Privacy Policy

The service is operated by BonusWallet, established in Italy. Our identity and contact details are set out at the end of this page. For everything related to personal data, contact contact@bonuswallet.eu.

Under the General Data Protection Regulation (GDPR) we act in two different roles, and it matters which one applies to you.

• We are the controller for the data of merchants and their team members (the businesses that subscribe to BonusWallet), for prospective merchants we contact, for people who write to us, and for visitors of our website.
• We are the processor for the data of a merchant’s customers, the people who join a loyalty program and add a pass to their wallet. The merchant decides why and how that data is used and is the controller; we process it on the merchant’s instructions, under the data processing terms in our Terms of Service.

If you hold a loyalty pass and have a question about your data, the shop that issued it is your first point of contact. You can always write to us too, and we will help or pass your request on.

When you create an account and set up your loyalty program we process the following data.

• Account: your name, email address and password (stored only as a hash by our authentication provider), the language you use and the times you sign in.
• Business profile: business name, category, country and city, one or more shop addresses with their map coordinates, website, phone number, time zone, currency, brand colours and the logo you upload.
• Setup answers: how you reward regulars today, your goal and your weekly volume, which we use to tailor your setup.
• Team: the names, email addresses and roles of the team members you add, their scanner PIN (stored only as a salted hash), the devices they use the staff scanner from and when they last signed in.
• Plan and billing: the tier, billing cycle and number of locations you choose, subscription status and any invoices we issue.
• Support: the messages you send us through the dashboard or by email.
• Activity and security records: changes to your account and program, an audit trail of sensitive actions, and technical logs such as IP address, browser type and timestamps.

We use this data to provide the service you subscribed to and to bill you (performance of a contract), to keep the platform secure and prevent abuse (our legitimate interest), to answer your requests (contract and legitimate interest), to send you service emails such as sign-in links, PIN codes and staff invitations (contract), and to meet legal obligations such as tax and accounting rules. We do not sell your data.

Our support staff can open your dashboard as you see it in order to help you. Every such access is recorded in an audit log.

You can delete your whole business account yourself from Settings, Profile, Delete account in the dashboard. This erases your business, your team members, your customers and their passes and your uploaded logo, marks your Google Wallet passes as expired, stops updates to passes in Apple Wallet, and removes your login.

When you join a shop’s loyalty program by scanning its QR code or opening its link, the shop collects the following data through BonusWallet, and we process it on the shop’s behalf.

• What you enter: your name, mobile number, email address and birthday, plus the language of your phone and the shop or location you joined at.
• Your loyalty activity: stamps or points collected, rewards unlocked and redeemed, visits, the amount spent when the shop records it, and the segment the program places you in (for example new, regular or at risk).
• Your pass: a unique code, the identifiers Apple or Google assign to the pass, whether it is installed, and, for Apple Wallet, the device registration and push token Apple sends us so the pass can update.
• Messages: which offers and notifications were sent to you, whether they were delivered, and your marketing consent status.
• Email history: previous email addresses you used with the same shop, so your card is not lost when you change address.

The shop uses this data to run its loyalty program and, if you agreed to it when joining, to send you offers and news. The lawful bases are the shop’s and we only act on its instructions. The shop can export its customer list and can ask us to correct or delete your data at any time.

We never collect your location. Your pass carries the shop’s coordinates so that your phone can show it on the lock screen when you are nearby; that decision is made entirely on your device, and nothing about your whereabouts is sent to us or to the shop.

• Visiting our website: our hosting providers keep standard server logs (IP address, browser, requested pages and timestamps) for security and to operate the service. We use IP addresses transiently to limit abusive request rates. We do not run analytics or advertising trackers; see our Cookie Policy.
• Contact form and support: the name, email address and message you send are stored in our database and forwarded to our team by email so we can reply. Legal basis: taking steps at your request before a contract and our legitimate interest in answering you.
• Prospective merchants: we keep business contact details of shops we think could benefit from BonusWallet (business name, category, address, website, phone and email), taken from public sources or entered by our team, to introduce the service. Legal basis: our legitimate interest in business-to-business marketing. You can object at any time and we will stop.
• Error monitoring: when something breaks we receive an error report with technical details about the page or request. See the Cookie Policy for what this involves.

A loyalty pass is a file installed in Apple Wallet or Google Wallet. It shows your first name, your code, your balance and the shop’s branding and news. Apple and Google process the pass under their own privacy policies:

• Apple Wallet: when you add a pass, your iPhone registers with our pass service and gives us a device token. When the shop updates your card we ask Apple’s push service to tell your phone that an update is available; the push contains no content, your phone then fetches the new pass from us.
• Google Wallet: the pass is stored as an object in Google’s Wallet service. When the shop updates your card we update that object through Google’s API and Google notifies your phone.

You can remove a pass from your wallet at any time. When you do, updates stop and the device registration is deleted; the shop keeps your balance so the card can be added back later, unless you ask the shop to delete your data.

We send two kinds of email on behalf of shops: service emails (for example the link to install your pass) and marketing emails (offers, news and automatic messages such as a birthday greeting or a reminder when a reward is close).

• Marketing emails and wallet notifications from a shop are sent only if you agreed to them when you joined its program. Your consent is recorded with your card.
• Every marketing email contains an unsubscribe link and supports one-click unsubscribe in email apps. Unsubscribing withdraws your consent immediately; your loyalty card keeps working.
• If an email permanently bounces or you report it as spam, our email provider tells us and we automatically withdraw marketing consent for that address.
• Wallet notifications are part of the pass itself. To stop them, remove the pass or change the notification settings of your wallet app.

We use a small number of service providers to run BonusWallet. They process data only on our instructions and under contracts that meet GDPR requirements.

We also disclose data when the law requires it, to protect our rights or safety, or, with notice to you, if the business is transferred to a new operator. The shops that use BonusWallet receive the data of their own customers, as described above.

Our database, authentication and file storage are hosted in the European Union (Ireland). Our API runs in the United Kingdom, which the European Commission recognises as providing adequate protection.

Some providers are established in the United States or may access data from there. For those transfers we rely on the EU-US Data Privacy Framework where the provider is certified under it, and otherwise on the European Commission’s Standard Contractual Clauses, together with technical safeguards such as encryption in transit and at rest. You can ask us for a copy of the relevant safeguards.

• Merchant accounts: for as long as your account exists. When you delete your account from the dashboard, your business, team, customers, passes and logo are erased immediately. Invoices and accounting records are kept for 10 years as Italian law requires, and technical logs expire as described below.
• Customer data: for as long as the shop keeps you in its loyalty program. It is erased together with the shop’s account, or earlier if the shop deletes you or you ask for erasure.
• Enquiries, support and prospect records: up to 24 months after our last exchange, unless a contract follows.
• Technical logs and error reports held by our providers: retained for a short period, typically no more than 90 days.
• Our own audit trail of account actions: kept for security purposes. Once an account is deleted, its entries contain no personal data, only technical identifiers.
• Data on your device: see the Cookie Policy for the lifetime of each cookie and storage item.

All traffic is encrypted in transit, and our providers encrypt data at rest. Passwords and staff PINs are stored only as salted hashes. Access to data is restricted by role, enforced at database level, and sensitive actions are recorded in an audit log. No system is perfectly secure; if we learn of a breach affecting you we will inform you and the competent authority as the law requires.

Under the GDPR you can ask to access the personal data we hold about you, to correct it, to erase it, to restrict or object to its processing, and to receive a copy in a portable format. Where processing is based on consent you can withdraw it at any time, without affecting what was done before.

To exercise these rights write to contact@bonuswallet.eu. We may ask you to confirm your identity. We answer within one month, and tell you if we need longer. Merchants can also correct their data in the dashboard, export their customer list and delete their whole account themselves.

If you hold a loyalty pass, the shop that issued it is the controller: ask the shop directly, or write to us and we will pass your request on and assist. You can also remove the pass from your wallet at any time.

You also have the right to lodge a complaint with a supervisory authority, in particular the Italian Garante per la protezione dei dati personali or the authority of the EU country where you live.

BonusWallet is a service for businesses and their adult customers. We do not knowingly collect data from children under 14, or under the age of digital consent that applies where you live. If you believe a child has given us data, contact us and we will delete it.

We update this policy when our service or the law changes. The date at the top shows the current version. For material changes we notify merchants by email or in the dashboard before they take effect.