Privacy statement

1. Introduction

Loyyo (“we,” “us,” or “our”) provides business-to-business (B2B) solutions for customer engagement, loyalty, and payment-linked analytics. We have four main products:

• Data product
• Tap, Earn, Burn App (Android) 
• Wallet pass and server
• Loyalty web app

This privacy policy explains how we collect, use, and protect data related to these products. We operate in accordance with all relevant privacy legislation, including the General Data Protection Regulation (GDPR). We also hold an ISO 27001 certification, demonstrating our commitment to strong information security practices. Further information on our controls can be found in our Trust Center (https://trust.loyyo.com).

2. Scope and audience

Scope: This policy covers data processed by Loyyo across its four products.

B2B nature: We primarily serve merchants, who typically act as data controllers for their customers’ personal data. Loyyo usually acts as a data processor or sub-processor, following the merchant’s instructions. In cases where we independently determine how and why data is processed (for example, when providing a direct loyalty program), we may act as a (joint) controller.

Merchants’ privacy statements: Because our products are used by merchants to serve their own customers, those merchants must have or update their own privacy notices. If you are a customer of a merchant using Loyyo’s technology, please review the merchant’s privacy policy to learn how your personal data is handled.

3. Our products and data processing

3.1 Data product

What it is: Our data product relies on anonymized or pseudonymized payment data (payment tokens) to provide merchants with analytics and real-time updates after a transaction.. Examples include measuring repeat purchases and calculating average spending.

Data categories

• Payment tokens generated by payment providers (pseudonymized identifiers)
• Transaction metrics such as timestamps, amounts, or frequency of visits
• No direct personal identifiers, unless a user profile is later linked (see section 3.3)

Pseudonymized vs. anonymized

• Tokens provided by payment providers are generally not re-identifiable by Loyyo or the merchant. Only the payment provider has the “key” to connect a token to a real person, and that information is never shared with Loyyo.
• As a result, the data we handle is effectively anonymized from our perspective unless it becomes linked to a specific user account.

Optional consent-based link

If an end user later registers for a loyalty program (see section 3.3) and consents to linking the token, it can become personal data because it is then tied to identifiable information.

3.2 Tap, Earn & Burn app

Tap, Earn & Burn is an Android point-of-sale app for merchants. End customers do not log in and do not create an account in this app. Merchant staff log in with the merchant’s Loyyo credentials. Those credentials and the Mollie keys are stored encrypted on the device.

After a Mollie Tap payment, the app processes the amount, payment status, a pseudonymous payment token (card fingerprint), and limited card details from Mollie, such as the last digits, card brand, and country. The full card number is not stored. Staff may enter a phone number to register the customer as a member. That number is sent to Loyyo with the payment. Registration can also happen through a QR code that opens the member web app (section 3.4)

If the payment token is already linked to a member, the app shows that member’s profile, including name, email, phone number, points, and rewards. If the customer is not yet a member, they are not recognized until they register and consent to linking the token.

The camera is used only to scan a QR code or barcode, for terminal setup or a member code from the member web app (section 3.4) or from the wallet pass of a member (section 3.3).

3.3 Wallet pass and wallet server

What it is: Our wallet pass solution allows merchants to create and manage digital passes (for example, loyalty cards or coupons) that customers can store in their mobile wallets (Apple Wallet, Google Wallet). Loyyo also provides a server for enrolling users, updating pass details, and distributing passes.

Data categories

• Pass information (loyalty points, membership IDs, expiration dates)
• Optional user data if included on the pass (for example, name, email, or phone number)
• Enrollment or sign-up forms where end users may enter personal information

When personal data is collected

• If the merchant’s pass includes personal data fields, we process that data on behalf of the merchant.
• In most cases, the merchant is the data controller; Loyyo acts as the data processor. We may store or synchronize this pass data in our server as needed to keep the pass current.

3.4 Loyalty web app

What it is: The loyalty web app provides end users with a “my account” environment for their loyalty program. Typical features include:

• Viewing and redeeming loyalty points and rewards
• Checking membership status or level
• Downloading a loyalty pass (section 3.2)
• Accessing purchase history or frequently asked questions

Users log in via an external account (single sign-on) or with a secure username and password that we or our partner provide.

Data categories

• Login details (email, username, identity provider data)
• Profile information (name, contact details, loyalty tier)
• Transaction or loyalty history (points, rewards, past purchases)
• Technical data (logs, session IDs, IP addresses for security)

Payment-linked integration

• The loyalty web app can integrate with our data product so that a user’s payment token is linked to their loyalty profile. In such cases, the token becomes personal data because it is tied to an identifiable account. This only is the case when the customer (member) has given consent.
• After a Tap, Earn & Burn payment, the app uses the payment token to recognize a member when that token is already linked to a loyalty profile. The app can then show that member’s profile, points, and rewards. If the customer is not yet a member, staff can enter a phone number in the app, or show a QR code to the member web app. The token is linked to a profile only after the customer registers and consents. End customers do not log in to the Tap, Earn & Burn app.
  

4. Why we process this data (purposes and legal basis)

Purposes

• Providing our services to merchants and end users: analytics, wallet pass management, loyalty web app functionality
• Technical maintenance and optimization: ensuring service reliability, investigating performance issues, and maintaining security
• Direct user relationships: if Loyyo itself provides the loyalty or enrollment features, we may handle personal data directly with user consent or under a contract
• Providing the Tap, Earn & Burn app to merchant staff, including taking a Mollie Tap payment, recognizing a linked member, and registering a new member by phone number or QR code

Legal basis

• Consent (GDPR art. 6(1)(a)): when an end user opts in, enrolls for a pass, or links a payment token to their loyalty account
• Contractual necessity (GDPR art. 6(1)(b)): when data processing is required to fulfill a contract (with our merchant clients or possibly with an end user directly)
• Legitimate interests (GDPR art. 6(1)(f)): for internal analytics, security, or fraud prevention, provided these interests do not override data subject rights
• Merchant’s own legal basis: in many scenarios, the merchant decides the legal basis (for example, if they gather consent for marketing). Loyyo processes data according to that basis and under the merchant’s instructions.
  

5. Roles and responsibilities

• Merchant as controller: Typically, the merchant (our B2B client) is the data controller for their own customers’ data. Loyyo processes data based on their instructions.
• Loyyo as processor or sub-processor: For data we handle on behalf of the merchant, we act as a processor.
• Loyyo as (joint) controller: In situations where we directly collect personal data and decide how it is processed (for example, our own loyalty program), we become a (joint) controller. In that case, we clearly inform data subjects.

6. Data sharing and disclosure

• No sale of personal data: We do not sell or rent data to third parties.
• Sub-processors: We may engage trusted providers (for instance, hosting or analytics services) who process data under our instructions. We sign data processing agreements to ensure GDPR compliance. You can find more details in our Trust Center.
• Payment providers: Payment tokens are generated by the payment provider. Loyyo does not receive or store the full payment card number. The Tap, Earn & Burn app receives a pseudonymous payment token and limited card details (such as the last digits, card brand, and country) from Mollie in order to link the payment to the loyalty profile. The token is sent to Loyyo. It becomes personal data only when it is linked to an identifiable member profile.

7. International data transfers

We aim to store and process data within the European Economic Area (EEA). If transfers outside the EEA are needed, we implement appropriate safeguards such as standard contractual clauses, in accordance with GDPR.

8. Security measures and ISO 27001

We maintain an ISO 27001-certified information security management system (by Sprinto). Examples of our safeguards include:

• Technical and organizational controls (such as access controls, encryption, secure software development)
• Incident response procedures for identifying, reporting, and addressing security events
• Continuous improvement through regular audits, updates, and best-practice adoption
• For more details, please see our Trust Center (https://trust.loyyo.com).

9. Data retention

• Data product: We retain pseudonymized transaction data for as long as needed to deliver analytics or meet contractual requirements, then securely delete or anonymize it.
• Wallet pass and server: Personal data is stored according to merchant instructions or legal requirements.
• Loyalty web app: User accounts remain active until deleted by the user or the merchant. If a user withdraws consent or terminates their account, we remove or anonymize personal data unless otherwise required by law.
• Tap, Earn & Burn app: Merchant login details and Mollie keys remain encrypted on the device until the merchant removes them or uninstalls the app. Payment and member data shown in the app are processed for that transaction and then handled under the retention rules for the data product and the loyalty web app.

10. Rights of data subjects

When Loyyo acts as a (joint) controller, individuals in the EU have rights under GDPR, such as:

• Right of access: to know whether and which personal data we process
• Right to rectification: to correct inaccurate or incomplete data
• Right to erasure: to request deletion if no lawful basis exists to retain the data
• Right to restrict processing: to limit the processing in specific situations
• Right to object: to object to processing based on legitimate interests, if applicable
• Right to data portability: if processing is based on consent or a contract, to receive data in a commonly used format

Usually, Loyyo is a processor acting on behalf of the merchant, so requests should go to the merchant’s privacy contact. If you believe Loyyo is acting as a (joint) controller for your data, please contact us directly (see below).

11. Contact and complaints

If you have questions or concerns about this policy, or if you wish to exercise your rights in a scenario where Loyyo is the (joint) controller, please contact:

Loyyo – Data Privacy

Marksingel 2D

4811NV, Breda

info@loyyo.com

+31 76 231 0245

If you feel we are not meeting GDPR requirements, you may lodge a complaint with your local supervisory authority (for example, the Dutch Data Protection Authority). But please check our trustcenter first where our GDPR compliancy status is monitored on a daily basis. 

12. Policy updates

We may update this policy from time to time (for example, due to changes in our services or in legislation). The most recent version is always available in our Trust Center (https://trust.loyyo.com). We encourage you to check periodically for updates.