Please read this Privacy Statement carefully before joining the Webloyalty Programme or using this website.
WL is the data controller for this Website.
WL has appointed, in accordance with Article 27 of the GDPR, the company WL France SAS as its representative within the European Union. WL France SAS is located at 124 rue Réaumur 75002 Paris (France) and registered in the Paris Trade and Companies Register under number 499 925 956. – dpd@webloyalty.fr Please address any questions or requests to the customer service address at confidentialite@webloyalty.fr or to the Data Protection Officer. You aim to provide a response within a maximum of 30 days.
This is the WL privacy Statement which discloses the privacy practices for the Webloyalty Programme and the Webloyalty Membership Service and the completesavings.ie Website ("Website"), which may be amended from time to time in accordance with the changes to this Privacy Statement section below (the "Privacy Statement").The Webloyalty Membership Service and Website are owned and operated by WL, WL is a limited company registered in Switzerland, with registered number CHE-344.043.246, and its registered office is at Avenue Reverdil 8, 1260 Nyon, Switzerland. WL uses the domain www.one-time-offer.com to enable consumers to register as a Member of the Webloyalty Programme. Therefore, this privacy statement is also applicable to consumers who access and utilise, WL's online registration page to sign up for the Programme under the domain www.one-time-offer.com. If you have any questions about this Privacy Statement, please feel free to contact WL at customerservice@completesavings.ie or write to WL at Avenue Reverdil 8, 1260 Nyon, Switzerland.
This Privacy Statement explains: (a) what sort of Personal Information WL collects; (b) how that Personal Information is used; (c) to whom WL may disclose your Personal Information; (d) how you can correct or change the Personal Information WL holds about you and (e) how you can change your preferences to opt-in or opt-out of receiving marketing communications.
This Privacy Statement is incorporated into, and forms part of, the Membership Terms of Service, which govern your participation in the Webloyalty Programme and your use of the Webloyalty Membership Service and this Website.
If you have a concern about your data or a question about this Privacy Statement, please contact our Data Protection Officer by email at dpo@completesavings.ie.
It is up to you what Personal Information and data we collect and you may decline to provide us with it. However, if you choose not to provide us with your Personal Information and data which is necessary to provide you with the Webloyalty Programme, you will not be able to use the Webloyalty Programme.
Membership
To become a Member of the Webloyalty Programme, you will be asked to provide a basic profile about yourself by filling out an online registration form with your name, mailing address, email address and payment information (including credit and/or debit card number and expiration date). In some cases, you may expressly authorise a marketing partner of WL to transfer certain contact information to WL (i.e. name, email address) to pre-fill part of the online registration form. The completion of this online registration form is necessary to authenticate your identity, register you to receive the relevant services including the day to day servicing of your membership and process your payment for the Webloyalty Programme. Without it, WL will not be able to sign you up and/or provide you access to the use the Webloyalty Programme. The specific legal ground WL are processing your personal data on is under performance of a contract with you. WL processes such information in accordance with this Privacy Statement. The marketing partners of WL may have different privacy practices and you are encouraged to read their privacy statements.
Your data is also necessary to detect and if necessary withhold you from re-enrolling in the Webloyalty Programme where your membership was terminated due to a breach of terms and conditions such as misuse of the Webloyalty Programme or fraudulent activity. This constitutes a legitimate business purpose of WL.
After joining the Webloyalty Programme, WL may request that you verify your Personal Information previously provided, provide additional contact information (your telephone number, for instance), indicate your communication preferences and create your permanent member identification and password for secure use of the Website. You may also be required to select a challenge question and provide the answer so that WL can assist you if you forget your member identification or password. Any data requested helps WL to provide you with your benefits, and to personalise and properly service your Membership.
Depending on the benefits that you elect to use, you may be asked for additional information to properly service your Membership. For those benefits that require you to submit a reimbursement claim, you will be required to complete a form requesting information needed to process the claim. Depending on the type of claim and the circumstances surrounding the claim, you may be required to provide additional documentation to support your claim.
Feedback and Surveys
From time-to-time WL may provide you as a Member of the Webloyalty Programme the opportunity to participate in contests or surveys made available through the Website. If you participate, WL will request certain Personal Information from you. Participation in these surveys or contests is voluntary. This will be to improve the Webloyalty Programme and services for your continued enjoyment and to assist in the development of new Webloyalty Programmes and services based on your feedback. The requested information typically includes contact information (such as name, email and/or mailing address) and demographic information. WL may use this information to publish contest winners, to monitor Website traffic or personalise the Webloyalty Membership Service (in the case of anonymous information collected in surveys) and to send participating Members an email newsletter. WL may use a third party service provider to conduct these surveys or contests; that company will be prohibited from using your Personal Information for any other purpose. WL will not share the Personal Information that you provide through a contest or survey with any other third parties unless you so consent or as otherwise provided in this Privacy Statement. The use of such third party service providers for surveys and contests will be made aware to you before you choose to participate.
Refer a Friend
WL may offer a referral service so that WL can tell one of your friends about our Webloyalty Programme by forwarding certain marketing communications and/or emails to an individual you believe may be interested in joining the Webloyalty Programme.
Anonymised data and Aggregated data
Anonymisation is the process of converting personal data to anonymised data so that it does not identify you or any individual and will not allow you or any individual to be identified through its combination with other data. WL collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but it is not considered personal data in law as this data does not directly or indirectly reveal your identity. In addition to the way WL process your data explained above, WL will use anonymised data and aggregated data to improve the quality of WL's existing products/services, develop new features, products/services and for overall research purposes. An example would be where WL aggregate your data on how often you use the product/service to calculate the percentage of users accessing a specific website feature. As this data is anonymised and does not identify you, WL may share this data with WL's group companies as well as third parties and partners. However, if WL combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, WL treat the combined data as personal data which will be used in accordance with this privacy policy.
Profiling
WL will use aggregated data, data from third party analytic providers such as Google Analytics (see section below), and the data WL collect about you through cookies including your online behaviour whilst using WL's services and your personal data to form a view on what WL think you may want or need, or what may be of interest to you. This is how WL decides which products, services and offers may be relevant for you. You will receive marketing communications from WL about similar products and services if you have requested information from WL or purchased goods or services from WL or if you provided WL with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing by clicking the unsubscribe link in the email or SMS. WL will also use this data to tailor your servicing communications. The content of the communications sent to you are determined by automated decision making which does not produce legal or similar effects concerning you.
Please note that when you are redirected to a partner or third party website from this Website, if you provide personal data to any of those partners or third parties, your data will be governed by their privacy statement/policy. You should read their privacy statement/policy before you submit any of your data to their websites.
Usage
WL only processes Personal Information for the purposes described in this Privacy Statement (including as set out in the what information we collect and how we collect it section above and the Cookies Policy section below) for the following purposes:
- to identify you as a Member of the Webloyalty Programme;
- to provide the Webloyalty Membership Services and benefits that you request, and to communicate with you in that regard (including sending you emails related to the Webloyalty Membership Service and for billing purposes);
- to ensure the proper functioning of the Website;
- to meet our research and product/service development needs and to improve the Website, and the Webloyalty Membership Service; and
- to personalise your experience, including targeting the Website and the Webloyalty Membership Service to you.
WL may combine the information you submit under your account with other information made available to WL or third parties, including information WL receives from its marketing partners, and/or its benefits suppliers to better target the advertising and to improve the quality of the Webloyalty Membership Service.
User Communications
When you communicate with WL (by telephone, email or otherwise), WL may record and/or retain those communications to be able to process enquiries, respond to your requests and improve the Webloyalty Membership Service. WL will process your data for legitimate business purposes namely quality assurance and training purposes and to ensure WL have collected and recorded any consent you provide over the phone. WL will always inform you if such recording or monitoring is taking place.
Where WL need your consent
WL will ask you for your express opt-in consent before WL share your personal data with any company outside WL group companies for marketing purposes. WL will provide you with more information about the categories of these companies at the time of asking you for your express opt-in consent. This will typically be for products/services offered by other companies which may be of interest to you based on the product/service you have with WL or may be for another purpose which will also be made clear to you at the time of obtaining your express opt-in consent.
WL will also ask you for your express opt-in consent before WL send you marketing communications about WL group company products/services that are not similar to what you currently have with us.
If you provide your explicit opt-in consent to receive such marketing communications, WL may provide you with further options where you can choose how to receive it, such as email, SMS, physical mail or telephone and the frequency of such marketing communications. If you have provided your explicit consent to receive marketing communications but later change your mind, you can edit your preferences on how you receive them, how often you receive them or even stop receiving them altogether by contacting WL or updating your preferences in your member profile page.
Disclosure
WL may disclose your Personal Information:
- to WL's group companies, suppliers and service providers, to enable WL to provide the Webloyalty Membership Services to you, including WL's benefit and/or discount suppliers, to third parties who process payments to or from you on behalf of WL, hosting companies, content providers and software and/or hardware vendors who may have access to WL's databases.
- to the marketing partner that provided you with details of WL's offer, for the legitimate business purpose of enabling them to track the offer that you accepted from WL and enabling them to undertake market research and data analysis in relation to but not limited to your shopping trends and behaviours. This is used to determine the value of the Webloyalty Programme for members. Data shared with the marketing partner may include name, address, email address, details on purchasing patterns and/or details on the status of your Membership, and will not be used for promotional or marketing purposes, and will not be disclosed by them to third parties, other than for the purposes stated above, who have undertaken in a binding agreement to process and maintain the confidentiality of your data in line with applicable law. WL requires that its marketing partners and suppliers agree to process your Personal Information in accordance with instructions from WL, this Privacy Statement and any other appropriate confidentiality and security measures. These types of third parties are not permitted to use your information for any secondary purposes.
If you provide your explicit consent (either when joining the Webloyalty Programme or via the communication preferences pages available through your Member profile area on the Website), WL will also share your Personal Information with its group companies so that WL and/or its group companies may send you information about other products and services which are not similar to the product and service you already have and which WL considers to be of interest to you.
If you provide your explicit consent (either when joining the Webloyalty Programme or via the communication preferences pages available through your Member profile area on the Website), WL may also share your Personal Information with third parties (who are not group companies) so that WL and/or those third parties may send you information about any products and services considered to be of interest to you. Note that third parties may have different privacy practices and WL encourages you to read their privacy statements.
WL may transfer your information to third parties as a result of or in connection with a sale, merger, consolidation, transfer of assets, reorganisation or liquidation, and WL shall notify you of any such activity if your Personal Information becomes subject to a different privacy statement.
WL may disclose certain information about you such as first name, first initial of last name and city/town of residence publicly as an example of representative savings and/or to identify you as a Member of the Webloyalty Program.
As part of the Service, we may use the services of financial institutions or bank's subcontractors, subject to legal reporting requirements. In such circumstances these financial institutions or bank's subcontractors may carry out identity checks before any financial transaction is processed. Any information, which is processed by way of transfer to said financial institutions or bank's subcontractors, is intended for their use only and for this specified purpose only.
As a result, we may ask you to provide us with a copy of your proof of identity (ID/passport) as well as some additional information such as, bank statement, date and place of birth, occupation, address and phone number.
We inform you that your failure or refusal to provide the information requested will prevent us from providing the benefits of the membership and may result in the termination of your membership. There may also be some delay to us commencing delivering of your benefits to you as a result of these checks.
In certain cases you may be presented with the opportunity to download software from WL or its licensors and suppliers that may improve the services of the Webloyalty Membership Service and the Webloyalty Programme. In such cases, you will be presented with, and required to agree to separate terms and conditions specifically related to the download application ("Download Application") prior to downloading the software.
Although acceptance of the Download Application Privacy Statement is required to utilise a specific part of the Webloyalty Programme, the right to receive most benefits as included in the Webloyalty Membership Service can still be accessed by logging onto the Member's Only area of the Website.
At any time you can stop your use of this Download Application by uninstalling the Download Application from your computer. The only authorised means to uninstall the software is to use the Add/Remove Programmes facility in the Microsoft Windows Control Panel. After the removal of the Download Application, you will no longer be able to use the features of this Download Application.
- data minimisation and encryption of personal data;
- the ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services;
- the ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident; and
- a process for regularly testing, assessing and evaluating the effectiveness of technical and organisational measures for ensuring the security of the processing.
You agree not to hold WL responsible for any breach of security except as set out in the Membership Terms of Service. In addition, unencrypted e-mail is not a "secure" means of communicating with WL, since e-mail may be intercepted by a third party in the course of its delivery.
You are responsible for maintaining the strict confidentiality of your Membership password, and you shall be responsible for any access to or use of the Website or the Webloyalty Membership Service by you or any person or entity using a password provided to you, whether or not such access or use has been authorised by or on behalf of you, and whether or not such person or entity is your employee, relative or agent. You agree to (a) immediately notify WL of any unauthorised use of your password, membership number, or any other breach of security, and (b) ensure that you exit from your account at the end of each session. It is your sole responsibility to control the dissemination and use of your password, control access to and use of your account and membership number, and notify WL when you desire to cancel your Membership.
Whenever WL process or transfer your personal data out of Switzerland, WL always ensure that an adequate level of protection is afforded to it. It is the case for example when WL process or transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission (to see the list, please visit: http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm). Whenever WL affiliates or providers based in the US process your data, WL include relevant mechanisms (such as standard contractual clauses approved by the European Commission, so-called EC model clauses) in contracts and agreements with them. When providers or affiliates based in other countries that have not been deemed to provide an adequate level of protection for personal data by the European Commission process your data, WL always use EC model clauses in contracts and agreements with them to maintain a similar level of protection as if your data was processed within Switzerland.
You can contact WL's Data Protection Officer if you want further information on the specific mechanism used by us when transferring your personal data out of Switzerland.
WL shall assume responsibility for the data that You submit if WL fails to honor its duty to provide reasonable protection of your personal information. It should be borne in mind, however, that you cannot hold WL accountable for a security violation unless if WL is at fault, in which case WL's liability shall be subject to the limits as set out in the Membership Terms of Service.
If WL is going to use your personal information in a manner different from that stated at the time of collection, you will be notified via email, and you will have a choice as to whether or not WL uses your personal information in this different manner.
1) One-time-offer.com domain or Program registration page and Program registration confirmation page.
2) Product page www.completesavings.ie
3) Billing descriptor: www.completesave.ie
Why do we use them?
We use these technologies in order to collect information (personal and anonymous); provide the service; improve the service (by gathering statistical information on traffic, our audience and use of the program); show content and adapted advertising to users and customers; distinguish you from other user of the website; and allow you to share our content on social networks.
The use of cookies allows WL to provide you with your cashback rewards.
We use both first party cookies (WL cookies) and third party cookies, which are cookies provided by other people's websites. For example, a third party content provider might provide a cookie when you access content hosted on their site. We do not have access to those third party cookies and their providers will have their own cookie and privacy policies which we encourage you to read.
More details on how businesses use cookies is available here: http://www.allaboutcookies.org/
In the following sections, WL will explain to you which cookies (and other similar technologies) are used on the website (and for what purpose).
You can give consent to cookies, or withdraw any consent you have previously given, through our cookie tool or your browser settings - for more detail, please see “How to modify or uninstall cookies or similar technologies” below. Please note that, in order to refuse cookies that are set by third parties, you must use your browser settings or visit the third party site and follow the instructions in their cookie notice.
Strictly necessary. These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preference, logging in or filling in forms. You can disable these by changing your browser settings but this may affect how the website functions.
Performance. These first party cookies collect information about how visitors use the website, for example, the number of visitors, which email or web page visitors clicked through from in order to visit the website, which pages are the most and least popular and how visitors move around the site. All information collected by these cookies is aggregated and therefore anonymous. These cookies help us measure and improve the performance of the website. If you do not allow these cookies, we will not be able to monitor the website performance.
Personalisation & Analytics. These cookies enable the website to provide personalization and enhanced functionality based on your browsing history. They may be set by us or by third party providers whose services have been added to our website. If you do not authorize these cookies, we will not be able to provide you a personalized experience.
Marketing. These cookies may be set through our site by us or by third-party advertising partners. They may be used to build a profile of your interests and show you relevant adverts on other sites.
Social Media. These cookies are used so that visitors can interact with the content of different social media platforms (Facebook, YouTube, Twitter, LinkedIn, etc.) and are generated only for the users of these social media platforms. Please refer to the relevant social media platform's privacy policies for information about their cookies.
A. COOKIES
You can access the details of cookies used on the following domains in the Consent Management Platform (CMP) the first time you access the website, or in the “Cookie Preferences” section in the footer of the website which can be accessed at any time:
1) One-time-offer.com domain or Program registration page and Program registration confirmation page.
2) Product page: www.completesavings.ie
3) Billing descriptor: www.completesave.ie
B. SIMILAR TECHNOLOGIES
In addition to cookies, we use other technologies, which due to their characteristics and ability to collect data, must be included in this policy.
1. Milestones and Event Tracking
This type of technology collects information on the time that users spend on our web pages, complementing the information that cookies and other similar technologies collect. The most common events tracked by these technologies are:
- Compliance interactions: How many people choose not to use marketing cookies?
- Page interactions: Do users click on tabbed content? Or in box x?
- Document downloads: How many people download documents in a certain format?
- E-Commerce interactions: Do people add products to their cart and never complete their purchase?
- Form events: Is there a problem with the forms? Do people start filling them out but never send them?
- Lead generation: On which pages do people fill out the newsletter sign-up form?
- Off-page links: How many people actually click on the email links, site email address and phone number?
- On-screen interactions: Do people scroll enough to see the footer of the website?
- Interactions with social media buttons - How many people find your social media profiles on the site? Are they sharing the content of those buttons in blog posts?
Clear gifs (or Web Beacons / Web Bugs) are tiny graphics with a single identifier that track a user's journey on the website. Unlike cookies, they are not stored on the user's computer hard drive, but are incorporated invisibly on web pages.
We use clear gifs to manage website advertising as they tell us which content is the most used by our users.
3. Log files
A "log file" is a file on the server that stores information about the origin of website traffic, the way users navigate through the site and what visitors to our pages are looking for.
Among the information that we can collect with them are:
- in fixed terminals or laptops and similar: the IP address, the URL of the page prior to registration in the program, the browser and the version used, the date and time of the display of the advertisements of our program on third party pages; and
- (ii) on mobile and similar terminals: the name of the device used, the size of the screen used (pixels), the orientation of the device (vertical / horizontal), the language of the device, the identification number of the device and the version of the operating system used.
4. Web scripts & tags
WL uses these technologies in order to obtain certain pseudo-anonymized personal data that allows us to identify whether you are a registered member of the Webloyalty Program, in order to provide you with relevant messages and offers through our advertisements as well as to remind you where you can use the benefits of your subscription.
This technology is used both on our websites and on the pages of our business partners (partners with whom we have commercial agreements to promote our program). Business partners will use these technologies to collect a unique identifier on their website which WL can use to recognise its members.
If you are not a member of the Webloyalty Program, the data collected through the web scripts will remain anonymous and will be stored for a maximum of 12 months (for more details, you can consult the privacy policy of our business partners).
Refusing the use of this technology will not stop advertisements, but the advertisements you see will not be adapted / personalised.
5. Bloomreach Events
As a member of the Webloyalty Program or as a subscriber to our newsletter, we will send you emails, in which we have included certain tracking technologies that, among other information, such as your name and customer number, may collect your IP address.
The main objective of these is to provide you with the service correctly (which is necessary), however we can also use them for purely statistical purposes (all of which is anonymous) that allows us to improve our advertising campaigns, as well as solve any type of incident.
6. Automatic data for browsing the website
When you browse the Internet, you leave a track of electronic information on each of the websites you have visited, it is the so-called “fingerprint”, which can be tracked and stored by the servers of our websites. The navigation course data indicates the type of terminal and the navigation software that was used or the Internet address of the website from which you logged into our website.
We will use this data in aggregate and anonymously to compile statistical data on the time that users spend on our website or to understand how they navigate through the website which will help us improve the program and the user experience.
7. Customer experience analytics services
In order to analyse the behaviour of the visitors on the website, WL uses some customer experience analytic services. Through this technology, WL does not collect or transfer any personal identifiable information, and uses these analytic services only to record, on a completely anonymous basis, information such as mouse clicks, mouse movements, scrolling activity as well as non-personally identifiable information which you type whilst on the website.
For example, WL uses the ClickTale customer experience analytics service. ClickTale does not create a user profile for the purpose of tracking a user across unrelated web sites and will only use such information pursuant to its privacy policy (located at http://www.clicktale.com/privacy_service.aspx ). You can choose to disable the ClickTale service at http://www.clicktale.net/disable.html.
C. HOW TO MODIFY OR UNINSTALL COOKIES OR SIMILAR TECHNOLOGIES
You may refuse to accept, or withdraw your previous consent to the cookies installed on your computer or device in two ways:
1. you can do so through the Cookies Preferences link (which can be found in the footer of all our web pages, under the heading "Cookies Preferences”). Essential cookies cannot be disabled through the Cookies Preferences link because they are necessary to make the website function. You may change your mind about the cookies you have selected through our Cookies Preference link at any time. Please be aware that the Cookies Preferences link cannot be used to block cookies on third party websites linked to from our website. In order to remove these cookies you will need to visit the relevant third party site and follow the instructions in their cookie notices. Alternatively, follow the instructions below to turn off these cookies using your browser settings.
2. Your browser settings may allow you to refuse the setting of certain cookies. The “Help” or “Internet Settings” functions within your browser should tell you how. For information on how to manage cookies on popular browsers please see the following links:
With regard to third-party cookies and similar technologies, we want to make sure that you understand that once you have allowed their use and installation on your computer, if you later decide to block them, this means that WL will no longer receive data that could be collected by these cookies.
This does not mean that these cookies are permanently uninstalled from your terminal, for this it will be necessary that you go to the browser settings that you used to access the Program and follow the instructions to that effect.
Finally, if you do not want any tracking technology to be installed on your terminal, you can use the "do not track" tools, which will allow you to enable a "do not track" function or even send you notices when certain types of cookies that you have predefined as "unwanted" are identified; These tools work in a similar way to so-called "incognito browsing". However, we remind you that part of the provision of this service requires that your purchases be tracked in order to offer you confirmation of purchases and associated refunds. In the event that you browse incognito or use any of these tools, we may not be able to track your purchases and we may not be able to provide the service correctly.
Remember, you can always contact us, both at the contact address and via email to our data protection officer at dpo@completesavings.ie to receive additional information and to expressly request the deletion of any personal data that is collected through the use of these technologies.
Please remember that uninstalling or modifying the cookies that have been classified as technical or necessary (and some performance cookies) may mean that we are not able to ensure the correct provision of the service (for example, monitoring of your purchases to obtain refunds) or maintain the full functionality of the website adjusted to the preferences.
D. CHANGES TO THE COOKIES POLICY
WL reserves the right to modify the Cookies Policy at any time by posting the amended terms on the website. All amended terms will automatically take effect immediately on posting, so please review it periodically on the website to inform yourself of any changes. If you do not accept the changes made, you should immediately stop using the website or amend your cookie settings accordingly.
Due to the constant updates made to these technologies, WL has the firm commitment to carry out a complete review of the technologies at least once a year to ensure that we always have the most up-to-date information.
It is possible that during these annual reviews, some of the technologies identified above may be modified or some new ones may be added. In any case, we assure you that these technologies will not have a different purpose than those they replace and new technologies will never be added that do not fit into any of the categories mentioned above.
By using the Website and/or using the Webloyalty Membership Service, you signify your acceptance of this Privacy Statement
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