Privacy and Cookies Statement


By entering into the Membership Agreement with Webloyalty International SARL ("WL"), you will become a Member of the Webloyalty Programme ("Webloyalty Programme"). As a Member of the Webloyalty Programme WL grants you the right to participate in the Webloyalty Programme, which includes the right to earn cash-backs, purchase vouchers at a discount and to earn or receive other benefits. Collectively, the grant of the right to participate in the Webloyalty Programme and the right to earn and receive cash backs and other benefits is referred to as the Webloyalty Membership Service ("Webloyalty Membership Service").

Please read this Privacy Statement carefully before joining the Webloyalty Programme or using this Website.
Revision Date
This Privacy Statement was last modified on 03 December 2013.
Data Controller
Webloyalty SARL is the data controller for this Website.

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 Clause 14 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 CH-550-1105751-7, and its registered office is at 23 route de Crassier (Business Park Terre Bonne, Bâtiment A3), 1262 Eysins, 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 23 route de Crassier (Business Park Terre Bonne, Bâtiment A3), 1262 Eysins, Switzerland.


  1. Purpose of this Privacy Statement
    WL recognises 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 WL.

    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.

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  2. Truste Certification

    WL has been awarded TRUSTe's Privacy Seal signifying that this privacy statement and practices have been reviewed by TRUSTe for compliance with TRUSTe's programme 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 WL at customerservice@completesavings.ie. If you are not satisfied with the response you can contact TRUSTe here. TRUSTe will then liaise with WL 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 WL.

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  3. What Information We Collect and How it is Collected

    Membership

    To become a Memberof the Webloyalty Programme, 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 WL to transfer certain contact and billing information to WL (including your mailing address and payment information (including credit and/or debit card number and expiration date). 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.

    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.

    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. 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.

    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.

    Cookies and Logfiles

    This section our Privacy statement sets out how WL uses cookies and similar technologies ("cookies") on and in connection with the Website. 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 the Website.

    How WL uses information WL collects through cookies

    WL stores information that WL collects through cookies, log files, clear gifs, and/or third party sources to create a summary of your preferences. WL ties 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 Website for you and/or to determine your preferences. WL 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 WL works with, such as companies that perform marketing services and other business operations for WL.

    More information about cookies

    WL use session and persistent cookies on this Website. 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 the Website, but you may not be able to access all the Website's functionality or your access may be limited.

    How WL uses cookies

    WL uses cookies to:

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

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

    2. remember and recognise you on subsequent visits to the Website,

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

    (c) deliver content and advertising more relevant to you and your interests. This allows WL to serve you more relevant content and advertising when you use the Website and the Webloyalty Membership Service 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 WL uses third party cookies for advertising and re-targeting purposes" below for further information. WL links the information WL obtained from the cookies to any Personal Information that we gather about our Members (see "How WL uses information WL collects through Cookies" above).

    How WL uses third-party cookies for advertising and re-targeting purposes

    WL may also use cookies to enable the use of advertising technology to serve you advertisements that WL feels may be relevant to you when you visit search engines, the Website and/or third party Websites upon which WL advertises.

    This technology uses information about your previous visits to our Website and the third party websites upon which WL advertises 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 WL to recognise you. This Website also uses Google Analytics, a web analytics service provided by Google, Inc. ("Google"). Google Analytics uses cookies to help analyse how visitors use the Website. Information about your use of this Website (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 webite, compile reports on Website activity for WL, 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

    WL uses web beacons, provided by WL's ad serving partner, to help manage the online advertising of WL. These web beacons allow WL and/or its ad serving partner to access individual cookies when a browser visits the Website. This allows WL to identify which advertisements or listings served by its ad serving partner bring users to the Website.

    Web beacons are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of users of the Website. 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. WL link the information gathered by clear gifs to the Personal Information WL gathers about its members (see How we use information we collect through Cookies above).
    Logfiles

    Like many websites, WL gathers certain information relating to use of the Website 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. WL uses this information, which does not by itself identify individual users, to analyse trends, to administer the Website, to track users' movements around the Website and to gather demographic information about the user base as a whole. After collection, during our processing of the data, WL links this automatically-collected data to the Personal Information that WL holds.


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  4. How Personally Identifiable Information is Used and Disclosed

    Usage

    WL only processes 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 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.

    Marketing Data From Third Parties

    WL will retain your information as needed to provide you the Webloyalty Membership Services. WL will also retain and use your information as necessary to comply with WL's legal obligations, resolve disputes, and enforce WL's agreements. If you wish to cancel your account or request that WL no longer use your information to provide you the Webloyalty Membership Services, contact WL at customerservice@completesavings.ie . In such event, WL will no longer use your information to provide you with the Webloyalty Membership Service, however, your information will be retained by WL in accordance with WL's standard business practices.

    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.

    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 to enable them to track the offer that you accepted from WL and to enable them to undertake market research and data analysis in relation to but not limited to your shopping trends and behaviours. 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.

    WL 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 WL believes is necessary or appropriate to satisfy any law, regulation or other governmental request, to operate the Website properly, or to protect or defend the rights of WL or the rights or well-being of WL's 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 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 its group companies so that WL and/or its group companies may send you information about any products and services which are considered to be of interest to you.

    If you 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 Programme.

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  5. Choice


    Opting Out

    You can make choices about how your Personal Information may be shared by WL with third parties for marketing purposes and/or how your Personal Information may be used by WL for purposes not related to your Membership. WL 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 (a) will not apply to communications that are directly related to your Membership, the Webloyalty Membership Service and the benefits and/or the fulfilment of a specific transaction you have requested (for example, a claim submitted for a specific benefit and/or emails describing the benefits of the Webloyalty Membership Service or special Member offers; (b) shall not preclude WL, including its 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 of the Webloyalty Programme and (c) shall not preclude WL 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

    WL 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
    The Website may contain links or references to third party websites and the privacy statements of these websites may differ from this Privacy Statement. Please be aware that WL has no control over such websites (other than those controlled by WL's group companies) and this Privacy Statement does not apply to such websites. We encourage you to read the privacy statements of such websites.

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  7. Download Application
    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 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.

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  8. How WL Protects the Security of Personal Information
    The security of your Personal Information is an important concern to WL. WL takes appropriate measures to protect against unauthorised access to or loss, misuse, disclosure, alteration or destruction of Personal Information. WL implements generally accepted standards of technology security including firewalls and Secure Socket Layer (SSL) encryption when storing sensitive Personal Information and billing information. In addition, for any Personal Information you submit to WL through the Website, such Personal Information shall be transmitted to WL 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 WL strives to protect your information, it cannot be guaranteed that any information stored on WL's servers, or transmitted to or from a user, will be free from unauthorised access and 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.

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  9. Transfer of Personal Information outside the EEA
    You acknowledge that WL 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 WL 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, WL takes every reasonable precaution to protect your personal information.

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

    WL shall therefore assume responsibility for the personal information that you submit, if WL fails to honour 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 Services.

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  10. Safe Harbor Participation
    The Webloyalty Programme 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. WL has certified that the Webloyalty Programme 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 Programme, and to view WL's certification, please visit http://www.export.gov/safeharbor/ .

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  11. Children's privacy
    Protecting the privacy of children is very important to WL. Membership of the Webloyalty Programme is not open to anyone under 18 years of age. WL does not collect or maintain Personal Information from people whom WL knows are under 18 years of age. To prevent the collection of information from people under 18 years of age, WL requires valid credit card information to sign up to the Webloyalty Programme.

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  12. How to update your Personal Information
    WL takes reasonable steps to ensure that the Personal Information it collects and processes is accurate, complete and current, but WL depends on its 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 you will need to confirm your identity first. Any change to your "Member Profile" on the Website will be recapped in an e-mail that is automatically sent out by WL 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 WL about you. WL 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 WL 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 email at customerservice@completesavings.ie or writing to WL 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
    WL reserves the right to modify this Privacy Statement at any time, so please review it frequently on the Website. If WL makes any changes, you will either be notifed by email or WL will post a notice on the Website's homepage. WL will also summarise any material changes to the Privacy Statement on the Website. WL encourages you to read any revised Privacy Statement.

    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.

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  15. Your Acceptance of this Privacy Statement
    By using the Website and/or using the Webloyalty Membership Service, you signify your acceptance of this Privacy Statement.

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