personal Data, which is processed within the Loyalty Program, is incomplete or unreliable, the Participant shall have the right to make a motivated request to the Organizer to change his/her Personal Data. The Organizer undertakes to correct all Personal Data of the Participant, based on the data to be provided by the respective Participant.
Legislation on data protection may provide for other rights, which the Participant may exercise in the process of implementing the Loyalty Program.
RETENTION PERIOD AND DELETION OF DATA
Personal data provided by the Participant to the Organizer to participate in the Loyalty Program, as well as Personal data collected by the Organizer during the Loyalty Program, shall be retained for the duration of your participation in the Loyalty Program. Upon termination of your participation in the Loyalty Program, the Organizer irrevocably deletes the Personal Data provided by you.
It should be noted that the Organizer may process some Personal Data provided by the Participant to the Organizer, when it is required to implement the obligations under the legislation of the country of registration of the Organizer, also the legislation of the Republic of Belarus, but no more than 5 (five) years from the date of termination of the Participant's involvement in the Loyalty Program. For example, this may apply to cases where the Organizer may use Personal Data for filing, execution or defense against claims or suits, within the general limitation period, or when it is necessary for tax purposes, accounting, as well as for the purposes of submission of tax and statistical reports.
PERSONAL DATA PROTECTION
The Organizer, taking into account the latest developments, costs of their development and implementation, context, volume, purposes of Personal Data processing, as well as risks to the fundamental rights and freedoms of individuals, shall take all necessary organizational and technical measures to ensure an adequate level of protection of Personal Data. The Organizer, where possible, shall apply technical means for data encryption in order to prevent access to data by unauthorized persons, leakage of Personal Data, unauthorized intrusion into the relevant databases or to prevent alteration and/or distortion of Personal Data, or use in any unlawful way. The Organizer shall make every effort to ensure the confidentiality, availability, security and flexibility of all information systems within which Personal Data is stored or processed. At the same time, the Organizer guarantees the possibility to restore prompt access to the availability of Personal Data in the event of any physical or technical incident. The Organizer shall ensure continuous monitoring and evaluation of the level of adherence to the adopted organizational and technical measures, in accordance with the requirements necessary to ensure the security of personal data, in particular in the context of current threats. Among other things, the Organizer, in order to organize the maximum protection of personal data, has developed internal documents, procedures and regulations through which the processing and security of Personal Data is regulated.
The Organizer takes the most reasonable approach to the issue of providing access to Personal Data to its employees, as well as to all other persons who in one way or another may participate in the Loyalty Program. All employees and persons involved in the processing of Personal Data shall have an obligation to the Organizer to observe strict confidentiality with respect to Personal Data processed under the Loyalty Program.
AUTOMATIC COLLECTION OF PERSONAL DATA
In the process of the Loyalty Program implementation, the Organizer can collect certain information by automatic means, such as cookies and system files. Personal data, which can be collected automatically, is used by the Organizer to improve the operation of the Website, implementation of the Loyalty program, as well as for timely and operative providing information about the Loyalty program to the Participants.
Use of cookies. Cookies are information in the form of text or binary data obtained from the Website on a web server, which is stored on a browser, and which is used by the Participant during the use of the Website. The use of cookies, for example, helps Organizer determine whether and when a Participant has previously visited the Website. The information that is collected through cookies also allows the Organizer to make offers regarding new Awards that can be exchanged by the Participant for the accumulated Points.
In general, the following types of cookies can be used:
• mandatory cookies;
• statistical cookies;
• marketing cookies.
Mandatory cookies help ensure proper and smooth operation of the Website. The use of mandatory cookies also allows Participants to take part in the Loyalty Program properly, such as earning and exchanging Points. The use of cookies primarily enables Participants to make appropriate use of the Website.
Cookies may also be used for statistics and analysis purposes, which allows us to find out how many users visited the Website, as well as the relevant pages of the Website that those users were interested in. This helps to understand and improve the Website, as well as to understand the failings of the Website that need to be corrected immediately in order to ensure proper implementation of the Loyalty Program.
Marketing cookies provide an opportunity to understand Participant preferences, including those regarding Awards offered on the Website, and to select the most relevant information that may be of interest to Participants as part of the Loyalty Program and that may be forwarded to Participants.
If you do not want cookies containing your Personal Data to be used by the Organizer, you may use the functionality of the browser you use to visit the Website and set appropriate cookie management options. For example, you can set up and provide cookie management on the applicable browser by clicking on the following links:
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Internet Explorer |
https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies |
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Firefox |
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Google Chrome; |
http://support.google.com/chrome/bin/answer.py?hl=en&answer=95647 |
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Opera |
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Safari |
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Safari iOS (iPhone, iPad, iPod touch) |
Using system files. While using the Website, the Organizer may also automatically collect certain log files, such as the IP address, browser type, links/pages and URLs, number of clicks and interactions with the Website, domain name, landing pages/content, revised pages/content, device identifier and its location. IP address should be understood to mean the specific identifier that certain electronic devices use to identify and communicate with each other on the Internet. When a Participant visits the Website, the Organizer is able to collect information about the IP address of the device that the Participant uses to connect to the Internet. In combination with other data, the information contained in the system files helps the Organizer know which pages are most appealing to our visitors. System files also help the Organizer to ensure the proper implementation of the Loyalty Program and the functioning of the Website.
LINKS TO OTHER WEB RESOURCES
The Organizer, ensuring the proper implementation of the Loyalty Program, can place links to other web resources on the Website, functioning independently from the Website. However, the web resources the Website is linked to are not managed by the Organizer, but by third parties, and, therefore, the Organizer is not responsible for their functioning. The Organizer is not responsible for the content of these web resources, any goods or services that may be offered through these web resources, or any other use of them. These web resources may have their own documents governing their activities and how they handle the personal data of the users of the respective web resources. We strongly recommend that you read such documents before using such web resources.
PROCEDURES FOR SUBMITTING COMPLAINTS AND REQUESTS
All requests regarding realization of Participant's rights, as well as all complaints regarding the processing of Personal Data by the Organizer under the Loyalty Program can be sent to the following e-mail address: privacy.eesti@loyalty.services.
CHANGES
The Promoter, at its sole discretion, may, from time to time, make changes to this Privacy Policy by publishing the changes on the Website. Changes to this Privacy Policy become effective on the date they are published on the Website. Each Participant agrees to independently and regularly review updates to this Privacy Policy. You agree that by continuing participation in the Loyalty Program and by using the Website in the future, you accept all changes to this Privacy Policy. If you do not agree to the changes in this Privacy Policy, you must stop using the Website and terminate your participation in the Loyalty Program by deleting your Account.