Revised date: December 14, 2020
Personal information (also referred to as "personal data" in some jurisdictions) is any information, or a combination of pieces of information, that can be used to identify you or that we can link to you, including but not limited to a name, address, email address or telephone number.
Our primary activity is assisting our clients in relation to their own loyalty and rewards programs and other customer related marketing functions, and helping our retailer clients and their suppliers understand their business performance and customer behavior (together, "Programs"). Where you are a member of, or otherwise participate in a Program, or are interested in or eligible to become a member of a Program, we may have access to your personal information. We Process this personal information on behalf of our clients, and our clients are responsible for its collection and use. Where European data protection law applies, Kognitiv entities are 'processors' of this personal information and, where they are required to by applicable data protection law, our clients will explain more about how personal information is used in their Programs.
1. COLLECTION OF PERSONAL INFORMATION
The types or categories of personal information we will collect and Process will depend on the circumstances, and may include:
o social media platforms (for example, when you interact with us on those platforms or access our social media content); and
o publicly available or publicly accessible sources
The categories of information that we collect about you from other sources may include:
Please note that we may be required by law, or as a result of a contractual or other relationship we have with you, to collect certain personal information about you. Failure to provide this information may prevent or delay the fulfilment of these obligations. Where required by law, we will inform you at the time your information is collected whether its provision is compulsory and of the consequences of the failure to provide such information.
Our websites are not directed toward individuals under the age of 16 and we do not knowingly or intentionally collect or process personal information from individuals under the age of 16.
2. USE AND DISCLOSURE OF PERSONAL INFORMATION
We Process your personal information to:
We may automatically Process your personal information to evaluate personal aspects and predict outcomes. For example, we may make automated decisions about you based on your personal information to show tailored content on our websites. These types of decisions will not have legal or similar effects for you, but you can still contact us for further information.
European data protection law requires us to have a legal basis to Process your personal information. In most cases where we need a legal basis, it will be one of the following:
In carrying out our business, we may share your personal information with third parties, For example:
3. TRANSFERRING PERSONAL INFORMATION OUTSIDE THE JURISDICTION IN WHICH IT WAS COLLECTED
We may disclose personal information to destinations outside the jurisdiction from which it was collected.
In the conduct of our business, we disclose to, hold or access personal information from various countries, including without limitation, Australia, Bahrain, Canada, European Union Member States, Hong Kong, South Korea, Japan, Malaysia, Singapore, Qatar, Thailand, United Arab Emirates, United Kingdom, and the United States of America.
The privacy laws of the countries to which we transfer personal information may not provide the same level of protection as the privacy laws of the country from which the personal information was collected or be regarded as ensuring an adequate level of protection for personal information under European data protection law. However, this does not change our commitments to safeguard your privacy and we will put in place appropriate safeguards in accordance with applicable legal requirements to ensure that your personal information is adequately safeguarded. For more information on the appropriate safeguards in place, please contact us using the details below.
4. BUTTONS AND LINKS TO OTHER WEBSITES
5. YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION
Subject to local applicable law, you have a number of rights in relation to your personal information, including the right to:
If you would like to discuss or exercise such rights, please contact us at the details below.
We encourage you to contact us to update or correct your personal information if it changes or if the personal information we hold about you is inaccurate.
We will contact you if we need additional information from you in order to honour your requests.
Nevada Residents: If you are a Nevada resident, you have the right under Nevada law to request that we do not sell your personal information for monetary consideration to certain other parties. This right applies even if your personal information is not currently being sold.
California Residents: If you are a California resident, you have certain rights under the California Consumer Privacy Act (CCPA) described below:
6. SECURITY OF YOUR PERSONAL INFORMATION
We will endeavour to take all reasonable steps to keep secure any personal information which we hold about you, and to keep this personal information accurate, up to date and complete. We require our employees and service providers to respect the confidentiality of any personal information held by us, and implement appropriate safeguards as required under local applicable law.
7. RETENTION OF PERSONAL INFORMATION
We will keep your personal information for as long as we have a relationship with you. Once our relationship with you has come to an end, we will retain your personal information for a period of time that enables us to:
We will delete your personal information when it is no longer required for these purposes. If there is any information that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further processing or use of the information.
8. CONTACTING US
Kognitiv has appointed a data protection officer. The data protection officer can be contacted at: Privacy@IRIworldwide.com
Subject to local applicable law you also have the right to lodge a complaint with your data protection supervisory authority. For individuals in Europe, the relevant data protection supervisory authority will be that in the European country where you work, reside or where the subject-matter of your complaint arises.
Nevada Residents: If you are a Nevada resident and wish to exercise your rights under Nevada law (see Section 5 above), you may submit your request by sending an email to Privacy@IRIworldwide.com. We will need to verify your identity in order to process your request.
California Residents: If you are a California resident and wish to exercise your rights under the CCPA, you may do so via an interactive web form, or via the toll-free number 1-866-467-8688 (enter service code #1135). We will need to verify your identity in order to process your requests.