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Terms &

Privacy Notice

Last updated 02.09.2021

This privacy notice explains how we, PEC Parkfield S.àr.l. of 4, rue deu Fort Wallis with company number B256590 (we, us, our) process your personal data (user, your) when you use our app (services).

Please do not use our services unless you are 18 years old or over.

  1. Who does this privacy notice apply to?

This notice applies to:

  • users of our services; and
  • persons who interact with us, when you call us, email us or visit our premises.

This notice applies to you whether you act in your personal capacity or as an employee or agent of an organisation.

2. What personal data is processed about you?

Generally, “personal data” refers to any information that identifies you or relates to you. We will process personal data including:

  • your user details collected when you sign up for our services and as you use our features, such as your title, name, email address, language, preferred centre, mobile, city, postcode, country and date of birth, sex and other information;
  • when accessing our services, your device will automatically provide unique information such as mobile device ID, IP address, cookie ID, online identifiers, geolocation data, operating system, browser type and time zone setting and other information;
  • our systems may generate usage data about how you navigate and engage with our services, which pages you view, which offers you access, your preferences (including language), methods used to access our services, interests known, observed or inferred as well as security logs;
  • GPS location data if you enable the functionality on your device in relation to our services, we will be able to offer you location-based features and notifications. When you reach our centre, we will collect the time, date and duration of your visit, each store visit and technical information about your device. We do this to determine which products and services you may be interested in, particularly based on store visits, for direct marketing purposes, to send you relevant notifications and offers while at our centre or later and to allocate rewards to your loyalty account;
  • third party data such a confirmation that you have scanned a barcode at a participating store, data about your interaction with our posts and content and ‘likes’ on social media platforms, profile information from advertising and analytics partners and information from our suppliers;
  • when we send you emails, SMS or push notifications, we may collect technical communication interaction data, such as open rates or what content you clicked on; and
  • when you interact with our services, contact or visit us, we may process your image, complaint details, details of your requests, communications, feedback, keep a relationship history, details of your survey submissions or other interaction data.

We will likely be unable to provide all our features unless you provide the relevant personal data, and some personal data will be mandatory for our compliance with the law. Nevertheless, we would ask that you only provide the necessary personal data to us.   

3. How do we process your personal data and why?

The type of personal data we collect about you will depend on your interaction with our services and features and your user settings.

Generally, we will use your personal data as “controller” to (i) provide our services; (ii) to send you relevant information; (iii) ensure the security and technical availability of our services; (iv) develop and promote our organisation and services; and (v) as further described in this notice.

We will update you about any new purposes of processing of your personal data from time to time and we will obtain your prior consent where we are required to do so at law.

4. Data Accuracy

We and our clients who are the participating stores will rely on the information provided by you as accurate, complete and up to date, and we shall be grateful if you would inform us of any changes without delay.

We would ask that you do not provide to us information about others unless you have their permission to do so.

5. What data do we collect and why?


Personal data

Legal ground for processing

To enable you to sign up for our services, to understand your basic demographic information and verifying that the format of the information provided by you is correct.

  • user details 

Necessary for our legitimate interest in reasonably ensuring that the information provided by users is accurate and understanding the basic demographic information about our users who might be interested in our services.

To provide our services such as our user engagement and loyalty app and features, keeping count of your points and rewards.

  • usage data
  • device data

Necessary for our performance of our contract with you and, where applicable, our legitimate interest in providing relevant service features to our users.

To send you promotional information through various marketing channels including email, social media, telephone, SMS, push notification, etc. about our services and our organisation, reviewing campaign performance and profiling information about your interests known, observed or inferred for direct marketing purposes.

For example, we may send you our update email or use your contact details to display relevant ads on Facebook or Instagram and other social media platforms or send you a push notification if you visit our centre or a participating store. Social media and advertising providers may use their own information about you to help us make our ads most relevant.

  • user details 
  • usage data
  • device data
  • GPS location data
  • communication interaction data
  • third party data

Where you signed up for our services, we may send you relevant information and offers in the performance of our contract with you.

We will use your information based on our legitimate interest in understanding your interests based on the information available to us, information observed or inferred for direct marketing purposes and to understand campaign metrics.

We may rely on the soft opt-in exemption to send you marketing emails and push notifications if you are an existing customer. This means that consent will not be necessary but you will have the right to opt out at any time.

We will obtain your consent for direct marketing where the soft opt-in exemption does not apply or where consent is the most appropriate basis for our activities.

For example, your consent will be required to place cookies or similar technologies on your device or to read information on your device. Where you have provided consent, we will combine cookies information with your user details and usage data for direct marketing purposes.

To send you information about matters relevant to your engagement with our services, such as competitions, events, surveys, changes in our terms, welcome you at our centre as described below, etc.

  • user details 
  • usage data
  • GPS location data
  • interaction data
  • third party data

Service notifications are necessary for the performance of our contract with you.

Other notifications are necessary for our legitimate interest in keeping our users engaged and organising related business activities.

Use your location data based on GPS and third party data to welcome you at our centre, to send you relevant offers by way of push notification, to record your visits, allocate rewards to your loyalty account and to count purchases if you are at a participating store, you requested an offer at the store or scanned a bar code.

  • GPS location data
  • third party data

If you enable the functionality on your device, we will use the minimum necessary GPS location data and third party data in connection with our legitimate interest in providing our services and provide meaningful functionalities and, where applicable, the performance of our contract with you in order to provide the requested service features.

Sharing necessary information with participating stores and receive information from participating stores to verify your purchase including if you scan a bar code at the store.

  • third party data

Necessary for our performance of our contract with you.

We will use anonymised information including sex, age and other demographic information to create market reports and similar materials for statistical and commercial purposes.

  • anonymised data

Necessary for our legitimate interest in understanding the customer base, sharing market information, developing our services, exploring business opportunities and informing business decisions.

To improve and develop our service functionality, including to:

  • obtain user feedback and improve user experience;
  • make services and features more relevant;
  • conduct statistical analysis on usage data, device data and other data;
  • use data to develop algorithms, software and other technologies; and
  • work with third parties and evaluate data to improve and develop our services.
  • anonymised data

Necessary for our legitimate interest in developing and improving our services and business.

To ensure proper administration of our business, including to:

  • keep appropriate records;
  • resolve complaints;
  • conduct troubleshooting; and
  • debt collection.
  • user details
  • usage data
  • device data 
  • interaction data
  • communication interaction data

Necessary for our legitimate interest in the proper administration of our business, dispute resolution, ensuring technical operation of our services and debt collection and as is necessary for compliance with our legal obligations.

  • To share your information with our third party providers who facilitate the provision of our services and the fulfilment of essential service functions, such as hosting, cloud storage, analytics, advertising and marketing tools, plugins, communications providers, accounting or security tools and others.
  • all information necessary to enable the relevant service

Some are necessary for the performance of our contract with you, others are necessary for our legitimate interest in ensuring proper operation of our services and features.

To monitor our networks, systems and services for suspicious activities, crime detection and prevention, testing, audit and deployment of security measures, including information from third parties who may alert us about suspicious activities. 

  • user details
  • usage data
  • device data
  • interaction data
  • third party data

Necessary for our legitimate interest to ensure the security of our organisation, people and services and in detecting and preventing fraud and illegal conduct, ensuring that the information provided by you is accurate and as is necessary for compliance with our legal obligations.

To share information for legitimate purposes within our offices and our group companies.

  • limited data necessary and proportionate to achieve our legitimate purposes

Necessary for our legitimate interest in using our group’s resources to organise, develop and deliver our services, run our organisation and decide on future strategies.

To share data with a successor or partner legal entity in compliance with the law for the purposes of a joint venture, collaboration, financing, sale, merger, reorganisation or similar event relating to our business.

  • limited data necessary in connection with the transaction

Necessary for our legitimate interest in acting in the best interest of our shareholders and investors and complying with our legal obligations.

To process information as is required for our compliance with the law or to establish, exercise or defend legal claims.

To process and share information with other third parties where required by law, such as regulators, law enforcement agencies or where mandatory under a court order.

  • data necessary in connection with the legal requirement, proceedings or request

Where processing or sharing your data is necessary for compliance with a legal obligation to which we are subject, to establish, exercise or defend legal claims or, where appropriate and proportionate, in order to satisfy our legitimate interest in complying with best practice and applicable laws.


  • Personal data

Legal ground for processing

6. Sharing your data

We will generally not share your information except with (i) our clients who are the participating stores, (ii) with our third party service providers, commercial partners and group companies for the purposes set out above, (iii) where we are compelled by law, and (iv) other third parties where you have provided your consent.

Our service providers:

  • Codilink UK Ltd (trading as Coniq) incorporated and registered in England and Wales with company number 06269999 whose registered office is at 3 Wesley Gate, Queens Road, Reading, Berks, RG1 4AP, In order to ensure your data is accessed and processed securely, the appropriate safeguards in the form of ‘model clauses’ are in place. They assist us with:
    • storing and combining data;
    • processing transaction information of users;
    • communicating with our users about the benefits of these loyalty programmes;
    • communicating with customers who have signed up to receive our newsletter; and
    • communicating with entrants of competitions and contests we may run from time to time;
    • communicating for operational emails;
  • Kodilink Dooel Skopje (a subsidiary of Codilink UK Ltd) incorporated and registered in North Macedonia with company registration number 7274980 and registered address at 16, 8 mi Septemvri Blvd, Hyperium Business Centre, Skopje, 1000, North Macedonia. In order to ensure your data is accessed and processed securely, the appropriate safeguards in the form of ‘model clauses’ are in place

7. Third parties may process your data

Our services may contain links to other websites, third party services and plugins. You should check the privacy statements of these third party providers before using their services as we are not responsible for how they may process your personal data.

8. How long is your personal data kept?

We will keep your personal data for as long as is necessary for the purposes listed above or longer, as may be required by law. Generally, the retention periods below will apply. You may contact us for further details or request deletion of your personal data at any time.

Category of personal data

Retention period

user details

1 year following account closure

usage data, device data, interaction data

1 year following account closure

all other personal data

1 year following account closure

After the retention period, your personal data will either be securely deleted or anonymised and it may be used for analytical purposes. You must back up your data if you wish to keep it for longer.

9. How do we secure your personal data?

We maintain appropriate organisational and technological safeguards to help protect against unauthorised use, access to or accidental loss, alteration or destruction of personal data. We also seek to ensure our service providers do the same.

We have put in place procedures to deal with any suspected personal data breach and will notify you and the data protection authority of a personal data breach where required by law.

We will endeavour to use the least amount of personal data as is required for each purpose. We will employ pseudonymisation and anonymisation, where appropriate. 

Our staff will access your personal data on a need to know basis.

10. Where is your personal data processed?

Generally, our data is held in the EEA. However, we may transfer your personal data to our clients, group companies, suppliers and other third parties in countries different to your country of residence. For example, our processor Kodilink Dooel Skopje is located in North Macedonia.

Where we transfer your personal data outside the European Economic Area (EEA), we will only do so, where we are satisfied that your data protection rights are adequately protected by appropriate technical, organisational and contractual safeguards in accordance with data protection laws.

Where we share information with the participating stores, we will do so on the basis of performance of our contract with you.

You may request further information on the measures used for the international transfers or access to your personal data from outside the EEA.

11. Your right to opt-out

If you would like us to stop sending you marketing communications and to process your personal data for direct marketing purposes, please let us know.

You can stop our marketing communications at any time by clicking on the unsubscribe link at the bottom of the message.

12. Your data protection rights

Subject to certain exemptions, limitations and appropriate proof of identity, you will generally have numerous rights in relation to your personal data, including the following:

    • Right to information about matters set out in this notice.
    • Right to make an access request to receive copies of personal data.
    • Right to rectification of any inaccurate or incomplete personal data. 
    • Right to withdraw consent previously provided.
    • Right to object to our processing of personal data based on our legitimate interests, and any automated processing and profiling.
    • Right to erasure of personal data, within limited circumstances.
    • Restriction on the processing of personal data.
    • Right to data portability from one service provider to another, where applicable.
    • Right to lodge a complaint with your country’s data protection authority, such as the Information Commissioner’s Office.

All requests will be processed in a timely manner, generally within one month. If we cannot process your request within this period, we shall explain why and process it as soon as possible thereafter.

13. Contact us

Please contact us if you have any queries or concerns about how we use your personal data. You can contact us using the details below. We will try to resolve your query as quickly as we possibly can.


14. Updates

If we make any changes to our notice you will be able to see them on this page. You should regularly check for updates, as indicated by the “Last updated” date at the top.

If any such changes significantly affect you, we will ask for your prior consent where required by law. However, if you do not agree to the changes, please consider not using our content or services.