Complete Savings Privacy and Cookies Statement
Privacy Statement Index

Please read this Privacy Statement carefully before joining Complete Savings or using this website.
Effective Date:
05 December 2012.
Revision Date
This Privacy Statement was last modified on 05 December 2012.
Data Controller
Webloyalty SARL is the data controller for this website.
This is the Complete Savings ("Complete Savings") privacy statement which discloses the privacy practices for the Complete Savings service and the completesavings.ie website (which may be amended from time to time in accordance with Clause 14 below) (the "Privacy Statement"). The Complete Savings service and website are owned and operated by Webloyalty SARL ("Webloyalty"). Webloyalty is a limited company registered in Switzerland, with registered number CH-550-1105751-7, and its registered office is at 23 route de Crassier (Business Park Terre Bonne, Bâtiment A3), 1262 Eysins, Switzerland. Complete Savings uses the domain www.one-time-offer.com to enable consumers to register for the programme online. Therefore, this privacy statement is also applicable to consumers who access and utilise our 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 us at customerservice@completesavings.ie or write to us at 23 route de Crassier (Business Park Terre Bonne, Bâtiment A3), 1262 Eysins, Switzerland.
  1. Purpose of this Privacy Statement
    At Complete Savings, we recognise the importance of protecting the personally identifiable information such as your full name, telephone number and e-mail and mailing address ("Personal Information") you provide to us.

    This Privacy Statement explains: (a) what sort of Personal Information we collect; (b) how that Personal Information is used; (c) to whom we may disclose your Personal Information; (d) how you can correct or change the Personal Information we hold 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 Terms of Service, which govern your use of the Complete Savings service and this website ("Site").

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  2. Truste Certification

    Webloyalty.com, Inc. has been awarded TRUSTe's Privacy Seal signifying that this privacy statement and practices have been reviewed by TRUSTe for compliance with TRUSTe's program requirements including transparency, accountability and choice regarding the collection and use of your personal information. The TRUSTe program does not cover information that may be collected through downloadable software. TRUSTe's mission, as an independent third party, is to accelerate online trust among consumers and organizations globally through its leading privacy trustmark and innovative trust solutions. If you have questions or complaints regarding our privacy statement or practices, please contact us at customerservice@completesavings.ie. If you are not satisfied with our response you can contact TRUSTe here. TRUSTe will then liaise with Webloyalty to resolve your concerns.TRUSTe's involvement will not affect your statutory rights in relation to the way in which your Personal Information is processed by us.

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  3. What Information We Collect and How it is Collected

    Membership

    To become a Complete Savings member, you will either be asked: to (a) 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); or (b) expressly authorise a marketing partner of ours to transfer certain contact and billing information to us (including your mailing address and payment information (including credit and/or debit card number and expiration date). We process such information in accordance with this Privacy Statement. Our marketing partners may have different privacy practices and we encourage you to read their privacy statements.

    After joining Complete Savings, we 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 service. You may also be required to select a challenge question and provide the answer so that we can assist you if you forget your member identification or password. Any data requested helps us 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 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.

    Surveys

    From time-to-time we may provide you the opportunity to participate in contests or surveys on our Site. If you participate, we will request certain Personal Information from you. Participation in these surveys or contests is voluntary. The requested information typically includes contact information (such as name, email and/or mailing address) and demographic information. We may use this information to publish contest winners, to monitor site traffic or personalise the site (in the case of anonymous information collected in surveys) and to send participants an email newsletter. We 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. We 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.

    Refer a Friend

    We may offer a referral service so that we can tell one of your friends about our Site or services by forwarding certain marketing communications and/or emails to an individual you believe may be interested in our products and services.

    Cookies and Logfiles

    This section of our privacy statement sets out how we use cookies and similar technologies ("cookies") on and in connection with this Site. Cookies are text files containing small amounts of information which are downloaded by your internet browser and stored on your PC or other device when you visit a website.

    How we use information we collect through Cookies

    We store information that we collect through cookies, log files, clear gifs, and/or third party sources to create a summary of your preferences. We tie your personally identifiable information, and/or your membership usage history in order to provide tailored promotions and marketing offers, to improve the content of the site for you and/or to determine your preferences.We may match information collected from you through different means or at different times, including, for example, information collected online and offline, and use such information along with information obtained from other sources, including third parties. To do this, it is often necessary to share this information with carefully selected vendors and business partners we work with, such as companies that perform marketing services and other business operations for us.

    More information about cookies

    We use session and persistent cookies on this Site. A session ID cookie expires when you close your browser. A persistent cookie remains on your hard drive for an extended period of time.

    You can remove persistent cookies and reject persistent and session cookies by following the directions provided in your Internet browser's "help" file or by visiting www.allaboutcookies.org. If you reject persistent or session cookies, you may still use our Site, but you may not be able to access all the Site's functionality or your access may be limited.

    How we use cookies

    We use cookies to:

    (a) remember choices you have made and personalise your use of the Site. This includes cookies that:

    a. store your password(s) for and keep you logged into the Site so that you don't have to enter passwords more than once per visit; and

    b. remember and recognise you on subsequent visits to the Site,

    (b) identify how you use this Site, including tracking how you use the Site, such as information on where you came from, what content you viewed on the Site, and the duration of your visit; and

    (c) deliver content and advertising more relevant to you and your interests. This allows us to serve you more relevant content and advertising when you use Complete Savings and not to serve you content or offers you may already have opted-out of. This includes cookies used by advertising networks, which may be subject to a separate privacy statement on how the advertising network uses information they collect. Please see the How we use third party cookies for advertising and re-targeting purposes below for further information. We link the information we obtain from or store in cookies to any Personal Information that we gather about our members (see How we use information we collect through Cookies above).

    How we use third-party cookies for advertising and re-targeting purposes

    We may also use cookies to enable the use of advertising technology to serve you advertisements that we feel may be relevant to you when you visit search engines, our Site and/or third party sites upon which we advertise.

    This technology uses information about your previous visits to our Site and the third party sites upon which we advertise to tailor advertising to you. In the course of serving these advertisements, a unique third-party cookie may be placed or recognised on your browser to enable us to recognise you. This Site also uses Google Analytics, a web analytics service provided by Google, Inc. ("Google"). Google Analytics uses cookies to help analyse how visitors use the Site. Information about your use of this Site (including your IP address) will be transmitted to and stored by Google on servers in the US, and Google will use this information to evaluate your use of the Site, compile reports on website activity for us, and provide other services relating to website activity and internet usage, but will not associate your IP address with any other data held by Google. For more information on the use of Google Analytics, including how to opt out, visit http://www.google.ie/intl/en/analytics/privacyoverview.html.

    Web Beacons

    We use web beacons, provided by our ad serving partner, to help manage our online advertising. These web beacons allow us and/or our ad serving partner to access individual cookies when a browser visits the Site. This allows us to identify which advertisements or listings served by our ad serving partner bring users to our Web site.

    Web beacons are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users. In contrast to cookies, which are stored on a user's computer hard drive, clear gifs are embedded invisibly on Web pages and are about the size of the period at the end of this sentence. We link the information gathered by clear gifs to the Personal Information we gather about our members (see How we use information we collect through Cookies above).
    Logfiles

    Like many websites, we gather certain information relating to website use automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp and clickstream data. We use this information, which does not by itself identify individual users, to analyse trends, to administer the Site, to track users' movements around the site and to gather demographic information about our user base as a whole. After collection, during our processing of the data, we link this automatically-collected data to the Personal Information that we hold.


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  4. How Personally Identifiable Information is Used and Disclosed

    Usage

    We only process Personal Information for the purposes described in this Privacy Statement (including as set out in the Cookies and Logfiles section above) for the following purposes:

    • to identify you as a member;
    • to provide the services and offerings that you request, and to communicate with you regarding such services and offerings (including sending you service-related emails and for billing purposes);
    • to ensure the proper functioning of the Site and our services;
    • to meet our research and product/service development needs and to improve our Site, services and offerings; and
    • to personalise your experience, including targeting our services and offerings to you.

    Marketing Data From Third Parties

    We will retain your information as needed to provide you services. We will also retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. If you wish to cancel your account or request that we no longer use your information to provide you services, contact us at customerservice@completesavings.ie . In such event, we will no longer use your information to provide you with services, however, your information will be retained by us in accordance with our standard business practices.

    We may combine the information you submit under your account with other information from other Webloyalty services or third parties, including from our marketing partners, and/or our benefits suppliers to better target our advertising and to improve the quality of our services.

    User Communications

    When you communicate with us (by telephone, email or otherwise), we may record and/or retain those communications to enable us to process enquiries, respond to your requests and improve our services.

    Disclosure

    We may disclose your Personal Information:
    • to our group companies, suppliers and service providers, to enable us to provide the services to you, including our benefit and/or discount suppliers, to third parties who we request to process payments to or from you on our behalf, hosting companies, content providers and software and/or hardware vendors who may have access to our databases.
    • to the marketing partner that provided you with details of our offer to enable them to track the offer that you accepted from us and to enable them to undertake market research and data analysis in relation to but not limited to your shopping trends and behaviours. Information shared with the marketing partner may include name, address, email address, 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.

    We require that our marketing partners and suppliers agree to process your Personal Information in accordance with our instructions, 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.

    We may also disclose your Personal Information to government, regulatory and law enforcement agencies to the extent disclosure is required or authorised by law and otherwise as we believe is necessary or appropriate to satisfy any law, regulation or other governmental request, to operate our Site properly, or to protect or defend our rights or the rights or well-being of our employees, users or others and/or if you are involved (or are suspected of being involved) in any illegal activity (even without a subpoena, warrant or court order).

    If you consent (either when joining the Complete Savings programme or via the communication preferences pages available through your Member profile area on the Site), we may also share your Personal Information with our group companies so that we and/or our group companies may send you information about their respective products and services and which we or they consider may be of interest to you.

    If you consent (either when joining the Complete Savings programme or via the communication preferences pages available through your Member profile area on the Site), we may also share your Personal Information with third parties (who are not group companies) so that we and/or those third parties may send you information about their respective products and services and which we or they consider may be of interest to you. Note that third parties may have different privacy practices and we encourage you to read their privacy statements.

    We 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 we shall notify of any such activity if your Personal Information becomes subject to a different privacy statement.

    We 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 our service.

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  5. Choice


    Opting Out

    You can make choices about how your Personal Information may be shared by us with third parties for marketing purposes and/or how your Personal Information may be used by us for purposes not related to your membership. Complete Savings enables Members to opt out of email marketing and to opt in to marketing from third parties by modifying their online profile. A link to this profile will be available in marketing emails. You can also unsubscribe to email marketing by sending an email to customerservice@completesavings.ie with "opt out" in the subject line. If you elect to opt out, such election will not apply to (a) communications that are directly related to your membership, service benefits and/or the fulfilment of a specific transaction you have requested (for example, a claim submitted for a particular benefit and/or emails describing the benefits of the service or special member offers; (b) shall not preclude us, including our employees, contractors, agents and other representatives, from accessing and viewing your Personal Information to provide benefits, to provide support and for any other purpose relating to your membership in the Complete Savings programme and (c) shall not preclude us from disclosing your Personal Information as described in this Privacy Statement for purposes other than sending you promotional and marketing materials not related to your membership.

    Information-Sharing Choices

    Webloyalty only shares Personal Information with selected third parties for marketing purposes after providing Members the ability to opt in to such sharing.

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  6. Links to Third Party Sites
    Our Site may contain links or references to third party websites and the privacy statements of these sites may differ from our own. Please be aware that we have no control over websites (other than those controlled by our group companies) and our privacy statement does not apply to such websites. We encourage you to read their privacy statements.

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  7. Download Application
    In certain cases you may be presented with the opportunity to download software from Complete Savings or its licensors and suppliers that may improve the services of the programme. In such cases, you will be presented with, and required to agree to a separate terms and conditions specifically related to the download application prior to downloading the software.

    Although acceptance of the Download Application Privacy Statement is required to utilise this part of the programme, most programme benefits can still be accessed by logging onto the Member's Only area of this site.

    At any time you can stop your use of this programme enhancement by uninstalling the 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 software, you will no longer be able to use the features of this programme enhancement using the software.

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  8. How We Protect the Security of Personal Information
    The security of your Personal Information is an important concern to us. We take appropriate measures to protect against unauthorised access to or loss, misuse, disclosure, alteration or destruction of Personal Information. We implement generally accepted standards of technology security including firewalls and Secure Socket Layer (SSL) encryption when we store sensitive Personal Information and billing information. In addition, for any Personal Information you submit to Complete Savings through this Site, such Personal Information shall be transmitted to Complete Savings using SSL encryption.

    Unfortunately, "perfect security" does not exist on the Internet, and no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect your information, we cannot guarantee that any information stored on our servers, or transmitted to or from a user, will be free from unauthorised access and you agree not to hold us responsible for any breach of security except as set out in our Terms of Service. In addition, unencrypted e-mail is not a "secure" means of communicating with us, 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 our Site or the Complete Savings services 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 us 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 us when you desire to cancel your account on our Site.

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  9. Transfer of Personal Information outside the EEA
    You acknowledge that we may need to host or store data outside the European Economic Area (EEA), and in particular in Switzerland and the United States of America.

    Although we cannot guarantee the same level of protection for your personal information as afforded in EEA member states, and despite the risks entailed with on-line communications, we take every reasonable precaution to protect your personal information.

    We have adopted and implemented the strictest privacy statement and data security measures required by the on-line consumer protection organisation, TRUSTe, and have obtained its privacy seal certification.

    We shall therefore assume responsibility for the personal information that you submit to us, if we fail to honour our duty to provide reasonable protection of your personal information.

    It should be borne in mind, however, that you cannot hold us accountable for a security violation unless if we are at fault, in which case, our limits of liability shall be solely as set out in our Terms and Conditions of Use of the Services.

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  10. Safe Harbor Participation
    The Complete Savings programme through Webloyalty.com, Inc complies with the U.S. -E.U. Safe Harbor framework and the U.S. - Swiss Safe Harbor framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data from European Union member countries and Switzerland. The Complete Savings programme through Webloyalty.com, Inc. has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view WebLoyalty's certification, please visit http://www.export.gov/safeharbor/. If you would like to contact Webloyalty directly about the Safe Harbor program, please send an e-mail to privacy@webloyalty.ie.

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  11. Children's privacy
    Protecting the privacy of children is very important to us. Membership of Complete Savings is not open to anyone under 18 years of age. We do not collect or maintain Personal Information from people whom we know are under 18 years of age. To prevent the collection of information from people under 18 years of age, we require valid credit card information to purchase our services.

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  12. How to update your Personal Information
    We take reasonable steps to ensure that the Personal Information we collect and process is accurate, complete and current, but we depend on our members to correct or keep up to date their Personal Information. When returning to your Member Profile Maintenance section, you can review and update your Personal Information. You may also change your password, but will need to confirm your identity first. Any change to your "Member Profile" on the Site will be recapped in an e-mail that is automatically sent out by Complete Savings to the e-mail address on file in your Member Profile.

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  13. Access Rights
    You have the right to request a copy of the information held by us about you. We may charge a fee for this which will not exceed €6.35. You will also have a right to access your data, have changed any inaccuracies in the details we hold about you, the right to object to the use of your data and the right to block any specific uses of your data by means of a request by writing to us at customerservice@completesavings.ie or Complete Savings C/O Loyalty Build, Station Road, Ennis, Co. Clare. We will respond to all access requests within 30 days.

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  14. Changes to this Privacy Statement
    We reserve the right to modify this Privacy Statement at any time, so please review it frequently on the Site. If we make any changes, we will either notify you by email or post a notice on the Site's homepage. We will also summarise any material changes to the Privacy Statement on the Site. We encourage you to read any revised Privacy Statement.

    If we are going to use your personal information in a manner different from that stated at the time of collection, we will notify you via email, and you will have a choice as to whether or not we use your personal information in this different manner.

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  15. Your Acceptance of this Privacy Statement
    By using our Site and/or using the Complete Savings service, you signify your acceptance of our Privacy Statement.

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