As GDPR compliance and everyone’s privacy is a core belief of Péarlaí we will strive to make this as jargon free as possible.

The information that we collect:

Submitted Information

The information you provide when you apply for VIP membership, such as demographic details, shopping preferences or details provided on a form.

Additional Information

The information on the shops you visit, the text messages we send you and responses to any of the surveys we send to you. We do not collect any information used to make financial transactions.

Device Information

Information about the device (smart key fob) you are using.

Location Information

If you are carrying your Péarlaí smart key fob, we collect information on where in the venue you have been.

How we store your data

Data is stored on our own secure servers in accordance with local regulations. If you are not identified in a Péarlaí venue for more than 12 months, all personally identifiable data we store about you is deleted.

How your data is used

Your data may be used to understand how you use a particular venue, to communicate with you and to offer you relevant goods and services.

Who may use your data?

Your data may be used by Péarlaí Ltd, the owner of the venue you visited or selected third parties. Your data will NEVER be shared with any third party without your prior consent.

Your data may also be provided to regulatory bodies where we are under a legal obligation to do this, to protect our own rights or if we feel someone’s safety is at risk

Accessing your own data

You can access and amend the data we hold on you at any time by visiting your Profile Portal and requesting to do so. If you request for your data to be deleted we may be required to request proof of your identity such as a drivers license or passport.

Data Protection

Please take time to read our Data Protection Policy

In the information age, we offer customers the means to be always connected. This requires data to be collected and processed. We adhere to this principle: When storing and transmitting data, we must ensure a high level of data protection and data security. That goes for information pertaining to our customers, prospects, business partners and employees.

Your data protection is of paramount importance to Péarlaí at all times and Péarlaí strive to set the standard in data protection. For that reason, we view it as our duty, as an international corporation, to comply with the various legal regulations around the world that govern the collection and processing of personal data. Our top priority is to ensure universally applicable, worldwide standards for handling personal data. For us, protecting the personal rights and privacy of each and every individual is the foundation of trust in our business relationships.

Our Corporate Data Protection Policy lays out strict requirements for processing personal data pertaining to customers, prospects, business partners and employees. It meets the requirements of the European Data Protection Directive and ensures compliance with the principles of national and international data protection laws in force all over the world. The policy sets a globally applicable data protection and security standard for our company and regulates the sharing of information between our Group companies. We have established multiple data protection principles – among them transparency, data economy and data security – as our guideline.

Our teams are obligated to adhere to the Corporate Data Protection Policy and observe their local data protection laws. It is our duty to ensure that the rules and principles of data protection at Péarlaí are followed around the world.

Péarlaí are pleased to answer any questions you have about your data protection and security.

GDPR

Péarlaí takes data privacy very seriously and our platform and systems have been design with GDPR compliance at its core.

We have conducted a detailed review of our controls, procedures and practices in light of the GDPR and consider our processes, procedures and solutions to be materially compliant.

Our Policy

This privacy policy sets out how Péarlaí Ltd uses and protects any information that you give Péarlaí Ltd when you use this website and our services. Péarlaí Ltd is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website and our services, then you can be assured that it will only be used in accordance with this privacy statement. Péarlaí Ltd. may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes. This policy is effective from 22 April 2016.

What we collect;

We may collect the following information:

· First name, Date of Birth, marital status & employment status.

· Contact information including email address.

· Demographic information such as postcode, preferences and interests.

· Other information relevant to customer surveys and/or offers.

What we do with the information we gather

We require this information to understand your needs and provide you with a better service, and in particular for the following reasons:

Internal record keeping.

We may use the information to improve our products and services.

· We may periodically send promotional emails about new products, special offers or other information which we think you may find interesting using the email address which you have provided.

· From time to time, we may also use your information to contact you for market research purposes. We may contact you by email, phone or mail. We may use the information to customise the website according to your interests.

Security

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.

How we use cookies

A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences. We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

Links to other websites

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

Controlling your personal information

You may choose to restrict the collection or use of your personal information in the following ways:

· Whenever you are asked to fill in an application form on a shopping centres website or a Péarlaí website, you will be allocated your own personal account where you can choose to select you do not want the information to be used by anybody or specific brands for direct marketing purposes.

· If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by updating your preferences in your profile account portal.

We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so. We may use your personal information to send you promotional information about third parties which we think you may find interesting if you tell us that you wish this to happen. You may request details of personal information which we hold about you under the Data Protection Act 1998. A small fee will be payable if you request your information more than once. If you would like a copy of the information held on you please indicate in your profile account page by selecting request details of information held on me or write to Péarlaí Ltd, Unit 4a, 75 Belfast Road, Newry, BT34 1QH.

If you believe that any information we are holding on you is incorrect or incomplete, please write to or email us @ contact@pearlai.com as soon as possible or at the above address. We will promptly correct any information found to be incorrect.

By accessing and using the services provided by Péarlaí Ltd you (the “Customer”) agree to be bound by these Terms and conditions Policy displayed at http://vip.péarlaí.com/ Please read the Terms and conditions carefully before you start to use the Services. If you do not agree to the Terms and conditions do not use the Services.

Péarlaí may revise the Terms and conditions at any time by amending the page at http://vip.péarlaí.com/ You are expected to check this page from time to time to take notice of such changes, as they are binding on you.

The Services are owned and provided by Péarlaí Ltd Unit 4a, 75 Belfast Road Newry, BT34 1QH Northern Ireland

THE SERVICE

Péarlaí performance of its obligations under the Terms and conditions is prevented or delayed by:

b) any interruptions, delays or faults affecting any third party platform or website which is monitored by the Service from time to time,

Péarlaí shall not be liable for any costs, charges or losses sustained or incurred by the customer that arise directly or indirectly from such prevention or delay.

Péarlaí shall maintain the security and integrity of the customers Data.

Péarlaí shall:

(a) comply with all applicable laws in using the Services, including any applicable laws, regulatory requirements or generally accepted practices or guidelines which relate to the purpose for which the Customers makes use of the Services.

(d) not interfere with or disrupt the integrity or performance of the Services or the data contained therein

(e) not adversely affect Péarlaí business (which includes damage to Péarlaí reputation or business standing, affecting its profitability, conflict with business strategy of Péarlaí or conflict with Péarlaí’s ethical standards and policies

Péarlaí shall have the right to periodically perform maintenance on the Services (or the servers and networks which are connected to the Services), which may result in interruption to the provision of the Services. The dates and times of this maintenance shall be advertised by Péarlaí in advance, via its website or other media. Péarlaí shall attempt to ensure that minimal disruption is caused by such maintenance.

Smart Key Fobs

Péarlaí uses electronic smart key fobs which can determine carriers whereabouts in any shopping centres or locations which have Péarlaí readers installed used to send you offers from the retailers via text message.

The smart key fob (Device) shall pass to the customer at the point at which the smart key fob leaves the allocated centre which the customer shall be fully liable for, and will indemnify and hold harmless to Péarlaí and its affiliates against all losses, liabilities and costs (including legal expenses) sustained, incurred or suffered by them arising out of or in connection with use of, damage to, or the loss or theft of the smart key fob while in the company’s possession or under its control. The liability for loss or theft will be £5 as a minimum cost

If the Device suffers a fault, Péarlaí will use all reasonable endeavours to repair or replace such Device within seven (7) Working Days (being any day other than a Saturday, Sunday or public holiday in N.Ireland) of receipt of written notification from the customer of such fault and receipt of the faulty Device.

Emails

When Péarlaí sends emails to customers we may sometimes track who has opened (or not opened) the emails or clicked on hyperlinks. Péarlaí does this to measure the performance of campaigns, and to improve its offerings to specific customer groups.

Personal data:

Péarlaí will need to collect certain personal data about you in order to register you as an authorised user, grant access to the Services, collect payment and to provide the Services. This may include name, post code, email address, phone, mobile phone number, and other information such as gender, occupation and other demographic information. Péarlaí may also use personal data to enable it to deal with any queries that you have about the Services and to notify you of any changes to the Services. Péarlaí will NEVER share your data with any 3 rd parties other than a relevant shopping centres, centre landlords or tenants without your prior consent.

Monitoring compliance with the Terms and conditions Péarlaí may sometimes review the content of campaigns using the Services to verify compliance with the Terms and conditions. In this regard, Péarlaí uses software with algorithms to detect any failure to comply with the Terms and conditions. For example, Péarlaí may check that the email address or mobile numbers of an individual who opts out of receiving emails or texts has been removed from distribution lists.

Offer distribution. Péarlaí will use information provided by you via our services to provide you with offers generated by Service Users. By using these services you hereby acknowledge and agree that Péarlaí will receive, use, store and process your information.

Péarlaí may disclose your personal data as follows:

3rd parties that are specifically engaged by Péarlaí to provide services to it, in which case Péarlaí will require those parties to keep that information confidential and secure and to use it solely for the purpose of providing the specified services to Péarlaí.

(b) If Péarlaí or substantially all of its assets are acquired by a third party, in which case personal data held on the Services will be one of the transferred assets.

(c) If Péarlaí is under a duty to disclose or share your personal data in order to comply with a court order or other legal or regulatory requirement.

DATA PROTECTION

Péarlaí undertakes that:

(a) it has obtained all consents, registrations and notifications (covering the types of processing envisaged by the Terms and conditions) required by the Data Protection Legislation 1998 in respect of Personal Data to be supplied or disclosed to Péarlaí;

(b) it will at all times comply with its obligations under the Data Protection Legislation;

(c) Personal Data is accurate and up to date when disclosed.

Personal Data is processed and disclosed fairly and lawfully (as required by the Data Protection Legislation) by the customer when supplying or disclosing such Personal Data to Péarlaí.

The Parties acknowledge that for the purposes of the Data Protection Act 1998, the customer is the Data Controller and Péarlaí is the data processor in respect of any Personal Data.

Péarlaí shall process the Personal Data only in accordance with, and for the purposes described in, the Terms and conditions shall not process the Personal Data for any other purpose unless expressly authorised by the customer.

The customer acknowledges that Péarlaí is reliant on the customer for direction as to the extent to which Péarlaí is entitled to use and process the Personal Data. Consequently, Péarlaí will not be liable for any claim brought by a Data Subject arising from any action or omission by Péarlaí, to the extent that such action or omission resulted directly from the Customer instructions.

(a) Péarlaí undertakes that it will at all times comply with its obligations under the Data Protection Legislation.

(b) Péarlaí shall process the Personal Data only in accordance with Péarlaí’s lawful instructions from time to time and shall not process the Personal Data for any purpose other than those expressly authorised by Péarlaí.

“Data Protection Legislation” means the Data Protection Act 1998, the Data Protection Directive (95/46/EC), the Regulation of Investigatory Powers Act 2000, the Telecommunications (Lawful Business Practice) (Interception of Communications) Regulations 2000 (SI 2000/2699), the Electronic Communications Data Protection Directive (2002/58/EC), the Privacy and Electronic Communications (EC Directive) Regulations 2003 (SI 2426/2003) and all other applicable laws and regulations in any jurisdiction relating to the processing of personal data and privacy, including where applicable the guidance and codes of practice issued by the Information Commissioner or any other regulatory, statutory, governmental or local authority in any jurisdiction; and

“Data Controller”, “Data Processor”, “Data Subjects” and “Personal Data” shall have the meanings given in the Data Protection Legislation