Privacy Policy

1. Who is responsible for personal data?

When a business uses Adeo Cards for its loyalty programme, that business determines the purposes of customer registration, campaigns, stamps, rewards and customer communication. The business is the controller and Adeo Marketing AB processes the data as a processor under the business's instructions.

Adeo Marketing AB is the controller for its own business contacts, agreements, billing, account administration, support, security, service monitoring, website and own marketing.

2. Data we process

• Card users: name, email address, phone number and the relevant business or campaign.
• Loyalty data: stamps, rewards, redemptions, campaign status and relevant history.
• Technical data: registration and consent timestamps, security and log data, card tokens and technical identifiers required to operate the service.
• Wallet data: Apple Wallet or Google Wallet identifiers, card status and data required to create, distribute and update a Wallet pass.
• Business accounts and staff: name, email, role, business association, login and security data and support communication.
• Commercial data: contact details, order, subscription, invoice information and payment status.
• Website data: cookie choices, language preference and technical information described in the Cookie Policy.

3. Purposes and legal bases

For data in a business's loyalty programme, the business determines the legal basis. This may include contract, legitimate interests or consent where consent is required, particularly for certain marketing. Adeo Marketing AB processes that data under documented instructions.

For Adeo Marketing AB's own processing, the main legal bases are performance of a contract, legal obligations, legitimate interests in administering and protecting the service and consent where required by law.

• create and administer digital loyalty and stamp cards
• record stamps, redemptions and rewards
• create and update Wallet passes and deliver technical updates
• manage business accounts, staff access, support, agreements and billing
• prevent abuse, troubleshoot and protect the platform
• comply with accounting, data protection and other legal obligations

4. Apple Wallet and Google Wallet

Adeo Cards uses official developer integrations and technical certificates or credentials for Apple Wallet and Google Wallet. Apple and Google provide and control their own Wallet services. Their own terms and privacy policies apply to processing in their environments.

Adeo Marketing AB is responsible for the Adeo Cards platform and technical pass management. The business operating the loyalty programme is responsible for its campaign, reward, pass content and customer relationship. Apple and Google are not parties to the agreement between Adeo Marketing AB, the business and the card user.

References to Apple Wallet or Google Wallet do not mean that Apple or Google sponsors or endorses Adeo Cards.

5. Location features and notifications

If a business activates a location feature, the business address may be used to make a pass relevant near that location. Adeo Cards does not need to store a customer's continuous location for this. The device operating system and Wallet provider decide whether and when a pass is shown.

Notifications may relate to stamps, rewards, campaigns or important pass information. The business is responsible for its campaign messages. Delivery and display cannot be guaranteed because they are controlled by the device, operating system and Wallet provider.

6. Recipients and suppliers

Personal data may be shared with the business whose loyalty programme you use and with suppliers required for databases, operations, hosting, content delivery, email, support, security and Wallet functions. Suppliers may only process data under contract and applicable instructions.

We do not sell personal data. Data may be disclosed to authorities or another party where required by law or to establish, exercise or defend legal claims.

7. Processing outside the EU/EEA

Some international technology providers may process data outside the EU/EEA. Where this occurs, a lawful transfer mechanism is used, such as an adequacy decision, the European Commission's Standard Contractual Clauses and supplementary safeguards where required.

8. Retention

Data is not retained longer than necessary for each purpose. For loyalty programmes, the business determines the retention period and may instruct Adeo Marketing AB to correct, export or erase data. When a business agreement ends, personal data is deleted or returned under the data processing terms unless law requires continued retention.

Agreement, invoice and accounting records are retained for as long as applicable law requires. Security logs and support data are retained for a limited period based on need and risk.

9. Your rights

For a specific business loyalty programme, contact the business first. You may also contact Adeo Marketing AB and we will help route the request to the responsible party.

• receive information and access your personal data
• request correction of inaccurate or incomplete data
• request erasure where the GDPR requirements are met
• request restriction of processing
• object to processing based on legitimate interests or direct marketing
• receive data in a structured format where data portability applies
• withdraw consent without affecting earlier lawful processing
• lodge a complaint with the competent data protection authority

10. Security and incidents

Adeo Marketing AB uses technical and organisational measures to restrict access, protect accounts, log relevant events and reduce the risk of loss, misuse or unauthorised access. No digital service can be guaranteed to be entirely risk-free.

If a personal data breach affects a business's data, Adeo Marketing AB informs the affected business without undue delay. The business, as controller, is responsible for any regulatory notification and communication to data subjects unless law or agreement provides otherwise.

11. Contact and changes

Questions and requests should be sent to kontakt@adeomarketing.se. The responsible legal entity is Adeo Marketing AB, company registration number 559506-4766, Kalmar, Sweden.

This policy may be updated when the service, suppliers or legal requirements change. The date at the top shows when the latest version was published.