Privacy & GDPR Policy

Last updated: 4 December 2025

Company: Unity Systems Ltd

Registered Address: 4–8 Ludgate Circus, London, England, EC4M 7LF

Website: https://unity-loyalty.co.uk

Data Protection Email: security@unity-loyalty.co.uk

Legal Queries: law@unity-loyalty.co.uk

Unity Systems Ltd (“Unity”, “we”, “us”, “our”) provides loyalty card and reward services to businesses (“Merchants”) and their customers (“users”, “you”).

This Privacy Policy explains how we collect, use, share, store, and protect your personal data.

By registering for a Unity Loyalty account or using a Unity Loyalty card, you agree to this Privacy Policy.

1. Who We Are

Unity Systems Ltd is the controller of your personal data for account registration, identity verification, and management of the Unity Loyalty platform.

For Merchant-specific activities (e.g., earning or redeeming rewards), Unity acts as a data processor, and the Merchant is the data controller.

This means:

  • Unity processes data on behalf of Merchants for loyalty functions.
  • Merchants only see data relating to their own customers, not customers of other businesses.

2. Personal Data We Collect

We collect the following information when you create an account:

2.1 Information You Provide

  • Full name
  • Email address or mobile number
  • Date of birth
  • Account password
  • Verification codes (for confirming phone/email)
  • Marketing consent preferences

2.2 Information Collected During Use

  • Points earned and redeemed
  • Purchase history from the Merchant where you use your card
  • Date and time of transactions
  • Items purchased (e.g., “latte”, “croissant”)
  • Reward history
  • Customer service interactions

2.3 Information We Do Not Collect

Unity does NOT collect or store:

  • GPS or location data
  • Payment card details
  • Device/browser fingerprints
  • IP address for marketing or profiling

Apple Wallet may trigger notifications based on your proximity to the Merchant, but Unity does not receive your location.

3. How We Use Your Data (Purposes)

We process your data for the following purposes:

3.1 To create and manage your loyalty account

  • Identity verification
  • Adding your loyalty card to Apple Wallet
  • Displaying points, rewards, and transaction history

Lawful basis: Performance of contract

3.2 To operate loyalty programs

  • Processing point earnings and redemptions
  • Providing Merchant-specific rewards

Lawful basis: Performance of contract

3.3 To send service notifications

Examples:

  • Account verification codes
  • Password reset
  • Expiry warnings

Lawful basis: Legitimate interests (service operation)

3.4 To send marketing communications (if you opt in)

Merchants may send:

  • SMS
  • Email
  • Push notifications
  • Apple Wallet geo-notifications

Lawful basis: Consent

Marketing is never sent without your active opt-in.

You may withdraw consent at any time via your account settings.

3.5 To improve and secure the Service

  • Fraud detection
  • System diagnostics
  • Analytics using anonymised data

Lawful basis: Legitimate interests

4. Apple Wallet Notifications & Location

  • Merchants may set geo-triggered notifications through Apple Wallet.
  • Apple controls the location trigger — Unity does not collect, store, or track your GPS location.
  • You may disable these notifications through Apple Wallet settings.

5. Sharing Your Data

We share your data only with:

5.1 Merchants

Merchants see:

  • Your name
  • Contact details
  • Date of birth
  • Points earned
  • Points used
  • Items purchased
  • Visit dates/times

Merchants do not see:

  • Data relating to other businesses
  • Your marketing opt-out preferences for other Merchants

5.2 Service Providers (sub-processors)

Examples:

  • Cloud hosting
  • Database providers
  • Email/SMS delivery services

All providers are vetted and bound by data protection agreements.

5.3 Legal Authorities

Only when required by law.

Unity never sells personal data.

6. Marketing Communications & Opt-Out

6.1 Opt-in Mechanism

Marketing consent is collected through:

  • A dedicated opt-in checkbox during registration
  • A clear explanation of what communications you will receive

6.2 How to Withdraw Consent

You can opt out anytime via:

  • Your user account
  • The unsubscribe link in emails
  • Reply “STOP” to SMS messages
  • Apple Wallet notification settings

6.3 Service Messages

You cannot opt out of essential messages (e.g., verification codes).

7. Data Retention

Unity retains personal data only as long as necessary:

Data Type

Retention Period

Account details

Until account deletion

Transaction history

Anonymised after account deletion

Marketing consent logs

6 years (legal requirement)

Support requests

12 months

8. Account Deletion

You may delete your account at any time via your Unity account dashboard.

Upon deletion:

  • Your personal data is permanently removed.
  • Your transaction and points history are anonymised and retained for Merchant analytics.
  • All unused points are erased.
  • Your loyalty cards will no longer function.

Unity and Merchants may also close accounts for fraud or misuse.

9. Your Rights (UK GDPR)

You have the following rights:

  • Right of access – receive a copy of your data
  • Right to rectification – correct inaccurate data
  • Right to deletion – delete your account
  • Right to restrict processing
  • Right to object to marketing
  • Right to data portability
  • Right to withdraw consent at any time
  • Right to complain to the ICO

You can exercise your rights by contacting:

📧 security@unity-loyalty.co.uk

10. Security Measures

Unity implements the following protections:

  • Encrypted databases
  • Encrypted data transmission (HTTPS)
  • Access control and logging
  • Role-based access for Unity staff
  • Regular security audits
  • Data minimisation
  • Enforced password security
  • Secure backup and redundancy systems

We also require all Merchants to follow appropriate data protection practices.

11. Transfers Outside the UK

If data is transferred outside the UK, we use:

  • UK-approved Standard Contractual Clauses
  • Adequacy decisions where applicable
  • Technical and organisational safeguards

12. Cookies & Website Tracking

Our website uses:

  • Essential cookies (required for login and security)
  • Analytics cookies (with consent)

A full Cookie Policy is available separately.

13. Changes to this Policy

Unity may update this Privacy Policy to reflect:

  • Legal changes
  • Technical improvements
  • New features or services

Users will be notified of material changes.

14. Contact Us

For general enquiries:

📧 support@unity-loyalty.co.uk

For data protection matters:

📧 security@unity-loyalty.co.uk

For legal matters:

📧 law@unity-loyalty.co.uk

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